Is your Turkish bank account blocked because of a MASAK investigation? Learn why foreign accounts are frozen, how to identify the legal basis, challenge a prosecutor or court seizure, document international transfers and seek release of legitimate funds in Turkey.

A foreign national who discovers that a Turkish bank account has been frozen should first determine who actually imposed the restriction and under which legal authority.

This distinction is critical.

Customers and even bank employees sometimes use the expression “MASAK block” for several legally different restrictions. The account may be subject to enhanced bank compliance controls, a temporary transaction restriction connected with suspicious activity, postponement of a transaction under anti-money-laundering legislation, or a seizure order issued during a criminal investigation.

The legal remedy—and how quickly the money can potentially be released—depends on the precise basis of the restriction.

Most importantly, a frozen account does not by itself mean that the foreign account holder has committed money laundering or another crime.

Turkish banks and other obligated institutions have extensive duties to identify customers, understand transactions and report suspicious activity under Law No. 5549 on Prevention of Laundering Proceeds of Crime. A suspicious transaction report is therefore fundamentally a compliance mechanism rather than a criminal conviction.

For foreigners receiving international transfers, investment proceeds, property-sale money, cryptocurrency proceeds or large business payments, documenting the legitimate source and purpose of the funds can become central to obtaining release of the account.

What Is MASAK?

MASAK is Turkey’s Financial Crimes Investigation Board, operating under the Ministry of Treasury and Finance.

Its principal responsibilities relate to preventing money laundering and terrorist financing, receiving and analysing suspicious transaction reports and providing financial intelligence to competent authorities.

Banks are among the institutions subject to Turkey’s anti-money-laundering obligations.

This means Turkish banks must monitor transactions and, where the statutory conditions exist, submit suspicious transaction reports.

The customer is not normally entitled to be informed simply because the bank has filed such a report.

Does MASAK Personally Freeze Every Suspicious Bank Account?

No.

This is one of the most important misconceptions.

When a customer is told that an account has a “MASAK block”, the actual legal mechanism must be identified.

Depending on the case, the restriction may arise from the bank’s own compliance procedures, an anti-money-laundering transaction-postponement mechanism, or a criminal-procedure seizure decision.

Law No. 5549 also contains specific rules concerning protective measures and postponement of transactions. Under Article 19/A, transactions may be suspended or prevented from being carried out within the statutory framework where there is suspicion that the relevant assets were obtained illegally or are being used for illegal purposes.

Therefore, the first question should always be:

What is the legal basis and decision number behind the restriction?

What Should a Foreigner Do First?

The account holder should obtain as much information as legally available from the bank.

The foreign customer should determine whether:

the entire account is blocked,

only outgoing transfers are restricted,

a particular amount is frozen,

online banking has merely been restricted,

a specific transaction has been suspended,

or there is a prosecutor or court seizure order.

These situations are legally different.

A bank saying simply “your account is under review” provides insufficient information for determining the correct remedy.

Ask Whether There Is a Prosecutor or Court Decision

This is particularly important.

If the restriction originates from a criminal investigation, there may be a prosecutor’s decision, judicial order or investigation file number associated with the account.

If such information can be obtained, the foreign account holder should identify:

the prosecutor’s office, investigation number, date of the decision and scope of the restriction.

Once the investigation file is identified, a Turkish lawyer can assess what procedure produced the freeze and what legal remedy may be available.

Why Do Turkish Banks Report Transactions to MASAK?

A transaction can become suspicious for many reasons.

Banks evaluate transactions using risk-based anti-money-laundering systems.

Suspicion may arise where the transaction does not appear consistent with the customer’s known financial profile, has an unclear economic purpose or involves unusual movement of money.

The existence of a suspicious transaction report does not necessarily mean the transaction was illegal.

It means the bank identified circumstances requiring reporting under the applicable anti-money-laundering framework.

Turkish rules require suspicious transactions to be reported within the prescribed period and, in urgent cases, immediately. (Resmi Gazete)

Why Are Foreigners Particularly Vulnerable to Compliance Reviews?

Foreign customers often conduct transactions that naturally involve multiple jurisdictions.

For example, a foreign national may receive:

proceeds from selling property abroad,

salary from an overseas employer,

money from a foreign company,

investment capital,

family funds,

international business payments,

cryptocurrency proceeds,

or transfers between personal accounts in different countries.

None of these transactions is automatically illegal.

However, a large international transfer without clear supporting documentation can create compliance questions.

The practical solution is usually to establish the source of funds, reason for transfer and relationship between sender and recipient.

Example: Foreign Property Buyer Receives €300,000

Suppose a German national living in Turkey receives €300,000 from Germany.

The money is intended to purchase an apartment in İstanbul.

The transfer is legitimate.

But if the Turkish bank cannot understand where the money originated, who sent it or why it entered the account, the transaction may receive enhanced scrutiny.

The foreigner should be prepared to produce documents such as foreign bank statements, sale agreements, income documentation or other records demonstrating the origin of the funds.

A large transaction is not automatically suspicious merely because it is large.

The important question is whether its economic source and purpose can be explained.

What Documents Can Help Release a Frozen Account?

The appropriate documentation depends on the source of the money.

If the funds came from employment, employment agreements, payslips and foreign bank records may be useful.

If they came from a property sale, the foreign title documents, sale agreement and bank records may establish the source.

If the money represents company income, invoices, commercial agreements, corporate records and accounting documentation may become relevant.

If the transfer was a loan, the loan agreement and evidence identifying the lender can be important.

If it was a family transfer, evidence concerning the sender, relationship and origin of the funds may be requested.

The objective is to create an uninterrupted documentary chain:

Where did the money originate → why was it transferred → why did this person receive it?

What If the Money Came From Cryptocurrency?

Cryptocurrency-related transactions can receive significant compliance scrutiny.

Turkey strengthened its anti-money-laundering requirements for crypto-asset service providers during 2025, including additional customer-identification and transaction-monitoring measures. (Resmi Gazete)

A foreign customer receiving substantial funds after selling cryptocurrency should therefore preserve the complete transaction trail.

This may include exchange account statements, transaction histories, wallet information where relevant, original purchase records, proof of transfer to the exchange and bank records showing withdrawal of the proceeds.

Simply saying “the money came from crypto” may be insufficient.

What If the Money Came From Selling Cryptocurrency Abroad?

The same principle applies.

Suppose a foreign national sells cryptocurrency through a regulated foreign platform and transfers USD 250,000 into Turkey.

The relevant evidence may need to demonstrate:

the customer’s ownership of the foreign exchange account,

the acquisition history of the cryptocurrency,

the sale transaction,

the resulting fiat balance,

and the transfer from that balance to Turkey.

The stronger the documentary chain, the easier it is to explain the economic origin of the funds.

What If the Money Came From a Foreign Company?

The bank or authorities may need to understand why the company sent money to the individual.

For example, was it:

salary,

director remuneration,

dividend income,

loan repayment,

share-sale proceeds,

consultancy fees,

expense reimbursement,

or return of investment capital?

The answer should be supported by corporate and banking documents.

Large corporate transfers into personal accounts without an identifiable commercial basis can attract heightened scrutiny.

What If the Foreign Account Holder Received Money for Someone Else?

This can create substantially greater risk.

Foreigners should be particularly cautious about allowing friends, business partners or acquaintances to use their Turkish bank accounts.

For example, someone may say:

“My Turkish account isn’t working. Let €80,000 come into your account and send it to me afterwards.”

The account holder may view this as a favour.

From a financial-investigation perspective, however, the account can appear to function as an intermediary account in a chain of transactions.

If the original money later turns out to be connected with fraud or another offence, the account holder may have to explain why the money entered their account and where it was sent.

What If Fraud Proceeds Entered the Account Without the Foreigner Knowing?

Knowledge and intent can become extremely important.

Receiving criminal proceeds does not automatically establish that the recipient knowingly participated in the underlying offence.

Investigators may examine:

the relationship with the sender,

previous transactions,

communications,

whether the account holder retained a commission,

how quickly the money was transferred onward,

whether similar transactions occurred before,

and whether the account holder had a credible economic explanation.

The foreign account holder should preserve messages and other evidence demonstrating how the transaction arose.

Should the Foreigner Delete WhatsApp Messages?

No.

Deleting relevant communications after discovering an investigation can seriously damage the person’s ability to explain what happened.

Messages may show that the foreign account holder believed the transaction was legitimate.

For example, communications may demonstrate that the person believed the payment represented repayment of a genuine loan or payment under a commercial agreement.

Evidence preservation should begin immediately.

Can the Bank Explain Why It Filed a Suspicious Transaction Report?

Not necessarily.

Suspicious transaction reporting is subject to confidentiality rules.

The bank generally cannot simply disclose to the customer all details concerning a suspicious transaction report.

Therefore, the customer may receive limited information from branch personnel.

This is another reason why it is important to distinguish between an internal compliance restriction and an external judicial or prosecutorial seizure.

Is a Suspicious Transaction Report the Same as a Criminal Case?

No.

A suspicious transaction report does not itself establish criminal liability.

It is financial intelligence supplied under the statutory anti-money-laundering system.

MASAK can analyse financial information, and relevant information can ultimately contribute to investigations where appropriate.

But the filing of a suspicious transaction report should not be described as equivalent to a criminal conviction—or even necessarily proof that a criminal prosecution will follow.

What Is Transaction Postponement Under Article 19/A?

Law No. 5549 provides a mechanism allowing suspicious transactions to be postponed within the statutory framework where there is suspicion concerning illegal acquisition or illegal use of the relevant assets.

The provision is designed to prevent suspicious money from disappearing while the authorities assess the situation.

This mechanism should be distinguished from an indefinite criminal seizure.

The legal basis and duration of the particular restriction therefore need to be identified before choosing a remedy.

Can MASAK Restrictions Continue Indefinitely?

A temporary transaction-postponement mechanism should not be confused with a judicial seizure that may continue during an investigation.

If the initial temporary restriction is followed by a prosecutor or court decision, the account may remain restricted under that separate legal basis.

Therefore, a foreign customer should not simply wait because someone at the bank said, “MASAK blocks disappear automatically.”

The restriction may have evolved into a different procedural measure.

What Is a Criminal Seizure of a Bank Account?

Turkish criminal procedure permits seizure of assets in qualifying circumstances.

Law No. 5549 also contains provisions concerning protective measures in money-laundering investigations.

In urgent circumstances, a public prosecutor can issue a seizure decision subject to judicial review within the statutory framework. The legislation provides that a seizure ordered without an initial judge’s decision must be submitted for judicial approval within the prescribed period.

Once a criminal-procedure seizure exists, the strategy is different from simply providing documents to a bank’s compliance department.

Can a Foreigner Challenge a Bank Account Seizure?

Potentially, yes.

Where the account restriction is based on a prosecutor or court decision, the decision should be examined under the applicable criminal-procedure rules.

The account holder may be able to submit objections or requests seeking lifting or modification of the measure.

The application should usually address the actual legal and evidentiary basis of the seizure.

Merely saying “I need my money” will generally be weaker than demonstrating:

the documented lawful source of funds, legitimate purpose of the transaction, absence of connection with the suspected offence and disproportionality of continuing to freeze the relevant assets.

Can Only Part of the Account Be Released?

Potentially.

This can become important where only part of the balance is connected with the transaction under investigation.

Suppose a foreigner’s Turkish account contains 4 million TL.

Only 300,000 TL relates to a transaction under investigation.

The remaining amount can be traced to documented salary and property-sale proceeds.

Depending on the legal basis and circumstances, the account holder may seek a narrower restriction or release of demonstrably unrelated funds.

Whether partial release is possible depends on the particular order and investigation.

Can Salary Money Be Released?

Potentially, but there is no universal rule automatically releasing salary merely because the account holder describes it as salary.

The source should be documented.

Employment contracts, payroll records, Social Security Institution records and bank-transfer descriptions may help distinguish legitimate employment income from the transaction under investigation.

Where the freeze causes severe hardship, this may also be raised in an application seeking proportional treatment of the restriction.

What About Rent and Daily Living Expenses?

A foreign national may face serious practical problems where the frozen account is the only Turkish bank account used to pay rent, utilities, food and other necessities.

These circumstances should be documented when seeking modification or lifting of the restriction.

However, financial hardship alone does not automatically invalidate a lawful seizure.

The strongest application combines the hardship argument with evidence demonstrating that the relevant funds are legitimate and unrelated to suspected criminal proceeds.

What If the Foreigner Is a Business Owner?

A company-account freeze can be particularly damaging.

The business may become unable to pay:

employees,

taxes,

Social Security Institution liabilities,

rent,

suppliers,

loan instalments,

and operational expenses.

The application for release should therefore explain not only the source of the funds but also the commercial consequences of continuing the restriction.

Where only particular transactions are under investigation, proportionality can become an important issue.

Can a Company Account Be Frozen Because of Its Director?

Potentially, depending on the suspected transactions and investigation.

Investigators may examine whether the company itself was used to receive, transfer or conceal suspected criminal proceeds.

Foreign shareholders should not assume that the company is automatically insulated merely because the investigation initially concerns one manager.

At the same time, the existence of an investigation involving a director does not automatically establish that every company asset represents criminal proceeds.

Corporate accounting and transaction records can therefore become crucial.

Can a Personal Account Be Frozen Because of Company Transactions?

Potentially.

Where investigators believe funds moved between corporate and personal accounts as part of the suspected conduct, both categories of accounts can come under examination.

Foreign business owners should therefore maintain clear separation between personal and company finances.

Repeated unexplained transfers between company and shareholder accounts can create significant evidentiary difficulties.

What If the Account Was Frozen After Receiving Money From Abroad?

The foreigner should establish the complete international transfer chain.

Useful evidence can include:

the foreign account statement,

SWIFT payment record,

identity of the sender,

contract underlying the payment,

invoice,

proof of sale,

loan documentation,

tax documentation,

and correspondence explaining the transaction.

Where documents are in a foreign language, Turkish translation may become necessary during formal proceedings.

What If the Foreign Account Holder Cannot Explain the Transfer?

This is a serious warning sign.

A person should not invent an explanation or create backdated contracts after discovering the freeze.

False documentation can make the situation substantially worse.

The actual transaction should instead be reconstructed using objective evidence.

Bank records, emails, messages and accounting information can often establish the real chronology even where the account holder initially remembers few details.

Should the Foreigner Give a Statement to Police or Prosecutors?

If summoned, the person should understand what investigation they are being questioned about before providing substantive explanations where procedurally possible.

Bank-account investigations can involve complicated transaction chains.

An innocent explanation can appear inconsistent if the account holder does not remember amounts, dates or counterparties correctly.

The transaction chronology should therefore be reviewed carefully.

Foreign nationals who do not sufficiently understand Turkish also have procedural rights concerning interpretation.

Can MASAK Investigate Old Transactions?

Financial investigations are not necessarily limited to the single transaction that triggered the initial concern.

Once authorities examine an account, transaction history and connected accounts may become relevant depending on the investigation.

This is why a foreign account holder should not prepare an explanation only for one incoming payment if there are several unusual transactions requiring clarification.

A chronological transaction analysis is often much more effective.

Can Other Turkish Bank Accounts Also Be Affected?

Potentially.

If the restriction arises from a broader criminal investigation rather than a single bank’s internal compliance decision, accounts held at other banks can also become relevant.

Authorities may examine the person’s wider financial relationships.

This is another reason why the legal source of the first freeze should be identified quickly.

Does a Frozen Bank Account Affect a Foreigner’s Residence Permit?

Not automatically.

A bank-account restriction does not by itself cancel a Turkish residence permit.

However, if the financial investigation develops into criminal proceedings or other circumstances relevant to immigration law, separate immigration consequences can potentially arise.

The foreigner’s immigration status should therefore be assessed independently rather than assuming that the account freeze automatically means deportation.

Does a MASAK Investigation Mean the Foreigner Will Be Deported?

No, not automatically.

Financial investigation, criminal liability and immigration measures are separate legal questions.

A foreign national should not assume that a frozen bank account means deportation is inevitable.

If a separate deportation decision is later issued, that decision has its own legal framework and remedies.

How Long Does It Take to Remove a MASAK-Related Block?

There is no single answer.

The duration depends heavily on what type of restriction exists.

An internal bank compliance review may be resolved differently from a statutory transaction postponement.

A criminal seizure may continue while the investigation proceeds unless lifted or modified.

This is precisely why determining the legal basis is the first step.

A person cannot reliably calculate the expected duration simply from the phrase “MASAK block.”

Can the Bank Refuse to Give Any Information?

Banks can be restricted from disclosing certain information relating to suspicious transaction reporting.

However, the foreign customer should still request written clarification regarding the operational status of the account and any information the bank is legally permitted to provide.

If a judicial or prosecutorial file can be identified, the legal investigation should then shift toward that proceeding.

Repeatedly visiting different branches without determining the underlying legal basis often accomplishes very little.

Should Foreigners Contact MASAK Directly?

In many cases, simply sending a general request to MASAK is not the most effective first step.

The appropriate route depends on whether the problem is a bank compliance restriction, MASAK-related administrative measure or criminal-procedure seizure.

If a prosecutor’s investigation exists, applications may need to be directed within that investigation.

The case should therefore be mapped procedurally before documents are submitted randomly to different institutions.

What Is the Best Evidence for Proving Legitimate Source of Funds?

There is no single document.

The strongest evidence usually creates a continuous financial chain.

For example:

Property purchased in 2018 → property sold in 2026 → purchase price deposited into foreign account → same funds transferred to Turkish account.

Or:

Employment contract → monthly salary records → accumulated savings → international bank transfer → Turkish investment.

Or:

Company invoice → customer payment → corporate bank statement → dividend resolution → dividend transferred to shareholder.

The objective is to eliminate unexplained gaps in the financial story.

Example: Foreign Investor’s Account Frozen After USD 700,000 Transfer

Suppose a US investor receives USD 700,000 in a Turkish bank account.

The bank subsequently restricts transactions.

The investor assumes MASAK has accused them of money laundering.

In reality, several possibilities exist.

The bank may be conducting enhanced compliance checks. A suspicious transaction may have been reported. A temporary statutory restriction may exist. Alternatively, a prosecutor may already have ordered seizure in connection with a criminal investigation.

The investor should first determine the nature of the restriction.

If the USD 700,000 represents proceeds from the documented sale of shares in a US company, the investor should prepare the share-sale agreement, US bank statements, tax documentation and SWIFT transfer records.

If a judicial seizure exists, that evidence can then be used in the appropriate application seeking release.

Example: Foreigner’s Account Used in an Online Fraud Chain

Consider a different situation.

A foreign student allows an acquaintance to use their Turkish IBAN.

Several victims of online fraud send money into the account.

The foreign student immediately transfers the money to another person and keeps a small commission.

The account is subsequently frozen.

This is substantially more serious.

Authorities may examine whether the account holder knowingly facilitated the financial chain.

Messages, transaction history, commissions, previous transfers and the relationship between the parties can all become important.

The foreign account holder should not attempt to delete evidence or invent a commercial explanation.

2026 Legal Position

The central legislation remains Law No. 5549 on Prevention of Laundering Proceeds of Crime, together with the Turkish Criminal Procedure Code and secondary anti-money-laundering regulations.

Turkey’s framework requires obligated institutions to conduct customer due diligence and suspicious transaction reporting. Suspicious transaction reports are subject to confidentiality, and urgent suspicious transactions may require immediate reporting. (Resmi Gazete)

Law No. 5549 also contains mechanisms concerning protective measures and postponement of suspicious transactions. Amendments to Article 19/A have strengthened the consequences of acting contrary to a transaction suspension or prevention decision.

For foreigners, the critical practical rule in 2026 remains:

Do not assume that every bank restriction described as a “MASAK block” is legally the same.

The correct response depends on whether the restriction comes from bank compliance procedures, a temporary anti-money-laundering measure or a prosecutor/court seizure.

Frequently Asked Questions

1. Does a MASAK block mean I am accused of money laundering?

No. A restriction or suspicious transaction review does not itself establish that you committed money laundering or another crime.

2. What should I do first if my Turkish account is frozen?

Ask the bank for all information it can legally provide concerning the nature of the restriction and determine whether a prosecutor, court or investigation file is involved.

3. Can I challenge the account freeze?

Potentially, yes. The appropriate remedy depends on the legal basis of the restriction. A criminal seizure requires a different response from an internal bank compliance restriction.

4. What documents should I prepare?

Prepare documents proving the source and purpose of the funds, including bank statements, SWIFT records, contracts, invoices, employment records, property-sale documents, company records or cryptocurrency transaction histories where relevant.

5. Can cryptocurrency cause a Turkish bank account to be frozen?

Crypto-related transactions can receive enhanced compliance scrutiny, particularly where large sums enter the banking system without a clearly documented transaction history.

6. Can legitimate money be released while another transaction remains under investigation?

Potentially. Where funds can clearly be separated and shown to be unrelated to suspected criminal activity, partial release or narrowing of the measure may be requested depending on the legal basis of the restriction.

7. How long does a MASAK block last?

There is no universal duration. Temporary transaction restrictions and criminal seizure orders operate under different rules. The exact legal basis must first be identified.

8. Can I withdraw money for living expenses?

Not automatically. Where the account is subject to a judicial restriction, release of funds may require an appropriate application. Legitimate source of funds and financial hardship can be documented in support of the request.

9. Will my Turkish residence permit be cancelled because my account is frozen?

Not automatically. Financial investigation and immigration status are separate legal matters.

10. Can I handle the case while living outside Turkey?

In many cases, substantial procedural steps can be handled through a Turkish lawyer acting under an appropriate power of attorney, although personal participation may occasionally be required depending on the investigation.

Legal Support for Foreigners With Frozen Bank Accounts in Turkey

The first objective in a MASAK-related bank account case should be to identify exactly who imposed the restriction, which transaction triggered the issue, whether a criminal investigation exists and what evidence proves the lawful source of the money.

Fırat Fesih Kaya Law Office provides legal assistance to foreign individuals, investors and companies concerning frozen Turkish bank accounts, MASAK investigations, suspicious international transfers, cryptocurrency transactions, prosecutor and court seizure orders, criminal investigations and applications seeking release of legitimate funds.

Where a foreigner’s account has already been restricted, Fırat Fesih Kaya can assess the bank records, transfer history, source-of-funds documentation and relevant investigation file to determine the appropriate procedure for challenging or narrowing the restriction.

Particularly in cases involving large international transfers, business payments, property-sale proceeds or cryptocurrency, preparing a documented transaction chronology at the beginning can significantly strengthen the legal response.

Phone: +90 312 434 22 22
Mobile Phone: +90 532 769 22 22
Email: info@firatfesihkaya.av.tr
Address: Mevlana Boulevard No: 221, Yildirim Tower, Balgat, Cankaya / Ankara, Turkey