Why 451 Investors Lost Turkish Citizenship in 2025 – And How to Ensure You Are Not Next (2026 Update)
- Özgür Kurucuk
- 4 days ago
- 6 min read
Introduction
In 2025, 451 investors had their Turkish citizenship revoked. The figure was reported in industry analysis, including IMI Daily, and confirmed what many of us in legal practice already knew: enforcement has changed. Retroactive audits are real. Revocation is real. And “approval” is no longer the end of the story.
Turkish citizenship is not a product. It is a legal status granted by Presidential decree. It cannot be “sold” by agents. It can only be earned through compliant investment and verified legal representation.
The era of casual applications—2017 through 2023—is over. In 2026, the file you submit must survive scrutiny from the Land Registry, the Capital Markets Board (CMB), MASAK, and ultimately the Presidency.
This article explains, step by step, how to structure your investment to survive 2026 scrutiny.
THE 2026 RISK LANDSCAPE
1. The Revocation Wave
What happened in 2025 was not an anomaly. It was a signal.
451 investors lost citizenship because their files contained defects that had gone undetected during initial review: inflated valuations, phantom properties, undisclosed mortgages, forged documents, and manipulated purchase contracts. Many of these cases were structured by “consultants” who treated the $400k threshold as a target to be engineered, not a minimum to be cleanly exceeded.
Revocation is now an active enforcement tool. Files are being audited retrospectively. The three-year holding period is digitally tracked through Tapu annotation systems. If the non-sale commitment is missing, improperly registered, or later violated, the system records it.
In 2026, approval is conditional on continuing compliance.
2. The FATF Effect
Turkey’s exit from the FATF grey list required structural anti-money-laundering reform. That reform did not stop at banks. It now affects citizenship files.
Source-of-funds review mirrors banking compliance. A bank statement showing $400,000 is insufficient. The Ministry wants to know where it came from. Was it dividend income? A property sale? Inheritance? Corporate exit?
Cash deposits, crypto conversions, and third-party transfers are high-risk. If you cannot trace funds from origin to Turkish transfer with documentary continuity, your file is vulnerable.
3. The Agent Liability Gap
Agents and consultants have zero legal standing before Turkish ministries. If your application is rejected, an agent cannot file an administrative objection. They cannot initiate judicial review before the Administrative Court. They cannot represent you before the Ministry of Interior.
Only a licensed lawyer can do that.
If your current advisor says, “We work with a lawyer,” ask who that lawyer is, and whether you will engage them directly. If the answer is unclear, you are exposed.
THE FIVE FATAL APPLICATION ERRORS (2026 EDITION)
Error 1: The Seller-Selected Valuer
Mechanism: The developer recommends an appraiser. The appraiser values the property at precisely $400,000. The file is submitted. During audit, the Ministry cross-checks comparable sales and CMB data. Discrepancy detected. Application rejected.
The 2026 reality: CMB-licensed valuation is mandatory. However, license alone does not eliminate conflict of interest. Seller-influenced valuations are a rejection vector.
Kurucuk Protocol: We obtain the valuation report exclusively from GABİM, a government-approved valuation company whose reports are specifically issued for citizenship applications. Valuation reports obtained from any other source are considered invalid and cannot be used in the citizenship process.
Error 2: The Unannotated Tapu
Mechanism: Title deed (Tapu) is transferred, but the mandatory three-year non-sale annotation is not properly registered. File is submitted. Ministry review identifies absence or defect. Non-compliant. Rejection.
In 2026, Tapu annotation is digitally tracked. You cannot “correct it later” without consequences.
Kurucuk Protocol: Annotation is verified at the Land Registry at the moment of transfer. We obtain written confirmation and confirm digital registration before funds are fully released.
Error 3: The Hidden Encumbrance
Mechanism: Property appears attractive. Price meets threshold. After transfer, it emerges that the property carries an ipotek (mortgage) or other encumbrance. Clean title is a legal requirement for eligibility. Application collapses.
Kurucuk Protocol: We conduct full Tapu history investigation before transaction. Encumbrance certificate obtained. We review at least 50 years of registry history where available, including zoning compliance and condominium establishment status.
Error 4: The Off-Plan Mirage
Mechanism: Developer sells “future construction” with reservation agreement. No independent, transferable title deed exists. Investor pays deposit. Months later, application cannot proceed because citizenship requires issued Tapu. Pre-sales without transferable title are ineligible.
Kurucuk Protocol: We accept only transactions with issued and transferable title deed (kat mülkiyeti or valid kat irtifakı that is independently registrable). Marketing promises are irrelevant. Registry reality controls.
Error 5: The Source-of-Funds Shortcut
Mechanism: Applicant provides a bank statement showing $400,000. Ministry requests origin trace. Applicant cannot produce underlying contracts, tax records, inheritance rulings, or dividend resolutions. File is suspended or rejected.
In 2026, source-of-funds scrutiny mirrors FATF standards.
Kurucuk Protocol: Before submission, we prepare a source-of-funds opinion letter. We assemble documentary chains: real estate closing statements, corporate dividend registers, notarized share sale agreements, inheritance court decisions, tax assessment receipts. We do not submit balances. We submit narratives supported by evidence.
THE KURUCUK PROTOCOL – APPLICATION ARCHITECTURE FOR 2026 SURVIVAL
Phase 0: Pre-Engagement Vetting
We do not accept every file.
Our complimentary eligibility assessment reviews nationality risk profile, documentary readiness for source-of-funds, and suitability of investment route (real estate, bank deposit, fixed capital investment).
If the file is structurally weak, we say so.
Phase 1: Independent Valuation & Title Forensics
The client receives three CMB-licensed valuation firms. The client selects. The seller has no input.
We conduct forensic Tapu review: encumbrances, mortgages, military zone status, zoning compliance, condominium status, and historical ownership patterns. The $400k threshold is treated as a legal floor, not a marketing slogan.
Release conditions:
Clean Tapu registered in client’s name.
Three-year non-sale annotation confirmed.
Certificate of Conformity issued.
Direct transfers to developers without conditional control expose investors to unnecessary risk.
Phase 2: Source-of-Funds Fortification
We construct financial narratives aligned with MASAK expectations.
Accepted documents include corporate dividend resolutions, notarized share transfer agreements, inheritance court rulings, property sale deeds, and tax compliance certificates. Where necessary, we coordinate with foreign counsel to ensure cross-border documentation coherence.
Phase 3: Ministry-Grade File Assembly
All documents are translated by sworn translators, notarized, apostilled where required, and compiled in statutory format.
The file passes through security review, including intelligence agency screening and financial crimes board (MASAK) clearance, before Presidential submission.
Phase 4: Post-Citizenship Asset Protection
Citizenship does not end at approval.
We monitor the three-year holding period. We advise on resale strategy post-2027. We draft Turkish wills where necessary and coordinate tax residency analysis. Revocation risk continues if compliance fails.
VERIFIABLE CREDENTIALS – THE DIFFERENCE BETWEEN A CLAIM AND A FACT
We do not describe ourselves as the “best.”
We do not promise guaranteed approval.
We do not advertise “100% success rates.”
We state the following:
Özgür Kurucuk and Zeynep Atım Kurucuk are licensed lawyers registered with the Istanbul Bar Association. Bar registration is verifiable.
Our office is located in Maslak (European side) of Istanbul. Clients may request in-person meetings.
We have completed more than 200 citizenship-by-investment files. To date, no client has been rejected or revoked.
We accept zero commission from developers, sellers, or banks. Our legal fee is disclosed in writing at engagement. We do not profit from your property purchase. We profit from your compliance.
DECISION TOOLS – HOW TO SELECT THE RIGHT REPRESENTATION
Use this checklist before signing with any provider.
Are you a licensed avukat registered with the Istanbul Bar Association?
If yes, request the bar number and verify.
If no, or “we work with a lawyer,” terminate the conversation.
Who selects the valuation company?
If the seller influences selection, reconsider. Independent selection is essential.
What happens if my application is rejected?
If the answer includes administrative appeal or judicial review by the same licensed attorney, proceed.
If the answer is “we apply again,” that is not a legal strategy.
Can I meet the specific attorney handling my case before engagement?
If yes, evaluate their credentials.
If you are assigned to a “case manager,” you are likely in an agent model.
The Final Words to Consider
Turkish citizenship by investment is a legal status, not a retail product. It is granted by Presidential decree after multi-layered compliance review.
The era of passive applications is over. Active legal defense is now the minimum standard.
Kurucuk & Associates offers a complimentary eligibility assessment. No obligation. No sales pressure. We do not chase clients. We assess files.
Author Bio
M. Özgür Kurucuk is a licensed avukat and founding partner of Kurucuk & Associates, Istanbul Bar. Since 2006, he has advised international investors on Turkish real estate acquisition, corporate structuring, and citizenship by investment compliance. He responds personally to client inquiries.