Serka Law Firm acts as Turkish citizenship by investment lawyers for investors and their families, from the choice of route to the passport; the property, valuation and bank steps run on a power of attorney, and the investor applies in person, as the Directorate General of Civil Registration and Citizenship Affairs requires, to obtain the Certificate of Conformity, for the short-term residence permit, to collect the residence card and for citizenship. Every letter to him and his family is written in their own language.
The regulation fixes the figures: USD 400,000 in real estate with a three-year no-sale annotation on the deed; USD 500,000 held for three years in a Turkish lira bank deposit, in Turkish lira government debt instruments, in real estate or venture capital fund units, or in the private pension system; USD 500,000 of fixed capital; or 50 jobs created (Article 20(2) of the Regulation on the Implementation of the Turkish Citizenship Law). The spouse and the children who are minors or dependants join the same file with no second investment (Article 12(1)(b) of Turkish Citizenship Law no. 5901), and on our files of 2019 to 2021 a well-prepared file reached the passport in three to four months; in 2026 the security and archive research has kept many files waiting well beyond that. What decides a file is rarely the threshold. It is the order in which the money, the bank and the documents are put in place, and that order is set before the investor sends anything.
The currency rule that decides the file before the money moves
On five of the seven routes the investment has to arrive as foreign currency and be sold. Article 20(10) of the Implementing Regulation requires the currency to be sold, before the transaction, to a bank operating in Türkiye and by that bank to the Central Bank of the Republic of Türkiye; on the deposit, the bond and the pension routes the lira from that sale is what is held for three years, and on the fund route it buys the units that Article 20(2)(e) itself requires to be held for three years. The Central Bank’s Implementation Instruction of 16 May 2022 adds three rules that shape the transfer itself. The Central Bank buys only US dollars, euros, pounds sterling and Swiss francs (Article 5(2)), so a transfer in rubles, yuan or dirhams works because the Turkish bank converts it first, while a transfer in Turkish lira has nothing to sell and does not count. On the deposit route the bank that buys the currency must be the bank that holds the lira (Article 6(1)). And once the Central Bank has completed its purchase, the sale can be neither abandoned nor cancelled (Article 7). Since 1 October 2026 a fourth rule fixes the price: the Central Bank buys at the foreign exchange buying rate it announces at 11:00 on the day the currency is turned into lira (Article 3(1)(b), as amended that day), and the bank reports and transfers its purchases to the Central Bank by 16:00 on a full working day, 12:30 on a half day (Article 4(2)). The rate “taken from the Central Bank on the day”, as a bank wrote to us on 31 August 2026, now has its hour.
That last rule is why the bank, the account in the investor’s own name and the day of conversion are fixed in writing before a dollar moves. The foreign exchange purchase certificate (döviz alım belgesi, DAB) that proves the sale has to carry the investor’s own name, so the money goes to the investor’s own account in Türkiye first and never through a third party’s. A conversion made at the wrong bank, or in the wrong name, cannot be taken back.
An investor holding rubles, tenge or yuan meets two different figures, and the file turns on telling them apart. The first is the yardstick. Article 20(6) of the Regulation values the USD 500,000 at the Central Bank’s effective selling rate and/or its cross rate on the date the determining authority makes its finding, and the Central Bank’s daily list gives each of these currencies a cross rate to the dollar: on its list of 23 October 2026 the ruble stood at 80.78, the tenge at 451.10 and the yuan at 6.6708 to the dollar, so on that list USD 500,000 came to RUB 40,390,000, KZT 225,550,000 or CNY 3,335,400. The second is what the receiving bank books. Under Article 5(2) of the Instruction the bank first turns any other currency into dollars, euros, pounds or Swiss francs and only then sells those to the Central Bank, and the Instruction puts no price on that first conversion, so the bank’s own conversion rate decides how many dollars reach the sale. The amount to send is therefore fixed from that bank’s written figure for the currency and the sum, never from the yardstick alone. The yardstick is applied once, on the date of the finding, and the Regulation carries no later test of the dollar value, so a fall in the lira during the three years reaches the money held and not the citizenship.
What the banks wrote to us in 2026
The regulation says what an investment must be. Whether a given bank will carry it is a separate question, and we put it to the bank in writing before an investor commits. These are the written answers on our files of August and September 2026, as the banks gave them; no client is named.
- The government debt route is not run at every bank. On 31 August and 1 September 2026 three branches, two of one private bank and one of a participation bank, wrote that for citizenship they run only the three-year lira deposit or participation account, not government debt instruments. On 21 September 2026 a branch of a state-owned bank confirmed in writing that it runs the government bond route under Article 20(2)(d), opens the account under a power of attorney it can verify, does not set up internet banking under a power of attorney, and needs every banking act listed in that power one by one. Article 20(8) of the Regulation lets the investor move between investment types to complete the three years, so a file that cannot run on one route at one bank is carried to another route rather than abandoned.
- Bonds are chosen by their maturity, and the choice is final. The Ministry of Treasury and Finance’s revised procedure for the bond route, which replaces its procedure of 14 February 2020, excludes any instrument with less than three years to maturity and leaves the choice of instrument to the bank and the investor; it requires the lira from the currency sale to buy the bonds the same day or the next working day, at the same bank, with no transfer between banks; it allows no switch between instruments unless the Ministry redeems one early; and it accepts the file only as the bank’s own official letter, never from the investor or his lawyer directly (Articles 4(2), 4(4), 5 and 7(1)). Of the seven lira bond issues on the list a state bank’s branch gave us with value date 21 September 2026, one met the maturity rule.
- For Russian citizens, one branch refused a SWIFT transfer of the investment amount. On 31 August 2026 a private bank’s branch answered in writing under eight headings: no commission on the conversion; the rate taken from the Central Bank on the day and not fixed in advance; the three-year block requested by letter to its treasury unit and usually confirmed within one working day; approval in about two weeks, depending on the customer; a deposit rate of 35 per cent, neither fixed nor guaranteed for three years; and, for Russian citizens, no transfer of the investment amount by SWIFT, the amount to be paid in cash under its current procedure. Whether a bank accepts the transfer from the investor’s own country is therefore the first question on every Russian file, put to each bank in writing before a flight or a transfer is planned.
- Two participation banks set their own document rules. One asked for the Russian taxpayer number (INN) of a Russian citizen (1 September 2026). Another, opening a non-resident account, accepted the translated address page of the Russian internal passport in place of a utility bill, took a utility bill in the investor’s own name from any country if it was under three months old, and refused a bank statement and a title deed as proof of address (10 September 2026).
Where the investor lives decides the document route
A citizenship file carries two kinds of paper: the civil-status records that prove who the family is, and the banking records that prove where the money came from. Both have to stand in Türkiye, and the way they get there depends on the state that issued them. The Implementing Regulation’s list of the documents in the citizenship file names no criminal-record certificate (Article 20(3)), but the Directorate General’s own list asks for one from the authorities of the applicant’s own country, issued within the last six months, and the residence permit before it may ask for one from the country of nationality or of lawful residence (Article 32(1)(ç) of Law no. 6458); for an investor resident in the Emirates or Qatar that certificate follows the legalization route below. Türkiye is a party to the Hague Apostille Convention, and the Convention runs only between two parties.
Russia and Belarus: the documents, the bank transfer and the sanctions in 2026
Both states are parties to the Apostille Convention, in force for each since 31 May 1992 (the Hague Conference’s own status table, read 5 October 2026). A birth or marriage certificate, or a power of attorney signed before a Russian or Belarusian notary, takes an apostille and then a sworn translation certified by a Turkish notary, and the original itself travels to us: the apostille authenticates the foreign notary’s signature and does not turn a copy into an instrument. The Russian civil-registry certificates are apostilled in Russia only: on a file of ours the Russian Consulate General in Istanbul answered in writing on 7 October 2026 that it does not apostille them. They are therefore ordered in Russia on the day the file opens, and the bank account and the investment run on the passport and the power of attorney while the certificates travel; the Certificate of Conformity is applied for by the investor in person, as the Directorate General requires. A power of attorney drawn up by a Turkish consulate is Turkish from the moment it is signed and needs neither an apostille nor a translation (Articles 191, 193 and 103 of Notary Law no. 1512), and where the consulate will draw it up, that is the route we take. The money question comes first on these files: a ruble or dollar transfer qualifies once the Turkish bank has sold it on, but whether the bank will receive it at all is that bank’s answer, given in writing, as above.
Russia itself does not cap the transfer in 2026. From 8 December 2025 the Bank of Russia lifted its limits on transfers of foreign currency abroad by Russian citizens, which until then allowed no more than USD 1 million a month to accounts in foreign banks and USD 10,000 a month through money transfer systems (its notices of 26 September and 5 December 2025); its notice of 1 June 2026 keeps restrictions until 7 December 2026 only for non-residents from the countries Russia lists as unfriendly. The limit on a Russian file sits on the receiving side. Executive Order 14114 of 22 December 2023 added section 11 to Executive Order 14024: the U.S. Treasury may prohibit a foreign financial institution’s correspondent accounts in the United States, or block its property, if it has conducted or facilitated a significant transaction, or provided any service, involving Russia’s military-industrial base, and the order defines a foreign financial institution as any foreign entity that accepts deposits or buys and sells foreign exchange, which includes a Turkish bank. Since 12 June 2024 the Office of Foreign Assets Control counts every person blocked under Executive Order 14024, the Russian banks so blocked among them, as part of that base, and its advisory of that date names large cash payments and payments routed through third countries not otherwise involved in the transaction as red flags. Before anything moves, the sending bank is therefore named and checked against OFAC’s sanctions list, the Turkish bank is asked in writing whether it will receive from that bank, and where the money is to arrive in cash or through a third country, the source of funds file explains it before the bank asks.
On the Russian side the investor keeps his Russian citizenship: acquiring another does not end it, and Russia treats him only as its own citizen (Article 10 of Federal Law No. 138-FZ of 28 April 2023 on Citizenship of the Russian Federation). The same law requires a notification of every foreign citizenship acquired, filed with the internal affairs authorities within sixty calendar days of the acquisition, or, by a citizen who is abroad, with a Russian embassy or consulate; one who misses the period because he is abroad files within sixty calendar days of entering Russia, parents file for their minor children, and a representative may file on a notarised power of attorney (Article 11(2), (4), (5) and (6); the law’s text on the President of Russia’s site, read 20 October 2026).
Belarus answers differently. It does not recognise a Belarusian citizen’s other citizenship unless a treaty of Belarus provides otherwise, and acquiring one is not among the grounds on which Belarusian citizenship is lost. A citizen who acquires a foreign citizenship, or receives a residence permit or another foreign document granting benefits, must inform the internal affairs bodies or the diplomatic service within three months of receiving the documents, free of charge through the single portal of electronic services, or in person or through a representative (Articles 11 and 19 of Law No. 136-Z of 1 August 2002 on Citizenship of the Republic of Belarus, as amended to Law No. 242-Z of 5 January 2023; the text on etalonline.by, read 20 October 2026).
Kazakhstan and Uzbekistan
Kazakhstan goes further than Belarus. It does not recognise a Kazakh citizen’s citizenship of another state (Article 3), and Kazakh citizenship is lost if the person acquires the citizenship of another state (Article 21(5) of Law No. 1017-XII of 20 December 1991 on Citizenship of the Republic of Kazakhstan; the text on adilet.zan.kz, read 20 October 2026). For a family from Kazakhstan that question is settled before the application, not after the passport.
Uzbekistan holds the same line. It does not recognise its citizens’ belonging to the citizenship of a foreign state (Article 12), and Uzbek citizenship is lost if the person voluntarily acquires the citizenship of a foreign state (Article 25). The loss is decided by a decree of the President of Uzbekistan, and until that decree a citizen who also holds a foreign citizenship cannot evade the duties of an Uzbek citizen (Articles 4 and 12 of Law No. ZRU-610 of 13 March 2020 on Citizenship of the Republic of Uzbekistan, as amended to Law No. ZRU-963 of 20 September 2024; the text on lex.uz, read 20 October 2026). For a family from Uzbekistan that question, too, is settled before the application.
Ukraine
Ukraine’s rule stands in Law No. 2235-III of 18 January 2001 on Citizenship of Ukraine as amended by Law No. 4502-IX of 18 June 2025. A Ukrainian citizen who acquires another citizenship is treated by Ukraine only as its citizen (Article 2(1)). Ukrainian citizenship is lost when a citizen who is an adult at that moment voluntarily acquires the citizenship of a state whose citizens cannot acquire Ukrainian citizenship in the simplified procedure, and an application made under the other state’s own procedure is a voluntary acquisition (Article 19(1)(1)). The Cabinet of Ministers names the states of the simplified procedure (Article 10-1), and its list, Resolution No. 1412 of 5 November 2025 as amended by Resolutions No. 589 of 8 May 2026 and No. 826 of 24 June 2026, does not name Türkiye. A Ukrainian adult who applies for Turkish citizenship therefore meets that ground of loss. The loss takes effect on the date of the President of Ukraine’s decree, and until then the person keeps every right and duty of a Ukrainian citizen (Articles 19 and 20; the law and the list on zakon.rada.gov.ua, read 20 October 2026). A child who acquires Turkish citizenship as a minor with the parents is outside that ground, which reaches only a citizen who is an adult when the other citizenship is acquired. The list changes by government resolution, so it is read again on the date of the application.
The United Arab Emirates and Qatar: the documents, their legalization and the power of attorney
For an investor who lives in the Emirates or Qatar on another country’s passport, the documents come from two states. Neither the United Arab Emirates nor Qatar is a party to the Apostille Convention (status table, read 5 October 2026), so a document either of them issues has no apostille to obtain; it is legalized by the issuing state’s own authority and then by the Turkish mission, which can certify the Turkish translation in the same visit (Articles 195, 193 and 103 of Notary Law no. 1512). A certificate issued by the investor’s home state follows that state’s own rule, and where the home state is a party, its apostille is enough. For the power of attorney, we asked the consular section of the Turkish Embassy in Doha in writing whether it draws one up for a Qatari citizen; it answered on 27 September 2026 by naming its own sworn Arabic translators, through whom the act is done for a principal who does not read Turkish. For the account in Türkiye, the participation bank mentioned above takes a utility bill in the investor’s own name from any country; a bill in an employer’s or a landlord’s name is not the investor’s own. An investor who will not hold an interest-bearing deposit is not shut out of the deposit route: participation banks run it as a lira participation account, and one of them confirmed to us in writing on 10 September 2026 that it buys the currency, holds the lira and writes to the Banking Regulation and Supervision Agency itself, both when the account is opened and once the three years have passed without a breach. The Central Bank’s Implementation Instruction for these sales names deposit and participation banks alike as the banks that carry them (Article 3(1)(a)). What the investor accepts with a participation account is its nature under Article 3 of Banking Law no. 5411: it pays no return fixed in advance, it shares in the profit or loss of the bank’s use of the funds, and it does not guarantee the principal back as paid in.
A Qatari citizen settles his own law before the file opens, as a Chinese national does below. Qatar’s nationality law forbids holding Qatari nationality together with any other except by decision of the Emir (Article 18 of Law No. 38 of 2005), and an Emiri decision may strip a Qatari who acquires the nationality of another state of his Qatari nationality (Article 11, item 5), a loss that falls on him alone unless the decision says otherwise (Article 13). Turkish law asks no one to give up a first nationality, so this question is answered on the Qatari side, and before the application.
An Emirati citizen reads a rule that leaves no discretion in its words. Federal Law No. 17 of 1972 concerning Nationality and Passports provides that a national “shall be deprived of the State nationality” if he “willingly becomes a naturalised national of a foreign state” (Article 15(c), in the Ministry of Justice’s English text), and a national by operation of law who has acquired a foreign nationality may recover his nationality of origin only by renouncing the one acquired (Article 17). For an Emirati, Turkish citizenship is a question of his own nationality before it is a question of the investment, and it is settled before the application.
An investor who lives in the Emirates on another country’s passport settles that country’s law too, and for some of them the Turkish passport ends the first one. A decision granting Turkish citizenship takes effect on the day it is made (Article 20(1) of Law No. 5901). For an Indian national, the Consulate General of India in Dubai states that under Section 9 of the Citizenship Act 1955 a person ceases to be an Indian national on the day he acquires a foreign nationality, that possession of an Indian passport by a foreign national is illegal, and that the passport is to be surrendered no later than three years after the new nationality is acquired; in the Emirates the surrender is filed at a BLS centre with the original Indian passport, proof of the new nationality with its date of acquisition and an Emirates ID that already shows the new nationality (its instruction sheet for applicants in the UAE). Its renunciation form under Section 8 is for someone whose new state asks for proof of renunciation first, and Turkish law asks for none. For a Pakistani national, Section 14(1) of the Pakistan Citizenship Act 1951 ends Pakistani citizenship for a citizen who also holds another nationality unless he renounces that other nationality; the rule does not apply below the age of twenty-one, to a Pakistani woman married to a foreigner, or for the countries the Federal Government notifies (Section 14(1A), (4) and (3)), and the Directorate General of Immigration and Passports lists the twenty-two countries with which Pakistan has dual nationality arrangements, Türkiye not among them (its page, last modified 9 January 2026). An Egyptian national needs the prior permission of Egypt’s Ministry of Interior to take a foreign nationality, in one of two forms, keeping Egyptian nationality or giving it up; the request goes to the nationality section of the Passports Administration or to an Egyptian consulate abroad, and the permission, when granted, is a decree of the Minister within three months (the Ministry’s own page). A Jordanian who obtains a foreign nationality keeps his Jordanian nationality unless he gives it up under the Nationality Law, and a minor child whose father obtains one keeps it as well (Articles 17(a) and 10 of Law No. 6 of 1954, in the consolidated text of the Civil Status and Passports Department). Each of these answers is had before the application, because under Indian and Pakistani law the loss follows from the Turkish decision itself.
Saudi Arabia
Saudi Arabia acceded to the Apostille Convention on 8 April 2022 and the Convention has been in force for it since 7 December 2022 (status table, read 5 October 2026), so a document a Saudi authority issues takes the apostille of the Saudi competent authority instead of legalization. A Saudi citizen also settles his own law before the file opens. The Saudi Arabian Nationality System forbids a Saudi to take a foreign nationality without the prior permission of the President of the Council of Ministers, and a Saudi who takes one without that permission remains Saudi unless the government withdraws his Saudi nationality under Article 13 (Article 11). Article 13 allows that withdrawal by reasoned decree where a Saudi has entered another nationality contrary to Article 11, after a warning of at least three months, and on withdrawal his property is liquidated under the rules on real estate ownership and he may be refused residence in the Kingdom or return to it. The permission is therefore sought on the Saudi side, before the application. A power of attorney signed before a Saudi notary takes the same apostille, one drawn up at a Turkish mission is Turkish from the moment it is signed (as for Russia and Belarus above), and an investor who keeps his money out of interest takes the deposit route as the participation account described above.
Iran
An Iranian citizen reads his own Civil Code first. Iranians may give up their nationality only on the conditions of Article 988, among them the full age of twenty-five and the permission of the Council of Ministers. Under Article 989, an Iranian who acquires a foreign nationality without observing the legal provisions remains an Iranian national, the foreign nationality being void in Iranian law, and is barred from ministerial and deputy ministerial office, from the legislature, from provincial and municipal councils and from every government post. The words of Article 989 that had such a person’s immovable property sold under the local public prosecutor’s supervision were deleted by Article 13 of the Law on Supporting Iranians Abroad, passed by the Islamic Consultative Assembly on 15 October 2025 (23 Mehr 1404), confirmed by the Guardian Council on 5 November 2025 and published in the Official Gazette on 22 November 2025 (both texts in the legal database of the Assembly’s Research Center, read 20 October 2026). For an Iranian investor, a Turkish passport therefore does not end Iranian nationality in Iran’s eyes, and the article no longer orders the sale of his property in Iran.
Mainland China and Hong Kong: capital controls, the USD 50,000 quota and the documents
Two rules of Chinese law are settled before the file starts. Article 9 of the Nationality Law of the People’s Republic of China provides that a Chinese national who has settled abroad and acquires a foreign nationality of his own will loses Chinese nationality automatically, and Article 3 does not recognize dual nationality. Turkish law does not ask the investor to give up his first nationality, so the consequence on the Chinese side is weighed by the family before the application, not after it.
The second question is where the money can lawfully come from, and mainland China answers it by the person, not by the bank account. A Chinese citizen who holds a mainland resident identity card is a domestic individual under the People’s Bank of China’s Measures on the Administration of Individual Foreign Exchange of 2006 (Article 37), and a domestic individual buys foreign currency on his own identity card up to USD 50,000 equivalent a year (Article 2 of the State Administration of Foreign Exchange’s Implementing Rules of 2007, and Article 54 of its Guidelines on Current Account Foreign Exchange Business, 2020 edition). That facility serves current-account payments with a genuine transaction behind them. Every purchase is made on SAFE’s Personal Foreign Exchange Purchase Application, which the buyer signs: it forbids using the currency to buy property abroad, for securities investment, for life insurance or for any other capital-account item not yet opened, and it forbids lending one’s own quota to help another buyer or borrowing other people’s quotas to split a purchase. A buyer who breaks it goes on SAFE’s watch list and has no facility that year and the two years after it, and the breach brings an administrative penalty, a referral for anti-money-laundering investigation and an entry in his personal credit record (Annex 1 to SAFE Notice Huifa [2021] No. 13, on SAFE’s list of rules in force at 30 June 2026). None of the fourteen purposes the application lets the buyer tick is an investment abroad. That sits on the capital account, where a domestic individual’s direct investment abroad needs SAFE’s approval and his financial investment abroad goes through a domestic financial institution qualified for it (Articles 16 and 17 of the 2006 Measures). A USD 500,000 Turkish investment cannot be assembled from a family’s pooled quotas, and a file built that way carries, on the Chinese side, exactly the conduct the application names.
Hong Kong changes this only where the money or the person is already there. The Basic Law provides that no foreign exchange control policies are applied in the Hong Kong Special Administrative Region and that its government safeguards the free flow of capital within, into and out of the Region (Article 112). Savings earned and held in Hong Kong, or anywhere outside the mainland, go to Türkiye without touching the mainland facility, and a Hong Kong resident who holds the Mainland Travel Permit for Hong Kong and Macao Residents is an overseas individual under the 2006 Measures, outside the domestic individual’s purchase rules (Article 37). A Hong Kong account opened by a mainland resident changes nothing for money that still has to leave the mainland to fill it.
On the Turkish side, the bank that receives the transfer works under Türkiye’s Regulation on Measures for the Prevention of Laundering Proceeds of Crime and the Financing of Terrorism. It pays special attention to complex and unusually large transactions and obtains enough information on their purpose (Article 18), keeps checking over a continuing relationship that a customer’s transactions fit his occupation, business, financial standing and sources of funds (Article 19), may ask, in proportion to the risk it finds, where the funds and the assets come from (Article 26/A(1)(c)), and opens no relationship and carries out no transaction where it cannot establish who the customer is or what the relationship is for (Article 22). The foreign exchange purchase certificate must then carry the investor’s own name, as above. For a Chinese investor the source-of-funds file is put together before the transfer, in the order a bank reads it: the income or the sale that produced the money, the account it was held in, and the lawful channel by which it left the mainland or was already outside it.
China has applied the Apostille Convention since 7 November 2023, so a Chinese public document takes an apostille. On the mainland the Ministry of Foreign Affairs first requires a qualifying foreign-related notarial certificate or other certificate document, unless the document is one it authenticates directly, and the apostille is then issued by the Ministry or by a local foreign affairs office it has authorised; for documents bound for Türkiye it adds that any authorisation or power of attorney must be issued as a notarial certificate (China Consular Service, the procedure for domestic consular legalisation and apostille, its country table updated 9 October 2026, read 20 October 2026). A document issued in Hong Kong follows Hong Kong’s own place in the Convention, in force there since 25 April 1965: the High Court Registry’s apostille service apostilles it, a power of attorney signed before a Hong Kong notary public included (the Hague Conference’s page of competent authorities and the Hong Kong Judiciary’s apostille page, read 20 October 2026). A power of attorney can instead be drawn up at a Turkish consulate general in China, with a sworn Chinese interpreter present because the investor does not speak Turkish, and then it needs no apostille at all. On our Shanghai file of 2026 the consulate’s online system took no booking made for a foreign national, so the appointment was requested in writing with the passport copy, the draft power and the lawyer’s bar card. On the same file, a transfer from a Hong Kong bank reached Türkiye fourteen days after it was instructed, across two weekends in the correspondent chain; the sending bank would not release the MT103 to its own customer, and the transfer’s UETR is what both banks traced.
Who acts on your file
The file is run by Serka Law Firm, founded by Av. Serkan Kara. On a Turkish file the work is done by an advocate admitted in Türkiye and answerable to a bar that publishes its roll. For a reader used to English practice: Turkish law has one legal profession, and only an advocate on a bar roll may give legal opinions, draft the documents of a case and act before courts and tribunals (Article 35(1) of Attorneyship Law No. 1136), so the work a solicitor and a barrister share in England sits with one advocate on a Turkish citizenship file. Everything below can be checked before you send us a single document, and where a public register exists the link goes to the entry itself rather than to the institution’s front page.
- The founding advocate’s bar entry. The entry of Av. Serkan Kara on the İstanbul Barosu roll, with the link that opens the Bar’s own register, is on his page.
- CCBE Lawyer’s Professional Identity Card, issued under the Council of Bars and Law Societies of Europe. European recognition on this route is evidenced, not asserted.
- Both of the great legal families, examined in both. Turkish and continental civil law by a Bachelor of Law (LLB) from Uludağ University Faculty of Law in 2015, by admission and by practice; United States law on the CUSL program at the University of Cologne Faculty of Law in 2012 and 2013, covering US Family Law, Business Law, Legal Negotiations and American Legal Terminology, two of them graded vollbefriedigend. A cross-border file is read in both traditions by the same person instead of being handed across a border halfway through.
- Named in the Russian Ministry of Foreign Affairs list of lawyers in Türkiye, compiled by the Embassy in Ankara together with the Consulates General. It is named here without a link, because that document is itself a directory of law offices.
- In the legal profession since 2015, the year Av. Serkan Kara’s traineeship began.
Six checks before you sign with any citizenship lawyer
No statute makes a lawyer compulsory on this route, and an investor in Türkiye can file for himself. What an advocate holding a power of attorney adds is reach: the Turkish-language correspondence, the bank’s letters, the registry and the filings are done where they happen, and the investor travels only for the four applications he makes in person. Whoever you choose, six things can be checked before any money moves, most of them on a public register or in the text of Attorneyship Law no. 1136. Each check gives the rule, then how we meet it.
1. Is the lawyer on a Turkish bar roll?
Article 35 of Law no. 1136 reserves legal opinions, the conduct of proceedings before courts and other judicial bodies, and the drafting of the papers for them to advocates entered on a bar’s roll (“yalnız baroda yazılı avukatlara aittir”; official text). The opinion on whether your investment qualifies, and any objection or court step if the file is refused, are an advocate’s work, whoever else handles the paperwork. Av. Serkan Kara’s page carries his bar roll entry with the link to the Istanbul Bar’s own register.
2. Whose name will the power of attorney carry?
The person named in the power of attorney is the one who acts for you before the land registry, the banks and the migration and civil registration offices. Ask for that name before you sign at a notary or a consulate, and look it up on the bar roll. The powers of attorney we work under name Av. Serkan Kara, entered on the Istanbul Bar roll.
3. Is the lawyer paid by anyone on the other side of the deal?
Article 38(b) of Law no. 1136 obliges an advocate to refuse a matter where he has acted or given an opinion, in the same matter, for a party whose interest is opposed. In a citizenship purchase the seller, the developer and the agency that introduced you can each hold an interest opposed to yours, so ask who pays the lawyer they recommend. The investor instructs Serka Law Firm directly, and the firm takes no commission from an agency or any other intermediary.
4. Is there a signed engagement that names the service?
Under Article 163 of Law no. 1136 the engagement agreement covers a specified legal service, and an agreement left unwritten has to be proved under the general rules of evidence. Ask for a signed engagement that names each step, from the review of the deed or the bank’s letter to the citizenship decision. We open a file only on a signed engagement.
5. Does the lawyer work from the current rule, with its source?
The rules of this route move: the valuation rule changed on 28 September 2026, the Treasury rewrote its procedure for the bond route, and a bank’s practice differs from one branch to the next. A lawyer who cannot name the instrument behind each step is working from memory. Every rule on this page carries its instrument and its date.
6. Is what you send protected?
Article 36 of Law no. 1136 forbids an advocate to disclose what a client entrusts or what the advocate learns through the work, and even with the client’s consent the advocate may decline to testify about it. A citizenship file carries passports, family records and the full source of the money, so send them to an advocate bound by that article.
What the mandate covers
Serka Law Firm structures Turkish citizenship by investment files for investors and their families on any of the qualifying routes, including the ones who arrive with the investment already made and the paperwork already wrong. Representation is a defined scope of work, and this is the scope.
- Route selection decided on your own documents, before any money moves. The seven qualifying routes are not interchangeable. Your nationality, the currency you can actually remit, whether the funds are your own, and whether a family member is on the file each rule some of them out.
- Source of funds and the payment trail designed in advance of the transfer. A payment made first and explained afterwards cannot be repaired, because a transfer cannot be re-issued once it has cleared. Payer, beneficiary, date and stated purpose are fixed on paper first, and the name on the transfer is the name in the document that explains it.
- Written confirmation from each institution before funds move. The valuer, the bank, the land registry and the custodian each issue a document in a particular format, and a file is restarted rather than merely delayed when the format is wrong. What each one will issue for your transaction is confirmed in writing before the transaction happens.
- The filings themselves. The route confirmation before the determining authority, the Certificate of Conformity (Uygunluk Belgesi), the short-term residence permit under Article 31(1)(j) of Law no. 6458 before the Presidency of Migration Management, the citizenship application before the Directorate General of Civil Registration and Citizenship Affairs, the land registry steps on a property file, and the bank’s correspondence with the Banking Regulation and Supervision Agency on a deposit file.
- Family inclusion as one file rather than several. The spouse and dependent children are assessed with the main application, so their civil-status records are built to the same standard on the same timetable.
- Power of attorney with the consular roadmap. You give the power of attorney in your own city, for the property, valuation and bank steps: drawn up by the Turkish consulate, or signed before a local notary and then apostilled or legalized, sworn-translated into Turkish, then filed. A document legalized out of order is a document obtained twice.
What you receive
The legal work in Türkiye stays with the firm from the first filing to the passport: the sworn translation and notarization of your documents, the official inquiries and every filing are arranged by the firm, so no step is handed to a broker or a translation bureau you have to find yourself.
What arrives with the engagement: the engagement agreement in Turkish and your language, the document list, a written route comparison, the work plan, a guarantee letter, a non-disclosure agreement, the power of attorney draft with its consular roadmap, and a source-of-funds and bank-compliance guide.
The guarantee is of conduct, and it is deliberately not a guarantee of outcome. Turkish citizenship under Article 12 of Law no. 5901 is granted by Presidential decision after a national security and public order screening, and no lawyer anywhere controls that decision. What is controllable is the thing that actually sinks files: whether every document is in the format the receiving institution issues and accepts, whether the amounts reconcile across the valuation, the deed and the transfer, and whether the steps were taken in the right order. Anyone who guarantees you the passport is guaranteeing something they do not own.
What our own files show
The timings on this page are read from citizenship files we ran ourselves. From 2019 to 2021 Serka Law Firm carried the files of a residential developer’s foreign buyers from the Certificate of Conformity to the Turkish identity card. The dates below come from those files; the threshold and the valuation rules were different then, and the sequence they show is the one that runs today. No client is named.
The Certificate of Conformity starts the clock, and what happens on the day it arrives sets the weeks that follow. On 3 February 2020 two certificates reached us in the afternoon, both residence applications were at the migration desk that evening, and both citizenship applications were ready to file the next day. A file of the week before went from the residence filing to the citizenship application in two days, and in July 2021 the citizenship appointment was taken for the Friday of the week the residence was filed. In 2020 one certificate was issued and reached us only weeks later, and those weeks were simply lost: the certificate belongs on the desk of whoever files the next step.
The residence card took about three weeks. A residence application filed at the end of December 2019 gave the card in hand on 20 January 2020, and the citizenship application went in the next day; it was approved by 29 March 2020, together with four other applications of the same round. By 31 May 2020 all but two of the files on that list had been approved, among them applications filed at the end of January and early in February, through the first weeks of the Covid-19 closures. A family of seven whose residence was filed on 26 April 2019, with the citizenship application following in May, paid the fees for its identity cards and passports on 4 September 2019. Those dates are why a well-prepared file stood at three to four months then; in 2026 the security and archive research has kept many files waiting well beyond four months, and decisions have come in batches.
What held files back was paper, never the investment. The copy of a birth certificate sent for one file carried a wrong date of birth, and a new notarized translation was made from the original (December 2019). A power of attorney the applicant’s wife had drawn up in the wrong form stopped a file that was otherwise complete (December 2019). The translation of a marriage certificate was wrong and was done again under consular approval, then notarized (July 2021). The longest file took fifteen months, from the document list in August 2019 to the citizenship application on 10 November 2020, because its Certificate of Conformity took that long to come: the investor’s stay was kept lawful on an ordinary residence permit in the meantime, an information update was filed with the provincial migration directorate, and the investor residence permit was taken again once the certificate arrived. And the question that held one family for weeks in 2026, which spouse goes on the file, changes one document rather than the file, because Article 12(1)(b) of Law no. 5901 covers the minor or dependent children of the applicant as well as those of the spouse; the same family’s youngest child had no passport yet, and a child’s first passport is the document to start first.
What changed on 28 September 2026 for property files
The TTB, the land registry’s certificate of the amount invested, may now be up to twelve months old when the citizenship transaction is filed at the registry, where six months was the ceiling, and the valuation report behind it may come from any valuation firm authorized by the Capital Markets Board of Türkiye (SPK), where only GEDAŞ reports were accepted from 4 March 2024 (TKGM circular 2024/4, as amended by the Makam Oluru of 28 September 2026, no. 21914825). A seller that is a real estate investment trust (GYO) needs no TTB but must present the valuation report it published on KAP before the deed, or order a new one through WebTapu. The USD 400,000 threshold did not move. A file stalled on a TTB older than six months is inside the window again if the TTB is younger than twelve, and a fresh valuation no longer waits in one firm’s queue. Before any purchase the deed is read against the Land Registry’s own guide to these files, the Kılavuz of 9 December 2024 annexed to circular 2024/4. The unit must be an independent section under Condominium Law no. 634, or land registered as a building plot that carries a lawful permanent building with its occupancy permit; unbuilt land with the two-year project duty of Article 35 of Land Registry Law no. 2644, agricultural land and a timeshare do not qualify, and neither does a share of a property. On a notarized promise to sell, the USD 400,000 is reached in one single contract and paid in full by its date. The unit must not stand in the name of a foreigner, of the investor’s Turkish first-degree relative by blood, marriage or adoption, of a company in which the investor or any of his first-degree relatives, Turkish or not, is a partner or a manager, or of anyone naturalized under Article 12(1)(b) of Law no. 5901. A second-hand unit must never have reached its Turkish seller from the investor or his first-degree relatives, nor, in the last three years, from a foreigner or from anyone naturalized under Article 12(1)(b), a contractor’s units under a construction contract aside. A unit serves one citizenship file only. A foreign-currency loan used for the purchase is deducted from the price, a statutory mortgage or an annotation that could change ownership (a promise to sell, a pending suit) keeps the unit out, and the declared price, the payments and the TTB must each reach USD 400,000. The wording of the circular is on our page on the Turkish citizenship valuation report rule change.
My application was refused and I want the file taken over
A refused Turkish citizenship by investment file can be taken over, and the first task is not an appeal. Refusal notices on this route are short and rarely name the defect, so the file is reconstructed from the documents themselves: which threshold was tested, on which date and at which conversion rate, against which valuation; whether the non-disposal annotation was in fact recorded on the deed; whether the payer on the transfer is the applicant; whether a civil-status record contradicts the passport. Only then is it clear whether the file is repaired and refiled or the investment has to be restructured. That reconstruction is built on the refusal notice, the route confirmation file and the payment records, the three documents to have at hand when you instruct us. The recurring failure patterns are set out in our study of Turkish CBI rejection causes and how they are fixed.
I bought the property through an agent and the file is now stuck
A property already bought through an agent is the commonest stuck file on the real estate route, and it almost always stalls on one of four things. The valuation was not a report requested through Web Tapu from an SPK-authorized valuation firm, or the TTB built on it was more than twelve months older than the application for the citizenship transaction at the registry. The declared value on the deed does not match the valuation or the money that actually moved. Payments went to an intermediary account instead of bank to bank between the named parties, or brokerage and title charges were folded into the figure later presented as the purchase price. Or the seller was not a Turkish natural or legal person, which disqualifies the purchase outright. The deed, the valuation report and the transfer receipts show which of the four it is and whether the position is recoverable on this property. The valuation rules themselves are in our note on the SPK valuation report in a citizenship investment.
My citizenship was annulled after the August 2026 operation
An annulment is a decision of the authority that granted the citizenship, and it is challenged on the investor’s own documents. Under Article 31 of Turkish Citizenship Law no. 5901, a decision is annulled where the acquisition resulted from the person’s own false statement or the concealment of a material fact; under Article 32 the annulment takes effect from its date and reaches the spouse and the children who acquired citizenship through the applicant; under Article 33 the decision may order the investor’s assets in Türkiye to be liquidated within a year, and a suit against the decision puts the liquidation off until the case ends (Article 33(2)). Because Article 31 asks for the investor’s own act, the case is built on the foreign exchange certificate, the title deed and the bank’s records, which show whether the declared price is the price the investor paid, in the investor’s own name, through a Turkish bank. The route is set out in Turkish citizenship annulment and appeal. Serka Law Firm acts on written instruction under a signed engagement agreement, and the file opens on the annulment decision, the passport and the title deed.
The money is coming from a company or from a family member
Funds arriving from a company or a relative rather than from the applicant are workable, and they are also the commonest reason a file is questioned, so the legal basis is documented before the transfer and never after it. A transfer from a family member needs a documented gift or loan, dated ahead of the payment, with the relationship provable from civil-status records. A transfer from a company needs the applicant’s position in it, a corporate resolution authorizing the payment, and an account of how the company came by the money. The transfer instruction has to state its purpose, and the payer’s name has to match the document that explains it. The money may come from them, into the investor’s own account in Türkiye; on the property route the Central Bank’s Implementation Instruction requires the foreign exchange purchase certificate to name the foreign national for whom the currency is converted (Article 8(3)), so the sale is made in the investor’s name. Whether the money is already inside the country or already converted matters at the outset, because the currency rule runs in one direction only and lira already in Türkiye has nothing to sell.
I need my spouse and children on the same file
The spouse and the children who are under eighteen or dependent are included in the same application with no second investment; an adult child, a disabled one included, comes in as a dependent child, on documents that prove the dependency and are gathered before filing. Majority is Turkish majority, so a child under eighteen who is married is of age and comes in only as a dependant (Article 11 of Civil Code no. 4721). A son who acquires Turkish citizenship is liable to military service according to his age on that date (Articles 4 and 43(1) of Military Service Law no. 7179; military age begins on 1 January of the year he turns 20): he is treated as having served if he is 22 or older in the year of naturalization or documents service in the country he came from, and a dual national resident abroad may defer it through the Turkish consulate to the end of the year he turns 35 and, after three years actually abroad, discharge it by payment in foreign currency (Articles 38(1)(c) and 39(2)). What delays family files is almost never the investment; it is the civil-status paper. Marriage, birth and parentage records have to be issued, apostilled or legalized and sworn-translated, and the transliteration of every name must be identical across the passport, the marriage certificate and the birth record, or the family tie has to be proved again from scratch. A previous marriage, a custody order or a change of name is resolved by formal document, never by explanation. The family is assessed as one unit, so one incomplete member holds the whole group.
The route rules, in short
Turkish citizenship by investment is the exceptional acquisition under Article 12 of Law no. 5901, granted by Presidential decision after a national security and public order screening; a qualifying investment satisfies the condition and does not compel the decision. Five routes carry a three-year hold, recorded by the bank, the custodian or the pension system, or as a non-disposal annotation on the title deed; fixed capital and the employment route carry none and sit outside the currency sale. Each route has its own determining authority, and the residence permit that carries every file is issued under Article 31(1)(j) of Law no. 6458. The full treatment, with the documents, the authorities, the State’s own charges on a purchase and the timing, is in our guide to Turkish citizenship by investment; route by route: citizenship by bank deposit, citizenship by buying property and citizenship by establishing a company.
Questions clients ask before they instruct
Do I have to travel to complete the file?
Yes: four steps are the investor’s own, obtaining the Certificate of Conformity, the residence permit application, collecting the residence card and the citizenship application. The file runs on a power of attorney drawn up at the Turkish consulate in your country, or signed before a local notary and then apostilled or legalized, and sworn-translated into Turkish. The investor residence permit is a first application at the provincial migration directorate: an advocate may file it, but on our files the applicant has to be present at the appointment, as the Presidency of Migration Management’s own residence page allows it to require, and a provincial directorate’s published service standards state that fingerprints are taken on every first application. The Directorate General of Civil Registration and Citizenship Affairs requires the citizenship application to be made in person, and its citizenship FAQ names obtaining the Certificate of Conformity and collecting the residence card among the investor’s personal steps too; fingerprints are taken again at the citizenship application. The trips are planned around those steps from the day the file opens, and the work between them runs on the power of attorney. There is no residence requirement on this route and no language examination.
Does the passport change where I pay tax?
Not by itself. Turkish income tax reaches worldwide income only of a person settled in Türkiye, by a domicile there or by a continuous stay of more than six months in a calendar year that temporary absences do not break (Articles 3 and 4 of Income Tax Law no. 193); nationality is not among the tests. Inheritance and gift tax is the one that follows nationality instead (Article 1 of Inheritance and Gift Tax Law no. 7338), which is why a family’s succession is read before the file opens. Both rules, and the twenty-year exemption on foreign income for an investor who does move to Türkiye, are set out in our guide to Turkish citizenship by investment.
Who signs what, and in what order?
You sign first, on every document, and the firm’s side of the engagement is counter-signed on the copy you return. The order is the engagement agreement and the wording of the power of attorney, then its signing at the consulate or the notary, then legalization and sworn translation, then filing. A power of attorney drafted for a property purchase does not cover a citizenship application, and a bank may refuse a general banking clause, so the wording is settled with the bank before the consular appointment and not at it.
What happens if the application is refused?
The refusal is read against the documents rather than against the notice, because the notice rarely states the defect. We establish which condition failed, whether it is repairable on the investment already made, and whether the correct move is a corrected refiling or a restructuring. The commitment we give is one of conduct, not of outcome.
Will you take over a file another adviser started?
Yes. A file begun by an agent, a developer or another adviser is taken over on one condition, which is that we see the real documents first, including the ones you were told not to worry about. If the position is not recoverable on the investment already made, you are told so plainly.
Which language is my file run in?
Yours. Correspondence, the engagement agreement, the document list, the route comparison and every explanation come to you in the language you write to us in. The filings themselves are made in Turkish, because that is what the receiving institutions accept, and the firm arranges the sworn translation that gets them there.
Four facts decide which route fits
Route selection is a document question before it is a money question. Four facts decide it: your nationality, the amount and the currency you can actually remit and from which bank, whether the funds are your own or a third party’s, and the family members you want on the file.
An immigration agency or a family office introducing a family works on the terms set out in how an agency introduces a Turkish citizenship by investment file: the applicant instructs the firm directly, and no commission is paid in either direction.
Comparing Türkiye against other programs first? The citizenship by investment country comparison sets every open program beside the Turkish routes on the authorities’ own figures, and the naturalization route behind it is set out in how Turkish citizenship is granted.
General information, not legal advice. Turkish law. Your own position is assessed on your own documents.