Guide · Banking and compliance

    Changing a Turkish company director or signatory: bank-file checks

    Читать этот гайд на русском

    When a Turkish company changes its director or signatory, RelocationTR recommends cross-checking registration, bank and operational authority and asking the bank about its notification procedure. 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 the beneficial owner and ultimate control; and during an ongoing relationship the bank keeps client information and records current. The founder, the beneficial owner and the representative are different roles: one person may combine them, but a change in one does not mean a change in another. If a foreign shareholder manages the company and works in that role, the work-permit question is decided separately from the bank file. Corporate legal procedures and deadlines are not covered on this page.

    Who this guide helps

    • An owner or director of a Turkish company whose director, signatory or bank representative is changing.
    • A finance provider who supports bank operations and must reconcile previous and new authority.

    Scope and boundaries

    • This page does not describe corporate procedures for changing a director, requirements for the composition of company bodies, or deadlines: those need the primary text and the registry.
    • This page does not cover selling shares or payments to a director.
    • This page does not name a deadline for notifying the bank and does not guarantee the bank's decision.

    Three layers of authority and three roles

    After a change of management it is recommended to cross-check registration, bank and operational authority; the notification procedure should be confirmed with the bank.

    • Representative: the bank establishes the details of the person with authority to represent the company.
    • Beneficial owner: the examination includes the beneficial owner and ultimate control; a shareholding alone does not exhaust that examination.
    • Founder or shareholder: this is a separate role; changing it does not automatically change the representative or signatory, and vice versa.
    • Updating: during an ongoing relationship the bank keeps client information and records current.

    MASAK, Article 7(1)–(3) · MASAK, Article 17/A · MASAK, Article 19(1)

    Map of previous and new authority

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

    Layer or roleWhat there wasWhat there is nowWhich documents to cross-check
    Registration authority (director, manager)The previous person and scope of authorityThe new person and scope of authorityThe company's registration documents evidencing management
    Bank authority (signatories, representative)The persons recorded at the bankThe persons who should be recordedBank documents on authority and the identification of the representative
    Operational authority (online-banking access, payment approval)Previous accessNew access, with previous access revokedThe internal list of access rights and approval routine
    Founder or shareholderThe previous compositionThe current composition, if it changedDocuments evidencing participation; do not mix with the representative's role
    Beneficial owner and ultimate controlThe previous informationCurrent information on the beneficial owner and chain of controlDocuments evidencing the chain of control

    MASAK, Article 7(1)–(3) · MASAK, Article 17/A · MASAK, Article 19(1)

    Order of checks

    1. Draw up a map of previous and new authority across the three layers: registration, bank and operational.
    2. Check separately whether the roles of founder, beneficial owner and representative have changed.
    3. Prepare documents on the new representative's authority and their identification details for the bank.
    4. Update the information on the beneficial owner and ultimate control if it has changed.
    5. Revoke previous access and confirm new access inside the company.
    6. Confirm the notification procedure and evidence of new authority with the bank.

    MASAK, Article 7(1)–(3) · MASAK, Article 17/A · MASAK, Article 19(1)

    A foreign shareholder working as manager

    The ÇSGB work-permit FAQ treats a working foreign partner-manager of an Ltd and a partner-board member of an AŞ separately: working in those roles requires a work permit, and company registration or an appointment is not an automatic approval. This is a separate question from the bank file, and this page does not state the conditions or timing for obtaining one.

    ÇSGB: FAQ, question 31

    Sources and limits of this page

    MASAK regulation (Article 7(1)–(3), Article 17/A, Article 19(1)): 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 the beneficial owner and ultimate control; 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.

    MASAK, Article 7(1)–(3) · MASAK, Article 17/A · MASAK, Article 19(1)

    ÇSGB work-permit FAQ, question 31: a working foreign partner-manager of an Ltd and a partner-board member of an AŞ are treated separately.

    ÇSGB: FAQ, question 31

    The authority map is a practical recommendation; this page contains no corporate deadlines or requirements on the composition of company bodies.

    Common mistakes

    • Changing the director in the registry but not updating signatories and the representative at the bank.
    • Not revoking previous access to bank operations.
    • Mixing the roles of founder, beneficial owner and representative.
    • Describing the beneficial owner by shareholding alone.
    • Assuming that appointing a foreign shareholder as manager gives the right to work without a permit.

    MASAK, Article 7(1)–(3) · MASAK, Article 17/A · ÇSGB: FAQ, question 31

    Discuss your documents and task

    If your director or signatory is changing, send us your current bank authority and a description of the changes, and we will help build a map of previous and new authority and a list of documents for the bank.

    Discuss the task

    Frequently asked questions

    By when must the bank be notified of a change of director?

    Check the notification procedure and deadline with your bank under your agreement and its procedures. Agree the documents in advance, cross-check registration, bank and operational authority, and keep confirmation of the update.

    How do a founder, a beneficial owner and a representative differ?

    They are different roles. The bank establishes the details of the person with authority to represent the company and, separately, the beneficial owner and ultimate control; a shareholding alone does not exhaust the beneficial-owner examination.

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

    Do I need to update beneficial-owner information when the director changes?

    Only if the information on the beneficial owner and ultimate control has changed. During an ongoing relationship the bank keeps client information and records current, so their currency should be checked.

    MASAK, Article 17/A · MASAK, Article 19(1)

    Does appointing a foreign shareholder as manager give the right to work?

    No such conclusion can be drawn. The ÇSGB FAQ treats a working foreign partner-manager of an Ltd and a partner-board member of an AŞ separately: working in those roles requires a work permit, and registration is not an automatic approval.

    ÇSGB: FAQ, question 31

    Primary sources

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