Clients usually assume that «the bank» checks a payment. In reality a transfer passes through five independent circuits, and each can stop it on its own: the foreign exchange regime, the bank's compliance function, financial intelligence, sectoral clearance, and the banks' own sanctions policies.

The last circuit is not Turkish law but the bank's own decision protecting its dollar clearing. Citing statute against it is useless: the bank resolves every doubt in its own favour, because the cost of error for it is the loss of international settlement.

Three figures to know in advance

• USD 50,000 — the bank must report the transfer abroad to the designated authorities within 30 days. Not a prohibition: the payment goes through, but it becomes visible.
• EUR 10,000 — the threshold for taking cash out of the country; a special procedure applies.
• Any amount — where suspicion arises, or there is doubt about data previously obtained about you, checks are carried out regardless of amount.

Splitting a payment to stay under a threshold is pointless and harmful: thresholds are computed on the total of linked transactions, and structuring is itself a classic indicator of a suspicious transaction.

The contract-currency trap

Türkiye prohibits pricing in foreign currency, or indexing to it, in contracts between persons resident in Türkiye — for the sale and lease of property, leasing, and service and works contracts.

There are carve-outs, and one matters in practice: a service contract may be priced in foreign currency where a party holds no Turkish citizenship — even if that party lives in Türkiye. FX pricing is also available for cross-border services and for services that earn foreign currency. Check this before agreeing price, not after signature.

What to assemble before sending

• Documents on the origin of the funds — for each source separately
• Proof that tax was paid where the money arose
• Statements showing the movement of funds with no gaps in the chain
• The contract and invoice, which the payment purpose must match word for word
• Translations and, where required, an apostille

Assemble this pack in advance. After a block it is too late — and any document created after the event turns a financial question into a criminal one.

If the bank asks a question

This is the pivotal moment: how you answer matters more than what the documents say. Answer within twenty-four hours, fully and calmly. Do not demand that the bank justify its enquiry and do not threaten to complain — that moves you into a higher risk category. And do not ask whether the bank has reported you to the financial monitoring authorities: staff are forbidden to disclose this on pain of criminal liability.

If your account is closed

Refusal of service and account closure are decisions of the bank as a private company, not acts of a state authority. The dispute follows the rules of a civil claim, not those for challenging a public decision. That changes both the procedure and what can realistically be achieved.