Bank asks for documents after you open an account: the periodic KYC update in Türkiye

A letter or app message asking for documents months or a year after your account was opened is usually a routine customer-due-diligence refresh (müşterini tanı), not a sign of a problem. This guide explains the legal basis in Law No. 5549 and the Tedbirler Yönetmeliği, what banks typically request, how to answer in one clean package, and what the sources confirm about deadlines and silence.

Why the bank writes after the account is open

Opening an account does not end the bank’s due diligence. Under Law No. 5549 (Article 3 on identification, Article 4 on reporting) and the implementing Tedbirler Yönetmeliği, a bank must also monitor the customer’s status and transactions during the whole relationship (Article 19) and keep identification information and documents current. A request months later is therefore routine.

In the consolidated copies of the Regulation and of MASAK Communiqué No. 5 that we could read, no single review period is fixed for all customers. How often a bank refreshes a file follows its own risk-based policy. Triggers can be a change in your profile, an unusual transfer, an expiring passport or residence permit, or a scheduled review.

A request for documents is not an accusation, and it tells you nothing about whether any report has been filed. Banks cannot disclose such reports to the customer in any case, so the wording of the letter says little either way. The practical question is only what the bank needs and by when.

What a KYC update usually asks for

Requests differ by bank and customer type, so work from the bank’s own message rather than from a general list. A private account usually triggers a shorter list than a company account, where the bank also asks about activity and counterparties. The groups seen most often are:

• Identity: a valid passport or residence permit (Regulation, Article 6).
• Address: a residence record or a utility bill issued within the last three months.
• Occupation or business, expected monthly turnover and the purpose of the account.
• Source of funds: salary slips, contracts, dividend resolutions, sale deeds.
• For companies: trade registry extract, signature circular, tax number, shareholder list.
• Beneficial owners: each natural person holding more than 25 percent, with identity documents (Article 17/A).

If an item is unclear, ask the bank in writing what exactly it needs. Do not send documents it did not ask for, and do not leave an item out without a short written explanation; both lead to follow-up questions and delay.

How to answer in one clean package

Banks tend to come back with more questions when the first reply is partial or inconsistent. Prepare everything at once and make the story readable for a compliance officer who has never met you. Treat the reply as a small file with a clear order, so that each item can be checked against the bank’s list.

1. Note the deadline, the channel (branch, e-mail, app) and the exact items listed.
2. Gather current versions only: valid ID, address proof under three months old, source-of-funds papers.
3. Add a short cover letter: who you are, what has changed, or that nothing has, and where the funds come from.
4. Attach Turkish translations of foreign-language documents; ask whether a sworn translation is required.
5. Submit through the named channel and keep the receipt or stamped copy.

Spell names and match amounts exactly as in your earlier documents. Where a document has expired or a figure has changed, say so and attach the new version instead of leaving the bank to find the difference.

Deadlines and what silence can lead to

The deadline is set by the bank in its own notice. In the texts we reviewed the law and the Regulation fix no general number of days for a KYC refresh, so do not assume a fixed period and ask for an extension in writing before the date if you need one.

Exact steps, such as which services are limited first, depend on your agreement and are not set out in a public rule. If you disagree with how the bank handled your reply, a written complaint to the bank is the first step; the routes after that are described in our guide on a blocked bank account.

How ROSTU helps prepare the package

We read the bank’s request with you and turn it into a checklist: which items are mandatory, which can be explained and which depend on your profile. We then collect the documents, arrange Turkish translations and check that names, dates and amounts match across the whole file.

We draft the cover letter and can go with you to the branch or help you submit through the channel the bank named. The bank alone decides whether the answer is sufficient. If the situation has already moved to a freeze, see our guide on a blocked bank account.

The result is a file in a fixed order: cover letter, identity and address documents, source-of-funds papers, company papers where relevant, and translations. Each item is labelled, so the person at the bank can tick it off against their own list.

Sources

• masak.hmb.gov.tr — MASAK, Financial Crimes Investigation Board: obligations of banks, guides
• mevzuat.gov.tr — Law No. 5549 and the Regulation on Measures to Prevent Laundering of Proceeds of Crime (Tedbirler Yönetmeliği)
• albaraka.com.tr — example of a bank’s Banking Services Agreement (customer duty to update, bank’s right to suspend)
• tbb.org.tr — Banks Association of Türkiye: customer complaints and arbitration board

Questions