Turkish Citizenship by Investment for Russian Citizens

Av. Serkan KARA, Serka Law Firm (Istanbul Bar, no. 53770)

Last reviewed: 27 October 2026 · Reviewed by Av. Serkan Kara

A Russian citizen can pay for Turkish citizenship by investment from Russia in 2026, and the limit that decides the file no longer sits in Russia. The Bank of Russia lifted its caps on Russian citizens’ transfers of foreign currency abroad from 8 December 2025. What decides the file is the Turkish bank that is to receive the money: whether it accepts a transfer from the sending bank at all, by which channel, and on what record of where the money came from. That bank answers to Turkish anti-money-laundering law and carries its own exposure to United States secondary sanctions, and on our files of 2026 one bank’s branch wrote that it takes no SWIFT transfer of the investment amount from a Russian citizen and wants the amount in cash. Serka Law Firm puts these questions to the bank in writing, before the investor books a flight or instructs a transfer, and builds the file to the answer.

Russia no longer limits the transfer

From 1 October 2025 to 31 March 2026 the Bank of Russia allowed a Russian citizen to send no more than USD 1 million a month, or its equivalent, to accounts in foreign banks, and no more than USD 10,000 a month through money transfer systems (its notice of 26 September 2025). On 5 December 2025 it announced that from 8 December 2025 it was lifting the limits on transfers of foreign currency abroad for Russian citizens and for non-residents from friendly countries. What it kept, and on 1 June 2026 extended from 8 June to 7 December 2026, applies to non-residents from the countries it lists as unfriendly, not to a Russian citizen paying from his own account. For an investment of USD 400,000 in property or USD 500,000 by any other route, the Russian side of the transfer is therefore the sending bank’s own procedure and nothing more.

The receiving bank decides, and it is exposed

Executive Order 14114 of 22 December 2023 added section 11 to Executive Order 14024. It lets the United States Treasury prohibit or condition a foreign financial institution’s correspondent or payable-through accounts in the United States, or block its property, once it determines that the institution conducted or facilitated a significant transaction, or provided any service, involving Russia’s military-industrial base. The order defines a foreign financial institution as any foreign entity in the business of accepting deposits or buying and selling foreign exchange, which is every Turkish bank that would hold a citizenship deposit.

On 12 June 2024 the Office of Foreign Assets Control widened what that base covers to every person blocked under Executive Order 14024, the Russian financial institutions so blocked among them. The same guidance lists the red flags a bank is expected to watch for, and two of them describe exactly how an investment from Russia might arrive: large cash payments, and payments routed through third countries not otherwise involved in the transaction. Transactions that general licences authorise for United States persons, such as food, agriculture, medicine, energy and telecommunications, carry no exposure. A citizenship investment is none of those.

So the first act on a Russian file is to name the bank that will send the money and check it against the sanctions list, and the second is to ask the Turkish bank, in writing, whether it will receive from that bank. Both answers are on paper before the money moves.

What Turkish banks answered on our 2026 files

Every answer below was given to us in writing on a live file between August and September 2026. No client is named, and no bank gave a reason for its rule, so none is written here.

• No SWIFT transfer for Russian citizens. A private bank’s branch wrote on 31 August 2026 that, for Russian citizens, the investment amount could not arrive by SWIFT and was to be paid in cash under its current procedure. In the same answer it took the rate from the Central Bank on the day, charged no commission on the conversion, and asked its treasury unit for the three-year block by letter, usually confirmed within a working day.
• The Russian taxpayer number. A participation bank asked for the INN of a Russian citizen on 1 September 2026, and did not accept a general banking clause in the power of attorney.
• Proof of address without a Turkish residence. Another participation bank opened a non-resident account without a residence permit and accepted the translated address page of the Russian internal passport in place of a utility bill. It took a utility bill in the investor’s own name from any country if under three months old, and refused a bank statement and a title deed as proof of address (10 September 2026).
• The power of attorney is drafted to the bank. One private bank wanted the banking acts and powers covered in full (28 August 2026); a state-owned bank wanted every banking act listed one by one and sets up no internet banking under a power of attorney (21 September 2026).
• Not every bank runs every route. On 31 August 2026 a private bank’s branch ran only the three-year lira time deposit for citizenship, while on 21 September 2026 a state-owned bank’s branch confirmed that it runs the government bond route.

The bank is therefore chosen after these answers, not before them. A file refused at one bank is carried to another bank, or to another route, before any money moves.

Cash meets the first-movement rule

A bank that asks for cash and a bank that applies the strictest anti-money-laundering measure are asking for opposite things. Among the measures a Turkish bank may apply to a high-risk relationship is a requirement that the first financial movement of a new permanent relationship come from another financial institution that applies the customer identification rules (Article 26/A(1)(f) of the Regulation on Measures Regarding Prevention of Laundering Proceeds of Crime and Financing of Terrorism). A transfer of TRY 15,000 or more must also carry the sender’s name, account and one more identifier through every bank in the chain, and a Turkish bank that receives one without them returns it or has the sender’s bank complete it (Article 24(1), (4) and (6)). Which of these a particular bank applies to a Russian investor is asked of that bank in writing, and the source of funds file is written for the answer it gives. Cash does not remove the question of where the money came from; it moves the whole weight of the answer onto the papers.

Whoever pays must also be the person the bank is told about. Acting in one’s own name for someone else’s account without telling the bank in writing beforehand is an offence under Article 15 of Law No. 5549 on Prevention of Laundering Proceeds of Crime, so money from a parent, a spouse or a company becomes the investor’s own by a dated gift or loan before it is invested. What the bank asks and accepts for each origin of money is set out on our page on the source of funds for Turkish citizenship by investment.

Rubles, the conversion and the threshold

The Central Bank buys only US dollars, euros, sterling and Swiss francs in a citizenship sale. Rubles that reach the Turkish bank are converted by that bank first and then sold (Article 5(2) of the Central Bank’s Implementation Instruction of 16 May 2022, as amended on 1 October 2026). A lira transfer does not qualify at all, because there is no foreign currency to sell. The investment is measured against the threshold once, at the Central Bank’s effective selling rate or cross rate on the date of determination (Article 20(6) of the Regulation on the Application of the Turkish Citizenship Law), so a ruble file is sized with a margin over that day’s cross rate. Once the Central Bank has completed its purchase, the sale cannot be abandoned or cancelled (Article 7 of the Instruction), and on the deposit route the lira stays for three years in the same bank that sold the currency (Article 6(1)). The purchase is then documented by the Foreign Exchange Purchase Certificate.

The papers that come from Russia

Russia has been a party to the Apostille Convention since 31 May 1992 (the Hague Conference’s status table, read 5 October 2026), so a Russian birth or marriage certificate, or a power of attorney before a Russian notary, takes an apostille and then a sworn translation certified by a Turkish notary. The apostille is issued in Russia: the Consulate General of the Russian Federation in Istanbul answered in writing on 7 October 2026, on a live file, that it does not apostille Russian civil-registry certificates. Those certificates are therefore ordered in Russia on the day the file opens, while the account and the investment run on the passport and the power of attorney. A power of attorney drawn up by a Turkish consulate is a Turkish instrument from the moment it is signed and needs neither an apostille nor a translation (Articles 191, 193 and 103 of Notary Law No. 1512).

Russia after the Turkish passport

Acquiring Turkish citizenship does not end Russian citizenship, and Russia treats a dual citizen only as its own citizen (Article 10 of Federal Law No. 138-FZ of 28 April 2023 on Citizenship of the Russian Federation). Every foreign citizenship acquired must be notified to the internal affairs authorities within sixty calendar days of its acquisition, or, by a citizen who is abroad, to a Russian embassy or consulate. A citizen who misses the period because he is abroad notifies within sixty days of entering Russia, parents notify for their minor children, and a representative may notify on a power of attorney notarised under Russian law (Article 11(2), (4), (5) and (6)). The consequences of a missed notification are set out in Russian law outside this Article and are not stated on this page.

The texts this page rests on

• Bank of Russia, notices of 26 September 2025, 5 December 2025 and 1 June 2026
• Executive Order 14114 of 22 December 2023, 88 FR 89271, adding section 11 to Executive Order 14024; Office of Foreign Assets Control, updated guidance for foreign financial institutions of 12 June 2024
• Law No. 5549 on Prevention of Laundering Proceeds of Crime and the Regulation on Measures Regarding Prevention of Laundering Proceeds of Crime and Financing of Terrorism, consolidated texts
• Central Bank of the Republic of Türkiye, Implementation Instruction of 16 May 2022
• Federal Law No. 138-FZ of 28 April 2023 on Citizenship of the Russian Federation, consolidated text
• The written answers of Turkish banks and of the Russian Consulate General in Istanbul on our files of August to October 2026, with no client named

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.