Turkish Citizenship by Bank Deposit

Introduction: a clear route with banked funds

For globally mobile investors seeking a predictable route to a second nationality, Turkish citizenship by bank deposit offers a straightforward, non-property alternative. Subject to a Presidential decision and standard security checks, eligible applicants who place qualifying funds with a Turkish bank and maintain them for three years may acquire Turkish citizenship on an exceptional basis. The legal basis is Article 12 of Law No. 5901 and Article 20 of the Regulation on the Implementation of the Turkish Citizenship Law; operational rules (including mandatory foreign-exchange sales to the Central Bank) are set by the Central Bank of the Republic of Türkiye (CBRT). 

Key benefit: no need to purchase or manage real estate; funds remain on deposit (often interest-bearing/participating), with liquidity at the end of the holding period, subject to the three-year block.

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What the law requires (at a glance)

Under Article 20 of the Implementation Regulation and current government guidance:

• Minimum amount: USD 500,000 (or equivalent foreign currency) placed in a bank operating in Türkiye. The amount was reduced to USD 500,000 by the 2018 amendments and remains the benchmark threshold. 
• Holding period: three (3) years continuous holding, evidenced by a block on the account. 
• Foreign-exchange sale to CBRT: before (or at) the qualifying transaction, the relevant foreign currency must be sold via a Turkish bank to the CBRT under the CBRT’s Implementation Instruction; banks then credit the resulting TRY to the investor’s account. The CBRT limits eligible currencies to USD, EUR, GBP and CHF for this purpose. 
• Competent authority for suitability (conformity) certificate: the Banking Regulation and Supervision Agency (BDDK/BRSA) verifies the deposit and issues the conformity confirmation used in the citizenship file. (BDDK publishes the standard forms and handles notifications.) 
• Decision-maker: Citizenship is not automatic; it is granted by Presidential decision following due diligence and administrative checks. 

For applicants comparing pathways, note that Türkiye also recognises real estate investment (minimum USD 400,000) and capital-market routes such as real estate or venture capital fund units (USD 500,000, three-year hold); the latter are overseen for suitability by the Capital Markets Board (SPK). 

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Step-by-step: the MFY Legal process map

1) KYC, strategy and bank onboarding

• We verify your eligibility, source of funds and timelines, and decide whether fixed deposit, participation account (for interest-free banking) or a laddered approach suits you.
• You open an account with a licensed bank in Türkiye; banks will perform full KYC/AML checks and collect your tax number and passport details. (The bank must be authorised in Türkiye; off-shore accounts do not qualify.) 

2) FX sale and funding

• Prior to the qualifying deposit, your foreign currency is sold to the CBRT through your bank in line with the CBRT Implementation Instruction; the bank credits TRY proceeds to your account. This FX-sale mechanism is mandatory in citizenship investment transactions under Article 20 (covering bank deposits, real estate, government bonds, and fund units). 

3) Three-year block and BDDK conformity

• The bank blocks the qualifying balance for 36 months (no withdrawals or pledges below the threshold).
• The bank provides evidence to BDDK, which issues (or enables issuance of) the conformity confirmation that your investment meets Article 20 bank-deposit criteria; this document is uploaded into your citizenship file. 

4) Residence permit and citizenship filing

• With the BDDK conformity document, you apply for a short-term residence permit (required step).
• The citizenship application then proceeds to Nüfus ve Vatandaşlık İşleri (NVİ) for processing and background checks; the final decision is issued by the Presidency. 

5) Passports & ID

• Upon approval, you complete civil registration formalities and collect national IDs/passports for the principal applicant and eligible dependants (spouse and minor children), subject to statutory checks. 

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Detailed requirements and practical notes

Qualifying amount and continuity

• The deposit must reach at least USD 500,000 at the outset; the three-year counter starts when the block is set. Official investment guidance confirms this threshold across the investment programme. 
• Under the CBRT Instruction, the qualifying FX must be sold to the CBRT via a bank; the bank may open designated CBRT accounts and will document the sale. Eligible currencies are USD/EUR/GBP/CHF. 
• The block must remain intact throughout the 36 months. (Operational practices treat any investor-initiated drop below the threshold as disqualifying; bank-generated profit distributions do not usually count against the principal if the blocked balance remains ≥ USD 500,000 equivalent.) Always seek transaction-specific advice. 

Who certifies what?

• BDDK (BRSA) is the competent authority for bank-deposit conformity under Article 20. BDDK provides standardised forms and communications used during conformity checks and interacts with NVİ and the Migration Directorate for status updates. 
• For comparison: SPK handles conformity for fund-unit investments and explains the three-year hold mechanism and CBRT FX-sale check in its official guidance. 

Timelines

Case-by-case, but typical sequences are:

Banking & BDDK conformity (account opening to confirmation), followed by residence permit issuance, and then citizenship adjudication. Decision times vary with security vetting and document completeness and are not guaranteed.

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Advantages of the bank-deposit route

• Simplicity & speed: no conveyancing, construction milestones or property valuations.
• Liquidity at term: principal is typically accessible at the end of the block; profit-share/interest may accrue subject to product choice and bank policy.
• Clarity of compliance: CBRT’s Instruction and BDDK’s conformity process provide a clear documentary trail for the citizenship file. 

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Risks, restrictions and common pitfalls

• FX conversion is mandatory: skipping the CBRT FX sale step or using ineligible currencies will derail conformity. Ensure your bank issues the FX-purchase/sale confirmation aligned with the Instruction. 
• Threshold maintenance: withdrawals, pledges or liens that reduce the blocked balance below USD 500,000 equivalent may invalidate conformity; banks report changes to authorities. 
• Citizenship is discretionary: even with perfect investment documentation, the Presidency may refuse on security/public-order grounds. 
• Programme changes: Türkiye has updated thresholds and mechanics over time (e.g., 2018 reduction; 2022 CBRT FX-sale regime). Transactions should reflect the rules in force on your filing date. 

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How this compares to real estate and fund options

• Real estate: minimum USD 400,000 with a three-year no-sale annotation on title; Tapu ve Kadastro (TKGM) publishes detailed procedural guidance for land registry and investment determination certificates. 
• Capital-market funds (GYF/GSYF): USD 500,000 in fund units held three years with MKK block and SPK suitability; CBRT FX-sale rules also apply. SPK’s investor circular sets out verification and monitoring (including weekly checks). 

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Official sources you should rely on

• Invest in Türkiye (Presidency’s Investment Office) – programme thresholds and eligible routes. 
• CBRT Implementation Instruction – “Implementation Instruction Regarding the Sale of Foreign Exchange to the CBRT within the scope of the Regulation on the Implementation of the Turkish Citizenship Law” (May 16, 2022; latest consolidated on CBRT website). This governs the mandatory FX sale to CBRT and defines eligible currencies. 
• TKGM Guide (09/12/2024) – although focused on real estate, it is the most detailed official process guide for Article 20 investments (notations, DAB/FX certificates, payment evidence). Useful by analogy for documentary discipline. 
• SPK guidance – for fund-unit investments (requirements, blocking, monitoring). 

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Worked example (illustrative)

An investor wires USD 520,000 to a Turkish bank. The bank executes the FX sale to CBRT (eligible currency), credits TRY proceeds, and places a 36-month block on a TRY deposit or participation account reflecting the USD 500,000-equivalent threshold on day one. The bank files to BDDK, which confirms conformity. The investor applies for a short-term residence permit, then files for citizenship. After 36 months, if citizenship has been granted and no legal impediments arise, the bank lifts the block, and the client may withdraw, renew or reallocate funds (bearing in mind tax and banking rules). 

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Frequently asked questions (FAQ)

Is interest (or participation profit) allowed during the three-year period?

Yes, subject to bank product terms; the decisive factor is that the blocked principal does not fall below USD 500,000 equivalent during the hold. 

Must I fix the deposit in USD?

No. Under the CBRT Instruction, qualifying FX (USD/EUR/GBP/CHF) is sold to CBRT through the bank and the resulting TRY is placed on deposit/participation. Your bank documents the steps for conformity. 

Who issues the document proving my deposit qualifies?

The BDDK/BRSA is the competent authority for bank-deposit conformity under Article 20 and coordinates notifications to the population and migration authorities. 

Are my spouse and minor children included?

Dependants are commonly included, subject to standard checks and documentation. The final decision remains discretionary. 

Can rules change mid-process?

Yes. Türkiye has updated its regime (notably the 2018 thresholds and 2022 FX-sale rules). We structure your file to comply with the rules in force on submission and monitor any official updates. 

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What MFY Legal adds

• Expert risk management: We align every step with CBRT and BDDK requirements to avoid technical refusals (e.g., missing FX-sale evidence, non-qualifying currencies, or premature unblocking). 
• Evidence-led filings: We build the file around primary documents (CBRT FX-sale confirmations, bank blocking letters, BDDK conformity, clean criminal records), cross-referencing official guidance (Invest in Türkiye, TKGM where applicable, SPK for comparative pathways). 
• Holistic options: If a fund or real estate pathway better matches your objectives, we pivot quickly with the same diligence. 

Official Resources

• Invest in Türkiye (Official) – investment thresholds and options: https://www.invest.gov.tr/
• CBRT Implementation Instruction – FX sale rules & eligible currencies: https://www.tcmb.gov.tr/
• TKGM Real Estate Citizenship Guide (09/12/2024) – documentary standards for the land-registry path: https://www.tkgm.gov.tr/
• SPK guidance on the fund-unit route (GYF/GSYF): https://www.spk.gov.tr/

Considering Turkish citizenship by bank deposit? MFY Legal can structure your investment, implement the CBRT FX conversion correctly, and shepherd your file through BDDK conformity to a decision-ready application. Book a confidential consultation and receive a document checklist tailored to your profile today.

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Compliance note

This page relies exclusively on official, authoritative sources (government/organisational). Key legal and procedural references are cited inline to Invest in Türkiye (Presidency’s Investment Office), the CBRT Implementation Instruction and the TKGM 09/12/2024 Guide; comparative references to SPK cover the fund route for context. Always assess current rules before filing; MFY Legal monitors Official Gazette and regulator updates continuously. 

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Important: Nothing herein constitutes legal advice for a specific matter. Outcomes are case-dependent and contingent on eligibility, documentation and public-order checks.