Guide · Banking and compliance

    Turkish bank source-of-funds request: how to build a transaction response

    Читать этот гайд на русском

    If a Turkish bank has asked for the source of funds on a specific transaction, it is easier to build the response around the request itself: transaction → contract or invoice → performance → payment chain. This is a RelocationTR editorial recommendation, not a legal requirement. The bank's questions rest on the MASAK regulation: during an ongoing relationship the bank, as an obliged entity, monitors whether transactions match the client's profile and sources of funds and keeps client information and records current, and for higher-risk cases enhanced measures may include additional information, the source of assets and funds, the purpose of the transaction, and internal approval by a senior bank officer. Below you will find a document index, a step-by-step preparation process and common mistakes.

    Who this guide helps

    • An owner or finance lead of a Turkish company whose bank has sent a request about a specific payment or receipt.
    • An accountant or coordinator assembling the document set for a bank response.

    Scope and boundaries

    • This page does not describe the company's standing KYC file, which is covered separately.
    • This page does not cover restricted access to an account or other steps following a notice; a separate page deals with that.
    • This page does not set the format or timing of the reply, which are defined by the bank's request, and does not guarantee the bank's decision.

    What lies behind the bank's question

    In continuing relationships the bank checks that transactions are consistent with the client's profile and sources of funds, and information and documents are updated. For higher-risk cases, enhanced measures may include additional information, the source of assets and funds, the purpose of the transaction, and internal approval by a senior bank officer; one or more measures are applied in proportion to risk, and not all of them apply automatically to every client.

    MASAK, Article 19(1) · MASAK, Article 26/A — enhanced measures

    • The bank needs the company's registration data, its activity and the details of the person with authority to represent it.
    • The examination includes establishing the beneficial owner and ultimate control; a shareholding alone does not exhaust that examination.
    • A request about a transaction may concern its purpose and the source of funds; take the list from the bank's letter, not from this page.

    MASAK, Article 7(1)–(3) · MASAK, Article 17/A · MASAK, Article 26/A — enhanced measures

    Document index for a transaction

    This table is a recommended working check. Legal provisions are identified separately with source links; the document set depends on the specific task.

    Link in the chainWhat to showWhere it comes fromWhat to cross-check
    TransactionStatement or payment order: date, amount, payer, payeeThe company's bankWhether the data match the transaction named in the bank's request
    Contract or invoiceThe contract, annexes and invoice for this transactionCompany archive, counterpartyThe contracting party, subject matter and amount match the payment
    PerformanceAcceptance act, shipping documents, correspondence, confirmation that the service was renderedCompany archive, responsible staffPerformance matches the contract and invoice
    Payment chainWho paid and from which account, and through which accounts the money movedStatements, counterparty documentsNo gaps between the payer, the contracting party and the payee
    Source of assets and funds, if the bank asked for itDocuments evidencing the origin of funds, as the bank requestsDepends on the bank's requestExactly what was requested; do not send more than needed without reason
    Company and control informationRegistration data, activity, the person with authority to represent, beneficial owner and ultimate controlThe registry, internal company documentsThat the information is current: it is updated in continuing relationships

    MASAK, Article 7(1)–(3) · MASAK, Article 17/A · MASAK, Article 19(1) · MASAK, Article 26/A — enhanced measures

    How to assemble the response

    1. Get the bank's request in writing and note which transaction, period and questions it names.
    2. Build the response around the request itself: transaction → contract or invoice → performance → payment chain.
    3. Attach documents for each link and number them in the index.
    4. Cross-check party names, amounts and dates across all documents.
    5. If the bank asked for the source of assets and funds or the purpose of the transaction, answer exactly that question.
    6. Keep a copy of what you sent and the correspondence; update the company information if it has changed.
    7. Do not promise in advance that later transfers will pass without questions.

    MASAK, Article 19(1) · MASAK, Article 26/A — enhanced measures

    Sources and limits of this page

    MASAK regulation (Article 7(1)–(3) and Article 17/A): when identifying a company, the bank establishes its registration data, its activity and the details of the person with authority to represent it; the examination includes establishing the beneficial owner and ultimate control.

    MASAK, Article 7(1)–(3) · MASAK, Article 17/A

    MASAK regulation (Article 19(1) and Article 26/A(1)(a)–(e)): during an ongoing relationship the bank, as an obliged entity, monitors whether transactions match the client's profile and sources of funds and keeps client information and records current; for higher-risk cases enhanced measures may include additional information, the source of assets and funds, the purpose of the transaction, and internal approval by a senior bank officer. No amounts, deadlines or guaranteed outcomes follow from this. Source: the same MASAK regulation text.

    MASAK, Article 19(1) · MASAK, Article 26/A — enhanced measures

    The advice on the order of the response and the document index is editorial: the list and scope of documents are set by the specific bank's request.

    Common mistakes

    • Answering with general statements about the business instead of a chain built around the specific transaction.
    • Sending documents in which party names, amounts or dates differ.
    • Sending an invoice without evidence of performance, or a payment chain without the contract.
    • Ignoring the question on the source of assets and funds or the purpose of the transaction when the bank asked it.
    • Telling the owner that the bank will not ask further questions after the reply.

    MASAK, Article 26/A — enhanced measures

    Discuss your documents and task

    If you have received a bank request, send us its text and the list of documents for the transaction, and we will help build the index and see which links in the chain are missing.

    Discuss the task

    Frequently asked questions

    What can a bank ask a company about a transaction?

    In higher-risk situations, the bank may request additional customer information, the source of assets and funds, and the purpose of the transaction. Some enhanced measures involve internal approval by a senior bank officer; this is not a document the company must obtain itself. Use the specific written request to define your response.

    MASAK, Article 26/A — enhanced measures

    How should I structure the response to the bank?

    RelocationTR recommends building the response around the specific request: transaction, contract or invoice, performance, payment chain. This is an editorial recommendation, not a legal requirement.

    Is it enough to state my shareholding to pass the beneficial-owner check?

    No. The bank's examination includes establishing the beneficial owner and ultimate control, and a shareholding alone does not exhaust that examination.

    MASAK, Article 17/A

    Does a good response guarantee that later transfers will pass without questions?

    No. In continuing relationships the bank monitors whether transactions match the client's profile and sources of funds and keeps client information and records current, so new questions are possible. RelocationTR does not promise transfers without questions.

    MASAK, Article 19(1)

    Primary sources

    Prepared by RelocationTR. The dates below refer to checks of the cited source provisions.