BlogBank Account Blocked in Turkey or Transfer Delayed: What to Do?

A legal guide for foreign nationals and foreign-owned companies in Türkiye · Updated October 2026

If your bank account is blocked in Turkey, or an international transfer is delayed, rejected or returned, you may be unable to use your funds, meet your payment obligations or keep your business running.

Not every restriction, however, is linked to sanctions, a criminal investigation or a decision of a Turkish public authority.

The first legal question is who imposed the restriction, on what basis, and which transactions it covers. The answer determines which documents to submit, which authority to address and whether there are grounds to challenge the measure.

1. Why might a Turkish bank block an account or delay a transfer?

The reasons vary widely. In some cases the bank is running an internal review of the customer or the transaction. In others the restriction stems from enforcement proceedings, a criminal investigation or special measures provided for by law.

To assess the situation correctly, the following cases need to be told apart:

A message from the bank that a transaction is “under review” therefore does not, on its own, reveal the legal reason for the restriction.

2. What does a bank compliance review mean?

Turkish banks are required to identify their customers, monitor transactions and prevent the financial system from being used for unlawful purposes. As part of such a review, the bank may ask for:

• identity documents and proof of address;
• information about the activities of the customer or the company;
• information about the beneficial owners of a legal entity;
• documents showing the source of funds;
• contracts, invoices and other documents relating to the payment;
• information about the counterparty and the economic purpose of the transaction.

For companies operating internationally, the bank may also look at the ownership structure, the nature of the goods or services, the countries involved and the role of correspondent banks. A bank may apply its own risk-assessment rules within the limits of the applicable legislation.

Important: a request for documents does not in itself mean that the customer is suspected of an offence. At the same time, a bank is not obliged to approve every transaction or to continue a customer relationship regardless of the risks it identifies.

3. Enhanced checks on cross-border transactions

Cross-border banking transactions may be subject to additional checks. In practice, such checks are frequently encountered by, among others, Russian citizens and companies with Russian participation.

The reason does not necessarily lie in the customer’s citizenship. What may matter are specific sanctions restrictions, the ownership structure, the financial institutions involved, the nature of the transaction, the counterparties and the rules applied by correspondent banks.

Four different mechanisms need to be distinguished:

• the requirements of Turkish law;
• international sanctions applicable to particular parties or transactions;
• the internal policy of the Turkish bank;
• the requirements of a foreign correspondent bank.

These mechanisms are not interchangeable. Citizenship alone is not a ground for blocking an account. However, whether a specific transaction is lawful and whether it can actually be carried out has to be reviewed case by case.

Legal assistance in these situations is aimed solely at identifying the applicable requirements, preparing accurate documents and resolving the matter lawfully. It is not, and cannot be, aimed at circumventing sanctions or bank restrictions.

4. What is MASAK, and can it suspend a transfer?

MASAK (Mali Suçları Araştırma Kurulu) is the Financial Crimes Investigation Board under the Ministry of Treasury and Finance of Türkiye. Law No. 5549 on the Prevention of Laundering Proceeds of Crime provides a special mechanism for suspending financial transactions.

Under Article 19/A of Law No. 5549, where there are suspicions of the kind defined by law that assets are connected with money laundering or the financing of terrorism, a transaction may be temporarily suspended or its execution temporarily prohibited.

The period provided for in Article 19/A is seven working days. The decision under this procedure is taken by the Minister of Treasury and Finance or by a deputy minister to whom the power has been delegated. MASAK examines and analyses the suspicious circumstances and, where necessary, passes its findings to the competent authorities.

Three points should be kept in mind:

1. the seven-day period belongs to the special mechanism of Article 19/A, not to every kind of bank restriction;
2. the article itself provides for a seven-working-day period; a different, independent legal basis may apply afterwards;
3. the end of a MASAK suspension therefore does not mean that the funds become available in every case.

It follows that one cannot say that any blocked account must be released after seven working days.

5. Can the bank decline to disclose the reason for the restriction?

Yes. In certain situations the bank is limited in what it is permitted to tell the customer. This may be due to confidentiality requirements, including those that apply to suspicious transaction reports and related reviews.

Being unable to obtain a full explanation does not mean, however, that every restriction is automatically lawful or beyond legal assessment. It is worth establishing what information the bank is able to give, which documents have already been requested and whether there is a formal decision of a competent authority.

6. How does a bank restriction differ from attachment of an account for debts (haciz)?

Attachment in enforcement proceedings (haciz) may be applied in connection with the collection of a debt. Under Law No. 2004 on Enforcement and Bankruptcy, collection may extend to the debtor’s money held in a bank account.

One of the mechanisms provided by law is a notice served on the bank attaching the debtor’s claim against a third party (haciz ihbarnamesi), in particular under Article 89 of Law No. 2004.

If funds are restricted in such proceedings, the following should be checked:

• which office is conducting the enforcement proceedings;
• on what claim the collection is based;
• who is named as the debtor;
• what amount is being collected;
• which procedural documents have been sent or served;
• whether there are grounds for an objection or other steps provided by law.

In this situation, sending the bank further documents on the source of funds may not resolve the matter by itself. It is the enforcement file, and the procedural remedies attached to it, that need to be analysed.

The applicable time limits and procedures depend on the nature of the enforcement step and on the procedural position of the person concerned. Any documents received should therefore be reviewed without delay.

7. What if the restriction is linked to a criminal investigation?

If an account or funds are restricted as part of a criminal investigation, the provisions of the Turkish Criminal Procedure Code No. 5271 may apply, in particular Article 128 on the seizure of assets (elkoyma). The statutory conditions for this measure have to be taken into account, including the evidentiary requirements and the competence of the authority making the decision.

Article 17 of Law No. 5549 also contains special provisions on protective measures in cases relating to money laundering and the financing of terrorism.

The legal assessment depends on the nature of the measure, the competent authority, the content of the decision and the stage of the proceedings. Depending on the basis of the restriction, the law may provide for applications to the competent authorities or for a challenge before the courts.

It is therefore important to obtain and study the procedural documents that are available, rather than assume that the restriction was imposed by the bank alone.

8. How does a formal asset freeze differ from a bank’s sanctions screening?

A formal asset freeze (malvarlığının dondurulması) must be distinguished from a bank’s internal review or its refusal to carry out a transaction. In Türkiye the relevant mechanisms are laid down, in particular, in the following statutes:

The Turkish asset-freezing mechanism may apply to persons and entities included in the relevant UN lists or covered by decisions provided for under Turkish legislation. Banks may, in addition, apply their own international compliance and sanctions policies.

A bank’s restriction on a transaction therefore does not necessarily mean that a formal asset-freezing decision exists in Türkiye. Whether an appeal, a review of the decision or removal from a list is possible depends on the legal basis of the particular measure.

9. What to do if an international transfer is delayed or returned?

A transfer delayed in Turkey does not always mean that the account itself is blocked. A payment may be held or rejected because of a document review, the requirements of the sending bank, the receiving bank or a correspondent bank, or applicable restrictions.

For a legal assessment, the following should be collected:

1. the payment order and confirmation that it was sent;
2. details of the sending and receiving banks;
3. any available bank messages on the status of the payment;
4. the contract or other document showing the basis for the transfer;
5. invoices and documents on the underlying commercial transaction, where applicable;
6. written correspondence with the banks.

It should be established separately whether the transfer was rejected, returned, temporarily held or is still under review. Each of these has different consequences and calls for different next steps.

10. Can a blocked bank account be challenged?

Whether a challenge is possible depends on the legal basis of the restriction:

• if it is the bank’s own decision, the contractual relationship, the applicable banking rules and the facts of the case have to be analysed;
• if the restriction arises from enforcement proceedings, the procedures of enforcement law apply;
• if there is a judicial or procedural decision in a criminal case, the remedies under criminal procedure law have to be assessed;
• if a formal asset-freezing decision is in force, the special rules governing that measure apply.

There is no single procedure that fits every blocked account. Before filing a complaint or going to court, the legal nature of the restriction has to be identified correctly.

11. Which documents to prepare for a legal consultation?

For an initial assessment it is useful to prepare:

• an identity document or the company’s registration documents;
• the name of the bank and details of the account affected;
• statements showing the relevant transactions;
• the bank’s messages about the restriction or refusal;
• correspondence with the bank;
• documents on the source of funds;
• contracts and invoices for the transfers in question;
• any enforcement, court or procedural documents you have;
• a timeline: when the problem arose, which requests were sent and which replies were received.

For corporate clients, documents on the owners, managers and actual business activity may also be relevant. The more precisely the source of the restriction is identified, the more accurately the available remedies can be assessed.

12. What should you not do when an account is blocked?

Do not give the bank inaccurate documents, conceal material information about owners or counterparties, or take steps aimed at getting around restrictions that are in force.

Using third parties, nominee holders, split payments or other channels to move funds that are subject to a restriction may itself create legal exposure, both for the owner of the funds and for those who take part.

Nor should it be assumed that opening a new account will resolve the position of funds that are already restricted. If the restriction rests on a binding decision of a competent authority, changing banks does not set that decision aside.

Where there is an international element, requirements beyond Turkish law may also apply. Questions of foreign law should be put to a qualified adviser in the relevant jurisdiction.

13. When is it worth consulting a lawyer?

Legal assistance may be particularly important where:

• the bank has restricted access to a significant amount;
• a delayed transfer affects the performance of a commercial contract;
• the customer has been told of enforcement proceedings or a court measure;
• the bank has asked for a complex set of documents;
• the restriction remains in place and its legal basis is still unclear;
• several countries or financial institutions are involved in the transaction;
• it needs to be determined whether a challenge is possible and which authority is competent.

A lawyer can review the documents, identify the applicable legal procedure, prepare the necessary applications and assess the remedies available.

A bank, however, is not obliged to approve every transaction or to continue the customer relationship. Legal representation does not mean that access to the funds will be restored or that the bank will approve a transaction.

Conclusion: where to start

A blocked account or a delayed transfer in Türkiye may have quite different legal bases. It is important to distinguish between a bank compliance review, attachment in enforcement proceedings (haciz), criminal procedure measures (elkoyma), a temporary suspension of a transaction and a formal asset freeze.

A sensible order of steps:

1. establish the nature of the restriction;
2. collect the documents;
3. identify the competent authority;
4. check the time limits and procedures;
5. assess the lawful remedies.

Every case requires individual assessment. No outcome can be guaranteed.

How we work

Tercan Legal advises on Turkish law. Before accepting any matter we carry out identity, conflict and sanctions checks.

We do not act for persons or entities designated under the sanctions regimes we are required or have undertaken to observe, and we do not advise on, design or facilitate any arrangement intended to avoid sanctions, banking compliance, anti-money-laundering or currency rules.

Our work in this area is limited to identifying the legal basis of a measure, preparing accurate documents and using the remedies available under Turkish law.

Tercan Legal

Tercan Legal advises foreign nationals and companies on Turkish law, banking restrictions, commercial disputes and legal protection in cross-border situations.

If your account in Türkiye has been restricted or an international transfer has been delayed, our lawyers can review the documents, identify the legal basis of the restriction and the competent authority, and assess the remedies available.

To arrange a call, write to us at info@tercanlegal.com or on WhatsApp: +90 506 689 97 22.

This article provides general information as of October 2026 and is not legal advice. Rules and administrative practice change; check the requirements on the date of your transaction. Reading this article does not create an attorney-client relationship.