A business partner asks you to receive a customer payment and forward it to them. Their own account is still being opened, a transfer limit has been reached, or the bank has requested additional documents.
Before agreeing, establish why your business should receive the money.
On 12 October 2026, MASAK, Türkiye’s financial intelligence authority, published guidance on accounts used by third parties. It covers personal and corporate accounts, payment services and POS arrangements.
Keeping your password does not resolve the issue
You may retain your card, phone and banking credentials while personally making every transfer. Another person may still determine the amounts, recipients and timing. The guidance expressly addresses this arrangement.
The bank needs to understand who owns the funds, the purpose of the transactions and who actually directs them.
Giving a customer your IBAN to pay your own invoice is different from making your account available for someone else’s collections. Sharing an account number alone does not establish criminal conduct.
Case: collecting a partner’s revenue
Suppose a business entering Türkiye asks an established company to receive customer payments until its banking arrangements are ready.
The receiving company needs to explain those receipts through its contracts, supporting records and actual commercial role. Simply collecting and forwarding another business’s revenue requires a separate legal and banking assessment.
A payment reference cannot establish the entire basis for the transaction.
What can happen
Where there are indications of third-party account use, the guidance discusses restrictions on remote banking, lower limits and suspension of card or POS services. Depending on the circumstances, the banking relationship may end. These consequences are not automatic for every third-party payment.
Criminal liability requires a separate assessment of the facts.
Before accepting the arrangement
Establish who supplies the goods or services, who is entitled to payment and why your company participates. Review the proposed structure with your bank, Turkish counsel and accountant. Use bank-approved access arrangements when authorising employees.
If unexplained funds have already arrived, contact the bank before forwarding them and retain the relevant records.
A request to route another business’s revenue through your account deserves its own financial decision.
Official sources
- MASAK announcement, 12 October 2026.
- Kiralık Hesaplarla Mücadele Şüpheli İşlem Bildirimi Rehberi, sections C and G.
Checked: 16 October 2026.