Frozen Bank Account in Turkey: MASAK Reviews, Suspensions and Legal Remedies

Many account holders discover a restriction without warning: an overseas transfer fails to arrive, the app says the account is restricted, or a branch says the matter is with head office. These situations are often all called a “MASAK block.” But the Financial Crimes Investigation Board (MASAK) does not freeze accounts indefinitely. Many restrictions are imposed by banks or judicial authorities rather than MASAK.

This guide explains the different measures, their time limits and remedies. It does not cover attachments imposed by an enforcement office or tax authority, which have separate appeal routes.

1.What Is a MASAK Block and Why Does It Happen?

“MASAK block” is an informal term for stopping transactions amid suspected laundering of criminal proceeds or terrorist financing. The principal legal bases are Law No. 5549 on the Prevention of Laundering Proceeds of Crime and the Criminal Procedure Code.

The bank identifies and reports a suspicious transaction first. If it has information or suspicion that the funds are proceeds of unlawful activity, it must report the transaction to MASAK. There is no minimum reporting amount, so even a small transfer can be examined if its explanation does not match the customer's profile.

Common triggers include sums inconsistent with known income and poorly explained international transfers. Immediate cash withdrawals, intensive crypto-platform activity and a refund request from a fraud victim's bank may also trigger review. None of these circumstances alone proves a crime; they call for an explanation of the funds' origin.

2.How Can a MASAK Block Be Lifted?

The remedy depends on who imposed the restriction. Supply documents to the bank for its own compliance review; ensure evidence reaches MASAK for a transaction deferral; apply to the prosecutor for a 48-hour suspension; and object before the criminal judgeship of peace against judicial seizure. The decision-maker and time limit differ in each case.

This table excludes enforcement and tax attachments. Applying to a criminal judge against the bank's internal review will not solve that review. Merely writing to the bank about a judicial seizure, on the other hand, may cause the objection period to expire.

3.How Can I Find Out Who Restricted the Account?

Ask the bank in writing. MASAK offers no public portal through which individuals can check whether their accounts are blocked. The account-holding bank is the most direct source of information about the type of restriction and the date of any decision.

Its scope also matters: sometimes only a particular transfer or amount is held, rather than the whole account. If there is a judicial decision, its issuing authority and case number are needed to identify the decision to contest.

Do not rely solely on an oral branch response. A dated written record establishes what was learned and when, which may be decisive for deadlines. If there is a criminal investigation, a lawyer may also check available case details through UYAP.

4.Why Will the Bank Not Disclose a Suspicious Transaction Report?

A bank cannot tell its customer that it filed a suspicious transaction report with MASAK. The law prohibits disclosure to anyone, including transaction parties, other than supervisory officials and courts. This is why branch staff may say only that the compliance unit is reviewing the matter; disclosure can carry criminal liability.

That prohibition concerns the report itself. A deferral decision received by the bank, a prosecutor's letter or a judge's order directly affects the customer's legal position. The customer can therefore ask for the restriction's legal basis rather than for the report. In practice, banks often confirm that a deferral decision exists.

5.What Does a Request for Source-of-Funds Documents Mean?

A bank requesting evidence of the funds' origin often indicates that there is no official order yet and that its own compliance review is under way. Know-your-customer rules require banks to ask about a transaction's purpose and source of funds.

A coherent, complete explanation may end the matter before it reaches MASAK or a prosecutor. Conversely, a statement inconsistent with the transfer description, a contract apparently drawn up afterwards, or an unanswered request may reinforce suspicion.

The initial explanation given to the bank may remain in the file and be compared with later statements. A different account of the same transaction later given to MASAK or the prosecutor can itself create suspicion. The first written explanation should therefore match the documents precisely.

6.What If the Bank Keeps the Restriction After Receiving Documents?

If the bank continues a restriction without identifying a basis, possible routes include a complaint to the Banking Regulation and Supervision Agency (BDDK), an application to the Individual Customer Arbitration Panel where available, or a claim for release of the deposit. A bank is protected when complying with legal duties, but an indefinite restriction without a basis does not gain that protection.

Any customer may complain to BDDK. The Turkish Banks Association's Individual Customer Arbitration Panel is available to individual customers subject to conditions. These channels review the bank's conduct; they cannot cancel a prosecutor's or judge's decision.

If no official order supports the restriction, the account holder may sue for payment and release. For a company, the commercial court of first instance hears the case, and mediation is mandatory before filing. For an individual, jurisdiction depends on whether the holder is a consumer. The court examines the decisions and dates supporting the restriction. An action against the bank will generally not lift a valid deferral or seizure order.

7.How Long Does a MASAK Block Last?

There is no general statutory MASAK-block period of 15, 30 or 60 days. Each transaction-deferral decision lasts seven business days, but further decisions may follow new reports. If the case reaches the prosecutor, the measure may become a seizure without a fixed expiry date. The Minister of Treasury and Finance makes deferral decisions following MASAK's assessment and may delegate that authority to a deputy.

The law permits suspension of a suspicious transaction, or refusal to allow it, for seven business days to confirm suspicion, analyse the transaction or forward findings to competent authorities.

Weekends and public holidays do not count. Seven business days often means nine calendar days or longer if holidays intervene. When the bank reports a transaction and requests deferral, time runs from the report; for a decision made by MASAK on its own initiative, it runs from notification to the bank. The decision is communicated to the bank; the rules do not provide for separate service on the account holder, who may learn of it only from the bank's written reply.

8.Why Is My Account Still Restricted After Seven Business Days?

The expiry of seven business days may mean that a new deferral decision has been issued or that the legal basis has changed. The period applies to one decision and does not guarantee access to the account at its end.

Successive deferrals can follow new suspicious transaction reports. In a case considered by the Court of Cassation's 11th Civil Chamber on 24 April 2025 (E. 2025/1664, K. 2025/2763), nine separate deferrals were imposed on the same account over several months. The funds were released only after a decision not to defer the transaction.

The prosecutor may also have taken over the matter, in which case a prosecutorial or judicial measure, rather than the original MASAK deferral, controls. Seven business days passing does not automatically remove the restriction. Request an updated written explanation from the bank.

9.Can a MASAK Deferral Be Challenged in Court?

A MASAK deferral is an administrative act, so an administrative-law challenge may be considered. The general filing period for administrative cases is 60 days, but the starting date needs separate assessment when the decision was not served on the account holder. Because a deferral lasts only seven business days, a case may finish after that particular decision has expired.

Since the bank cannot share the suspicious transaction report, it also matters whether the documents submitted to the bank reached MASAK's assessment. A challenge can still matter: where decisions recur, a finding of unlawfulness may support a later compensation claim.

10.Who Can Be Affected by a 48-Hour Account Suspension?

Article 128/A of the Criminal Procedure Code, introduced by Law No. 7571 published on 25 December 2025, permits banks, payment institutions and crypto-asset service providers to suspend an account on their own decision for up to 48 hours. It commonly affects accounts through which suspected fraud proceeds have passed.

The power covers only specified offences: aggravated theft using information systems, misuse of bank or credit cards, and two forms of aggravated fraud—fraud using information systems or banks, or fraud by impersonating a public official or bank employee. On reasonable suspicion of one of these offences, an account used in the offence can be suspended, even if a person who received payment for an advertised item did not participate in the fraud. Suspected laundering outside those offence categories does not itself justify this measure.

11.How Do I Ask the Prosecutor to End a Suspension?

The holder of an account suspended for 48 hours may apply directly to the chief public prosecutor's office. The prosecutor must decide the request within 24 hours. The bank must notify both the prosecutor and the account holder of the suspension.

Because the limit is measured in hours, apply before the 48 hours end. The proceeds involved may be seized during that period. A seizure ordered in writing by the prosecutor must be submitted to a judge within 24 hours; if the judge does not rule within 48 hours, the seizure ends automatically. The law also excludes civil liability for a bank making a suspension under this article. The immediate route is therefore a prosecutorial application, not a claim against the bank.

12.When Can a Judge Order Seizure of a Bank Account?

Judicial seizure requires strong suspicion based on concrete evidence that a listed offence has been committed. The account is then restricted as part of a criminal investigation without a predetermined expiry date. Law No. 5549 also allows this procedure for suspected laundering and terrorist financing.

As a rule, a criminal judge of peace orders seizure. In urgent laundering or terrorist-financing investigations, a prosecutor may order it, subject to a judge's approval within 24 hours; the judge must decide within a further 24 hours. Without approval, the prosecutor's order ceases to have effect.

Ordinarily, a report on the value allegedly derived from crime must be obtained from MASAK, BDDK or another relevant body such as the Capital Markets Board. The report is due within three months, extendable by two months for special reasons. That report requirement does not apply to seizure within the 48-hour suspension procedure.

13.What Is the Objection Deadline for a Seizure Order?

The objection period is two weeks from learning of the judge's seizure decision. File a petition with the criminal judgeship of peace that issued it. If the judge does not revise the decision, the file is sent within at most three days to the next numbered competent judgeship for review.

An amendment published on 12 March 2024 increased the period from seven days to two weeks; some sources still state the former period. If the objection is missed, the decision becomes final, but seizure is a protective measure and can be reconsidered when circumstances change. The owner can ask the judge to decide again, for example when new evidence emerges, a required report is late or the investigation is prolonged.

A decision not to prosecute may not automatically reach the bank. Request return of the seized funds where needed and check that the release decision has been delivered to the bank.

14.How Long Can Seizure Continue?

The law gives no fixed maximum period, yet seizure cannot continue without limit. The Constitutional Court has repeatedly required proportionality in both the scope and duration of measures affecting property rights.

On 23 December 2025 (application No. 2023/72240), the Court found a property-rights violation where a weapon remained seized for over nine years during criminal proceedings. It emphasised the disproportionate burden of an unreasonably prolonged measure and the need for prompt, diligent action by judicial authorities. That reasoning may support a request to end a long-running account restriction; the original grounds alone may not justify its continuation years later.

15.What Rules Apply to Terrorist-Financing Lists?

Asset freezing under the terrorist-financing regime is distinct from both a MASAK deferral and criminal seizure. It is governed by Law No. 6415 on the Prevention of Financing of Terrorism, and decisions are published in the Official Gazette.

The regime has three sources: UN Security Council lists, requests from foreign states, and domestic decisions about assets in Turkey. A domestic decision requires a final court determination that the relevant structure is a terrorist organisation. On a recommendation from the Assessment Commission, the Ministers of Treasury and Finance and of the Interior decide jointly. The decision must go to the designated serious criminal court in Ankara within 48 hours. The court decides within five days, and an objection is possible.

Interested persons may apply to the Commission for release. It must also review, at intervals no longer than six months, whether reasonable grounds remain. This exceptional regime is unrelated to most bank-account restrictions. A person who merely shares a listed person's name can document the mistaken identity and request release.

16.Why Are Incoming International Transfers Examined More Closely?

An international payment may pass through one or more correspondent banks before reaching Turkey, with a separate compliance check at each stage. An undocumented relationship between sender and recipient, vague payment description or a high-risk origin can trigger review.

Since June 2026, foreigners have been permitted to open accounts remotely with a passport. MASAK General Communiqué No. 32 of 27 June 2026 treats accounts opened this way as high risk: incoming funds may come only from the holder's own accounts abroad and outgoing international transfers may go only to that person's own accounts. A third-party transfer may therefore be restricted under this particular rule.

Do Rules Differ by Nationality?

Turkish law does not generally prohibit bank accounts for a particular nationality. Differences arise from banks' risk assessments and international sanctions, not a nationality-based statutory ban. The same communiqué prevents banks from onboarding remotely, by passport, nationals of countries the bank itself classifies as risky.

Why Are Iranian Customers' Accounts Examined More Often?

As of June 2026, Iran is among the countries for which the Financial Action Task Force (FATF) calls for countermeasures. Turkish banks therefore apply enhanced scrutiny to Iran-linked customers and transfers. US sanctions also make Turkish banks using correspondent banks more cautious. BDDK's 18 September 2026 decision revoking the operating licence of Bank Mellat's Istanbul branch increased sensitivity in this area. Clear documents acceptable to Turkish authorities showing the origin of funds earned in Turkey or brought from abroad are especially important.

Why Do Russian Customers Face Additional Review?

Russia is not on FATF's lists. However, a US secondary-sanctions rule effective from December 2023 targets foreign banks facilitating Russia-linked transactions. According to press reports, some Turkish banks then closed Russian companies' accounts and tightened conditions for individuals. That is a bank risk policy, not a Turkish-law rule. Documents explaining the country, sending bank and underlying commercial relationship can reduce the risk of a restriction.

17.a Real Case: Why Was an Export Payment Blocked for Years?

In 2020 a company in Bursa received approximately €149,000 from a South Korean company. SWIFT messages from the sending bank soon alleged a fraud connection and requested return of the payment. The Turkish bank blocked the funds and reported to MASAK.

At least 13 successive deferral decisions followed, according to documents in the case. The bank told the company only that the transaction had been deferred under Law No. 5549. The company sued in June 2021 for release and damages. During proceedings, the prosecutor told the bank to keep the money blocked pending investigation, but there was no seizure order submitted for judicial approval. The prosecutor later decided not to prosecute.

On 7 February 2024, Bursa 3rd Commercial Court of First Instance (E. 2021/459, K. 2024/155) ordered release because indefinite blocking required a valid prosecutorial or court order. It rejected damages, finding no fault by the bank in light of MASAK's deferral notices. The majority decision was open to appeal; its final status is unknown. The case illustrates how serial deferrals can last months, while an unsupported indefinite block remains subject to judicial review.

18.Which Documents Matter When Reviewing a Restricted Account?

Evidence matters because it connects the source of funds to the transaction's date, amount and parties—not because of its volume. A contract dated after the transfer, a mismatched invoice or a sender who is not the contracting party may deepen suspicion.

For salary, employment contracts and payment records matter; for business payments, agreements, invoices and customs records. For property sales, title and sale papers are relevant; for inheritance and gifts, succession or gift documents. Foreign documents commonly require an apostille or consular legalisation and sworn translation.

The transfer reference also matters. “Payment” may be too vague, while describing a transfer as a “loan” and later calling it a “service fee” creates a contradiction. For crypto-related funds, platform statements and transaction IDs can help trace the source.

19.What Happens to Salary and Essential Expenses During a Block?

A MASAK deferral ordinarily stops a particular transaction. If the entire account is seized, the holder may ask the issuing judge to release funds for essential expenses.

The request can seek to confine seizure to the amount linked to the alleged offence and exclude salary, rent or maintenance payments. Turkish law does not create a separate named “partial release” procedure; the argument rests on proportionality. Specific amounts and supporting records matter. Routing money through others' accounts to evade a block may create a separate suspicion, and breaching a seizure order is independently punishable.

20.Can Compensation Be Claimed for an Unjustified Block?

If a judicial seizure was imposed without the necessary conditions or the seized money was not returned in time, pecuniary and non-pecuniary damages may be sought from the state. Apply to the serious criminal court where the claimant lives within three months of notification that the decision or judgment became final, and in any event within one year of finality.

A decision not to prosecute does not automatically create a compensation claim. The claimant must show, for example, a lack of concrete evidence or a required institutional report, or an unreasonably prolonged measure. A bank is generally not liable for a lawful 48-hour suspension. As the case above shows, MASAK deferral notices may also defeat a fault claim against a bank.

Compensation does not lift the block; it addresses loss afterwards. First seek removal of the restriction, then consider damages.

21.Which Deadlines Apply to a Frozen Bank Account?

Different measures carry deadlines of seven business days, 48 hours, 24 hours, two weeks and three months. Missing some of them can affect the available remedy.

These periods reflect the law in force as of October 2026. The dates of service and actual knowledge must be established for the particular file.

22.Conclusion: Identify the Source of the Restriction First

The decisive issue is not the amount in the account, but which authority imposed the restriction and on what basis. The same app warning may reflect a bank document request, serial deferrals or seizure in a criminal investigation. Obtain the current basis in writing, then give a consistent account supported by the same evidence to the relevant authorities. Correctly reading the order and deadlines can change the course of a case even when the documents are complete.

If you have learned the basis of the restriction and want to assess the appropriate route, you can contact Legal Istanbul with the bank's letter and your documents.