Updated: 26 September 2026
INTRODUCTION: WE HAD ALREADY WARNED ABOUT THE DEVELOPING CITIZENSHIP CANCELLATION ISSUE
On 19 September 2026, we published a detailed legal analysis concerning the cancellation and withdrawal of Turkish citizenship acquired through investment.
In that article, we examined false or allegedly inflated property valuation reports, sham real estate transactions, the legal position of good-faith investors, the distinction between cancellation under Article 31 of Turkish Citizenship Law No. 5901 and withdrawal under Article 40, and the judicial remedies available against citizenship-related administrative decisions.
Our previous detailed analysis is available here:
Only two days after that publication, a major new development substantially expanded the scope of the issue.
On 21 September 2026, Turkish authorities announced a new investigation concerning real estate transactions through which 1,070 persons were stated to have acquired Turkish citizenship.
According to the Istanbul Chief Public Prosecutor’s Office, the investigation concerns allegations including sham property sales, financial transactions that did not reflect genuine investment payments, and property valuation reports allegedly showing values substantially higher than the actual value of the properties.
Source:
Anadolu Agency, 21 September 2026
https://www.aa.com.tr/tr/gundem/istanbul-merkezli-usulsuz-vatandaslik-operasyonunda-73-zanli-yakalandi/4062988
For investors potentially affected by this investigation, the most important question is now:
“If I am one of the 1,070 people identified in this investigation, has my Turkish citizenship already been cancelled?”
The answer requires a careful legal distinction.
The public announcement did not state that all 1,070 persons had already received final individual decisions cancelling their Turkish citizenship.
The Istanbul Chief Public Prosecutor’s Office stated that the necessary administrative process had been initiated for the cancellation of citizenship considered to have been acquired irregularly.
This wording is legally significant.
Being identified within a criminal investigation, being subjected to an administrative review, having an investment conformity determination reconsidered, receiving an individual administrative decision concerning citizenship, and challenging that decision before the administrative courts are separate legal stages.
Accordingly, an investor who has been told that he or she is “among the 1,070 people” should not determine his or her legal status solely from general news reports.
The individual citizenship file must be examined.
I. WHAT EXACTLY IS THE 1,070-PERSON TURKISH CITIZENSHIP INVESTIGATION?
The investigation is being conducted by the Istanbul Chief Public Prosecutor’s Office.
According to the official information reported by Anadolu Agency, the authorities evaluated Land Registry and Cadastre records, expert reports, MASAK financial analyses and other documents together.
The Prosecutor’s Office stated that, in certain transactions:
- the foreign currency required for Turkish citizenship had allegedly not genuinely entered Türkiye;
- purchase and sale transactions had allegedly been structured using the financial resources of intermediary companies or sellers;
- sham or collusive property transactions had allegedly been created;
- and artificially high valuation reports had allegedly been prepared in relation to certain properties.
According to the same official statement, transactions totalling approximately USD 72.25 million were considered to have been carried out on a sham or collusive basis.
The Minister of Justice also referred to transactions exceeding TRY 3.5 billion in the second phase of the investigation.
This demonstrates an important point:
The current investigation is not limited to the question of whether a valuation report was accurate.
For an affected investor, the legal review may require examination of:
the title deed,
the purchase agreement,
the valuation report,
the Certificate of Conformity,
bank statements,
SWIFT records,
the source of the investment funds,
the amount actually received by the seller,
any subsequent repayment of funds,
and the complete citizenship application file.
The real economic and legal substance of each individual investment is therefore critical.
II. THE 1,070 PEOPLE ARE NOT 1,070 PRINCIPAL INVESTORS
One of the most important facts disclosed by the authorities concerns the composition of the 1,070-person group.
According to the information released by the Ministry of Interior and reported by Anadolu Agency:
263 persons are principal investors.
807 persons are family members.
This gives a total of 1,070 persons.
The authorities further stated that 1,015 persons acquired Turkish citizenship at the time of the original citizenship decision, while 55 children acquired Turkish citizenship after that decision.
Accordingly, it would be inaccurate to describe the matter as involving “1,070 investors”.
It concerns 263 principal investors together with 807 family members.
This distinction has substantial legal importance because the status of the principal investor and the citizenship status of a spouse or child may require separate examination.
III. HAS THE TURKISH CITIZENSHIP OF ALL 1,070 PEOPLE ALREADY BEEN CANCELLED?
Based on the official information currently available, it would not be accurate to state that all 1,070 persons have already received final individual cancellation decisions.
The wording publicly used by the authorities is that:
the necessary administrative process for the cancellation of citizenship has been initiated.
This distinction should not be treated as a technicality.
There may be several separate stages:
- Identification in the investigation.
- Administrative examination of the investment.
- Examination of the Certificate of Conformity.
- Examination of the citizenship file.
- Issuance of an individual administrative decision.
- Notification of that decision.
- Judicial review before the competent administrative court.
Accordingly, a person who believes that he or she falls within the 1,070-person group should first determine the exact current stage of the individual file.
IV. IS THERE AN OFFICIAL PUBLIC LIST OF THE 1,070 PEOPLE?
This point requires particular caution.
Various lists are currently circulating on social media and through private messaging groups, and some of these documents are being presented as lists of persons allegedly included in the 1,070-person investigation.
However, in the official public statements referred to in this article, the authorities have not published a complete list containing the names of all 1,070 persons.
The official announcements disclose the number of affected persons, the number of principal investors and family members, and general information concerning the investigation.
They do not publish a complete official name list.
Official source:
https://www.aa.com.tr/tr/gundem/istanbul-merkezli-usulsuz-vatandaslik-operasyonunda-73-zanli-yakalandi/4062988
Accordingly, lists circulating on social media should NOT be treated as an official confirmation that a particular person is or is not included in the investigation.
The accuracy, completeness and source of such lists are not presently confirmed by the official announcements cited in this article.
They may contain incomplete information, outdated information, spelling differences, duplicated names or persons who are not actually subject to an individual citizenship measure.
For this reason, the existence of a person’s name on a social media list should be treated only as information requiring verification.
Likewise, the absence of a name from an unofficial list does not prove that the person is outside the scope of the administrative investigation.
The correct approach is to verify the individual’s position through official citizenship records, the relevant administrative file and, where necessary, the underlying investigation records.
In short:
A social media list is not an administrative decision.
It is not an official citizenship record.
It is not proof that citizenship has been cancelled.
Each case must be verified individually.
V. WHY THE ACTUAL BANK PAYMENT MAY BE ONE OF THE MOST IMPORTANT ISSUES
One of the central allegations in the investigation concerns the reality of the investment payments.
According to the Prosecutor’s Office, in certain transactions the required foreign currency allegedly did not genuinely enter Türkiye, and financial arrangements were allegedly created using resources belonging to sellers or intermediary entities.
This makes the actual movement of funds extremely important.
A genuine investor may have:
paid the full purchase price from his or her own bank account;
used genuine personal or commercial funds;
transferred the funds directly to the seller;
received no undisclosed refund;
genuinely acquired the property;
and had no knowledge of or involvement in any allegedly irregular structure.
That factual situation is materially different from a transaction in which the required investment capital was only made to appear to originate from the investor.
Therefore, the analysis should not normally stop with one bank transfer receipt.
The entire transaction may need to be reconstructed:
source of funds
→ investor’s bank account
→ transfer to seller
→ receipt by seller
→ subsequent movement of funds.
Complete bank statements, SWIFT documents and evidence of the source of funds may become highly important evidence.
VI. “I DID NOT PREPARE THE VALUATION REPORT”
This issue may be particularly important where Article 31 of Turkish Citizenship Law No. 5901 is relied upon.
Article 31 concerns cancellation of the decision granting Turkish citizenship where citizenship was acquired as a result of a false statement by the person concerned or the concealment of material matters forming the basis of the acquisition.
The Directorate General of Population and Citizenship Affairs similarly explains that an investigation is conducted and that citizenship may be cancelled where concealment of matters forming the basis of the acquisition is clearly established.
Official source:
T.C. Ministry of Interior
Directorate General of Population and Citizenship Affairs
https://www.nvi.gov.tr/kurumlar/nvi.gov.tr/mevzuat/nufusmevzuat/genelge/5901Sayili_Turk_Vatandasligi_Kanuna_Gore_Aciklama2009.pdf
This distinction matters.
An allegation that a valuation expert prepared a false or inaccurate valuation report does not, by itself, establish that the investor knew the report was false.
Likewise, an allegation concerning acts by a seller, intermediary or third party does not, without further evidence, establish that every investor knowingly participated in those acts.
Where Article 31 is relied upon, the following questions may therefore become important:
What false statement did the investor personally make?
What material fact did the investor conceal?
Did the investor know that the valuation was allegedly inaccurate?
Did the investor request that the stated value be increased?
Did the investor receive any undisclosed return of the purchase price?
Did the investor submit any document knowing that it was false?
These questions concern the individual investor’s conduct.
VII. GOOD FAITH IS IMPORTANT — BUT IT MAY NOT ANSWER EVERY LEGAL QUESTION
A different legal issue arises under Article 40 of Turkish Citizenship Law No. 5901.
Article 31 and Article 40 should not be treated as interchangeable provisions.
Article 31 is primarily concerned with false statements or concealment attributable to the person concerned.
Article 40 concerns the withdrawal of a citizenship decision where it is subsequently determined that the legal conditions for the decision were not satisfied.
An investor may therefore have acted entirely in good faith.
The investor may never have met the valuation expert.
The investor may have relied upon the developer, advisers and official administrative documents.
There may nevertheless be a separate legal question:
Did the property genuinely satisfy the statutory investment requirement applicable at the relevant time?
Accordingly, a complete defence should generally address two separate questions:
- Did the investor personally participate in any false statement, concealment or irregularity?
- Were the objective legal conditions for the acquisition of Turkish citizenship actually satisfied?
We discussed the distinction between cancellation under Article 31 and withdrawal under Article 40 in greater detail in our previous article:
VIII. THE HISTORICAL VALUE OF THE PROPERTY MAY BE CRITICAL
Where the original valuation report is challenged, the relevant question is not necessarily:
“What is this property worth today?”
The relevant question may instead be:
“What was the true market value of this property on the relevant investment date?”
This distinction can be decisive.
An allegedly inaccurate valuation report does not necessarily mean that the property itself was below the statutory investment threshold.
A retrospective valuation may therefore become necessary.
Such an assessment may consider:
historical comparable sales;
other units sold in the same development;
floor area;
floor level;
location;
view;
state of completion;
historical exchange rates;
Land Registry data;
and market conditions prevailing on the relevant date.
The investment should be assessed under the factual conditions existing when it was made.
IX. THE CURRENT USD 400,000 THRESHOLD SHOULD NOT SIMPLY BE APPLIED TO HISTORICAL INVESTMENTS
The real estate investment threshold for Turkish citizenship has changed over time.
Accordingly, an investment made under an earlier legal regime must be assessed under the rules applicable to that investment at the relevant time.
The current USD 400,000 requirement should not simply be applied retrospectively to every historical citizenship file.
The following dates may therefore be important:
the property purchase date;
the payment date;
the valuation report date;
the Certificate of Conformity date;
the citizenship application date;
and the citizenship decision date.
The applicable legislation must then be determined according to the chronology of the individual case.
X. WHY THE CERTIFICATE OF CONFORMITY MATTERS
Citizenship by investment is not based solely upon a private declaration by the investor.
The investment must pass through administrative procedures and the relevant competent authority issues a Certificate of Conformity where the statutory investment requirements are considered satisfied.
The Directorate General of Population and Citizenship Affairs expressly regulates the role of the conformity determination in exceptional citizenship applications made by foreign investors.
The existence of a Certificate of Conformity does not necessarily mean that the citizenship decision can never subsequently be reviewed.
However, it is legally significant that the investment was previously examined within an official administrative process.
A later review must therefore consider both:
the new evidence now relied upon by the authorities;
and the earlier administrative determinations on which the investor relied.
XI. FAMILY MEMBERS: WHAT HAPPENS TO SPOUSES AND CHILDREN?
This question is particularly important because 807 of the 1,070 persons identified by the authorities are family members.
Under Turkish citizenship legislation, cancellation of a citizenship acquisition decision may also have consequences for spouses and children who acquired citizenship in connection with the principal applicant.
The official guidance issued by the Directorate General of Population and Citizenship Affairs addresses the effects of cancellation upon persons who acquired citizenship through the person concerned.
Official source:
https://www.nvi.gov.tr/kurumlar/nvi.gov.tr/mevzuat/nufusmevzuat/genelge/5901Sayili_Turk_Vatandasligi_Kanuna_Gore_Aciklama2009.pdf
However, each family member’s citizenship history should still be examined.
This is particularly important because the Ministry stated that 55 children within the relevant group acquired citizenship after the original citizenship decision.
Therefore, the precise date and legal basis on which each spouse or child became a Turkish citizen should be established individually.
XII. WHAT HAPPENED AFTER THE 21 SEPTEMBER OPERATION?
The criminal investigation remains active.
On 25 September 2026, Anadolu Agency reported that judicial procedures concerning 74 detained suspects had been completed.
Thirty-three suspects were remanded in custody.
Twenty suspects were subjected to a judicial-control measure requiring them not to leave their residence.
Source:
Anadolu Agency, 25 September 2026
https://www.aa.com.tr/tr/gundem/istanbul-merkezli-usulsuz-vatandaslik-operasyonunda-yakalanan-33-supheli-tutuklandi/4068739
These are criminal-procedure measures.
A remand decision is not a final criminal conviction.
Likewise, criminal proceedings involving sellers, intermediaries, valuation professionals or other suspects are legally distinct from an administrative determination concerning the citizenship status of an individual investor.
Evidence from the criminal investigation may be relevant to the citizenship proceedings.
However, the legal position of each investor must still be individually assessed.
XIII. ASSET MEASURES DO NOT MEAN THAT EVERY INVESTOR’S PROPERTY HAS BEEN SEIZED
The authorities announced measures involving:
2,011 properties;
one hotel;
86 motor vehicles;
two yachts;
42 bank accounts;
and 30 companies.
These figures should not be misunderstood.
They do not establish that the property of every person within the 1,070-person group has been seized.
Whether a particular investor’s property is subject to a restriction, seizure, annotation or another measure must be checked through that person’s own official records.
A criminal asset-protection measure and an administrative citizenship decision are separate legal matters.
XIV. WHAT SHOULD AN INVESTOR DO IF HE OR SHE MAY BE AMONG THE 1,070 PEOPLE?
The first task should be to establish the exact legal and administrative status of the individual case.
Questions to be answered include:
Am I actually included in the relevant investigation?
Is my citizenship file merely under examination?
Has any action been taken concerning my Certificate of Conformity?
Has an individual citizenship decision been issued?
If so, what is its legal basis?
Has the decision been formally notified to me?
What specific transaction or document is the administration relying upon?
Was my payment genuine and traceable?
Did my property satisfy the required investment value at the relevant historical date?
Was I personally involved in any alleged valuation or financial irregularity?
What is the separate citizenship status of my spouse and children?
XV. DOCUMENTS THAT SHOULD BE PRESERVED AND REVIEWED
Potentially affected investors should consider assembling the complete investment and citizenship record.
Important documents may include:
title deed records;
property sale contracts;
valuation reports;
Certificate of Conformity;
bank transfer receipts;
complete bank account statements;
SWIFT records;
foreign exchange documents;
invoices;
proof of source of funds;
communications with sellers or intermediaries;
citizenship application documents;
the citizenship decision;
and citizenship records relating to spouses and children.
Particular attention should be given to historical banking records because such documents can become more difficult to obtain with the passage of time.
XVI. WHAT IF THE INVESTOR IS CURRENTLY OUTSIDE TÜRKİYE?
A citizenship review should not automatically be equated with a criminal restriction on travel.
Being identified within a citizenship-related investigation does not, by itself, establish the existence of:
an arrest warrant;
a detention order;
a judicial-control measure;
or another individual criminal restriction.
Accordingly, an investor abroad should not assess the risks of travelling to Türkiye solely on the basis of having been told that he or she is “one of the 1,070”.
The following matters should be separately verified:
current citizenship status;
any individual administrative citizenship decision;
any criminal investigation concerning the investor;
any arrest or judicial restriction;
and the immigration consequences if Turkish citizenship has already been affected.
XVII. CAN A CITIZENSHIP CANCELLATION OR WITHDRAWAL DECISION BE CHALLENGED?
Yes.
A citizenship cancellation or withdrawal decision constitutes an administrative act and is subject to judicial review under Turkish administrative law.
The precise legal remedy, competent court, time limit and any application for a stay of execution must be assessed according to the individual decision and the authority that issued it.
This is another reason why the legal basis of the decision must first be established.
A decision based on Article 31 and a decision based on Article 40 raise different legal questions.
They should not simply be described by the single English word “revocation” without identifying the Turkish-law mechanism actually being used.
XVIII. THE CENTRAL QUESTION FOR THE 1,070 PEOPLE
The central legal question is not merely:
“Was there irregularity somewhere within the wider transaction structure?”
The relevant questions are individual:
Was this investor’s payment genuine?
Where did the money originate?
Did the seller actually receive the money?
Was any amount returned?
What was the property’s true value at the relevant historical date?
Did the investor know about any alleged valuation irregularity?
Did the investor make a false statement?
Did the investor conceal any material fact?
Were the objective statutory investment conditions actually satisfied?
What did the competent public authorities determine when the Certificate of Conformity was originally issued?
What new evidence is now relied upon to alter the earlier administrative position?
CONCLUSION: “1,070 PEOPLE” DOES NOT MEAN 1,070 IDENTICAL CASES
The investigation announced on 21 September 2026 is one of the most significant recent developments concerning Turkish citizenship acquired through real estate investment.
According to the information released by the authorities, the relevant group consists of:
263 principal investors;
807 family members;
1,070 persons in total.
However, a large-scale investigation does not transform hundreds of separate investments into one single legal case.
Each investor’s position must be examined individually.
The analysis should include:
the legislation applicable on the investment date;
the genuine movement of funds;
the historical value of the property;
the valuation report;
the Certificate of Conformity;
the investor’s own declarations and conduct;
any alleged return or circular movement of funds;
the legal position of spouses and children;
and the precise factual and statutory grounds relied upon by the administration.
The existence of an investigation involving third parties does not, by itself, determine whether a particular investor acquired Turkish citizenship unlawfully.
Equally, good faith alone may not resolve every possible issue where the authorities allege that an objective statutory investment requirement was not satisfied.
The correct legal method is therefore to reconstruct the individual investment and citizenship file, determine the statutory basis relied upon by the administration and test the allegations against the investor’s actual documents.
For our earlier comprehensive legal analysis concerning Turkish citizenship acquired by investment, cancellation, withdrawal, alleged false valuation reports, sham transactions and good-faith investors, see:
TD LAW FIRM
TD Law Firm advises and represents foreign investors in matters concerning Turkish citizenship by investment, administrative review of citizenship files, cancellation and withdrawal proceedings, Certificate of Conformity disputes, real estate valuation issues, alleged sham transactions and related administrative litigation.
In cases potentially connected with the 1,070-person investigation announced on 21 September 2026, the legal assessment should be based on the investor’s individual citizenship, property, valuation and banking records rather than general media reports or unverified lists circulating on social media.
Av. Murat Can Dolğun
Istanbul Bar Association – Registration No. 75860
TD Law Firm
Tel: +90 212 299 44 22
WhatsApp: +90 507 475 44 22
E-mail: av.muratcandolgun@gmail.com
Website: https://dolgun.av.tr
Address:
Istanbul World Trade Center (İDTM)
A2 Block, No: 206
Bakırköy / Istanbul, Türkiye
LEGAL NOTICE
This article is provided for general legal information only and does not constitute individual legal advice or a guarantee of any particular outcome.
The legal position of each investor must be assessed by reference to the individual administrative file, investment documents, banking records, citizenship records and the legislation applicable at the relevant time.
In particular, names appearing on lists circulated through social media, messaging applications or other unofficial channels should not be regarded as official confirmation of inclusion in the 1,070-person investigation unless and until the individual position is verified through official records.
SOURCES
- Anadolu Agency – 21 September 2026
Istanbul-centred investigation concerning allegedly irregular acquisition of Turkish citizenship:
https://www.aa.com.tr/tr/gundem/istanbul-merkezli-usulsuz-vatandaslik-operasyonunda-73-zanli-yakalandi/4062988 - Anadolu Agency – 25 September 2026
33 suspects remanded in custody:
https://www.aa.com.tr/tr/gundem/istanbul-merkezli-usulsuz-vatandaslik-operasyonunda-yakalanan-33-supheli-tutuklandi/4068739 - T.C. Ministry of Interior – Directorate General of Population and Citizenship Affairs
Official guidance concerning Turkish Citizenship Law No. 5901:
https://www.nvi.gov.tr/kurumlar/nvi.gov.tr/mevzuat/nufusmevzuat/genelge/5901Sayili_Turk_Vatandasligi_Kanuna_Gore_Aciklama2009.pdf - T.C. Ministry of Interior – Directorate General of Population and Citizenship Affairs
Procedures and Principles Regarding Exceptional Acquisition of Turkish Citizenship by Foreign Investors:
https://nvi.gov.tr/kurumlar/nvi.gov.tr/mevzuat/nufusmevzuat/talimat/yabanci-yatirimcilarin-istisnai-olarak-turk-vatandasligini-kazanmalarina-iliskin-usul-ve-esaslar.pdf - Previous detailed legal analysis – Av. Murat Can Dolğun
https://dolgun.av.tr/2026/09/19/yatirim-yoluyla-turk-vatandasliginin-iptali-geri-alinmasi/
