Bank account blocked in Türkiye: what the bank and MASAK ask, how to respond

A frozen account or a transfer on hold usually means the bank is doing a compliance check under Law No. 5549, not that a decision has been made against you. This guide explains what the bank may ask, how to answer once and in writing, which deadlines are fixed by law, and how to tell a compliance hold from a tax or SGK enforcement block.

Why a bank blocks an account

Banks in Türkiye are obliged persons (yükümlü) under Law No. 5549 on the Prevention of Laundering Proceeds of Crime. Article 3 requires them to identify the customer and apply know-your-customer measures before a transaction; Article 4 requires them to report any transaction they suspect to MASAK, the Financial Crimes Investigation Board. A hold (bloke) on an account or a single transfer is normally the bank pausing while it collects documents it needs to complete that check. The bank may not tell you whether it has filed a suspicious transaction report (şüpheli işlem bildirimi): Article 4(2) forbids disclosure to the parties. So the letter you receive will speak of missing documents or a customer update, not of MASAK. A hold can also come from a court order, enforcement office or tax authority, which is a different procedure covered in the last section.

What the bank may legally ask

Under the implementing regulation (Tedbirler Yönetmeliği) the bank collects and verifies for an individual: name, date and place of birth, nationality, passport or residence permit, address, occupation and contact details. Address is confirmed with a residence record or a utility bill issued within the last three months. It must also record the purpose and nature of the business relationship, so questions about why you opened the account and what the funds are for are lawful. Under the risk-based approach it may ask for a source-of-funds declaration (kaynak beyanı): salary slips, sale contracts, rental agreements, inheritance papers, dividend resolutions. For a transfer it may ask for the counterparty contract, invoice or customs declaration. For a company it checks the trade registry extract (ticaret sicil), signature circular (imza sirküleri), tax number and every natural person holding more than 25 percent (gerçek faydalanıcı).

How to write the reply

Answer once, in writing, through the branch or the channel named in the letter, and keep a stamped copy or the e-mail receipt. Structure the reply chronologically: who you are, why the account exists, where the money came from, what the held transaction is for. Match every amount to a document: a transfer of 48,000 euros should sit next to the contract, invoice and prior bank statement that show it. Foreign-language documents need a Turkish translation; ask the bank whether a sworn translation is required or whether a plain translation is enough. Do not open a new account at another bank for the same funds, do not split the transfer into smaller pieces and do not rely on telephone explanations: a call leaves no record, and Article 15 of Law No. 5549 makes undeclared action on behalf of another person a criminal offence, so state clearly whose money it is.

Timelines and escalation

The deadline for sending documents is set by the bank and is usually written in its letter; the law does not fix a general period. One period is fixed: under Article 19/A of Law No. 5549 the Minister may suspend a transaction for seven working days while MASAK analyses it. If the bank cannot complete identification or learn the purpose of the relationship, the regulation lets it refuse the transaction and end the relationship: in practice the transfer is returned to the sender and the account is closed. If you disagree with the bank, file a written complaint with the bank first. Under the Banks Association rules the bank must answer within 30 days (20 days for card disputes). If it does not, or the answer is unsatisfactory, an individual may apply within 60 days to the Individual Customer Arbitration Board (Bireysel Müşteri Hakem Heyeti), also via e-Devlet. Companies are outside that board and go to BDDK or court.

Compliance hold or e-haciz?

A different block comes from public debt enforcement. Under Article 79 of Law No. 6183 a tax office or the Social Security Institution can serve an electronic attachment notice (e-haciz) on bank head offices; the bank must reply within seven days and freezes the balance up to the debt. The signs are different: the bank asks for no documents, the frozen sum equals a specific debt, and the notice names the tax office or SGK directorate. You can check for an active attachment through the e-Devlet services of the Revenue Administration (gib.gov.tr). The remedy is also different: pay or restructure the debt, or object through the creditor office, after which the bank is released. A compliance hold, by contrast, lifts when the bank is satisfied with your documents. Reading the letter carefully tells you which path you are on before you spend time on the wrong one.

Sources

• masak.hmb.gov.tr — MASAK, Financial Crimes Investigation Board: obligations, FAQ
• mevzuat.gov.tr — Law No. 5549 (anti-laundering) and Banking Law No. 5411
• tbb.org.tr — Banks Association of Türkiye: Individual Customer Arbitration Board
• bddk.org.tr — Banking Regulation and Supervision Agency: complaints and supervision

Questions