Sending Money Abroad from Turkey: Banking and MASAK Regulations

Summary

Money transfers from Turkey by foreign residents are subject to several layers of regulation — including banking processes (SWIFT, EFT/FAST/payment institutions), the Anti-Money Laundering Law No. 5549 and its implementing regulations, MASAK suspicious transaction rules, the Central Bank’s (CBRT) Decree No. 32 on foreign exchange, and CRS/FATCA information-sharing frameworks.
This guide explains how to make compliant transfers abroad by understanding threshold values, required documentation, and bank reporting practices.

1) Who Can Send Money Abroad and Through Which Channels?

• Banks (SWIFT transfers): The most common, secure, and suitable for large amounts.
• Licensed payment institutions/fintechs: Lower fees and exchange-rate spreads, but MASAK obligations still apply.
• PTT / money transfer companies: Subject to transaction and country limitations.
• Carrying cash: A risky method dependent on customs declarations and limits; discouraged due to MASAK and customs controls.

2) Mandatory Legal Framework

• Law No. 5549 (AML/CFT): Customer identification, suspicious transaction reporting, record-keeping, and submission obligations.
• Regulation on Measures and MASAK Communiqués: Identification, remote onboarding, electronic fund transfer message requirements, and monetary thresholds (as of 2023, the identification threshold for electronic transfers increased to TRY 15,000).
• CBRT Decree No. 32 & related circulars: Foreign-exchange regime, reporting obligations, and classification of export/import/invisible transactions.
• International data-sharing obligations: FATCA (U.S.–Turkey Model 1 IGA since 2015) and OECD CRS automatic information exchange on financial accounts.

3) Identification and Transaction Thresholds

• The general transaction-based identification threshold is TRY 85,000 (per single or linked transaction).
• For electronic transfers (domestic or international), the TRY 15,000 threshold applies; sender/beneficiary data must be fully included in the transfer message and ID verification performed.
• Suspicious transactions have no threshold — MASAK reports are filed whenever abnormal patterns or inconsistencies are detected (clients are not notified).

4) The CBRT “USD 50,000” Rule: A Reporting Obligation, Not a Limit

• Banks must report outbound foreign-currency transfers exceeding USD 50,000 (or equivalent) within 30 days, unless related to imports, exports, or invisible transactions.
• Personal remittances (e.g., family support, living, tuition, medical expenses) are usually classified as invisible transactions and therefore not subject to the same reporting category — though banks may still request documentation and transaction-purpose codes.

Note: This is not a prohibition or cap — it serves statistical and supervisory purposes. Banks may also require written declarations per the Capital Movements Circular.

5) Documentation and “Tevsik” Checklist

1. Identity and residence: Passport + residence permit (or Turkish ID).
2. Proof of fund origin: Salary slip, sale contract, inheritance/gift document, rental contract, declaration + account statements.
3. Beneficiary details: Full name/company, country, bank name, IBAN/SWIFT-BIC, and sometimes address.
4. Purpose-of-payment code: Select the most accurate reason (education, living costs, loan repayment, gift, etc.). For transfers above TRY 15,000, message fields must include all sender/beneficiary data.

6) MASAK “Red Flags” and Bank Due-Diligence Questions

• Large or sudden outbound transfers inconsistent with prior account activity.
• Missing or vague explanations or documentation.
• Third-party accounts with unclear relationships.
• “Structuring” or smurfing (splitting into smaller amounts to evade thresholds).
• Transfers linked to crypto exchanges or cross-border digital-asset flows.

Such cases trigger internal risk review and, if warranted, a Suspicious Transaction Report (STR/ŞİB) to MASAK.

7) Tax and International Reporting (CRS / FATCA)

• FATCA: For U.S. persons, Turkish financial institutions report account data to U.S. IRS via the Model 1 IGA framework.
• CRS (OECD): Turkey exchanges financial account information automatically with partner countries. Your home-country tax authority may receive data on your Turkish accounts and income. Always verify your tax-filing obligations under your country’s residence laws.

8) Common Mistakes and Account Freezes — How to Avoid Them

• Vague or incorrect descriptions: Avoid generic terms like “family support”; provide a clear, documented purpose.
• Split transfers: Sending multiple sub-threshold amounts can raise suspicion.
• Third-party transfers: Provide legal justification (contract, power of attorney, etc.).
• Cash deposits followed by immediate transfers: Ensure transaction patterns align with account history.
• Recipient bank compliance checks: Be prepared for follow-up questions or document requests under AML/CRS controls.
• Crypto-related transactions: MASAK tightened oversight in 2025; travel rule compliance and remote identification requirements apply. Expect additional scrutiny both in Turkey and abroad.

9) Step-by-Step Example: Individual Transfer

1. Hold a valid account → update address/residence information if needed.
2. Initiate SWIFT via branch or online banking: enter beneficiary IBAN/SWIFT-BIC + purpose code + supporting documents.
3. For TRY 15,000+ electronic transfers, ensure message fields include all sender/receiver information.
4. Bank compliance review → release / request additional docs / rarely, temporary block or refund.
5. Expect potential CRS/FATCA-related follow-ups from the recipient bank.

10) Notes for Corporate Accounts

• For corporate inbound/outbound foreign-currency transactions above USD 50,000, documentation and written declarations are often mandatory to clarify whether the flow constitutes a loan, capital, or service payment.
• Export/import operations follow separate regimes (Export Circular, repatriation obligations, etc.).

Frequently Asked Questions (FAQ)

1 – Is there a “legal limit” for sending money abroad?
No general prohibition or ceiling exists. Banks only perform compliance and reporting under MASAK / CBRT regulations. The USD 50,000 rule concerns reporting, not a ban.

2 – Can I send money by splitting it below the threshold?
No. Structuring transactions may itself trigger a suspicious-activity report.

3 – What documents are required?
ID / residence, purpose of transfer (contract, invoice, declaration), source of funds (salary, sale, inheritance), and beneficiary data (IBAN, SWIFT). For electronic transfers above TRY 15,000, message fields are mandatory.

4 – Any extra risk when sending to the U.S.?
Yes. Due to FATCA, U.S.-linked accounts face additional data-sharing and compliance reviews.

5 – Transfers to or from crypto-exchange accounts?
MASAK’s 2025 rules impose travel-rule and remote-identification obligations on virtual-asset service providers. Banks may request further verification.

6 – What if my transfer is blocked? Can I recover the funds?
You should consult a specialized attorney experienced in cross-border banking and MASAK compliance. Multi-channel legal action may be required. We recommend reading our related blog post on recovering blocked transfers for detailed guidance.