Source of funds for a Turkish bank: which documents prove it, by type of income

When a Turkish bank asks for a source-of-funds declaration (kaynak beyanı), the answer is not a story but a set of documents that reconcile to the amount. This guide lists the set for each origin of money, explains how to make foreign papers acceptable and shows which gaps make the compliance unit (uyum birimi) refuse.

What the compliance officer is actually testing

Turkish banks are obliged parties (yükümlü) under Law No. 5549: Article 3 requires them to identify the customer and take the other required measures before a transaction. The implementing regulation (Tedbirler Yönetmeliği) adds enhanced measures (sıkılaştırılmış tedbirler, Article 26/A) for higher-risk cases, and the MASAK guide of 1 March 2021 lists what they contain: additional information on the customer, on the nature of the relationship, on the purpose of the transaction and, as far as possible, on the source of the assets and of the customer’s funds, with approval by a senior officer. FATF Recommendation 12 uses the same two ideas: source of wealth is how your overall wealth was built; source of funds is where this specific sum came from. A declaration therefore has to answer both questions: what you do for a living and which event produced the money now arriving. The compliance unit reads the declaration first, then checks whether the documents prove it.

Documents by type of income: work, property, business, savings

Each origin has a standard set. Supply the whole set, not one piece of it.

• Salary or employment abroad: employment contract, payslips for the period, the latest tax return or employer tax certificate, and the account statement showing the salary being credited.
• Sale of property abroad: the sale deed or land-registry extract showing the transfer, the sale contract with the price, and the bank statement showing receipt of that price into your own account.
• Business income or dividends: company registry extract naming you as shareholder or director, audited or filed accounts, the shareholder resolution approving the dividend, and the statement showing the payment.
• Savings accumulated over years: statements covering the accumulation period, the income documents that fed them and, where money sat in deposits, the deposit history.

The bank compares the amounts in these documents with the sum you want to transfer or deposit; the figures must reconcile, not merely look plausible.

Documents by type: inheritance, gift, sale of goods, crypto, loan

• Inheritance: death certificate, inheritance certificate or probate order naming you as heir, the estate distribution statement or executor letter, and the bank statement showing receipt.
• Gift from a relative: a signed and notarised gift declaration, proof of the family relationship, the donor’s passport and the donor’s own source-of-funds documents, because the bank traces the money one step further back.
• Sale of a car or valuables: sale contract or invoice, registration transfer or auction record, and the statement showing the payment.
• Crypto proceeds: exchange account statements, wallet transaction history, the fiat on-ramp (how you bought) and off-ramp (how you sold) with the bank statement at each end. Crypto service providers in Türkiye have been obliged parties under the same regulation since 1 May 2021, so the bank applies the same standard to their records.
• Loan: signed loan agreement, lender identity, disbursement shown on your statement and, for a private lender, that person’s own source.

Foreign documents and the chain principle

A foreign document helps only when the bank can read it and trust its origin. The regulation itself names the two routes for foreign official papers: an apostille under the 1961 Hague Convention (130 Contracting Parties including Türkiye; it is issued by the Competent Authority in the country of origin, and an e-Apostille cannot be refused for being electronic) or certification by a Turkish consulate where the issuing country is not a party. The Turkish translation is then made by a translator sworn before a Turkish notary and attested by the notary under Notary Law No. 1512. Ask the bank in advance whether a plain translation is enough for supporting papers such as statements; deeds and certificates usually need the notarial route. Then apply the chain principle: every hop from the origin to the Turkish account must be documented, so the officer can follow one unbroken line: event, receipt into your account abroad, transfer out, arrival in Türkiye. A gap between two statements is where most files fail.

Red flags that lead to refusal

Some patterns make the compliance unit stop regardless of the explanation:

• Unexplained cash deposits: cash has no prior statement, so the chain breaks at the first link. Move money through accounts, or document where the cash came from.
• Third-party transfers: money from someone who is not the account holder. Article 15 of Law No. 5549 requires anyone acting for another person to declare it in writing, and Article 17 of the regulation requires that person to be identified; an undeclared third party reads as concealment.
• Occupation and amounts do not match: a declared salary that could not have produced the balance.
• Stale or incomplete papers: an address proof older than three months, a registry extract from years ago, a statement that stops before the transfer.
• Edited files: screenshots, cropped statements, documents without issuer, stamp or date.

If identification or the purpose of the relationship cannot be established, the regulation lets the bank refuse the transaction and end the relationship, and it will normally not say why.

Sources

• masak.hmb.gov.tr — MASAK: Measures Regulation and Enhanced Measures Guide (1 March 2021)
• mevzuat.gov.tr — Law No. 5549, Measures Regulation No. 2007/13012, Notary Law No. 1512
• fatf-gafi.org — FATF Recommendation 12 and PEP guidance: source of wealth and source of funds
• hcch.net — Hague Apostille Convention (1961): Contracting Parties, Competent Authorities, e-Apostille

Questions