A legal guide for foreign account holders in Türkiye, including Iranian nationals · Updated October 2026
If a bank in Türkiye will not let you withdraw or transfer funds, a transfer has been stopped or access to your balance has been restricted, the first question is not how to move the money another way. The first question is: what is the legal basis of the restriction, and who imposed it?
“My account is blocked” can describe several quite different legal situations, each with its own remedy.
| 1. Haciz | Attachment in debt enforcement proceedings |
|---|---|
| 2. Elkoyma | Judicial seizure in a criminal case |
| 3. Suspension of a transaction | Temporary suspension under Article 19/A of Law No. 5549 (seven business days) |
| 4. Formal asset freeze | A freezing decision under Laws No. 6415 and 7262 |
| 5. The bank’s own decision | Internal compliance and risk review |
1. Is there a haciz on the account?
If enforcement proceedings are pending against the account holder, his or her claims and balances at the bank can be attached under the Enforcement and Bankruptcy Law. The bank is then not the source of the problem; it is carrying out the enforcement office’s order. You need to know:
- which enforcement office imposed the attachment and the file number;
- the amount claimed and its basis;
- whether objection, payment, release or another legal step is available.
Visiting the branch will not resolve a haciz.
2. Has the account been seized in a criminal case?
Elkoyma is not the same as haciz. Article 128 of the Code of Criminal Procedure allows, in defined circumstances, the seizure of assets, rights and claims, including bank accounts, during a criminal investigation or trial. The bank must comply. The decision itself, the authority that issued it, the underlying criminal file and the route of objection have to be examined.
In addition, Article 128/A, added at the end of 2025, allows banks and payment institutions, on reasonable suspicion of certain defined offences such as fraud committed through banking systems, to suspend an account for a short period (up to 48 hours) and report the matter to the public prosecutor. The account holder can ask the prosecutor to lift the measure.
3. Has a transaction been suspended under anti-money-laundering rules?
MASAK (Mali Suçları Araştırma Kurulu) is Türkiye’s financial intelligence unit. Under Article 19/A of Law No. 5549, where there is suspicion that the assets in a transaction are connected with money laundering or terrorist financing, the Minister of Treasury and Finance may suspend the transaction, or refuse to allow it, for seven business days so that it can be examined.
Not every transaction a bank declines has been stopped by MASAK. The bank may simply be running an internal review or asking for more documents. Before assuming that “MASAK closed my account”, establish what was actually decided and by whom.
4. Is there a formal asset-freezing decision?
Turkish law has specific asset-freezing mechanisms: Law No. 6415 on the prevention of terrorist financing and Law No. 7262 on the prevention of financing of the proliferation of weapons of mass destruction, which also implement United Nations Security Council resolutions. These decisions are published in the Official Gazette and restrict any use, transfer or disposal of the assets concerned. The law provides for objection, delisting requests and permission to access funds for basic expenses.
After the United Nations sanctions were reinstated in September 2025, Türkiye froze the assets in Türkiye of the listed persons and entities by a Presidential Decision published in the Official Gazette of 1 October 2025. That measure is list-based; it is not a general measure against Iranian nationals.
Iranian nationality, or a bank’s use of words such as “sanctions” or “compliance”, does not mean that a formal freezing decision exists. The real basis of the restriction has to be identified.
5. Is it the bank’s own compliance review?
Not every restriction comes from a court, an enforcement file or an official decision. Turkish banks are required by anti-money-laundering rules to know their customers, monitor transactions and apply a risk-based approach. A bank may want to know:
- where the money came from and what the transfer is for;
- how sender and recipient are connected;
- which contract or business activity the transaction relates to;
- who the beneficial owner is;
- whether the transaction fits the customer’s activity and financial profile.
Under Law No. 5549 a bank may not tell a customer that it has filed a suspicious transaction report, so it may be unable to explain all its reasons.
A bank may also decide, under its own compliance and risk policies, not to carry out a transaction or not to continue a relationship. That is not a “legal seizure” of the account, and the way to deal with it is different.
Why does the bank ask about the source of funds?
For significant transactions, the lawful origin of the funds and the purpose of the transfer are central. The right documents depend on the real source: bank statements, a property sale contract, evidence of income or business activity, company profit records, inheritance documents or the commercial contract behind the payment.
The documents must be genuine and must match the real origin of the money and the real nature of the transaction. Giving a bank an untrue document or explanation can give rise to criminal liability.
If the bank asks for documents
Before sending papers piecemeal, find out exactly what the bank is examining. The contract, invoice, company documents, statements and the customer’s explanation must be consistent with one another. Incomplete or contradictory information prolongs the review. For substantial commercial or investment payments, source-of-funds and purpose documents should be prepared before the money is sent.
Does being Iranian mean the account will be restricted?
No. Nothing in Turkish law bars a person from banking services on the ground of Iranian nationality alone. Banks do, however, apply their own compliance and sanctions policies and the requirements of their international correspondent banks in addition to Turkish law. Foreign sanctions rules relating to Iran have tightened in recent months, and banks can be expected to act more cautiously.
The outcome differs from bank to bank, customer to customer and transaction to transaction. No lawyer can guarantee that an account will be opened or a transaction accepted.
What not to do when a transfer is stopped
A stopped transfer should not be answered by trying to get around the restriction. Using other people’s accounts, splitting the amount, opaque routes or an untrue description of the payment do not solve the problem; they can themselves lead to a suspicious transaction report, closure of the account and criminal liability. Tercan Legal does not advise on such arrangements.
First establish whether:
- the bank simply wants documents or has imposed an internal restriction;
- there is an enforcement attachment;
- a judicial decision has been made about the account;
- a transaction has been suspended under anti-money-laundering rules;
- or another official decision exists over the assets.
Useful documents
- the bank’s message, email or notice about the restriction;
- the relevant statement and transfer receipt;
- the contract or invoice behind the payment;
- source-of-funds documents;
- company documents, if the transaction is commercial;
- any notice from a court or enforcement office.
Can a lawyer guarantee that the account will be released?
No. It depends on the cause. A lawyer can identify the legal basis of the restriction, assess the documents and the file and, where a lawful route exists, object, apply for release, respond to a document request or correspond with the authority concerned. The decision of a court or public authority, or a bank’s final assessment, cannot be guaranteed in advance.
How Tercan Legal can help
Tercan Legal reviews the banking and legal documents, identifies which type of restriction applies and, where a lawful route exists, represents the client in the related correspondence and proceedings. The firm’s experience in banking and finance law and international transactions is relevant to files where legal, banking and compliance issues arise together.
If your account in Türkiye has been restricted or a transfer is not going through, establish the exact cause and the authority behind it before doing anything else.
Contact Tercan Legal: info@tercanlegal.com · WhatsApp and Telegram: +90 506 689 97 22. We can communicate in Persian. The first 20-minute online introductory meeting is free; document review, written opinions and detailed consultation are provided for a fee.
Scope and compliance note
This article is general information on Turkish law as it stood in October 2026. It is not legal advice, does not create an attorney–client relationship and is no substitute for a review of your own file. It does not cover Iranian law or the sanctions laws of the United States, the European Union, the United Kingdom or any other jurisdiction; where those rules may apply, advice should be taken from counsel qualified in that jurisdiction.
Tercan Legal carries out identity and sanctions-list checks before accepting any engagement. We do not act for persons or entities that are subject to an asset-freezing decision in Türkiye or listed under applicable sanctions regimes, except to the extent the law permits, and we do not advise on or take part in arrangements designed to avoid bank controls or sanctions. No outcome before a court, a public authority or a bank can be guaranteed.
