Citizenship via Bank Deposit

Step-by-Step Process

Citizenship via Bank Deposit Method

All stages from planning the process within the scope of the bank deposit method to obtaining the identity card.

1. 1

   LEGAL FRAMEWORK OF CITIZENSHIP APPLICATION VIA BANK DEPOSIT

   Citizenship applications via bank deposit are evaluated under the exceptional citizenship provisions of the Turkish Citizenship Law. In this type of application, citizenship is not acquired directly and automatically; the investment must be determined by the relevant institution to be in compliance with the legislation, the residence permit process must be completed, the citizenship file must be prepared, and the final administrative evaluation must be positive.

   The basic condition in this method is that the foreign investor deposits at least USD 500,000 or equivalent foreign currency in a bank operating in Turkey and commits not to withdraw this amount for 3 years. The regulation stipulates that this investment condition is detected by the BDDK.

   Deposit investment, unlike real estate investment, does not involve risks such as title deed transfer, appraisal report, seller investigation, mortgage/lien control, or whether the real estate has been used in citizenship before. On the other hand, the most critical issue in this method is that the money transfer, foreign currency sale, account opening, block, and BDDK conformity certificate process are correctly set up from the beginning.

   The citizenship process in the deposit method generally consists of the following stages:

   • Pre-evaluation of the investor and family structure
   • Opening a bank account in Turkey
   • Transferring the investment amount to the bank
   • Performing foreign currency sale / TL deposit / blocking transactions
   • Giving a 3-year commitment not to withdraw
   • Executing the BDDK conformity certificate process
   • Applying for a short-term residence permit under clause (j)
   • Submitting the exceptional citizenship application
   • Evaluation of the application by administrative authorities
   • Turkish identity card and passport procedures after approval
2. 2

   DIFFERENCE OF THE DEPOSIT METHOD FROM OTHER INVESTMENT PATHS

   The bank deposit method is preferred especially by foreign investors who do not want to purchase real estate and want to manage their investment more simply and through the banking system. In this method, the investor does not have to buy any real estate. There are no real estate-sourced risks such as seller, title deed, appraisal, mortgage, project license, or the legal status of the property.

   However, the deposit method should not be seen as a simple transaction of "depositing money in the bank". There is a difference between the deposit subject to the citizenship application and an ordinary bank deposit. This amount must be structured in accordance with the citizenship legislation, the necessary bank documents must be obtained, protected for 3 years, and subject to eligibility detection before the BDDK.

   The advantages of the deposit method are as follows:

   • There is no obligation to purchase real estate.
   • There are no seller, title deed, appraisal, and project risks.
   • The investment is tracked within the banking system.
   • The document flow is more predictable when the process is set up correctly.
   • The investor can start the citizenship process without having to select real estate.

   The points to be considered in the deposit method are as follows:

   • The investment cannot be withdrawn for 3 years.
   • If the block / commitment mechanism is set up incorrectly, the application is put at risk.
   • The source of the money transfer and bank records must be clear.
   • The bank's internal compliance, sanction, and customer acceptance policies may affect the process.
   • Withdrawing money or lifting the block before 3 years expire can directly risk the citizenship right.

   Therefore, although the deposit method seems operationally simple, it is a citizenship path that must be managed meticulously in terms of document and bank processes.

3. 3

   BANK ACCOUNT OPENING AND PRE-PREPARATION PROCESS

   The first practical step for a foreign investor who wants to apply for citizenship via the deposit method is opening an account in a bank operating in Turkey. Account opening is not only a technical banking transaction, but also the basic step affecting the subsequent stages of the citizenship application.

   Banks apply their own internal compliance procedures during account opening. In this scope, passport, tax identification number, address information, contact information, occupation information, explanation regarding the source of income or funds, and additional documents when necessary can generally be requested from the investor. The investor's country of origin, the bank where the fund is sent from, the description of the transfer, and international sanction lists may be important in the bank's evaluation.

   The most important point to be considered at this stage is planning the account opening in accordance with the citizenship application from the beginning. Even if the investor has opened a normal personal bank account, blocking, commitment, and BDDK conformity processes must be executed separately for the amount subject to the citizenship application.

   The role of the lawyer in account opening is particularly important in the following headings:

   • Guiding the investor to the bank process suitable for the citizenship application
   • Conducting preliminary discussions with the bank
   • Preparing the documents required for account opening
   • Determining the areas that can be processed with a power of attorney
   • Explaining the compliance documents requested by the bank to the investor
   • Structuring money transfer descriptions and document flow in accordance with the citizenship file

   Although some transactions can be executed with a power of attorney, bank practices may differ. Some banks may request the investor to be physically present in account opening or signature processes. Therefore, the investor's travel plan to Turkey should be considered together with account opening and residence/citizenship application appointments.

4. 4

   MONEY TRANSFER, FOREIGN CURRENCY SALE, AND TL DEPOSIT PROCESS

   In citizenship applications via bank deposit, the investment amount must be traceable through the banking system. Therefore, the source of the money transfer, sender account, recipient account, transfer description, and bank receipts are important.

   The investor can transfer money from their own account abroad to the bank account in Turkey. In some cases, the fund may come from the investor's close relative or company; however, in such cases, the source of the fund and the transaction being made in favor of the investor must be clearly documented. Banks may request additional explanations and documents within the scope of anti-money laundering and combating the financing of terrorism obligations.

   In practice, the foreign currency amounts subject to the citizenship application are sold to a bank operating in Turkey and to the Central Bank by this bank before the transaction; for the deposit method, the Turkish Lira amount obtained as a result of the sale is kept in Turkish Lira deposit. The regulation states that the foreign currency amounts will be sold to the bank and to the Central Bank by the bank before the transaction; the TL amount obtained for the deposit method will be kept in Turkish Lira deposit for 3 years. The important point here is that USD 500,000 or equivalent foreign currency must be converted into Turkish Lira and the relevant value must remain in the deposit account as Turkish Lira for 3 years.

   The general flow at this stage can be summarized as follows:

   • The investor transfers the fund subject to the citizenship application to the bank in Turkey.
   • The bank evaluates the investment amount within the scope of the foreign currency sale process suitable for the citizenship legislation.
   • Foreign currency is converted into Turkish Lira within the framework of the relevant application.
   • The obtained Turkish Lira amount is kept in the deposit account opened in the name of the investor.
   • The investor gives a commitment that they will not withdraw this amount for 3 years.
   • The bank issues block / commitment / account documents.
   • Bank documents required for the BDDK conformity certificate process are prepared.

   A small mistake made in this transaction chain, for example, a transfer with an incorrect description, missing receipt, incorrect foreign currency sale document, insufficient commitment text, or account type not suitable for the application, may delay or risk the conformity certificate process.

5. 5

   3-YEAR BLOCK AND COMMITMENT MECHANISM

   The 3-year holding requirement lies at the heart of citizenship applications via the deposit method. The investor commits not to withdraw the deposit basis for the citizenship application for 3 years and not to reduce it in violation of the legislation.

   The basic point to be known here is this: The citizenship application is not completed only by depositing the money in the bank. It must be clearly shown in the bank records, commitment documents, and conformity certificate process that the investment amount will be held for 3 years for citizenship purposes.

   During the 3-year period:

   • The main investment amount must be protected.
   • The block / commitment must not be lifted.
   • The account balance must not fall below the minimum condition required for citizenship.
   • Transactions such as bank change, account transfer, or fund movement must be legally evaluated in advance.
   • Liens, measures, pledges, or similar restrictions on the account may create a risk for the application.
   • Bank documents and account movements must remain compatible with the citizenship file.

   It is possible to renew the deposit at maturity or to yield interest/dividend; however, the main amount basis for the citizenship application must be protected and the commitment condition must not be violated. The use of interest or dividend should be evaluated separately according to the bank's product structure, account type, and the scope of the citizenship block. However, in general, it can be said that the principal amount corresponding to USD 500,000 must be protected in the account, and the monthly or annual interest and return to be applied to this deposit can be evaluated and withdrawn from the account.

   Withdrawing the investment amount, lifting the block, or the amount falling below the level required in the legislation before the 3 years expire may cause the application to be rejected if the application is ongoing; and may cause the risk of cancellation later if citizenship has been acquired.

6. 6

   BDDK CONFORMITY CERTIFICATE PROCESS

   The primary document showing that the investment was made in accordance with the legislation in citizenship applications via the deposit method is the conformity detection made by the BDDK. In practice, this document may be referred to as the "Conformity Certificate", "conformity letter", or "BDDK detection letter".

   The purpose of the BDDK conformity process is to detect whether the investor has really deposited the amount of deposit prescribed in the legislation, whether this amount is held within the correct banking system, and whether a commitment has been given in accordance with the 3-year no-withdrawal condition.

   The person applying for citizenship deposits the amount corresponding to USD 500,000 into their own account; identity detection documents, declaration form, account statements, passport copy, and documents showing that the foreign currency/cash has been deposited or transferred are sent to the BDDK. The BDDK notifies the detection regarding applications meeting the conditions to the General Directorate of Population and Citizenship Affairs and the Directorate General of Migration Management.

   The following documents are generally important in the BDDK process:

   • Passport copy
   • Identity detection documents
   • Bank account opening documents
   • Account statement
   • Money transfer receipts
   • Foreign currency sale / conversion documents
   • 3-year no-withdrawal commitment
   • Block or commitment letter
   • Application letters issued by the bank
   • Power of attorney containing appropriate authority if processing via power of attorney

   The citizenship application stage should not be entered in a healthy manner without obtaining the conformity certificate. Because the basis of the citizenship application is that the investment has been approved by the relevant institution. With the issuance of the conformity document, the investment is officially accepted. Then, after the investor and their spouse, if any, come to Turkey, a residence permit application is filed on their behalf and transactions regarding the citizenship process continue. For detailed information on subsequent citizenship application procedures after the issuance of the Conformity Certificate, you can check our article titled Citizenship Application Process.

Critical Risks

Most Critical Risks in This Method

Despite the money being deposited, incorrectly establishing the block/commitment mechanism or failing to properly document the movement of money directly jeopardizes the process.

• Incorrectly Establishing the Block Mechanism

  Withdrawing the money or lifting the block before 3 years violates the investment requirement. The mechanism must be correctly established from the outset.

• Incorrect Documentation of Money Movement

  Failure to properly prepare foreign currency transfer documents and purchase/sale documents may disrupt the conformity certificate application.

• Insufficient Preparation of Bank Contracts

  Commitment texts that do not meet citizenship legislation requirements may lead to rejection of the application.

• Early Withdrawal or Transfer

  Any withdrawal or transfer to another bank within the 3-year period breaks the commitment and causes loss of the citizenship right.