A bank account blocked in Turkey after P2P trading is held by one of three measures, and each one comes off a different way. The bank may suspend the account on its own, but for no more than 48 hours, and must report the suspension at once to the prosecutor and to the account holder (Code of Criminal Procedure No. 5271, the CMK, article 128/A). The Minister of Treasury and Finance may suspend a transaction for seven business days while MASAK tests a suspicion of laundering (Law No. 5549 on the Prevention of Laundering Proceeds of Crime, article 19/A). A seizure (elkoyma), which can hold the money until the file closes, is ordered only by a judge (CMK article 128/9), or in an emergency by the prosecutor, whose order then goes to a judge for approval within 24 hours (CMK article 128/A/4; Law No. 5549, article 17/2). The first thing to establish is which of the three sits on your account, because the clock and the way out depend on it.
The step that lifts a block fastest is one of three, an application to the prosecutor, an objection to the judge or a complaint against the bank, and which one applies depends on the measure on the account, the authority that took it and the clock now running. Tell us the bank, the date the account was blocked and any notice or decision you have received, on WhatsApp at +90 530 127 59 35, or by e-mail at info@serkalaw.com.
Which measure is on your account?
| Measure | Who takes it | Clock | How it comes off |
|---|---|---|---|
| The bank’s own measure: a refused transaction, a closed relationship, a blocked card | The bank | None in the text; it lasts until the reason is gone | Documents on the source of the funds, a complaint answered within 20 days, then the BDDK |
| Suspension of the account (askıya alma) | The bank, payment institution or crypto-asset platform | Up to 48 hours (CMK article 128/A/1) | Application to the prosecutor, decided within 24 hours (CMK article 128/A/2) |
| Postponement of a transaction (işlemlerin ertelenmesi) | The Minister of Treasury and Finance on MASAK’s analysis | Seven business days, no extension in the article (Law No. 5549, article 19/A) | Runs out by itself |
| Seizure (elkoyma) | A criminal judgeship of peace (sulh ceza hakimliği); in an emergency the prosecutor, with a judge’s approval | As long as the file needs it (CMK article 131) | Objection within two weeks (CMK article 268), request for return (CMK article 131) |
The bank must answer a written complaint within twenty days, through the channel the complaint came in, provably and with reasons (the Central Bank’s Regulation on Payment Services, article 74/1). On one point the bank stays silent by law: it may not tell anyone, the parties to the transaction included, that it has reported the transaction to MASAK as suspicious (Law No. 5549, article 4/2). So the question to the bank is put in a form it can answer: is there a decision of a prosecutor or a judge, what is its date and number, and which authority sent it.
What is the 48-hour suspension, and how is it lifted?
Since 25 December 2025 a bank, payment institution or crypto-asset platform that has reasonable suspicion of qualified fraud using banks or information systems (Turkish Criminal Code No. 5237, the TCK, article 158/1(f) and (l)), qualified theft (article 142/2(e)) or misuse of bank cards (article 245) may suspend any account used in the offence for up to 48 hours (CMK article 128/A/1, added by Law No. 7571). This is the rule that lets the recipient’s account in a P2P trade be closed on the same day the victim reports the fraud.
From there the statute runs on hard deadlines. The bank sends the suspension and the account movements, with every document, to the prosecutor at once and notifies the account holder separately; the holder may apply to the prosecutor to lift the suspension, and the prosecutor decides within 24 hours (article 128/A/2). Within those 48 hours a judge, or in an emergency the prosecutor by written order, may seize the amount; a prosecutor’s seizure goes to a judge within 24 hours, and the judge announces a decision within 48 hours of the seizure or the seizure lifts by itself (article 128/A/4). What may be seized under this rule is the proceeds of the offence in the account, not the account as a whole.
That is why the first day decides more than the months after it. An application to the prosecutor filed on the day of the suspension should show at once that you received the money as the seller of crypto, not as a participant in a scheme: the order number on the exchange, the counterparty’s verified name, the order chat, the hash of the transaction by which you sent the crypto, and whether the payer’s name matches the buyer’s. Money that turns out to be the victim’s goes back to the victim (article 128/A/5).
What is a MASAK postponement?
A bank must report to MASAK (Mali Suçları Araştırma Kurulu Başkanlığı, Turkey’s financial intelligence unit) any transaction where there is information, suspicion or reason to suspect that the funds were obtained unlawfully or are used for unlawful purposes (Law No. 5549, article 4/1), within ten business days of the day the suspicion arose (Regulation on Measures for the Prevention of Laundering Proceeds of Crime and the Financing of Terrorism, article 28/2). On such a report the Minister of Treasury and Finance, or a deputy minister, may suspend the transaction or refuse to let it go through for seven business days, so that MASAK can confirm the suspicion, analyse the transaction and, where needed, pass the results to the competent authorities (Law No. 5549, article 19/A/1). The article provides no extension.
The bank may not tell anyone about the report itself, the parties to the transaction included (Law No. 5549, article 4/2; the Regulation on Measures, article 29/1), and bears no civil or criminal liability for keeping that duty (Law No. 5549, article 10/1). The branch will therefore not answer the question “why”; documents on the origin of the funds and work with the authority that actually took the decision answer it.
What if the bank itself restricted the account?
A bank must keep checking whether a customer’s transactions fit the customer’s occupation, business, financial position, risk profile and the information on the source of funds (Regulation on Measures, article 19/1), and must watch transactions made without the customer present with particular care, up to limits on amounts and numbers of transactions (article 20/2). Where the bank cannot establish the customer’s identity or obtain enough information on the purpose of the relationship, it does not carry out the transaction, and where doubts about information already given cannot be cleared, it ends the relationship (articles 22/1 and 22/2). A card or other payment instrument is closed on suspicion of fraudulent or unauthorised use; the bank gives the reason unless the law bars it, and reopens the instrument once the reason has gone (Regulation on Payment Services, articles 53/2 and 53/3).
A measure of this kind comes off with documents: where the money came from, who the buyer was, what you sent and when. If the complaint gets no answer within twenty days, or an answer that does not deal with it, the complaint goes to the BDDK through its e-Şikayet system, which passes it to the bank and assesses it together with the bank’s answer.
Who can seize the account, and for how long?
A bank account may be seized where there is strong suspicion, resting on concrete evidence, that the offence was committed and that the assets derive from it (CMK article 128/1(c)). Fraud (TCK articles 157 and 158) is in the list of offences for which such a seizure is allowed (CMK article 128/2(a)(6)). Only a judge makes the order (article 128/9), and the statute requires for it a report by the BDDK, MASAK or another competent body on the value derived from the offence; the report is prepared within three months at most and may be extended by two more (article 128/1). The order goes to the bank at once by technical means, and transactions made after it in order to defeat it are void (article 128/5).
The statute allows concretely identified assets of the suspect to be seized even where another person holds them (article 128/1). Being a witness therefore does not by itself free the account: the dispute is about which amount in your account is the proceeds of the offence. The first thing an objection tests is a seizure of the whole account beyond the amount of the disputed transfer.
Where the file is about laundering, the prosecutor may seize assets personally in an emergency; the order goes to a judge within 24 hours, the judge decides within 24 hours, the value report must arrive within three months, and without the judge’s approval or a timely report the prosecutor’s order falls away (Law No. 5549, article 17/2).
How is a seizure challenged, and how is the money returned?
An objection (itiraz) against a criminal judgeship of peace’s seizure order is lodged within two weeks of the day you learned of the order, with the same judgeship (CMK article 268/1). If the judge does not correct the order, the objection goes within three days to the next-numbered criminal judgeship of peace (articles 268/2 and 268/3(a)). The objection does not stop the order by itself, but the court may suspend it (article 269).
Separately from the objection, return can be asked for at any time: seized assets are returned by decision of the prosecutor, the judge or the court as soon as keeping them is no longer needed for the investigation or it is clear that they will not be confiscated, and a refusal can also be challenged (CMK article 131/1). The objection period runs from the day you learned of the order, so the first step is to obtain the order itself.
Are you a witness or a suspect?
The typical scheme runs like this: a fraudster deceives a third person, who pays money into your account for crypto that you then send to the fraudster; the victim goes to their bank and to the prosecutor, and the trail of the payment leads to your account. What you become in the file is decided by the facts. Fraud requires deception (TCK article 157), qualified fraud using banks carries four to ten years’ imprisonment (article 158/1), and accepting or using assets derived from an offence is punishable where the person knows their origin (article 282/2). A seller who honestly sent crypto for the payment received neither deceived anyone nor knew where the money came from, and the defence’s task is to make the file show that from the documents of the trade.
Since 31 July 2026 there is a rule everyone who trades P2P should know. Where a person’s part in a fraud is limited to handing over, for their own or another’s gain, their own or someone else’s bank card, or the data or tools that allow an account at a bank, payment institution or crypto-asset platform to be used, the penalty for that participation is halved (TCK article 158/4, added by Law No. 7589). The statute thus proceeds on the footing that handing over access to an account can be participation in fraud.
If you are called to give a statement, you must be told what you are suspected of, that you may choose defence counsel and decline to explain yourself on the suspicion, and that you may ask for concrete evidence in your favour to be gathered (CMK article 147/1(b), (c), (e), (f)). A statement taken by the police without counsel cannot ground a judgment unless you confirm it before a judge or court (article 148/4). Counsel may take part at every stage, and that right cannot be restricted (articles 149/1 and 149/3).
What must you not do while the account is blocked?
- Do not give anyone access to your account, card or exchange account, for money or for a while (TCK article 158/4).
- Do not move the balance out through other accounts after a seizure order: such transactions are void (CMK article 128/5), and acting against the order brings TCK article 289 into play (CMK article 128/8).
- Do not transfer the “disputed” amount to someone who writes to you as the victim or as a bank officer: the victim’s money goes back to the victim through the file (CMK articles 128/A/5 and 131/2).
- Do not give a statement without counsel (CMK articles 147/1(c) and 148/4).
- Do not delete the order history, the exchange chat or the payment confirmations: they are your evidence (CMK article 147/1(f)).
How does the block affect your residence permit?
Law No. 6458 on Foreigners and International Protection names among the grounds for deportation earning a living by unlawful means (article 54/1(ç)) and posing a threat to public order or public security (article 54/1(d)). A fraud file in which you are a suspect therefore concerns more than the money: its outcome matters for your residence permit too, and the defence is run with both in view from the first day.
Can the file be handled without coming to Turkey?
Yes. On a notarised power of attorney signed before a notary in Turkey, at a Turkish consulate, or before a notary abroad with an apostille, we file the applications to the prosecutor, examine and copy the investigation file within the limits the law gives defence counsel (CMK article 153/1), lodge the objections with the judge and run the complaints to the bank and the BDDK. What we need from you is the signature on the power of attorney and the documents of your trade.
Have your block read
Three papers show which measure is on the account and which clock is running: the bank’s notice, the prosecutor’s or judge’s decision if there is one, and the records of your P2P trades with the counterparties and the amounts. Have them ready when you write to us at info@serkalaw.com or on WhatsApp at +90 530 127 59 35.
Related: technology, data privacy and crypto law in Turkey, criminal defence for foreign nationals in Turkey and deportation orders and entry bans.
This page reports Law No. 5549 and the Regulation on Measures for the Prevention of Laundering Proceeds of Crime and the Financing of Terrorism, the Code of Criminal Procedure No. 5271, the Turkish Criminal Code No. 5237, Law No. 6458 and the Central Bank’s Regulation on Payment Services as read on the consolidated texts of mevzuat.gov.tr on 30.09.2026. It is general information about Turkish law and not advice on a particular file; representation begins only under a signed engagement.