A second bank for your Turkish company: why, how to choose and what carries over
Many companies in Türkiye run on one bank until a compliance hold, an outage or a refused credit line stops payments. This guide explains why a second bank reduces that concentration risk, how to choose it, why the new bank builds its own file from your documents, what it sees through the Risk Center and Findeks, and how to keep two accounts clean for your accountant.
Why one bank is a concentration risk
A company with a single bank has a single point of failure. If that bank places a compliance hold on the account, asks for an updated customer file or has a system outage on payroll day, payments to staff, suppliers and the tax office stop at once. A second relationship does not prevent these events; it keeps the business running while one of them is being resolved.
The risk is wider than blocks. Banks differ in which currencies they handle well, which correspondent banks they use abroad and how much appetite they have for a given sector or market. One bank may decline a loan, a POS terminal or a teminat mektubu (bid or performance bond) that another bank is willing to consider.
- Account holds and KYC reviews
- Outages and payment cut-off times
- Currency and correspondent coverage
- Credit lines, POS and teminat mektubu
- Receipt of export proceeds
How to choose the second bank
Start from what the first bank does badly, not from a ranking. Banking Law No. 5411 (Article 3) distinguishes deposit banks, participation banks, which raise funds through special current and participation accounts, and development and investment banks, which lend but do not take deposits. An operating company normally needs a deposit or participation bank.
| Criterion | What to ask the bank |
|---|---|
| Currencies and correspondents | Which currencies it sends and receives, and through which correspondent banks |
| Trade finance | Letters of credit, documentary collection, teminat mektubu, export loans |
| Digital banking | Corporate internet banking, user roles, dual approval, statement export for the accountant |
| Branch | A commercial branch near the company and a named relationship manager |
| Sector appetite | Whether it already serves companies with your activity and trading countries |
Ask these questions before you submit documents: the answers decide fit far more than any fee table. Compare the written replies with what the first bank offers and choose the bank that closes your most important gap, not the one with the longest product list.
What carries over from the first bank’s file
Nothing travels automatically. Under the BDDK regulation on sharing confidential information, based on Articles 73 and 93 of Law No. 5411, a bank may not pass customer secrets to third parties without the customer’s request or instruction, and even the fact that a company is its customer is a secret.
The second bank therefore builds its own file under the Measures Regulation: identification before the relationship starts (Article 5), registry and tax data of the company (Article 7) and every natural person holding more than 25 percent (Article 17/A). Approval at the first bank does not bind it, and its own risk assessment may reach a different conclusion.
What must carry over is the content. The same registry extract, signature circular, ownership chart and activity description should go to both banks, and answers on turnover, counterparties and countries should match. The bank may ask why you need a second account; Article 5 requires it to learn the purpose of the relationship, so give a concrete written reason.
Risk Center and Findeks: what the second bank sees
The Risk Center (Risk Merkezi) operates within the Banks Association of Türkiye under Additional Article 1 of Law No. 5411. Its members are deposit and participation banks and other institutions admitted by its board; it collects customers’ risk data and shares it with members and with the customers themselves. According to the Association, the records cover bounced cheques, protested notes and commercial and individual loans and card debt.
KKB (Kredi Kayıt Bürosu) runs the Center’s operational and technical work under an agreement with the Association, and its Findeks platform serves individuals and businesses. When the second bank assesses a credit line, POS or teminat mektubu, borrowing and cheque records from the first bank are part of its picture.
A company can obtain its own report through Findeks or apply to the Risk Center through authorised signatories with a trade registry certificate and signature circular. Reviewing the report before applying lets you correct or explain an old record instead of meeting it first in a credit department question.
Accounting, tax and running two accounts cleanly
A second account means a second set of statements for the accountant (SMMM). The uniform chart of accounts records funds at domestic and foreign banks in account 102 Bankalar; in practice each bank and currency gets its own sub-account, reconciled every month against the statement. Fees, interest and exchange differences at both banks are booked, so give the SMMM read-only access or regular statement exports.
- Give each account a role: collections, payroll and tax, suppliers, FX.
- Keep invoices and contracts ready for the bank that processes each payment.
- Describe transfers between your own accounts clearly.
- Update both banks when the manager, address, shareholders or activity change.
- Close an unused account in writing instead of leaving it dormant.
Article 16 of the Measures Regulation requires banks to keep identification data current, so a change reported to one bank only creates a mismatch the other will query. Keep a simple register of which documents each bank has received and when, and send updated registry papers to both banks on the same day.
Sources
- lexpera.com.tr — Measures Regulation on preventing laundering and terrorist financing, consolidated text: Arts. 5, 7, 16, 17/A (mevzuat.gov.tr blocks automated access, so this copy was used)
- alomaliye.com — BDDK Regulation on Sharing Confidential Information, based on Arts. 73 and 93 of Banking Law No. 5411
- riskmerkezi.org — Banks Association of Türkiye Risk Center: regulation on providing customers’ risk data (Law No. 5411, Additional Art. 1)
- kkb.com.tr — Kredi Kayıt Bürosu: operator of the Risk Center’s systems and of the Findeks platform
Questions
May a Turkish company hold accounts at several banks?
Neither the Banking Law nor the Measures Regulation limits a company to one bank. Each bank decides on its own whether to open the account.
Will the second bank get my documents from the first bank?
No. The BDDK confidentiality regulation bars banks from sharing customer secrets without the customer’s request or instruction, so you submit the documents yourself.
Why does the new bank ask why I need a second account?
Article 5 of the Measures Regulation requires the bank to learn the purpose and nature of the relationship. A short written reason, such as FX coverage or trade finance, answers it.
Will the second bank see my loans at the first bank?
Banks that are Risk Center members use its records, which cover commercial loans, card debt, bounced cheques and protested notes, when they assess credit.
Do I need to tell my accountant about the new account?
Yes. Every bank account is booked under account 102 Bankalar, and the SMMM needs the statements to reconcile it each month.