What Is a MASAK Block and How Long Does It Last? Postponement of the Transaction, Freezing of Assets and Remedies of Objection

Last updated: 01.11.2026 · Author: Attorney Coşkun Genç, Istanbul cybercrime lawyer

The restriction referred to in everyday language as a MASAK block may, legally, be one of five measures that differ from one another; each has its own duration, deciding authority and remedy of objection. The suspicious transaction report, the MASAK examination and the laundering offence are explained in the article on the money laundering offence; this article focuses on how a person whose account has been restricted can identify the measure and which remedy he or she should pursue.

What does a "MASAK block" mean legally?

There is no measure called a "MASAK block" in the legislation. Only the first two measures are directly linked to MASAK processes; the others are a judicial decision or the bank's own assessment.

The practical consequence of this distinction is as follows: applying to the public prosecutor's office for a seven-working-day postponement, or to the bank for a seizure, will not produce a result. The legal basis of the postponement is the following provision, the current text of which is also available on the Article 19/A of Law No. 5549 page:

How can I find out which measure has been applied to my account?

The safest way is to request a written answer from the bank and to compare that answer with official records. The bank may not disclose to anyone, including the parties to the transaction, that it has filed a suspicious transaction report, other than the inspectors carrying out compliance supervision and the courts during proceedings (Article 4(2) of Law No. 5549; Article 29 of the Regulation on Measures). This prohibition concerns the report itself; it is possible to ask in writing for the date of the restriction, the account and amount it covers, and whether it is the enforcement of a judicial decision or of an official decision.

1. Apply to the bank in writing: By petition to the branch, registered electronic mail (KEP) or notarial notice, ask for the start date of the restriction, which account and transaction it covers, and its legal basis.
2. Identify the 48-hour suspension: Under Article 128/A CCP, the suspension is notified to the account holder. If you have received such a notification, the authority to address is the Chief Public Prosecutor's Office.
3. Check the Official Gazette: Under Law No. 6415, freezing decisions are published in the Official Gazette and are deemed to have been notified to the person concerned on the date of publication (Art. 11(1)). It should be checked whether your name or company's trade name appears.
4. Identify the investigation file: If there is a seizure order, the criminal judgeship of peace that issued the order and the investigation number are ascertained. Defence counsel may examine the file during the investigation; this right may be restricted by a judge's decision only for the offences listed in the article (for example, establishing an organisation, drug trafficking), and statement records and expert reports fall outside the restriction (Article 153 CCP).
5. Enter the time limit in your calendar and apply to the correct authority: The postponement runs in working days, while the suspension and the approval of seizure run in hours; once the legal basis is clear, one of the remedies below is chosen.

How long does a MASAK postponement of the transaction last, and what happens when the period expires?

Each postponement decision lasts at most seven working days. During the decision, the bank may not carry out the transaction; an obliged party that carries out a transaction in breach of the decision is subject to an administrative fine equal to the amount of the transaction and not less than TRY 50,000 (Art. 19/A(3) of Law No. 5549).

The start of the period varies according to two situations. If the bank has filed a report with a request for postponement, it does not carry out the transaction until the Minister's decision is notified, and the postponement may not exceed seven working days from the date of the report. For assets identified by MASAK itself, on the other hand, the seven working days begin from the notification of the decision to the bank (Regulation on the Postponement of Transactions, Arts. 4(3), 5). The decision is notified not to the account holder but to the bank, electronically or by technical means of communication (Art. 7).

It is reflected in judicial decisions that, after the period has expired, a new postponement decision may be issued upon a new report. In a file examined by the Court of Cassation, the bank had filed ten suspicious transaction reports within approximately six months, MASAK had issued seven-working-day postponement decisions nine times, and the money was then paid following a decision not to postpone. In its first examination, the Chamber assessed the bank's liability as follows:

"However, the defendant bank's report, made on the presumption of a suspicious transaction, is not supported by any material evidence. In that case, it is understood that the bank's notification, which resulted in a block being placed on the claimant's account by MASAK, was unjustified. For this reason, the defendant bank is liable, on account of its irregular act, for the damage arising from the claimant's inability to use the account, as ultimately revealed when the grounds for the lifting of the block were stated."

Court of Cassation, 11th Civil Chamber, E. 2022/3529, K. 2023/7312, 12.12.2023 (the decision of the regional court of appeal was reversed)

The regional court of appeal insisted on its decision against this reversal (direnme); it stated that the bank had given reasons in its reports, had attached account statements, and that a postponement decision had been taken on the basis of each report. The 11th Civil Chamber of the Court of Cassation, finding no error in the decision of insistence, upheld it. Thus, the claim was dismissed in respect of the two accounts subject to postponement decisions, while in respect of the third account, for which there was no report and no decision, the following finding became final:

"…that the non-payment to the claimant of TRY 4,103.20 held in account no. TR...5006, which is the subject of the action and of the enforcement proceedings, is contrary to procedure and law, given that no suspicious transaction report was made by the defendant bank in respect of that amount and that there is no decision taken by MASAK to that effect…"

Reasoning of the regional court of appeal's decision of insistence; upheld by Court of Cassation, 11th Civil Chamber, E. 2025/1664, K. 2025/2763, 24.04.2025

Practical consequence: a postponement decision binds only the account and transaction it concerns; for a balance not covered by a decision, the bank must show a separate legal basis. The Law and the Regulation do not provide a special remedy of objection against a postponement decision; in the decisions examined, the dispute was resolved in an action for the annulment of the objection (itirazın iptali davası) to enforcement proceedings initiated against the bank. Since the Minister's decision is in the nature of an administrative act, an administrative action may also be considered (Article 7 of the Administrative Procedure Law (İYUK): as a rule, sixty days from written notification); however, the decision is not notified to the account holder, and seven working days is a short period.

How is a freezing of assets (Law No. 6415) lifted?

Freezing is the removal or restriction of the power of disposition over assets (Art. 2(1)(d) of Law No. 6415). The Law does not provide for a fixed period; the duration of the decision is stated in the text of the decision, and its lifting takes place by a separate decision (Arts. 11(2), 12(7)). It has three sources: decisions of the President of the Republic on the implementation of UN Security Council lists (Art. 5), decisions of the President of the Republic on requests of foreign states (Art. 6), and decisions taken jointly by the Minister of Treasury and Finance and the Minister of Interior concerning persons and entities in respect of whom there are reasonable grounds to believe that they have committed acts of financing of terrorism, after the courts have finally decided that the organisation is a terrorist organisation (Art. 7(3)). UN resolutions on the financing of the proliferation of weapons of mass destruction, on the other hand, are implemented by a decision of the President of the Republic pursuant to Article 3 of Law No. 7262, and the provisions of Law No. 6415 apply to their enforcement.

The freezing decision states against whom it has been issued, its grounds, its scope and duration, and the available legal remedies and the time limit for applying (Art. 11(2)); for this reason, the first document to read is the text of the decision in the Official Gazette. The person against whom the decision has been issued notifies MASAK of his or her receivables and debts and other assets within thirty days at the latest from publication (Art. 12(3)). Dispositions contrary to the decision are null and void (Art. 10). Transactions may be carried out on the accounts with MASAK's permission for minimum subsistence or for the operation of the business; mandatory payments to the public, such as taxes and premiums, may as a rule be made without permission (Art. 13(2)-(3)).

The remedy against a freezing decision issued jointly by the ministers is this special judicial review. The Council of State assessed a request for the annulment of such a decision as follows:

"…since it is provided that decisions on the freezing of assets to be taken on the basis of paragraph 3 of Article 7 of Law No. 6415 are subject to the approval of the Ankara high criminal court designated by the Council of Judges and Prosecutors, and that an objection may be made against the decisions of the Court in accordance with the provisions of the Code of Criminal Procedure, it is concluded that the ordinary (judicial) courts have jurisdiction to hear and decide the part of the dispute … concerning the annulment of the decision."

Council of State, 10th Chamber, E. 2024/5341, K. 2024/4965, 18.11.2024 (the statement of claim was rejected, to be renewed by separate petitions)

For lifting, an application may be made to the Evaluation Commission (Değerlendirme Komisyonu) on the ground that the reasonable grounds have ceased to exist; requests that the Commission does not find well-founded are sent to the relevant high criminal court in Ankara for a decision (Art. 7(6)). The Commission re-evaluates these decisions at intervals of six months at the latest from their publication in the Official Gazette (Art. 7(5)). A decision based on a request of a foreign state may be lifted if the requesting state does not initiate an investigation within one year from its publication in the Official Gazette (Art. 6(5)); applications against UN Security Council decisions are forwarded by MASAK to the Security Council through the Ministry of Foreign Affairs (Art. 5(3)). The text of the article is on the Article 7 of Law No. 6415 page.

How can seizure and the 48-hour suspension be objected to?

Seizure is a measure of criminal procedure and, under Article 128 CCP, is applied only by a judge's decision (Art. 128(9)). Where there is strong suspicion, based on concrete evidence, that the offence has been committed and that the assets have been obtained from that offence, bank accounts may be seized for the offences listed in the article (for example fraud, breach of trust, drug trafficking). For the decision, a report on the value obtained from the offence is obtained from institutions such as MASAK, the Banking Regulation and Supervision Agency (BDDK) or the Capital Markets Board (SPK); the report is prepared within three months at the latest and may be extended by two months for special reasons. Seizure based on Article 17 of Law No. 5549 in cases of suspected laundering is explained in the article on laundering.

An objection to a seizure order is made within two weeks from the date on which the order was learned of, by a petition submitted to the judgeship that issued the order (Art. 268(1) CCP). If the judgeship does not find the objection well-founded, it sends the file within three days at the latest to the reviewing authority, which, for decisions of criminal judgeships of peace, is as a rule the judgeship that follows it in number (Arts. 268(2), 268(3)(a)). In addition, lifting and return may be requested on the ground that retention is no longer necessary; Article 131 CCP governs the return of seized property and the objection to the rejection of such a request. Objections concerning the accounts of spouses, family members and third parties are discussed in the article on seizure and third parties.

The absence of an upper limit in the Law does not mean that seizure may last indefinitely. The Constitutional Court held that the right to property had been violated on account of measures placed on bank accounts under Article 128 CCP in 2008-2009 on an allegation of fraud, which were not lifted despite a judgment of acquittal:

"For a measure placed on the asset values of individuals to be regarded as proportionate, it must not become disproportionate, and therefore excessive, owing to the prolongation of the proceedings. It is also clear that whether this period is reasonable must be assessed according to the particular features of each case."

Constitutional Court (First Section), Besi Yılmaz and Others, App. No. 2016/9001, 18.07.2019 (violation of the right to property)

Article 128/A CCP, by contrast, applies only where there is suspicion of aggravated theft (Article 142(2)(e) TPC), aggravated fraud (Article 158(1)(f) and (l) TPC) and misuse of bank or credit cards (Article 245 TPC). A bank, payment or crypto asset service provider may suspend the account used in the offence for up to forty-eight hours; the suspension is notified to the account holder, the account holder may apply to the Chief Public Prosecutor's Office for its lifting, and the public prosecutor decides within twenty-four hours. If a seizure is made by written order of the public prosecutor during the suspension period, the measure is submitted for a judge's approval within twenty-four hours; if the judge does not announce his or her decision within forty-eight hours of the seizure, the seizure is automatically lifted. Details are set out in the article on Article 128/A CCP.

What can be done if the bank has restricted the account by its own decision?

Some restrictions are a decision neither of MASAK nor of a court. Under Article 22 of the Regulation on Measures, where the bank cannot carry out customer identification or cannot obtain sufficient information on the purpose of the business relationship, it does not carry out the requested transaction; where there is doubt about previously obtained identification information and verification cannot be made, the business relationship is terminated. Article 19 of the Regulation also imposes on the bank an obligation to monitor continuously the consistency of customer transactions with the customer's profession, financial situation, risk profile and sources of funds. The bank additionally assesses these situations in terms of a suspicious transaction (Art. 22(3)).

In this case, the most effective step is to complete in writing the information and documents requested by the bank and to request in writing the lifting of the restriction. If the dispute continues, for accounts qualifying as consumer transactions, application to the consumer arbitration committee (tüketici hakem heyeti) is mandatory below the monetary threshold set in the Law and increased each year by the revaluation rate; disputes above this threshold are heard by the consumer court, subject to the condition of applying to a mediator before the action is filed (Law No. 6502, Arts. 68, 73, 73/A). The consumer may also apply to the alternative dispute resolution bodies under the relevant legislation (Art. 68(5)).

What happens if money I do not recognise arrives in my account, or if I have let someone else use my account?

If money you do not recognise has arrived, you need to notify the bank in writing without withdrawing it, spending it or transferring it to anyone. A person who is enriched from another's assets without just cause is obliged to return the enrichment (Article 77 of the Turkish Code of Obligations (TCO, Law No. 6098)). Article 160 TPC, for its part, provides, upon complaint, for imprisonment of up to one year or a judicial fine for a person who disposes, as if the owner, of property that came into his or her possession by mistake, without returning it or informing the competent authorities; spending money received by mistake may also be assessed under this provision.

A more serious risk is the use of the account as an intermediary account through which fraud proceeds pass. Withdrawing the money on someone's instructions and handing it over, or renting out the account, may, depending on the case, be assessed in terms of assistance in the offence or laundering; the defence is explained in the article on account renting and the real user.

Which documents should be prepared?

• ✓The bank's written answer, screenshots and the acknowledgement of receipt of your application
• ✓Account statements and transaction receipts covering the periods before and after the restriction
• ✓Invoices, contracts, payslips, sale or lease documents showing the source of each incoming amount
• ✓Correspondence with the senders of the money; the notification you made to the bank regarding money received from a person you do not know
• ✓If any, the Article 128/A CCP suspension notification, the seizure order, the summons to give a statement or the freezing decision in the Official Gazette
• ✓For company accounts, the tax registration certificate, signature circular and documents showing the field of activity

Exceptions and common mistakes

• Counting the seven working days as calendar days: The postponement period runs in working days; weekends and public holidays are not counted.
• Assuming that the restriction ends automatically when the period expires: A new postponement decision upon a new report, or another measure, may have been imposed; the legal basis should be asked again.
• Missing the two-week time limit for objection: The time limit for objecting to a seizure order starts from the day on which the order was learned of.
• Moving the money around to other accounts: This may lead to new reports; after a seizure order, transactions aimed at rendering it ineffective are invalid (Art. 128(5) CCP).
• Overlooking the thirty-day notification in a freezing decision: The notification obligation under Art. 12(3) of Law No. 6415 runs from the publication of the decision in the Official Gazette.

Application Process for Account Restrictions with an Istanbul MASAK and Account Block Lawyer

In account restrictions, three points are decisive: correctly identifying the type of measure on the basis of documents, not missing short time limits such as seven working days, forty-eight hours and two weeks, and showing the source of the money credited to the account through receipts and contracts. Av. Coşkun Genç Law Office provides legal support in Istanbul at the stages of written applications and notices to the bank, applications to the public prosecutor's office for the lifting of a suspension, objections to seizure orders, applications concerning freezing decisions, and receivable disputes against the bank. In the work carried out as an Istanbul MASAK block lawyer, the legal basis and duration of the restriction are clarified first.

Persons wishing to obtain support from an Istanbul account freeze and seizure lawyer may request a preliminary assessment with the bank's written answer, account statements, income documents and, if any, the suspension notification or seizure order. The office's contact details are available on the contact page; the office's areas of work are set out on the cybercrimes page.

Sources

1. Law No. 5549 on the Prevention of Laundering Proceeds of Crime, Arts. 4, 17, 19/A – mevzuat.gov.tr
2. Law No. 6415 on the Prevention of the Financing of Terrorism, Arts. 2, 5, 6, 7, 10, 11, 12, 13 – mevzuat.gov.tr
3. Law No. 7262 on the Prevention of the Financing of the Proliferation of Weapons of Mass Destruction, Art. 3 – mevzuat.gov.tr
4. Code of Criminal Procedure (CCP, Law No. 5271), Arts. 128, 128/A, 131, 153, 268 – mevzuat.gov.tr
5. Turkish Penal Code (TPC, Law No. 5237), Art. 160 – mevzuat.gov.tr
6. Turkish Code of Obligations (TCO, Law No. 6098), Art. 77 – mevzuat.gov.tr
7. Law No. 6502 on Consumer Protection, Arts. 68, 73, 73/A – mevzuat.gov.tr
8. Administrative Procedure Law (İYUK, Law No. 2577), Art. 7 – mevzuat.gov.tr
9. Regulation on Measures Regarding the Prevention of Laundering Proceeds of Crime and Financing of Terrorism, Arts. 19, 22, 29 – mevzuat.gov.tr
10. Regulation on the Postponement of Transactions within the Scope of the Prevention of Laundering Proceeds of Crime and Financing of Terrorism, Arts. 4, 5, 7 – mevzuat.gov.tr
11. Court of Cassation, 11th Civil Chamber, E. 2022/3529, K. 2023/7312, 12.12.2023 – mevzuat.adalet.gov.tr
12. Court of Cassation, 11th Civil Chamber, E. 2025/1664, K. 2025/2763, 24.04.2025 – mevzuat.adalet.gov.tr
13. Council of State, 10th Chamber, E. 2024/5341, K. 2024/4965, 18.11.2024 – mevzuat.adalet.gov.tr
14. Constitutional Court, Besi Yılmaz and Others, App. No. 2016/9001, 18.07.2019 (Official Gazette 12.09.2019, No. 30886)