Source of Funds for Turkish Citizenship by Investment

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

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

The source of funds for Turkish citizenship by investment is examined by the Turkish bank before it opens the investor’s account or buys the currency. That bank is an obliged party under Law No. 5549 on Prevention of Laundering Proceeds of Crime: it must identify the investor and anyone the investor acts for, learn what the account is for, and, in an unusually large transaction or any case it judges high risk, apply further measures, among them finding out as far as possible where the assets and the funds come from (Article 3 of the Law, Articles 5, 18 and 26/A(1)(c) of the Regulation on Measures Regarding Prevention of Laundering Proceeds of Crime and Financing of Terrorism). Where it cannot establish who the customer is or what the relationship is for, it opens no account and carries out no transaction (Article 22). On our files of 2026 a bank’s list for a citizenship account already asked for a document of the investor’s monthly income.

The file is therefore built before the currency is sent, because once the Central Bank has completed its purchase of the currency the sale cannot be abandoned or canceled for any reason (Article 7 of the Central Bank’s Implementation Instruction of 16 May 2022). Serka Law Firm asks the bank in writing what its compliance unit will need, builds the source-of-funds file to that answer and does both before the transfer, as part of the work set out on our Turkish citizenship by investment lawyer page.

The law the bank works under

Law No. 5549 makes banks obliged parties and requires them, before a transaction, to identify both the person who carries it out and the person on whose behalf it is carried out, and to take the other measures needed (Article 3(1)). A bank’s suspicious transaction reports go to the Financial Crimes Investigation Board (MASAK) (Article 4(1)). The detail is in the Regulation on Measures, issued under Article 27 of the Law. Its definition of a permanent business relationship names the opening of an account (Article 3(1)(i)), so the account a citizenship investment runs through is opened only after identification, whatever the sum, and with information on what the relationship is for (Article 5(1)(a), 5(2) and 5(3)).

For as long as the relationship lasts, the bank checks that the customer’s transactions fit his occupation, commercial activity, business history, financial standing, risk profile and what it knows of his sources of funds (Article 19(1)). The occupation an investor gives at the opening is therefore the measure a transfer of USD 500,000 is held against, and the document of the income, the sale or the gift that produced the money is what makes the two agree.

What the bank establishes about you

For a foreign national the bank records the name, date of birth, nationality, the type and number of the identity document, the address, a specimen signature, information on occupation and business, any telephone number and e-mail address, and the place of birth, and it verifies the identity on the passport, a residence document or another identity document the Ministry accepts (Article 6(1) and 6(2)(b), as amended on 25 December 2024). The address of a customer in a permanent relationship is verified on a certificate of residential address, a bill in the customer’s own name for a subscription service such as electricity, water, gas or telephone issued within three months before the transaction, a document from any public institution, or another document or method MASAK accepts (Article 6(3)). What the banks on our 2026 files accepted and refused as proof of address is in their written answers on our lawyer page.

The money question starts at the same counter. On 28 August 2026 a private bank’s branch listed in writing the documents for the citizenship account: a document showing monthly income, a document showing the official residential address, the passport and a Turkish tax number. It added that the account could be opened under a power of attorney covering the banking acts and powers in full. On 31 August 2026 another branch of the same bank wrote that its approval varies by customer and generally takes two weeks.

Where a lawyer or another representative opens the account, the bank identifies the representative under Article 6 and verifies the authority on a notarized power of attorney, and where it cannot verify the investor’s own identity under Article 6 it does so on that power (Article 14(2)). The banks on our files set their own wording for the power, so it is drafted to the bank’s list rather than to a template.

Whose money it is

Law No. 5549 punishes a person who acts in his own name but for someone else’s account and does not tell the obliged party in writing, before the transaction, whose account he acts for, with six months to one year’s imprisonment or a judicial fine (Article 15). The Regulation has a financial institution take the customer’s written declaration on that point when a permanent relationship begins. A customer who declares that he acts for someone else has that person identified too, and a bank that suspects he does despite a declaration that he does not applies the measures for finding the beneficial owner (Article 17(1), 17(2) and 17(5)): the natural persons who carry out the transaction, and those who ultimately control, or have the final influence over, the person on whose behalf it is carried out (Article 3(1)(h)).

For a citizenship file this means the money is the investor’s own before it is invested in the investor’s name. Money from a parent, a spouse or a business partner becomes the investor’s by a gift or a loan, and the document that says so is dated before the transfer. Money that stays someone else’s while it is held in the investor’s name, with no written declaration to the bank, is the case Article 15 describes.

Where the money comes from

The bank gives special attention to complex and unusually large transactions and to those with no apparent reasonable legal and economic purpose, and obtains enough information on their purpose (Article 18). It gives the same attention to persons resident in the risky countries the Ministry announces and to the nationals of those countries (Articles 25(1) and 3(1)(ı)). In those transactions, in those made through new technologies or without meeting the customer face to face (Article 20), and in any case it judges high risk, it applies one or more of these measures, in proportion to the risk (Article 26/A(1)):

• More information on the customer, and the identity data of the customer and the beneficial owner updated more often.
• More information on the nature of the relationship.
• Information, as far as possible, on the source of the assets involved and of the customer’s funds.
• Information on the purpose of the transaction.
• Entering the relationship, keeping it or carrying out the transaction made subject to a senior officer’s approval.
• Closer monitoring, with more controls and transaction types marked for further checks.
• A requirement that the first financial movement of a new permanent relationship come from another financial institution that applies the customer identification rules.

Two rules can meet head on here. On 31 August 2026 one branch wrote to us that a Russian citizen’s investment could not arrive by SWIFT and had to be paid in cash under its current procedure, while a bank that applies the last measure above takes the first money of a new relationship only from another financial institution. Which rule a bank applies to the file is asked of that bank in writing before the money moves.

The file we build, origin by origin

No article lists the documents for each kind of money. Article 26/A(1)(c) asks for information as far as possible, and what is enough is the bank’s judgment of the risk. We build the file in the order the money moved: the event that produced it, the account it was held in, and the transfer that brings it to Türkiye, each with a document that names the investor or shows why it names someone else.

The transfer carries the payer’s name

Under Article 24(1) a transfer message of TRY 15,000 or more carries the sender’s name, account number and one more identifier (an address, the date and place of birth, or a customer, citizenship, passport or tax number), and those data are verified; it also carries the recipient’s name and account. Every bank in the chain passes the sender’s data on, and a Turkish bank that receives a transfer without them returns the money or has the sending bank complete them (Article 24(4) and 24(6)). The Turkish bank therefore sees who paid. Where the payer is a parent or a company rather than the investor, the document that explains the payment is in the bank’s file before the transfer arrives. A sending bank does not always release the transfer message to its own customer, and a 2026 transfer on one of our files was traced by its UETR, as our page on the Foreign Exchange Purchase Certificate sets out.

Money from a company

A company that pays from abroad appears on the transfer as its sender. Where the company itself becomes the bank’s customer in Türkiye, it is identified on the documents that correspond to those asked of a Turkish company, approved by a Turkish consulate or apostilled by a state party to the Apostille Convention, and on notarized Turkish translations where the risk calls for them (Article 11(1)). The bank then finds the natural persons who ultimately control the company, and for a company registered in a trade registry that search starts with the natural persons holding more than 25 per cent, then those in ultimate control, then the highest registered executive (Article 17/A(2) to 17/A(5)).

A participation bank gave us its list for a company’s non-resident account on 10 September 2026: a potential Turkish tax number for the company, its shareholders and its authorized directors; a document showing the company was active in 2026 and one showing its officers in 2026; the articles of association, with a document of the field of activity where the articles do not carry it; a 2026 document of the ownership chain down to the natural person; and a signature circular from a Turkish notary or apostilled. Every document is apostilled where the country is a party to the Convention, issued in 2026 except the articles, and translated into Turkish and notarized in Türkiye. For a company in Dubai the procedure differs, and the bank did not supply it. How a document from a state outside the Convention is legalized instead is set out under the document route on our lawyer page.

When the bank says no

A bank that cannot establish the customer’s identity or the purpose of the relationship opens no account and carries out no transaction, and it assesses the case as a possible suspicious transaction (Article 22). A suspicious transaction is reported to MASAK whatever the amount, within ten working days of the suspicion (Articles 27(2) and 28(2)), and neither the bank nor its staff may tell anyone, the parties to the transaction included, that a report has been or will be made (Article 4(2) of the Law, Article 29 of the Regulation). The Minister of Treasury and Finance may also suspend a transaction, or not allow it, for seven working days where the assets are suspected of a link to laundering or terrorist financing (Article 19/A of the Law). An investor is never told whether a report was made, so the explanation goes to the bank before the money moves, not after a refusal. What the investor hands in stays on the bank’s file for eight years, and an account’s identification records for eight years from the day it is closed (Article 8 of the Law, Article 46(1) of the Regulation).

Where the money starts: China, Russia and the Gulf

The investor’s own state has its rules before the Turkish bank reads the file. A mainland Chinese resident buys foreign currency within an annual facility of USD 50,000, on a purchase application that rules out using it to buy property abroad, to invest in securities or for other capital items not yet open, while Hong Kong applies no exchange control (Article 112 of the Basic Law). Both are set out with their sources in the mainland China and Hong Kong section of our Turkish citizenship by investment lawyer page, and the Russian payer’s route on our page on Turkish citizenship by investment for Russian citizens. The Gulf investor’s transfer from the UAE, Qatar or Saudi Arabia is on our bank deposit page.

The Chinese investor’s file: capital controls and what the Turkish bank sees

For a mainland Chinese investor the source-of-funds question has two readers, and the Chinese one comes first. Foreign currency bought within the personal facility of USD 50,000 a year is bought on a purchase application, the 《个人购汇申请书》, which the buyer fills in himself and answers for (Article 57 of SAFE’s Guidelines for Current Account Foreign Exchange Business, 2020). The application lists the purposes the facility serves, among them travel, study, medical care, family support and foreign-currency savings at home, and none of them is an investment abroad. It forbids using the purchase to buy property abroad, to invest in securities or for other capital items not yet open, and it forbids lending one’s own facility to another buyer or borrowing other people’s facilities to split a purchase (SAFE Notice Huifa [2021] No. 13 and its Annex 1). A buyer who breaks those terms goes on a watch list with no facility that year and the next two, and is referred for an anti-money-laundering investigation (the same Notice). A remittance abroad of more than USD 50,000 a day is made on transaction documents, and the bank checks that the purpose of the purchase matches the purpose of the payment (Article 64(1) of the Guidelines).

The Turkish bank then reads what arrives. Every transfer of TRY 15,000 or more names its sender (Article 24 of the Regulation on Measures), so a USD 500,000 investment assembled from several relatives’ yearly facilities reaches the Turkish bank as several payers, each of whom the file has to explain, each of whom declared a purpose on his own purchase application in China. Money already held outside the mainland is read differently. Hong Kong applies no foreign exchange control and safeguards the free flow of capital into and out of the Region (Article 112 of the Basic Law), so a Hong Kong account in the investor’s own name, with its history, is the document the Turkish bank’s question is answered on. On one of our 2026 files a transfer instructed at a Hong Kong bank on 20 May was released by that bank on 27 May and credited in Türkiye on 3 June, and because the sending bank does not release the payment message to its own customer, the transfer was traced by its UETR.

This page states what each text says and what the Turkish bank will see; it gives no opinion on Chinese law. The Chinese nationality rule that sits beside these is in the mainland China and Hong Kong section of our Turkish citizenship by investment lawyer page.

Before the money moves

The source-of-funds file decides whether the bank opens the account at all, and it is written once, before the currency is sent. Where the money is held, how it was earned and who is paying are the first three things we ask.

The texts this page rests on

• Law No. 5549 on Prevention of Laundering Proceeds of Crime, Articles 2, 3, 4, 8, 15 and 19/A, consolidated text
• Regulation on Measures Regarding Prevention of Laundering Proceeds of Crime and Financing of Terrorism, consolidated text
• Central Bank of the Republic of Türkiye, Implementation Instruction of 16 May 2022
• Financial Crimes Investigation Board, Preventive Measures, the Ministry’s English summary, whose thresholds predate the amendments of 2021 and 2023
• The written answers of Turkish banks on our files of August and September 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.