Turkish Citizenship by Investment (CBI) is a prestigious route for foreign nationals who invest in Turkey through real estate, bank deposits, or business formation. However, in recent years, Turkish authorities have increased scrutiny on the origin of investment funds. As a result, an increasing number of CBI applications are rejected due to unexplained or unverifiable source of funds.
At ER&GUN&ER Law Firm, we specialize in representing high-net-worth individuals, families, and investment advisors in all stages of Turkish citizenship application review, refusal, and appeal. Our English Speaking Turkish Lawyers work closely with applicants from Gulf countries, Central Asia, Africa, and Eastern Europe to ensure that fund origin documentation is legally valid, institutionally acceptable, and resistant to rejection by MASAK (Financial Crimes Investigation Board), the Immigration Authority, and the Ministry of Interior. As the best lawyer firm in Turkey for citizenship risk management, we turn application failures into structured legal victories.
Why Are Citizenship Applications Rejected in Turkey?
While the legal framework for CBI is relatively clear—regulated under Law No. 5901 and Regulation No. 2010/139—the interpretation and enforcement depend on several agencies. In practice, your application may be rejected for various reasons, such as:
- Missing documents (valuation reports, title deeds, bank SWIFTs)
- False declarations or inconsistent information
- Pending criminal records or INTERPOL alerts
- Source of investment funds cannot be clearly proven
- Bank transfer origin does not match applicant identity
Our Turkish Law Firm analyzes rejection notices, tracks the procedural violation or material inconsistency, and drafts objections or lawsuits to challenge unlawful decisions based on fund source misinterpretations.
Legal Framework for Fund Source Review
While the CBI regulations do not specifically list “source of funds” as a mandatory approval criterion, multiple indirect regulations empower authorities to evaluate financial transparency:
- Law No. 5549 on Prevention of Laundering Proceeds of Crime
- MASAK Guidelines on Suspicious Transaction Reporting (STR)
- Central Bank Circulars on capital inflows and FX conversion
- CBI bank deposit certificate requirements (3-year term + matching identity)
Our lawyers ensure fund transfers meet MASAK compliance standards by documenting legal origin through tax declarations, sale agreements, international bank statements, or inheritance court decisions. We also secure expert CPA reports and notarial declarations where necessary.
Examples of High-Risk Fund Transfers Leading to Rejection
In our experience handling over 200 CBI clients, the following fund transfer patterns frequently trigger rejection or MASAK audit:
- Investment funds sent from a company rather than the applicant personally
- Use of multiple third-party accounts without notarized declarations
- Cash-based transactions or undocumented foreign exchange offices
- Transfers from high-risk jurisdictions (e.g., sanctioned or offshore tax havens)
- Mismatch between applicant name and SWIFT message sender
We structure fund paths through Tier-1 compliant banks, obtain apostilled KYC documents, and proactively submit explanations to the investment monitoring committee to reduce scrutiny and accelerate approval.
What to Do If Your Citizenship Application Is Rejected
If your CBI application is rejected based on the source of funds, you have two primary legal pathways:
- Administrative Objection: File an objection with the Directorate of Population and Citizenship within 60 days of receiving the refusal
- Judicial Challenge: Initiate an annulment lawsuit before the Administrative Court (İdare Mahkemesi) within 60 days
Our Turkish Law Firm prepares legal briefs explaining why the investment complies with legal origin requirements, attaches financial audits, and invokes Article 125 of the Constitution guaranteeing judicial protection against administrative acts.
Can You Reapply After Rejection?
Yes. In many cases, the issue lies in how the documentation was presented—not in the investment itself. Reapplication is possible if:
- Funds are re-routed through appropriate financial channels
- Corrective statements and documents are submitted
- A cooling-off period passes and reputation is restored
We assist clients in redesigning investment routes, registering new property, or extending fixed deposit terms to trigger a new application process from a clean compliance base.
Strategic Legal Tips to Avoid Future Rejection
- Always transfer funds from an account in your personal name
- Use banks in jurisdictions with FATF compliance
- Include full SWIFT codes and explanation letters
- Submit notarial declarations if a third party assists
- Hire a licensed attorney to oversee the application and document control
Internal Legal Resources
- Turkish Citizenship by Investment Overview
- Citizenship Rejected Due to Missing Documents
- Real Estate Due Diligence for Investors
- Foreign Investment Compliance in Turkey
- Banking and Compliance in Turkey
FAQ: Citizenship Rejection Due to Source of Funds in Turkey
- Q1: Is the source of funds a legal requirement?
Not explicitly, but lack of clarity leads to rejection under AML and regulatory concerns. - Q2: Can I transfer funds from my company?
No. Funds must come from the personal account of the applicant or properly declared third parties. - Q3: What if my investment is legal but the paperwork is unclear?
You can file an objection or reapply with corrected documentation. - Q4: Are there restrictions on country of origin?
Yes. Sanctioned or high-risk jurisdictions may trigger additional scrutiny or rejection. - Q5: Can my lawyer receive the funds on my behalf?
Only if declared via notarial PoA and compliance statements. Even then, caution is advised. - Q6: Is MASAK involved in every application?
Not officially, but banks often submit STRs if transfers are unusual, which flags your file. - Q7: Can I challenge a rejection in court?
Yes. An administrative lawsuit is your constitutional right. - Q8: Does rejection affect future visa or residence?
Potentially, especially if rejection was based on suspicious activity. Legal clarification helps. - Q9: How long does it take to fix and reapply?
Usually 2–4 months depending on investment type and document readiness. - Q10: How can a Turkish Law Firm help?
We audit your fund structure, fix legal gaps, file objections, and design clean reapplication strategies.
Overcome Citizenship Rejection with Legal Strategy from a Turkish Law Firm
Rejection due to “source of funds” is one of the most frustrating outcomes in the Turkish citizenship by investment program—but it is not the end of the road. With the right legal team, you can identify the cause, challenge the decision, and secure a compliant path forward.
At ER&GUN&ER Law Firm, our English Speaking Turkish Lawyers provide full risk analysis, represent clients in objection and litigation, and redesign applications for success. As the best lawyer firm in Turkey for citizenship recovery cases, we turn rejections into resolved outcomes—legally, quickly, and strategically.