This version uses accurate legal and financial terminology, consistent with Turkish law (YUKK, MASAK, CMK, BDDK) and international compliance standards (AML, CFT, FATF).
In recent years, the number of bank account freezes (blockages) in Turkey has significantly increased, affecting both local and foreign individuals.
Such blocking decisions may arise from internal bank compliance checks, MASAK (Financial Crimes Investigation Board) investigations, public prosecutor orders, or enforcement proceedings.
Each situation requires a different legal path for the release of the funds.
This article explains — step by step — which type of legal action or administrative remedy applies depending on the authority imposing the freeze, and how to seek urgent interim relief such as injunctions or stay of execution orders.
a) Blockages Imposed by Banks
Banks may temporarily freeze funds under Law No. 5549 on the Prevention of Laundering of Crime Revenues and their MASAK obligations if a suspicious transaction is detected.
The first step is to request written information from the bank specifying the transaction and the date that triggered the freeze.
If the blockage was imposed arbitrarily or without legal grounds, the account holder may:
Additionally, if the account holder’s objection to the bank’s decision is rejected, an administrative complaint before the Banking Regulation and Supervision Agency (BDDK) can be filed.
b) Blockages Imposed by MASAK (Following a Suspicious Transaction Report)
MASAK may issue a temporary freeze order under Article 19 of Law No. 5549 based on Suspicious Transaction Reports (STR) submitted by banks.
Such orders usually concern money-laundering suspicions or terrorism-financing allegations.
In this case, the affected person may:
Legal Basis: Article 19 of Law No. 5549 — “Decisions of the Financial Crimes Investigation Board to freeze assets.”
If there is a risk that the frozen funds might lose value or disappear during the proceedings, an interim injunction (ihtiyati tedbir) may be requested to lift the freeze temporarily.
c) Blockages Ordered by the Public Prosecutor or Criminal Courts
If the public prosecutor orders a freeze under Article 128 of the Turkish Criminal Procedure Code (CMK) as part of an ongoing investigation, this constitutes a judicial seizure rather than an administrative act.
In such cases, the following remedies are available:
Because this process involves coordination between both the prosecution authority and the banking system, professional legal assistance is essential.
A freeze decision is unlawful if:
In such cases, the affected party may file an annulment lawsuit before the competent court and request a stay of execution to ensure the release of the funds.
Accounts held by foreign nationals often fall under MASAK’s “high-risk transaction” category, especially when large international transfers are involved.
Therefore, for foreigners, the following documents are generally required:
Working with an attorney experienced in both Foreigners’ Law and Financial Law accelerates the process and minimizes the risk of deportation or tax investigation arising from the financial scrutiny.
Recovering blocked funds is not a simple banking procedure; it is a multi-layered process involving administrative, judicial, and financial authorities.
Therefore, especially in cases of MASAK or prosecutor-ordered freezes, professional legal representation is essential.
Our law office provides comprehensive legal services in:
If your funds have been blocked and you wish to recover them or initiate legal proceedings, you may contact our office for individual legal consultation.
1. Why do banks block customer accounts?
Banks may freeze accounts due to suspicious transactions, tax audits, court orders, or MASAK notifications.
Large-amount international transfers often trigger the bank’s internal risk system, causing a temporary freeze for compliance review.
You should obtain a written explanation from the bank and consult a lawyer to challenge the decision.
2. How long does it take to lift a freeze?
The duration depends on which authority imposed it:
3. Why does MASAK freeze funds?
MASAK may freeze funds under Law No. 5549 if a Suspicious Transaction Report (STR) is submitted.
This typically occurs when:
4. How can a MASAK freeze be lifted?
Steps to remove a MASAK freeze:
5. What if the Public Prosecutor imposes the freeze?
Under Article 128 CMK, prosecutors may freeze assets suspected to be crime-related.
Remedies include:
6. When is a bank freeze unlawful?
A bank freeze is unlawful if:
7. Can I get my money back with interest?
Yes.
If the freeze is later found unlawful, the bank or the authority must return the funds with accrued interest.
You may also claim losses due to currency fluctuations during the blocked period in a compensation lawsuit.
8. Why are foreign nationals’ accounts frozen more often?
Foreign clients’ transactions are often flagged as high-risk under Turkish AML compliance systems.
Unverified sources of funds or frequent international transfers may trigger MASAK alerts.
For this reason, foreign nationals should work with a lawyer experienced in both immigration and financial law to resolve the issue.
9. What should I do if my international transfer is blocked?
If a transfer abroad is stopped by MASAK or the bank:
10. What are the deadlines for filing legal action?
11. What if the blocked funds come from cryptocurrency or digital assets?
Large transfers from crypto exchanges often prompt MASAK to request proof of the legal origin of the funds.
Providing exchange account statements and blockchain wallet records usually resolves the issue.
Otherwise, the freeze may remain or escalate to a criminal investigation.
12. Can I send money abroad while my account is frozen?
No.
If a freeze exists, the bank system automatically blocks all SWIFT and EFT operations.
After the freeze is lifted and documents are verified, international transfers may proceed under foreign-exchange (FX) reporting requirements.
13. Why is hiring a lawyer advantageous?
A lawyer determines the correct legal route and supporting evidence depending on the authority involved.
They prepare professional petitions before MASAK, BDDK, or the competent courts, and can request interim injunctions or stay-of-execution orders to expedite the release of funds.
14. How are attorney fees determined in blocked-fund cases?
Fees depend on the authority imposing the freeze, the amount of money, and the complexity of the proceedings.
MASAK and prosecutor-related freezes usually require more extensive work; therefore, fees are assessed accordingly.
Our office provides free preliminary assessments followed by transparent pricing.
15. Does a freeze allow access to my personal data?
No.
A freeze applies only to financial transactions.
Bank confidentiality and personal data remain protected under the Personal Data Protection Law (KVKK).
However, specific financial records may be shared with MASAK or courts when required by law.
The recovery of blocked funds involves banking, administrative, criminal, and financial law simultaneously.
Without professional guidance, individual attempts to resolve the matter are often unsuccessful.
Our law firm offers specialized assistance in:
Contact us to receive expert legal support from our experienced attorneys in Financial Law, MASAK procedures, and Foreigners’ Law.
