How to answer a Turkish bank's compliance and source-of-funds questions
A payment is held, and the bank sends a short e-mail: explain the nature of the transaction, provide the underlying documents, state the source of funds. Replying late, vaguely or in the wrong language is the most common reason a transfer is returned and an account is closed. This guide explains what the bank is legally obliged to ask, what counts as proof, and how a good reply is built.
Why the bank asks
Under Law 5549 and the MASAK regulations, banks must know their customer (müşterini tanı), understand the purpose and nature of each business relationship and verify the source of funds when a transaction does not fit the profile. The compliance officer is not accusing you; the officer is building a file that must satisfy an internal audit and, potentially, MASAK. If the file cannot be completed within the bank's deadline, the safe choice for the officer is to return the payment. Your job is to make the file easy to complete.
What the letter usually asks
- Who is the counterparty, what is your relationship and since when.
- What goods or services the payment is for; where they come from and where they go.
- The underlying documents: contract, proforma or commercial invoice, packing list, transport document, customs declaration.
- Source of funds: where the money paid to you or by you originally comes from (sales, capital, loan, savings, salary).
- Ownership: who the ultimate beneficial owner of your company and of the counterparty is.
- Sanctions-related questions: countries involved in the production, transport and payment chain; whether any party appears on a sanctions list.
Which documents prove the source of funds
| Source | Documents the bank accepts |
|---|---|
| Trade income | Invoices, contracts, customs declarations, previous bank statements showing the same counterparties |
| Shareholder capital | Registry gazette, capital increase decision, the shareholder's own bank statement and source |
| Loan | Loan agreement, lender's identity documents, transfer record |
| Salary or dividends | Payslips, employment contract, dividend resolution, tax declarations |
| Sale of property or shares | Title deed transfer, sale contract, notarised share transfer, proceeds on statement |
| Savings | Statements over time from the originating bank, tax returns |
Foreign documents are accepted in English by most compliance departments; documents in other languages need at least a sworn translation, and some banks ask for notarised translation (≈ ₺884 per page at the 2026 notarial tariff, paid by you to the notary).
How a good reply is structured
A reply that gets a payment released is short, written in Turkish, and ordered the way the officer's checklist is ordered. We draft replies in four blocks:
- Who we are — company, activity, shareholders, since when, turnover range, tax office.
- What this transaction is — goods, quantity, route, Incoterms, counterparty and relationship, how the price was agreed.
- Where the funds come from — the chain from origin to this payment, with amounts that reconcile to the statement.
- Document index — each statement in blocks 1–3 cross-referenced to a numbered attachment.
Every sentence in the reply is taken from a document you already have; nothing is asserted that cannot be shown. The reply is signed by you or your director; we draft, you check and send through the bank's channel. Our turnaround for a standard reply is one business day from complete documents; banks typically give five to ten business days.
State fees and notarial tariffs are paid by you directly to the state or to the notary; they never pass through us and we receive nothing from any notary. The figures above are the official 2026 tariff, last checked 24.10.2026.
Last verified: 24.10.2026 · source: MASAK Tedbirler Yönetmeliği; 2026 Noterlik Ücret Tarifesi — adalet.gov.trWhat makes a reply fail
- Answering in English or Russian to a Turkish bank officer who must file in Turkish.
- Explaining the business in general instead of this transaction in particular.
- Amounts in the explanation that do not match the invoice or the statement.
- Missing transport or customs evidence for a goods payment.
- Silence on a country the officer can see in the shipping route; disclosed and explained is safer than discovered.
- Replying after the bank's deadline.
Sources
- masak.hmb.gov.tr — MASAK: customer due diligence and suspicious-transaction rules
- mevzuat.gov.tr — Law 5549; Regulation on Measures (Tedbirler Yönetmeliği)
- bddk.org.tr — Banking regulator
- ticaret.gov.tr — Customs declarations and trade documents
Questions
How long do I have to answer?
The bank's letter states a deadline, usually five to ten business days; for an incoming transfer the correspondent bank may impose a shorter one. If you cannot gather everything in time, send what you have with a dated list of what follows; a partial, punctual reply is better than a complete late one.
Can the bank close my account even if I answer?
Yes. A bank may end a relationship without giving reasons. A complete, consistent reply makes that unlikely for an ordinary trading company; a reply that contradicts the documents makes it likely. We never write anything that your documents do not support.
Should I translate every attachment?
No. Attach originals in English as they are; most compliance departments read English. Translate contracts or invoices in other languages with a sworn translation, and have them notarised only if the bank asks for it in writing, because notarisation costs ≈ ₺884 per page.