Turkish Citizenship Due Diligence: Checking an Investment Before the Money Moves

Turkish citizenship due diligence means checking, before any money moves, that an investment will qualify. For property, that covers the title type, previous foreign ownership, the seller, a valuation and amount determination document of at least USD 400,000, and a bank conversion certificate (DAB) issued before the deed. As of November 2026, source of funds and sanctions checks complete it.

• Why it matters: a purchase that misses one rule leaves you owning an asset that cannot support the citizenship file, and the defect can rarely be cured after the deed.
• Property type: since 12 December 2023, only units with condominium ownership (kat mülkiyeti) or a construction servitude (kat irtifakı), or land with a building on it.
• History: not registered to a foreign individual, not transferred to a Turkish citizen or company by a foreign individual or an investor-citizen in the last three years, and no earlier use for citizenship.
• Amount: under the TKGM guide, the deed price, the valuation and the converted currency on the DABs must each reach USD 400,000.
• Valuation: since 28 September 2026, by any valuation firm authorised by the Capital Markets Board (SPK), active in the valuers' association (TDUB) and registered in the land registry's valuation system; the amount determination document is usable for 12 months.
• Payment: foreign currency sold through a bank in Türkiye to the Central Bank before the deed, with bank receipts showing payment to the seller.
• Funds and sanctions: lawyers are obliged parties under the anti-money laundering Law No. 5549 for real estate transactions, and banks run their own checks.
• Enforcement: on 4 August 2026 the Ministry of Interior announced that 6,134 people's citizenship decisions had been annulled or withdrawn, mainly over sham or irregular transactions, chiefly inflated valuations.

Who needs citizenship due diligence

Anyone about to commit money to a citizenship investment, above all buyers who:

• have been offered a property described as "citizenship-eligible" by an agent or developer;
• are buying off-plan, buying several units, or buying from a company;
• will pay from a mix of accounts, countries or family members;
• are investing through a bank deposit, bonds, fund units, a pension or a business, where the checks differ but are just as strict.

It does not replace the authorities' review, an engineer's survey or home-country tax advice. It sits alongside the ordinary real estate due diligence, which asks whether the property is safe to own; citizenship due diligence asks whether the purchase will count.

The rules behind the checks

The investment routes are set by art. 20(2) of the Regulation on the Implementation of the Turkish Citizenship Law, under art. 12(1)(b) of the Turkish Citizenship Law No. 5901. For property, the General Directorate of Land Registry and Cadastre (Tapu ve Kadastro Genel Müdürlüğü, TKGM) applies them through its guide on the regulation, revised in 2023, February 2024 and December 2024, and through its circulars on currency conversion (2022/1) and valuation (2024/2 and 2024/4, both changed, as reported, by an approval of 28 September 2026). The registry's questions and answers for foreign buyers summarise its practice.

The CBI due diligence checklist for a property

1. The property type

Since Presidential Decision No. 7938 (Official Gazette of 12 December 2023), the property must carry condominium ownership or a construction servitude, or be land with a building on it. Bare land and fields no longer qualify. Residential and commercial units both qualify with the right title type. The check is made on the certified title extract, not the brochure.

2. Previous foreign ownership and earlier use

• The property must not be registered to a foreign individual, including your own spouse and children, so in practice you cannot buy for citizenship from a foreign owner. A second-hand property must also not have been transferred to a Turkish citizen or company by a foreign individual, or by a person who acquired citizenship by investment, in the last three years.
• A property that has supported one citizenship application cannot support another, even after it changes hands.

3. The seller

Under the TKGM guide as applied since 2023, these sellers are excluded:

• a person who obtained Turkish citizenship through investment, as reported (see also the three-year transfer rule above);
• your first-degree relatives (by blood, marriage or adoption) who are Turkish citizens;
• a company in which you or your first-degree relatives by blood or marriage are a partner or manager;
• a Turkish company with foreign capital within art. 36 of the Title Deed Law No. 2644;
• a Turkish citizen or company that bought the property from you, your spouse or your first-degree relatives: buy-backs do not count.

The relatives rule covers a parent or child who is a Turkish citizen, including by birth. A sibling is a second-degree relative and is not named, so treat that case by case and get written confirmation.

4. The structure of the purchase

• Sole ownership. Shared ownership has not supported an application since the 2023 TKGM guide, so the title must be entirely in the applicant's name. Spouses should not co-own; the spouse qualifies as a family member.
• Personal name. A property bought in a company's name does not qualify for this route.
• Off-plan. A notarised promise-to-sell contract on a unit with kat irtifakı or kat mülkiyeti, with the whole qualifying amount in a single contract. Separate contracts are not added together, and a shortfall in completed purchases cannot be made up with a promise to sell.
• Financing. Under TKGM's published answers a bank loan secured on the unit is not a bar in itself, but the loan is deducted: the price paid apart from it must reach USD 400,000. A legal mortgage (kanuni ipotek) securing unpaid price leaves at most the part paid in advance, and some versions of the guide exclude such property. If a property bought subject to a mortgage or attachment is later sold by enforcement, the certificate is reported for cancellation, so have such entries released. Any financing needs prior confirmation.

5. Valuation and the amount determination document

A citizenship purchase needs a valuation report issued through the valuation information system (TADEBİS), which leads to the amount determination document (Tutar Tespit Belgesi, TTB). From 4 March 2024 to 28 September 2026 only one firm, GEDAŞ, could prepare these reports. Since then, any SPK-authorised firm with active membership of the valuers' association (TDUB) and integrated into TADEBİS may do so, and the report and TTB are usable for 12 months instead of six. As reported, the applicant may choose the firm through Web Tapu or let the system assign one. A TTB presented on paper is not accepted.

The lawyer checks that:

• the deed price (or the promise-to-sell price), the TTB value and the converted amount on the DAB each reach USD 400,000, as the TKGM guide requires. A higher figure cannot make up for a lower one, so in effect the lowest decides, and the guide takes the amount from the DABs;
• a report dated after the sale is brought back to the DAB date with the producer price index (Yİ-ÜFE), and for instalment sales the first instalment's DAB date is used;
• the declared deed price is not below the municipal property-tax value;
• the value is realistic against comparable sales: inflated valuations are behind most of the 2026 revocations.

6. The DAB and the payment trail

The price must be paid in foreign currency; investment in Turkish lira has not been accepted since January 2022. The currency is sold to a bank in Türkiye and by the bank to the Central Bank of the Republic of Türkiye (CBRT), and the bank issues a foreign exchange purchase certificate (döviz alım belgesi, DAB), which it sends to the land registry by registered e-mail (KEP). The DAB must exist before the deed is signed. For the certificate of conformity, the registry also asks for a certified bank receipt showing that the converted amount reached the seller's account. Cash does not evidence the investment.

From 1 December 2026, title deed sales are due to move to the Ministry of Trade's Secure Payment System (Güvenli Ödeme Sistemi), unless that start date is postponed again. As of November 2026, how it fits with the DAB step has not been confirmed, so check the payment sequence with the bank and the registry before signing.

7. The three-year annotation

At the deed the buyer commits not to sell for three years (for off-plan units, not to transfer or cancel the promise-to-sell contract), and the commitment is annotated on the title register. The lawyer checks that the transaction was recorded as a citizenship-purpose purchase, because the registry's data then feeds the certificate of conformity.

Checks on the other investment routes

• Bank deposit, government bonds, fund units and private pension (BES): the CBRT conversion record, an account in your sole name, the blocking or holding evidence (for fund units, the Central Registry Agency's citizenship blocking sub-account), and the product terms, such as the pension fund restrictions or, for bonds, the Treasury rule that instruments with less than three years to maturity are, as a rule, not used.
• Fixed capital: whether the spending counts as fixed capital, and the sworn financial advisor's (YMM) special-purpose report.
• Employment: social security records of at least 50 Turkish-citizen employees; the Ministry takes into account the continuity of full-time staff over the last six months.

Source of funds and source of wealth

Source of funds is where the money for this investment comes from; source of wealth is how you built the wealth behind it. Banks ask about both. Under the Law on Prevention of Laundering Proceeds of Crime No. 5549, self-employed lawyers are also obliged parties for listed transactions, including buying and selling real estate. The lawyer must identify you and any beneficial owner, understand the source of funds and, within the defence rights and professional confidentiality that the law reserves, report suspicious transactions to MASAK (the Financial Crimes Investigation Board) without telling the client. Where identification is not possible, the transaction is refused, and a red flag that cannot be cleared is a reason for the lawyer to decline the file.

A clean file shows a documentary trail from the origin of the money to the Turkish bank, in the applicant's own name. Typical evidence:

• salary or business income: employment contracts, payslips, tax returns, company accounts;
• sale of an asset: the sale contract and the bank credit of the proceeds;
• dividends: the company's accounts and the distribution resolution;
• inheritance or gift: the succession or gift documents and the transfer record;
• the transfer chain: statements for every account the money passed through.

Money coming from a relative's or a company's account should first reach your own account, with documents that explain the transfer. Each bank sets its own document list.

Sanctions, PEP and reputation screening

Screening covers asset-freezing decisions published in the Official Gazette under Law No. 6415 on the prevention of terrorist financing, which gives effect to UN Security Council listings, and Law No. 7262 on the prevention of proliferation financing, as well as the US (OFAC), EU and UK lists, which do not themselves freeze assets in Türkiye but which banks check for their own compliance. It also covers politically exposed person (PEP) status, for which MASAK rules require enhanced measures, adverse media and criminal records; in current practice, criminal record certificates are asked for the main applicant and spouse at the residence stage. These checks matter for the bank onboarding and for the Ministry of Interior's review, where the legal test is the absence of any obstacle on national security or public order grounds.

What the 2026 revocations show

On 4 August 2026, the Ministry of Interior announced that the citizenship decisions of 6,134 people, 1,413 principal investors and their family members, had been annulled or withdrawn under arts. 31 and 40 of Law No. 5901. According to the statement:

• 5,391 people (1,150 investors, whose certificates of conformity were cancelled) lost citizenship over sham or irregular transactions, mainly inflated valuation reports on cheaper properties;
• 743 people (263 investors and their family members) had their citizenship withdrawn on public order and national security grounds;
• the announcement followed an operation in 16 provinces against false valuation reports.

The lesson: a property valued well above comparable sales is a risk to the buyer, not a bargain, and, as the figures show, family members can lose citizenship too. The checks on this page are meant to show, at the time of purchase, that the investment was real, correctly valued and properly paid.

The process, step by step

1. Engagement and conflict check. The lawyer confirms that the firm does not act for the seller, developer or agent in the same transaction, and agrees the scope in writing.
2. Client identification and source of funds. Reviewed first, because a bank or the lawyer may refuse a file that fails here.
3. Screening the property. The lawyer obtains the certified title extract and encumbrance printout, and checks the title type, the ownership history and any earlier citizenship use.
4. Screening the seller. Identity, authority, investment history, shareholdings and any link to your family.
5. Valuation and TTB. The lawyer reviews the valuer's authorisation, the report and the TTB against the price and the expected DAB amount.
6. Contract and payment plan. The lawyer reviews or drafts the contract, plans the bank conversion and the DAB, and sets conditions so that no money passes before the checks are complete.
7. Signing day. A final title check, confirmation that the DAB has reached the registry, the deed, and the three-year annotation.
8. After the deed. The lawyer checks the bank receipts and the registry data that feed the certificate of conformity, then moves on to the residence permit and the citizenship application.

What you receive

A written due diligence report, in English, Turkish or French, that:

• lists each eligibility condition with the finding and the document it rests on;
• states where the law is unsettled, such as some financing structures or a sibling as seller, rather than giving false certainty;
• sets the conditions to be met before any payment, and the contract clauses that protect you;
• attaches the title extract, TTB, seller documents and, once paid, the DAB and bank receipts, as the evidence file for any later question.

Documents the lawyer will ask for

• your passport and, once obtained, your Turkish tax number;
• a special power of attorney if the lawyer is to act for you, from a Turkish notary or consulate, or a foreign notary with apostille and sworn translation;
• marriage and children's birth certificates, for the family structure and the excluded-seller check;
• source-of-funds and source-of-wealth documents, and statements for the transfer chain;
• the property details, the draft contract or reservation form, and any developer documents you have been given.

How long the checks take

A title and seller review usually takes a few working days once the lawyer has authority to obtain the records. The valuation depends on the valuation firm's schedule, and the source-of-funds review, often the longest part, on how quickly documents arrive. All of it should be finished before any deposit is paid.

Costs, explained without prices

• the valuation report fee, set by the valuation firm;
• notary fees for the power of attorney and any promise-to-sell contract, under the Notary Fee Tariff updated each year;
• sworn translation, and apostille or consular legalisation of foreign documents;
• the title deed fee under the Fees Law No. 492, currently 2% from the buyer and 2% from the seller on the declared price (the rate can be changed by Presidential decision), and the land registry's revolving-fund fee, set each year;
• the lawyer's fee, agreed in writing before work starts.

Common mistakes and how the checks prevent them

• Paying a reservation deposit before the checks. It is hard to recover if the property fails.
• Relying on the "citizenship-eligible" label. Eligibility depends on the history, the seller and the valuation, not on the project.
• Co-owning with a spouse, buying through a company or splitting off-plan contracts. None supports the application.
• A seller-arranged valuation well above comparable sales.
• Under-declaring the deed price or paying part in cash. Neither counts towards the threshold.
• Converting the currency after the deed. The DAB must come first.
• Money from third-party accounts with no documents explaining the transfer.

Ordinary purchase checks and citizenship checks compared

How the lawyer works on a citizenship file

Av. Kaan Karanfiloğlu, founder of Karanfiloglu Law Firm in Istanbul (Istanbul Bar, registration no. 58270), handles each file personally. The firm does not sell property, does not act as an agent and takes no commission from sellers or developers, so the review is made only for the buyer. The lawyer works in Turkish, English and French; Russian and Chinese speaking clients are served through native-speaking advisors at the office. Most of the work can be done under a power of attorney while you are abroad. Meeting every condition makes the file eligible; the President still decides. To discuss a property or an investment, use the contact page.

Frequently asked questions

What is Turkish citizenship due diligence?

It is the legal check, made before any money is paid, that an investment will support a Turkish citizenship application. For property it covers title type, ownership history, seller, valuation, the DAB and payment trail, plus source of funds and sanctions screening.

Can I buy a property from a foreign owner for Turkish citizenship?

No. A property registered to a foreign individual does not qualify, including one owned by your own spouse or children, and nor does a second-hand property that a foreign individual transferred to a Turkish citizen or company in the last three years.

What happens if the valuation is lower than the agreed price?

The declared price, the TTB value and the converted amount on the DAB must each reach USD 400,000, so a valuation below the threshold stops the file even if you paid more. Obtain and review the valuation before paying anything.

Why must the DAB be issued before the title deed is signed?

Article 20(10) of the regulation requires the foreign currency to be sold to a bank in Türkiye, and on to the Central Bank, before the transaction, and the registry checks the DAB before the sale. Currency converted afterwards does not evidence the investment.

What documents prove my source of funds?

Documents that trace the money from its origin to your Turkish account: payslips, tax returns or company accounts, sale contracts, dividend resolutions, inheritance or gift papers, and statements for every account the money passed through.

Can a property already used for citizenship be used again?

No. A property that has supported one citizenship application cannot support another, even after a sale to a new owner. The lawyer checks this in the land registry history.

Could my citizenship be revoked later, as in the 2026 cases?

A decision obtained by false declaration or concealment of material facts can be annulled under art. 31 of Law No. 5901, and one taken without the legal conditions being met can be withdrawn under art. 40; as the 2026 figures show, family members can be affected too. Most 2026 cases involved sham or irregular transactions, chiefly inflated valuations. A realistic valuation and a complete payment trail are the protection.

Do I still need ordinary real estate due diligence if the property is eligible?

Yes. An eligible property can still carry mortgages, attachments, permit defects or earthquake risk, so the ordinary checks still apply. Both reviews are usually done together.

Related pages

• Turkish citizenship by investment: all routes
• Citizenship by real estate investment
• Real estate due diligence
• Citizenship by bank deposit
• Citizenship by government bonds
• Citizenship by investment fund shares
• Citizenship by private pension (BES)
• Citizenship by capital investment or employment
• How to spot tapu fraud
• Off-plan property: legal risks
• The tapu transfer process
• Power of attorney for foreigners
• Family members in a citizenship application

This page is general information as of November 2026 and not legal advice; the eligibility rules, valuation procedures and payment systems change, and the decision on citizenship rests with the President of the Republic of Türkiye.

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