There are two parallel paths for the customer who is blacklisted with an incorrect STR: 5549 SK art.19 objection + annulment case to the administrative court.
Objection procedure
- Objection of the 7-day injunction to the criminal judgeship of peace.
- Documentary proof of source (invoice, contract, swift).
- Financial advisor expert report - critical for the defense.
Administrative court
- MASAK decision is an administrative action; An annulment lawsuit can be filed.
- Duration: 60 days from notification of the decision.
- Quick measures can be requested (stay of execution).
Bank communication tactics
- The bank is bound by MASAK decision; does not accept additional requests.
- Written communication with customer relations manager — document in defense.
Frequently asked
Is the account released immediately after the measure is lifted?
When the cautionary decision notification reaches the bank, it is processed within 24-48 hours.
There is a blockage in more than one bank; all at the same time?
Yes; MASAK decision is communicated to all banks at the same time.
If the objection to the measure is rejected?
Continue with a direct annulment case to the administrative court.
Relevant legislation
- Law No. 5549 on the Prevention of Laundering Proceeds of Crime Article 19 — 7-day temporary measure in suspicious transactions.
- 5549 SK article 13 — Administrative fines (obliged person, manager, employee).
- Turkish Penal Code art.282 — Laundering of proceeds of crime (3-7 years + judicial money).
- CMK article 128 — Confiscation of goods and rights; peace penalty approval.
- 5549 SK Implementation Regulation — Suspicious transaction reporting (STR), regular activity reporting.