A frozen bank account in Turkey has one of six legal sources, and the remedy depends on which: a garnishment notice from an enforcement office (İcra Dairesi) in ordinary debt collection, a provisional attachment (ihtiyati haciz) ordered by a court before judgment, an electronic attachment by the tax office or the Social Security Institution for a public receivable, a civil injunction (ihtiyati tedbir) in a dispute over a specific right, a criminal seizure ordered by a judge or, since December 2025, a 48-hour suspension by the bank itself on suspicion of online fraud, and a deferral by the Financial Crimes Investigation Board (MASAK) or a hold the bank applies under its own compliance rules. Each has its own authority, its own objection period, some as short as seven days, and its own way of being lifted, and the first task is to obtain from the bank the written basis of the block, because a petition filed with the wrong authority or after the wrong period is lost whatever its merits.
- Ask the bank in writing for the legal basis, the issuing authority, the file number and the date; the bank must say which measure it is applying even where it may not disclose a suspicious transaction report.
- Ordinary garnishment follows a payment order that was not objected to in seven days; the bank blocks the debt with interest and costs, not the whole balance, and wages above one quarter and social security pensions are protected.
- Provisional attachment is objected to within seven days before the court that ordered it, on limited grounds, and can be lifted at any time against cash or a bank guarantee.
- Civil injunctions are objected to within one week; criminal seizures within two weeks since June 2024; the bank's own 48-hour suspension is lifted by the prosecutor within 24 hours of an application.
- A MASAK deferral lasts at most seven business days; a bank compliance hold has no statutory period and is resolved by documentation or litigation.
Six sources of a frozen account and how to identify the one you face
The block the account holder sees in online banking looks the same whatever its cause, but the document behind it is different in each case: a garnishment notice (haciz ihbarnamesi) from an enforcement office, a court's provisional attachment decision executed through an enforcement office, an electronic attachment notice from a tax office or the Social Security Institution under the Law on the Collection of Public Receivables, a court's injunction order sent directly to the bank, a judge's seizure order or a prosecutor's written instruction in a criminal investigation, a MASAK deferral instruction, or an internal compliance decision with no external document at all. The bank is required to tell the account holder, on request, which authority ordered the block and under what file, and in our practice the written request to the bank's branch and compliance unit is sent on the first day, because every period below runs from notification or from the day the account holder learned of the measure. Our practice page on enforcement and bankruptcy law in Turkey covers the enforcement system from the creditor's side; this article covers the account holder's.
Two features of Turkish practice make the identification harder than it should be. Enforcement offices, tax offices and courts send their notices to banks through the national judicial and tax networks, so the block often appears before any document reaches the account holder, and a foreign account holder whose address in the file is a former residence or a Turkish lawyer's old office may never receive the payment order that started the proceedings. And several measures can sit on the same account at once: a garnishment can be applied to an account that is under criminal seizure but cannot be executed until the seizure ends, a MASAK deferral can precede a prosecutor's application for seizure, and a bank may keep its own hold after a court has lifted the legal measure. The account holder therefore lists every block on the account separately, with its source, before deciding what to do about any of them.
Enforcement garnishment: the payment order, the notice to the bank and the complaint
Most frozen accounts in Turkey are the result of ordinary debt collection. A creditor with an invoice, a loan, a rent arrear or a judgment starts enforcement proceedings at the enforcement office, the office serves a payment order on the debtor, and if the debtor does not object within seven days the proceedings become final and the creditor may ask the office to attach the debtor's assets, including bank accounts; a judgment creditor needs no objection period at all. The office then sends the bank a garnishment notice. The bank must answer within seven days whether it holds money of the debtor; if it does not answer, it is treated as owing the amount itself. The notice is for the debt with interest and costs, and in current practice the bank blocks that amount and leaves the rest of the balance available; a block on the whole balance is a bank error to be corrected on request, not a feature of the law.
The account holder's remedies depend on the stage. A payment order that was never properly served, or served at an address the debtor had left, is challenged by complaint before the enforcement court, and a debtor who could not object in time because of an obstacle such as absence abroad may file a late objection within three days of the obstacle ending, with proof of it. A debt that does not exist or has been paid is contested, once the proceedings are final, by a negative declaratory action before the civil court, which can stop the payment to the creditor against security. Property that the law protects from attachment is released on a complaint to the enforcement court: only one quarter of wages and salaries may be attached, so a salary account is released above that share, and pensions paid by the Social Security Institution cannot be attached at all except for maintenance claims, the Institution's own receivables or with the pensioner's consent. Foreign pensions paid into a Turkish account do not have that protection. Practice may vary by authority and year.
Where the debt is real, the fastest release is payment into the enforcement file, after which the office lifts the attachment and the bank releases the balance on receipt of the office's letter. A garnishment of a maintenance debt is treated differently, because the current month's maintenance is deducted in full before any other creditor, as our note on alimony in Turkey explains. Our note on debt collection in Turkey describes the payment order mechanism from the start.
Provisional attachment: the seven-day objection and release against security
A provisional attachment is a court order, obtained before or during a lawsuit and without hearing the debtor, that allows a creditor to attach the debtor's assets as security for a money claim that is due, or for a claim not yet due where the debtor has no fixed domicile or is preparing to hide assets or leave. The creditor shows the claim to the standard of approximate proof, usually deposits security in a percentage of the claim set by the court, and must ask the enforcement office to execute the order within ten days of obtaining it; the office then sends the banks the same garnishment notices as in ordinary enforcement, and the creditor must start enforcement proceedings or file the main action within seven days of the attachment, failing which the attachment lapses. A foreign creditor may obtain one on the same conditions, and a foreign debtor is a common target, because leaving the country is itself one of the grounds.
The debtor's objection is filed within seven days, from the attachment if the debtor was present or from service of the attachment record if not, before the court that ordered the attachment, not the enforcement office, and the grounds are limited by law to three: the grounds of the attachment, which include whether a claim was shown at all and whether the conditions for attaching an undue claim existed; the court's jurisdiction; and the security. Payment of the debt and other defences on the merits belong to the main action or the enforcement objection, not to this procedure. The court hears both sides, decides quickly, and its decision is subject to appeal to the regional court, whose decision is final; the appeal does not stop the attachment. A third party whose account was attached as if it were the debtor's objects on the same basis within seven days of learning of it.
The objection is not the only exit. The debtor may at any time, including after the seven days have passed or the objection has failed, apply to the court to lift the attachment against security: money deposited with the court, a mortgage, pledged securities or a written guarantee from a reputable bank, and in our files a bank guarantee for the claim with interest is the usual instrument where the company needs its accounts for payroll and suppliers while the dispute runs. A creditor whose attachment is later found unjustified, because the main action fails or the attachment is lifted on objection, is liable for the debtor's loss, and the security the creditor deposited is held for that purpose. Our practice page on the enforcement and bankruptcy lawyer in Turkey covers both sides of the attachment.
Tax and public receivables: the electronic attachment by the tax office and the Social Security Institution
Taxes, tax penalties, social security premiums, administrative fines and other public receivables are collected under a separate law that gives the tax office and the Social Security Institution their own enforcement powers without a court. The office serves a payment order giving fifteen days to pay or to show that the debt does not exist; if nothing happens, it attaches assets itself, and bank accounts are attached electronically through the tax administration's system by a notice to every bank at once, so that a foreign resident with an unpaid tax assessment or fine can find accounts at several banks blocked at once. The bank must answer within seven days and blocks the amount in the notice; a bank that blocks the whole balance is asked to correct it with reference to the notice.
The remedies run before the tax court. The payment order is contested by an action within fifteen days of service, on the grounds that there is no such debt, that it has been paid or that it is time-barred; a tax assessment that was never notified to the taxpayer, which is frequent where a foreign owner's address in the tax register is the property itself, is contested through the payment order when it surfaces. The attachment itself is contested by a separate action within the period for tax court actions, with a request to suspend execution, which the court grants where the measure would cause damage hard to repair and appears unlawful. The office lifts the attachment on payment, on the grant of a deferral and instalment plan, which requires an application and usually security above a threshold, or under one of the restructuring laws that Parliament passes from time to time, which allow public debts to be paid in instalments with reduced interest; in current practice attachments are lifted in proportion to the instalments paid.
One point matters for foreign account holders in particular. The tax office attaches on the basis of the identity number in its register, so a foreign national whose accounts were opened under a potential tax number and a later foreigner identity number may find that a block attaches to one identity and not the other, and the correction has to be made in the register before the bank can act. Our practice page on the tax lawyer in Turkey covers the assessment and objection stages that precede the attachment, and our note on tax residency for foreigners in Turkey who is liable in the first place.
Civil injunctions: the one-week objection, modification and security
A civil injunction is the measure a court orders in a dispute over a specific right or thing rather than a money claim: a shareholder dispute over a company's accounts, a claim that funds in an account belong to the claimant, or a measure to stop a transfer pending a judgment. The court orders it, usually without hearing the other side, where delay would cause harm hard to repair, against security from the applicant, and sends the order directly to the bank; a money claim as such belongs to provisional attachment, and a court asked for an injunction to secure one applies the attachment rules instead. An injunction ordered before the lawsuit lapses by itself if the applicant does not file the main action within two weeks of asking for its execution.
The party affected objects within one week, from the execution of the measure if present at it and otherwise from its notification, before the court that ordered it, on the grounds that the conditions of the measure were not met, that the court lacked jurisdiction or that the security is insufficient; a third party whose interests are affected has the same week from learning of it. The court hears the parties and may keep, change or lift the measure, and the decision is subject to appeal to the regional court, which decides on the file. Two later routes have no deadline: the affected party may ask the court to replace the measure with security, so that a frozen account is released against a bank guarantee or deposit, and either party may ask for the measure to be changed or lifted where the circumstances have changed.
An applicant whose injunction turns out to be unjustified, because the main claim fails, the action is not filed in time or the measure is lifted on objection, is liable for the loss it caused, and the claim is brought within a year of the judgment becoming final before the court that heard the main case. In our practice the objection and the application to substitute security are filed together, because the court is more willing to release an account against a guarantee than to decide on the first day that its own ex parte order was wrong. Our practice page on the Turkish business and commercial lawyer covers the company disputes in which these measures are usual.
Criminal seizure: the judge's order, the 48-hour suspension and the two-week objection
In a criminal investigation, bank accounts and other assets may be seized by a judge's order where there is strong suspicion that they were obtained from one of the offences the Code of Criminal Procedure lists, including fraud, embezzlement, money laundering, drug trafficking, bribery and organised crime, and the law requires a report from the competent financial authority, such as the banking regulator, the capital markets board or MASAK, before the order; unlike the seizure of ordinary movables, this seizure can be ordered only by a judge, not by the prosecutor. The seizure is not a conviction: it preserves the assets for a possible confiscation at the end of the case, and it is lifted by the judge or the court when it is no longer needed, on the account holder's application or at the end of the proceedings, with the funds returned to the owner.
The objection is filed within two weeks of learning of the decision, a period that was seven days until the amendment that took effect in June 2024 and is still quoted as seven days in many older texts, before the judgeship that ordered the seizure, which either corrects its decision or passes the objection to the next-numbered criminal judgeship of peace; the objection does not by itself suspend the seizure. The grounds are the ones the law sets: that the offence is not among those listed, that the suspicion that the assets derive from it is not strong, that the asset has no connection with the offence, that no financial authority's report was obtained, or that the measure is disproportionate. In our files the objection is built on the source-of-funds record, bank statements, contracts, invoices and tax returns tracing the balance to lawful income. Partial release for payroll, taxes and existing suppliers is applied for at the same time, with the amounts and recipients itemised, and is granted where the judge sees that the funds serve purposes unrelated to the alleged offence.
A new and faster measure was added to the Code in December 2025. A bank, a payment institution or a crypto-asset service provider may itself suspend an account for up to forty-eight hours where it reasonably suspects that the account was used in online theft, online fraud or bank card misuse, must report the suspension to the prosecutor and inform the account holder, and the prosecutor decides within twenty-four hours on the account holder's application to lift it; within the forty-eight hours the prosecutor may order seizure of the suspected proceeds, which the judge must confirm within forty-eight hours of the seizure or it lapses, and funds shown to belong to the victim are returned to the victim during the investigation. The measure is aimed at mule accounts, and a foreign account holder who received a transfer from a fraud victim will meet it before any court does. Our practice page on the criminal lawyer in Turkey covers the investigation itself, and our note on Interpol Red Notices and extradition in Turkey the cross-border cases in which a foreign prosecutor's request leads to a Turkish seizure through mutual legal assistance, which the judge examines for the same conditions plus dual criminality.
MASAK deferral, bank compliance holds and the position of foreign account holders
The Financial Crimes Investigation Board does not freeze accounts; it can defer a transaction. Under the law on the prevention of laundering, where there is suspicion that a transaction relates to laundering or terrorist financing, the Minister, who may delegate the power, can suspend that transaction for up to seven business days, during which MASAK analyses it and either lets it proceed or refers the matter to the prosecutor, who must then obtain a judicial measure. Terrorist financing is governed by a separate law under which assets are frozen by presidential decision on a listing or a foreign request, and the application to lift that freeze goes to the evaluation commission the law establishes, not to a court in the first instance.
The bank's own hold is the most common block of all for foreign nationals, and the hardest to see. Banks are obliged to know their customers, to monitor transactions and to report suspicious ones, and they may not tell the customer that a report was made; what they may and must do is say that the account is restricted under the bank's compliance procedures and what documents would resolve it. The usual triggers are a residence permit that has expired, an address that no longer matches, an incoming transfer that does not fit the declared profile, a crypto-exchange transaction, or an account opened under a potential tax number without a later identity number, and the usual resolution is documentation: the permit or its renewal application, proof of address, the contract or sale behind the transfer, the tax return abroad or the pay slip. A bank that keeps a hold after the documents are provided is pursued by written notice, by complaint to the banking regulator's customer channel, by application to the consumer arbitration committee where the account holder is a consumer and the amount is within its limit, and otherwise by an action before the civil court for the release of the deposit with interest. Practice may vary by authority and year.
Foreign account holders should expect three things. Service of the documents that start the measures above goes to the address in the file, so the address at the bank, the tax office and the population register is kept current or the measure arrives as a block rather than as a letter. A power of attorney issued abroad, notarised and apostilled, lets a Turkish lawyer obtain the file, object and apply for release without the account holder travelling. And accounts outside Turkey are not reached by any of these measures directly; a Turkish creditor or prosecutor who wants assets abroad must apply in that country, and a foreign measure reaches a Turkish account only through recognition by a Turkish court or through mutual legal assistance.
Frequently asked questions
- How do I find out why my Turkish bank account was frozen? Ask the bank in writing for the legal basis, the issuing authority, the file number and the date of the block. The bank must identify the measure even where it may not disclose a suspicious transaction report; the answer tells you which authority to apply to and which period applies.
- How long do I have to object to a bank account freeze in Turkey? Seven days for a complaint to the enforcement court and for an objection to a provisional attachment; fifteen days against a tax payment order; one week against a civil injunction; two weeks against a criminal seizure since June 2024; and an application to the prosecutor at any time against the bank's 48-hour suspension, decided within twenty-four hours.
- Can the bank block my whole balance for a small debt? No. A garnishment or tax attachment covers the debt with interest and costs, and the bank blocks that amount; a block on the whole balance is corrected on request with reference to the notice. A criminal seizure or an injunction may cover the whole account if the order says so.
- Can I get the account released by providing security instead of winning the objection? Yes for a provisional attachment, at any time, against cash or a bank guarantee accepted by the court, and for a civil injunction on an application to replace the measure with security. A criminal seizure is released by the judge when it is no longer needed, and partial release for payroll and taxes can be requested.
- Are my salary and pension protected from attachment? Only one quarter of wages and salaries may be attached, and pensions paid by the Turkish Social Security Institution cannot be attached except for maintenance claims, the Institution's receivables or with consent. Foreign pensions paid into a Turkish account are not protected.
- What is a MASAK block and how long does it last? MASAK can defer a specific transaction for up to seven business days on suspicion of laundering or terrorist financing, after which the transaction proceeds or the prosecutor must obtain a court measure. A block that continues after that has a different basis, usually the bank's own compliance hold or a judge's seizure order.
- Can I handle a frozen account from abroad? Yes. A power of attorney issued before a notary abroad and apostilled lets a Turkish lawyer obtain the file, object, apply for release and receive the funds; keep the address at the bank, the tax office and the population register current so that payment orders reach you as letters rather than as blocks.
Author: Av. Mirkan Günay Topcu, Managing Partner, ER&GUN&ER Law Firm, Istanbul Bar No. 67874. He advises foreign nationals and foreign-owned companies on frozen accounts and attached assets in Turkey, objections to provisional attachments and injunctions, tax attachments, criminal seizures and bank compliance holds, and on the recovery of funds. Education: Istanbul University Faculty of Law (2018); Galatasaray University, LL.M. (2022).
Profile: Av. Mirkan Günay Topcu. LinkedIn: Profile. Istanbul Bar Association: Official website. Related practice page: Criminal law in Turkey.