The Foreign Exchange Purchase Certificate, known in Turkey as the Döviz Alım Belgesi or DAB, is a bank-issued document that proves foreign currency was brought into Turkey and sold to the Central Bank through a Turkish bank before it was used for a citizenship-by-investment transaction. It is not an optional banking receipt. Under the citizenship-by-investment framework made pursuant to Law No. 5901 on Turkish Citizenship, the investment funds of five of the seven routes must be sold to the Central Bank through a Turkish bank and the conversion must be documented, and the DAB is the document that evidences that conversion. A file with a clean investment but a missing, late, or mismatched DAB can be queried or refused on the documentation alone.
Serka Law Firm fixes the payer, the bank and the wording of the DAB before the money is sent, within the mandate set out on our Turkish citizenship by investment lawyer page. Write on WhatsApp at +90 530 127 59 35 or to info@serkalaw.com before the transfer.
This guide explains what the DAB is, why the citizenship-by-investment regime requires it, how it fits the fund-transfer sequence, the errors that weaken it, and how it connects to the rest of the evidentiary chain. For the full route overview, see our pillar guide on seven routes, their thresholds and holding periods.
What is the Foreign Exchange Purchase Certificate (DAB)?
The DAB is a certificate issued by a Turkish bank confirming that a specified amount of foreign currency was sold to the Central Bank of the Republic of Turkey and converted, recording the amount, the currency, the exchange rate, the date, and the parties. In a citizenship-by-investment file it is the bridge between the money the investor sends from abroad and the qualifying investment made inside Turkey. It turns an international transfer into documented, regulator-visible evidence rather than an unexplained inflow of funds.
The certificate exists because Turkish citizenship by investment is built on a documented money trail, not on the mere presence of an asset. Whether the investment is real estate, a bank deposit, government debt instruments, real estate or venture capital fund units, or a private pension, the regulator wants to see that the qualifying capital entered the country lawfully, passed through a Turkish bank, and was sold to the Central Bank as required. The DAB is the standardized proof of that step. The two company routes, a fixed capital investment and the employment of 50 people, carry no such sale and no DAB.
Why does Turkish citizenship by investment require a DAB?
The regime requires a DAB because the rules expect the qualifying funds to be brought into Turkey, sold to the Central Bank through a Turkish bank, and converted into Turkish Lira before the investment is completed, and the certificate is the document that proves this happened. The rule is Article 20(10) of the Implementing Regulation, added by Presidential Decision No. 5072 of 6 January 2022 and given its present wording by Presidential Decision No. 5554 of 13 May 2022; the Central Bank’s Implementation Instruction of 16 May 2022 sets how the banks carry it out.
The deeper reason is anti-evasion and source-of-funds integrity. A passport granted on an investment is only as defensible as the trail that supports it. If the money cannot be traced from the investor, through a bank, to the qualifying asset, the file is fragile. The DAB anchors the financial side of that trail so the citizenship decision rests on documented capital rather than on a verbal account of where the money came from.
How does the DAB fit the fund-transfer sequence?
The DAB sits in the middle of the sequence: the investor transfers foreign currency into a Turkish bank, the bank sells that currency to the Central Bank and issues the DAB, and only then is the converted amount applied to the qualifying investment. Getting the order right is what keeps the file coherent, because a certificate produced out of sequence has to be explained rather than simply presented.
- Pre-transfer legal review. Confirm eligibility, the route, the bank and the source-of-funds story before any money moves, because once the Central Bank completes its purchase the sale cannot be abandoned or cancelled (Article 7 of the Implementation Instruction).
- Inbound transfer. Send the foreign currency to an account at a bank operating in Turkey, with sender, beneficiary, and purpose consistent with the eventual application.
- Sale to the Central Bank and DAB issuance. The bank sells the foreign currency to the Central Bank and issues the Foreign Exchange Purchase Certificate documenting the conversion.
- Qualifying investment. Apply the converted funds to the chosen route, whether a property purchase with a notarized contract recording the full price, a blocked deposit, or another eligible instrument.
- Certificate of conformity. Obtain the certificate confirming the qualifying investment meets the threshold, supported, on the property route, by the TTB that the land registry’s system builds from the valuation report of an SPK-authorized valuation firm (TKGM circular Genelge 2024/4, as amended on 28 September 2026).
- Residence permit, then citizenship filing. Secure the investor residence permit, then file the citizenship application, with the DAB sitting inside the supporting documentation.
For a deeper look at the valuation step that runs alongside this on the property route, see our note on the SPK valuation report within our real estate and property acquisition practice.
What must a DAB show to support a citizenship file?
A supporting DAB must match the rest of the file on amount, currency, date, bank identity, and the underlying transaction, so that a reviewer reading the certificate against the application sees one consistent story. Internal consistency is the whole point of the document; a technically valid certificate that contradicts the tapu records, the valuation, or the application dates creates exactly the discrepancy it was meant to prevent.
- Amount and currency. The converted sum should align with the qualifying investment and with the price recorded in the underlying contract.
- Date and sequence. The conversion date should sit logically before the investment step it supports, not after it.
- Bank identity and parties. The issuing bank and the named parties should match the accounts and persons in the application.
- Link to the transaction. The certificate should be traceable to the specific property purchase, deposit, or instrument it funds, supported by transfer records and the notarized contract.
For the real estate route the Central Bank’s instruction fixes the explanation field of the DAB itself: it must carry at least the foreign buyer’s name and surname, the passport number or foreign identity number, the US dollar equivalent of the currency bought, and a statement that the sale is made under Article 20(10) of the Implementing Regulation (Article 8(3) of the Implementation Instruction of 16 May 2022), the dollar equivalent computed at the dollar rate announced at the same time as the rate of the currency sold (Article 8(4)). A DAB missing one of those four items is incomplete on the instruction’s own terms. The Central Bank buys only US dollars, euros, pounds sterling and Swiss francs (Article 5(2)), so a transfer in roubles, yuan or dirhams is first converted by the Turkish bank, and a transfer in Turkish lira cannot produce a DAB at all. Once the Central Bank completes its purchase the sale cannot be cancelled (Article 7), the bank reports it to the Central Bank by 17:00 the same day (Article 4(2)), and on the deposit route the bank that sells the currency and the bank that holds the lira must be the same bank (Article 6(1)).
What are the common DAB mistakes that weaken a file?
A file is weakened when the DAB is treated as a standalone bank form and isolated from the rest of the file, because a certificate that does not reconcile with the money trail, the contract, and the timeline can leave a formally valid document inside a fragile application. The other recurring errors are sequencing and after-the-fact repair, both of which force the applicant to explain inconsistencies instead of preventing them.
- Missing or late conversion. Funds used without the required sale to the Central Bank, or a certificate obtained after the investment, break the documented sequence.
- Amount or party mismatch. A DAB whose figure or named parties do not match the contract and the application invites a query.
- Bank credit counted as investment. Money borrowed from a Turkish bank does not count toward the qualifying amount; the capital should be the investor’s own funds, documented through the banking channel.
- Direct crypto payment. Paying directly in cryptocurrency does not satisfy the rule; value has to pass through the banking channel and be converted, with the conversion documented.
- Late corrections. Repairing the banking side after the file is built usually creates the very inconsistencies a reviewer looks for.
Because these defects are documentary rather than commercial, they are largely avoidable with the right sequence. Where a transfer has already gone out, the payment is traced by its SWIFT reference (the UETR) through the sending bank and the receiving bank; that is how a 2026 transfer from Hong Kong, instructed on 20 May, released on 27 May and credited in Türkiye on 3 June, was followed to the account, after the sending bank declined to release the interbank message to its own customer.
How does the DAB relate to full-value documentation?
The DAB is one pillar of full-value documentation, working alongside the notarized contract and the banking records to prove that the real, complete price moved through traceable channels. Full-value documentation matters because the administration reviews certified investments after the grant: in 2026 it cancelled eligibility certificates resting on forged valuation reports and annulled the citizenship decisions built on them (Ministry of Interior, 4 August 2026), and on the property route the registry counts the amount only as far as the DAB records it, even where the valuation’s figure is higher (guidance to TKGM circular Genelge 2024/4). Documenting the true amount, with the DAB confirming the converted sum, is what makes a file structurally consistent rather than merely hopeful.
This is a discipline question, not a tactic. The aim is a file where the notarized price, the converted amount on the DAB, the valuation, and the application all describe the same transaction. Where the figures agree, there is nothing to reconcile later. Any request to understate value should be declined outright, because it is the gap between the documents, not the size of the figure, that creates exposure.
Does the DAB requirement differ by investment route?
The DAB belongs to five of the seven routes. Article 20(10) of the Implementing Regulation requires the foreign currency of the real estate (b), bank deposit (ç), government debt instrument (d), fund unit (e) and private pension (f) routes to be sold, before the transaction, to a bank operating in Turkey and by that bank to the Central Bank, and Article 1 of the Central Bank’s Implementation Instruction of 16 May 2022 limits its own scope to the same five routes. The fixed capital route (a) and the employment route (c) carry no foreign exchange sale and therefore no DAB. On the five routes the DAB evidences the currency conversion; what changes is what it sits next to in the file.
| Route | Role of the DAB | Sits alongside |
|---|---|---|
| Real estate purchase | Documents conversion of funds used to buy the property | Notarized contract, SPK-authorized valuation report and the TTB, title deed with the no-sale annotation |
| Bank deposit | Documents conversion of funds before they are blocked | Certificate of conformity, no-withdrawal undertaking |
| Government debt instruments, fund units or private pension | Documents conversion of the funds before they are placed and held for three years | Certificate of conformity from the relevant authority, holding records |
| Fixed capital or employment of 50 people | None: these routes carry no sale to the Central Bank and no DAB | Certificate of conformity from the determining ministry (Sanayi ve Teknoloji Bakanlığı or Çalışma ve Sosyal Güvenlik Bakanlığı) |
The bank deposit route holds the capital in Turkish lira for three years and carries the whole currency risk, since no Turkish bank prices a three-year lira deposit and the deposit is rolled at the prevailing rate; the property route converts once and holds a real asset whose price re-rates with the currency. The citizenship right itself is fixed on the date of determination and a later fall of the lira does not take it away (Article 20(6)). Investors comparing structures often run this alongside establishing a company or foreign direct investment work in Turkey, which should be coordinated under one legal plan to avoid conflicting timelines.
When should the DAB be reviewed?
The safest time to review DAB logic is before funds move, because designing the transfer and conversion correctly at the start prevents the inconsistencies that later corrections create. If the money has not yet moved, this is the point to set the sequence, the accounts, and the documentation so the certificate aligns with the file from the first transfer. If the transaction is already underway, the task shifts from design to defect detection, finding and fixing any mismatch before filing assumptions harden.
Either way, the DAB should be read as a control point in the evidentiary chain, not as a form to collect at the end. The investors who avoid problems are the ones who treat the banking step as part of the legal architecture from the beginning.
Frequently asked questions
Is the DAB just a routine bank formality?
No. In a citizenship-by-investment file the DAB is part of the evidentiary chain that links the investor’s funds to the qualifying investment. It has to reconcile with the contract, the timeline, and the application, so it functions as a control point rather than a disposable receipt.
Can the DAB be obtained after the investment is made?
It should not be. The regime expects the foreign currency to be brought in, sold to the Central Bank, and documented before the investment is completed. A certificate produced out of sequence has to be explained, which is exactly the kind of inconsistency that weakens a file.
Does paying in cryptocurrency satisfy the requirement?
No. Direct payment in cryptocurrency does not meet the rule. Value must pass through the banking channel and be converted, with the conversion documented, before it can support a citizenship application.
Does the DAB requirement or the investment threshold ever change?
Yes. Both are set by the Implementing Regulation and changed by Presidential Decision: the sale to the Central Bank was added on 6 January 2022 and took its present wording on 13 May 2022, and the real estate figure rose to USD 400,000 on 13 June 2022. The amount is measured at the Central Bank’s effective selling rate, or its cross rate, on the date the determining authority fixes the investment (Article 20(6)).
The DAB and the transfer records, read before the filing
If your file involves property or investment transfers tied to Turkish citizenship, the DAB and the wider money trail have to be clean before you rely on them, and a gap is cheapest to close before the application is filed. On instruction the file opens on three papers, the DAB, the SWIFT message with its UETR, and the bank’s record of the currency sale; write on WhatsApp at +90 530 127 59 35 or to info@serkalaw.com, and the mandate is set out on our citizenship by investment page. Investors managing related matters can draw on our work in immigration and residence permits and tax and customs regulation so the banking, residence, and tax steps stay aligned under one plan.
This article provides general information on Turkish law and is not legal advice. No attorney-client relationship is formed by reading it; such a relationship arises only through a signed engagement with Serka Law Firm.