Guide · Banking and compliance

    KYC and EDD for a Turkish company: how to maintain the bank file

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    A Turkish company's bank KYC file covers registration data, business activity, the representative, beneficial ownership and ultimate control. It is more than an account-opening check: during an ongoing relationship, the bank monitors whether transactions match the customer's profile and sources of funds and keeps information current. Enhanced EDD measures are proportionate to risk and may involve additional information, sources of assets and funds, transaction purpose and internal approval by a senior bank officer. This does not mean EDD automatically applies to every foreign company. Owners can maintain a change log recording what changed, which documents need review and who supplies information to the bank.

    Who this guide helps

    • An owner or director of a Turkish company who wants to maintain the bank file regularly, not only when the bank asks.
    • A finance provider responsible for updating the company's information and documents.

    Scope and boundaries

    • This page does not describe account opening and does not guarantee that a bank will open an account or approve transactions.
    • This page does not cover a response about a single transfer (see the separate page) or restricted access to an account.
    • This page does not state that EDD is mandatory for all foreign founders or companies.

    Ordinary KYC and enhanced measures are different levels

    • Identification: the bank establishes the company's registration data, its activity and the details of the person with authority to represent it.
    • Beneficial owner: the examination includes establishing the beneficial owner and ultimate control; a shareholding alone does not exhaust that examination.
    • Ongoing monitoring: the bank monitors whether transactions match the client's profile and sources of funds and keeps client information and records current.
    • Enhanced measures for higher risk: one or more measures from a list — additional information, the source of assets and funds, the purpose of the transaction, internal approval by a senior bank officer — in proportion to risk.

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

    If the bank cannot identify the customer or obtain sufficient information about the purpose of the relationship, it does not establish the business relationship or carry out the requested transaction. If doubts about the adequacy or accuracy of previously obtained identity information require renewed identification and verification, but these cannot be completed, the bank terminates the business relationship. These are narrow provisions, not a description of every situation.

    MASAK, Article 22(1) · MASAK, Article 22(2)

    Change events: what to update and who confirms

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

    EventWhich document to updateWho confirmsWhat it rests on
    The person with authority to represent the company changesA document on the new representative's authority and their identification detailsThe director or another authorised person; the bank acceptsThe bank establishes the details of the person with authority to represent
    The company's activity changesA description of the activity and supporting documentsThe company's directorThe bank establishes the company's activity
    The beneficial owner or ultimate control changesInformation on the beneficial owner and the chain of controlThe shareholders and the directorThe examination includes the beneficial owner and ultimate control
    Transactions no longer match the profile: new counterparties, new kinds of paymentsAn explanation, contracts, an updated profile descriptionThe director and the finance providerConsistency with the client's profile and sources of funds is checked and information is updated
    The bank asks for more information in a higher-risk caseDocuments as requested: source of assets and funds, purpose of the transactionWhoever prepares the reply; the bank decidesEnhanced measures may include this information and internal approval by a senior bank officer

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

    How to maintain the file

    1. Name a person responsible for the file and for replies to bank requests.
    2. Keep a log of events: change of representative, activity or beneficial owner, and new kinds of transactions.
    3. After each event, review your file and provide current information to the bank under the procedure agreed with it.
    4. Keep current registration data, the description of the activity, and information on the beneficial owner and ultimate control.
    5. If the bank asks for extended information, answer the bank's request on its substance without adding more than needed.
    6. Do not promise in advance that the bank will not ask further questions or that restrictions will not arise.

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

    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, 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)

    MASAK regulation (Article 22(1)–(2) and Article 26/A(1)(a)–(e)): if the bank cannot identify the customer or obtain sufficient information about the purpose of the relationship, it does not establish the business relationship or carry out the requested transaction; if doubts about the adequacy or accuracy of previously obtained identity information require renewed identification and verification, but these cannot be completed, the bank terminates the business relationship; in 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.

    MASAK, Article 22(1) · MASAK, Article 22(2) · MASAK, Article 26/A — enhanced measures

    The columns 'Which document to update' and 'Who confirms' are practical suggestions, not a list of requirements in the source.

    Common mistakes

    • Treating KYC as a one-off check at account opening.
    • Assuming that enhanced measures apply automatically to every foreign company.
    • Not reporting a change of representative, activity or beneficial owner and not updating documents.
    • Describing the beneficial owner and ultimate control by shareholding alone.
    • Promising that no questions will follow once the file is updated.

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

    Discuss your documents and task

    If you want to check how far your bank file reflects the company's current state, send us the list of documents and a description of recent changes, and we will help build an event log and an update list.

    Discuss the task

    Frequently asked questions

    Is KYC a one-off check at account opening?

    No. 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 19(1)

    Is EDD mandatory for every foreign company?

    No such conclusion can be drawn: in 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, and one or more measures are applied in proportion to risk.

    MASAK, Article 26/A — enhanced measures

    What happens if the required identification or purpose information is missing?

    If the bank cannot identify the customer or obtain sufficient information about the purpose of the relationship, it does not establish the business relationship or carry out the requested transaction. This is a narrow provision; the specific situation is determined by the bank's notice.

    MASAK, Article 22(1)

    What if re-identification cannot be completed?

    If doubts about the adequacy or accuracy of existing identity information require renewed identification and verification, but these cannot be completed, MASAK Article 22(2) provides for termination of the business relationship. This is a specific condition, not the consequence of every document-update request.

    MASAK, Article 22(2)

    Primary sources

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