My Bank Account Was Restricted under Article 19/A: Postponement of Transactions and Available Remedies

Your account balance is visible, but transfers do not go through. The branch may refer to a “MASAK review” or “Article 19/A”. The first task is to identify the legal basis of the restriction and the transactions it actually covers. The word “block” can describe very different legal processes.

In brief: Article 19/A of Law No. 5549 regulates the postponement of certain suspicious transactions. Not every banking restriction is based on this provision, and the seven-business-day period does not mean that every restriction will automatically disappear after seven business days. The appropriate remedy depends on whether the measure is an internal bank control, an administrative postponement or a judicial order.

What can be postponed under Article 19/A?

The provision concerns the temporary suspension of a transaction, or the refusal to execute it for a limited period, where the assets involved are suspected of being connected with money laundering or terrorist financing and further examination is required. The statutory authority and the procedural rules should be considered together with the relevant regulation.

This does not mean that the account holder has been found guilty of an offence. At the same time, it should not be dismissed as a routine check. Documentary explanations may be required regarding the source, recipient and economic purpose of the transaction. Depending on the circumstances, the matter may also be referred to the competent judicial authorities.

What kind of restriction are you facing?

A bank compliance hold, a postponement under Article 19/A, an enforcement or tax attachment, and a seizure measure in a criminal investigation are not the same legal mechanism. For example, Article 128/A of the Code of Criminal Procedure provides a separate framework for suspending or seizing accounts in connection with certain offences involving information systems.

For this reason, a petition should not be prepared solely on the basis of terminology used by a call-centre representative. Where possible, record the authority that imposed the measure, the decision or file number, the date and the scope. Information that the bank may disclose can be limited by investigation secrecy and suspicious transaction reporting rules.

Records to prepare at the outset

The bank’s screen message, written notice and application/reference number.
The date on which you first noticed the restriction and the date of the last successful transaction.
The dates, amounts, senders, recipients and descriptions of the relevant transfers.
Documents evidencing the source of funds, such as a sale, loan, salary, inheritance or investment.
Any document from a prosecutor, court, enforcement office or tax authority.

For example, if funds came from the sale of real estate, it is more useful to match the sale document to the bank movement than simply to state that “I sold my house”. In a crypto transaction, the chain from the original acquisition to platform records and the transfer back to the bank should be shown. Explanations should reflect the real course of events; false supporting stories should never be created after the fact.

What if seven business days have passed?

First determine when the period started and what kind of postponement was imposed. If the transaction is still blocked after the relevant period, ask whether the same measure continues, a new measure has been imposed, or a different bank control applies. Counting calendar days does not displace a subsequent judicial measure.

A request should focus on the particular amount or transaction affected and the legal reason for the restriction rather than seeking the release of every account in abstract terms. Whether the application should be directed to the bank, an administrative authority or a judicial file depends on the measure concerned.

Release of the account and compensation are separate issues

If a delayed payment has caused commercial loss, the delayed transaction, the counterparty’s demand and any additional costs should be documented. The fact that a restriction is lifted does not automatically establish liability for compensation. Unlawfulness, liability, loss and causation must each be examined separately.

Keep a copy of any written application submitted to the bank and evidence of delivery. General information obtained by telephone may not be sufficient to establish the scope or date of your formal request.

Frequently asked questions

Must the bank tell me whether it filed a suspicious transaction report?

No. Suspicious transaction reports are confidential. A request for information should focus on the shareable legal basis and scope of the restriction rather than attempting to compel disclosure of the report itself.

Does a restriction mean that I am necessarily under criminal investigation?

No. A bank review and a criminal investigation are separate processes. If a judicial order is identified, however, the position should be assessed through the relevant file.

Prepare a clear record before making an enquiry

In a written information request, identify the account or transaction, the date you noticed the restriction and the bank’s reference number. Ask for the shareable legal basis, start date, scope and any requested documents. Keep the response with your source-of-funds records; do not request the contents of a suspicious transaction report.

DISCUSS YOUR CASE

Discuss the restriction on your bank account

We can review the bank’s notice, transaction records and the legal basis of the restriction to assess your options under Turkish law.

Open the contact form

A brief summary and important dates are enough for an initial enquiry. Send documents only when requested by our lawyers, through the channel they specify. Do not share passwords, one-time codes or wallet keys.

Sources and legislation

Law No. 5549 on the Prevention of Laundering Proceeds of Crime, particularly Articles 3, 4 and 19/A
Regulation on the Postponement of Transactions
Code of Criminal Procedure No. 5271

Originally prepared on 8 September 2026. This article provides general information on Turkish law. Remedies and deadlines should be assessed against the documents and circumstances of each case. The image is illustrative.