Bank KYC questionnaire in Türkiye: question blocks, consistent answers and typical mistakes
Before a Turkish bank opens an account, and again during the relationship, it asks you to complete a KYC questionnaire (müşteri tanıma formu or KYC formu). Your answers become the profile against which every later transaction is compared. This guide walks through the question blocks for companies and individuals, shows how to back each answer with a document, lists the mistakes that most often lead to follow-up questions and explains what to do when your business changes. Status checked on 14 November 2026.
Why the bank asks and what the form is for
Banks are obliged parties under Law No. 5549. Article 3 requires them to identify customers, and anyone on whose behalf a customer acts, before a transaction. The Measures Regulation (Tedbirler Yönetmeliği) adds the detail: under Article 5(3) the bank obtains information on the purpose and nature of a continuing business relationship, and Articles 6 and 7 list the identity data for individuals and companies.
The questionnaire is where the bank records all of this. It is not filed and forgotten: under Article 19 of the Regulation the bank monitors whether your transactions fit your profile, your business and your source of funds, and keeps customer information current. Every answer becomes a benchmark.
- Identity and ownership: who the customer is and who stands behind it.
- Profile: activity, expected volumes, counterparties and countries.
- Risk questions: source of funds, PEP status and tax residency.
The question blocks and what each is checked against
Forms differ from bank to bank, but most contain the same blocks. A company answers for the entity and its beneficial owners; an individual answers only for himself or herself. The bank compares each answer with a document, so prepare the right-hand column before you start.
| Block | Typical question | Checked against |
|---|---|---|
| Identity | Name, ID or registry number, tax number, address | Passport, residence permit or registry record; address document |
| Ownership (UBO) | Natural persons above 25% | Share ledger, ownership chart |
| Activity | What the business actually does | Articles of association, contracts |
| Turnover | Expected monthly inflows and outflows | Contracts, financial statements |
| Countries and counterparties | Main customers, suppliers, countries | Invoices, customs declarations |
| Source of funds | Origin of the deposit and assets | Salary slips, sale deeds, dividend resolutions |
| PEP | Public function of you or relatives | Your declaration |
| Tax residency | Countries, foreign TIN, US status | CRS/FATCA self-certification |
The form usually ends with a signed statement that the answers are true and complete. Every figure is then attributed to you, so check each line against these documents before signing a draft that someone else prepared.
Answering activity, turnover and counterparty questions
Most follow-up questions come from the profile block. Describe the activity concretely: not “trade” or “consulting”, but “import of industrial pumps from Germany for resale to Turkish factories”. It should match the activity subject (faaliyet konusu) in your articles of association, which Article 7 of the Regulation lists among the data the bank records.
- Base expected turnover on contracts, orders or last year’s figures, and keep a note of the calculation.
- Give a realistic range, not a round figure chosen to look small or impressive.
- List every country you will pay to or receive from, including the banks’ countries.
- Name the counterparties you already know and keep a contract or invoice for each.
Say plainly whether you act for yourself or for someone else. Article 17 of the Regulation requires the bank to take a written declaration, and Article 15 of Law No. 5549 makes undisclosed action for another person’s account an offence.
Source of funds, PEP status and tax residency
Source of funds is where the money entering the account comes from; source of wealth is how your assets were built overall. Keep both short and traceable: “sale of an apartment in 2025, deed and bank statement attached” works better than a page of career history.
The PEP question follows MASAK General Communiqué No. 21. It covers persons entrusted with a significant public function in Türkiye or abroad, senior managers of international organisations, and their spouses, first-degree relatives and close associates. A “yes” is not a refusal: the bank needs senior approval, takes reasonable measures on the source of assets and funds and monitors more closely, for at least one year after the person leaves office.
The tax residency block is a self-certification for CRS and, for US persons, FATCA. A declared foreign residence is reported through the Revenue Administration (GİB); a declared Turkish residence must be verifiable, for example through the address registration system. The bank does not decide your residency for you; ask a tax adviser if in doubt.
Typical mistakes and what happens when answers change
Most follow-up requests do not mean the bank suspects anything. They usually come from a few inconsistencies between the form, the documents and the account activity, which a monitoring system flags automatically. The most frequent are:
- A vague activity that does not match the articles of association.
- Expected turnover far from what the contracts show.
- Payments involving a country not listed in the form.
- Beneficial owners that differ from the share ledger or the GİB filing.
- Blank PEP or tax residency answers.
Answers are not fixed for ever. Article 19 obliges the bank to keep customer information current, so it may send a new questionnaire or ask for documents. If your business changes, tell the bank first: a new country, shareholder or jump in volume is easier to explain in advance.
If the bank cannot identify you or learn enough about the purpose of the relationship, Article 22 says it neither opens the relationship nor carries out the transaction; if doubts later arise about data already given, the relationship is ended.
Sources
- lexpera.com.tr — Law No. 5549 on the Prevention of Laundering Proceeds of Crime, consolidated text, Articles 3, 4, 8 and 15 (mevzuat.gov.tr blocks automated access, so this copy was used)
- lexpera.com.tr — Regulation on Measures against Laundering and Terrorist Financing, consolidated text, Articles 5, 6, 7, 17, 17/A, 19 and 22
- ms.hmb.gov.tr — MASAK General Communiqué No. 21 (Resmî Gazete 17.11.2022) on politically exposed persons
- ziraatbank.com.tr — a Turkish bank’s official page on CRS: GİB as competent authority, residence declarations and verification
Questions
Is the KYC questionnaire required by law?
The form is the bank’s own, but the information is required: Article 3 of Law No. 5549 and Articles 5 to 7 of the Measures Regulation oblige the bank to identify the customer and learn the purpose and nature of the relationship.
What if my real turnover turns out higher than I declared?
That is not a violation in itself, but under Article 19 the bank compares transactions with your profile and may ask for an explanation. Update the bank with contracts before the change shows in the account.
Does answering “yes” to the PEP question mean refusal?
No. MASAK General Communiqué No. 21 requires senior approval, measures on the source of assets and funds and closer monitoring. The decision to open or continue stays with the bank.
Can I leave the tax residency section blank?
It should not be left blank. A declaration of foreign residence is reported through GİB, and a declaration of Turkish residence must be verifiable; the bank may not proceed until the section is complete.
Will the bank explain why it sends new questions?
Not always. Article 4(2) of Law No. 5549 forbids disclosure of a suspicious transaction report to anyone, so a request may simply be framed as a customer information update.