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  • Turkish Citizenship Revocation 2026: Official Figures

    Turkish Citizenship Revocation 2026: Official Figures

    DOLĞUN AKADEMİ | LEGAL RESEARCH

    Turkish Citizenship Revocations in 2026: Official Figures, 6,134 Decisions, the Investigation Involving 1,070 People, and International Media Coverage

    Author: Attorney Murat Can Dolğun – Istanbul Bar Association

    Published: October 22, 2026

    Research Areas: Turkish Citizenship Law, Immigration Law, Administrative Law, Criminal Law, Private International Law and Foreign Investment.

    Read this article in Turkish:
    Click here to read the original Turkish version.

    Abstract

    The cancellation and withdrawal of Turkish citizenship acquired through investment have become significant issues in Türkiye’s legal and international investment landscape. Criminal investigations and administrative reviews conducted in 2025 and 2026 have raised questions concerning the legality of property transactions, the reliability of valuation reports, the authenticity of financial transfers, and the legal validity of citizenship decisions issued in previous years.

    According to public statements attributed to the Turkish Ministry of Interior, citizenship acquisition decisions concerning 6,134 individuals, including 1,413 principal investors and their family members, have been cancelled or withdrawn following reviews of investment eligibility and security assessments.

    A separate investigation announced on September 21, 2026, concerned 1,070 people, comprising 263 principal investors and 807 family members, whose citizenship acquisitions were linked to property transactions examined by the Istanbul Chief Public Prosecutor’s Office.

    These figures do not represent identical legal proceedings. In particular, it would be incorrect to conclude that every person within the group of 1,070 had already been subjected to a final individual citizenship cancellation decision.

    This study examines official announcements, the chronology of investigations, their criminal and administrative dimensions, and their presentation in Arabic, English, Russian and Chinese-language media up to October 22, 2026.

    It also considers the position of genuine investors, constitutional protection of nationality, legal certainty, legitimate expectations, individual responsibility and effective judicial review.

    Research limitation: Allegations made during criminal investigations are distinguished from established facts and final judicial findings. Media commentary, commercial publications and individual social-media posts are not treated as independent official evidence or representative scientific surveys of investor opinion.

    1. Why Have Turkish Citizenship Revocations Become an International Issue?

    Acquisition of Turkish citizenship through investment is one of the exceptional naturalisation mechanisms established under Turkish law to facilitate foreign investment. Its principal statutory basis is Article 12 of Turkish Citizenship Law No. 5901, together with Article 20 of the Regulation on the Implementation of the Turkish Citizenship Law.

    The Turkish citizenship-by-investment system operates at the intersection of private law and public law. An investor may enter into a private contractual relationship by purchasing immovable property, making a bank deposit or undertaking another qualifying investment. The decision granting Turkish citizenship, however, is an exercise of public authority.

    A construction company may sell a property. A bank may execute transfers. An appraisal company may determine a property’s market value. A consultant may assist with administrative documentation. None of these private parties has the legal authority to grant Turkish nationality.

    Citizenship is acquired through a decision issued by the competent state authority under the applicable legal framework.

    Consequently, when a citizenship decision granted several years earlier is subsequently challenged because of an allegedly false document, an irregular valuation or a disputed investment transaction, the legal implications extend beyond the contractual relationship between investor and seller.

    The matter also concerns the stability of administrative decisions, the protection of nationality as a legal status, the rule of law and the confidence that individuals may reasonably place in governmental acts.

    Two Competing Legal Considerations

    One approach emphasises the state’s legitimate responsibility to investigate fraud, sham transactions and applications that did not meet the statutory conditions for naturalisation.

    The other stresses the need to distinguish genuinely compliant investors from third parties who may have committed irregularities during a transaction. An individual who actually transferred the required funds, purchased property and obtained the official certificate of conformity may face circumstances materially different from those of a person who knowingly participated in a fictitious investment.

    These objectives are not necessarily incompatible. A legal system may pursue fraud prevention while simultaneously requiring individual examination, adequate evidence, proportional legal consequences and effective judicial protection.

    2. Chronology of Turkish Citizenship Investigations in 2025–2026

    2.1. September 24, 2025: Investigation Into Allegedly Sham Property Transactions

    The investigations became particularly visible with the operation announced on September 24, 2025.

    According to Anadolu Agency, authorities investigated allegedly fictitious or sham real estate transactions used to facilitate Turkish citizenship acquisitions. The operation took place across 19 provinces and concerned transactions linked to 451 foreign investors and a reported total of 1,198 citizenship acquisitions including family members.

    The publicly reported allegations included the absence of genuine foreign-currency inflows, inflated property appraisals, and subsequent transfers of properties to previous owners or associated parties.

    The investigation demonstrated why the registration of a property transfer in the land registry does not necessarily prove that every requirement of the citizenship-by-investment legislation was satisfied in economic substance.

    Source:
    Anadolu Agency, September 24, 2025.

    2.2. August 4, 2026: Proceedings Concerning 687 People

    On August 4, 2026, the Turkish Ministry of Justice announced another operation coordinated by the Istanbul Chief Public Prosecutor’s Office.

    The Ministry stated that comparatively low-value properties had allegedly been represented as higher-value investments through false appraisal reports and sham sales transactions.

    According to the announcement, the legal process had been initiated to cancel the citizenship of 687 individuals considered to have obtained Turkish citizenship through those arrangements.

    The authorities also reported detention decisions involving 90 suspects, the apprehension of 72 suspects, and protective measures affecting corporate and other assets.

    The Ministry referred to approximately TRY 2.5 billion in foreign-currency funds that allegedly should have entered Türkiye but had not actually done so.

    An essential distinction must be maintained: the initiation of criminal proceedings and legal steps intended to cancel citizenship does not establish that every affected individual lost citizenship on August 4, 2026.

    Source:
    Turkish Ministry of Justice, Official Statement, August 4, 2026.

    2.3. September 21, 2026: Investigation Involving 1,070 People

    A further operation coordinated by the Istanbul Chief Public Prosecutor’s Office was announced on September 21, 2026.

    According to the official statements reported by Anadolu Agency, investigators examined property transactions involving Gül İnşaat AŞ, Beyaz İnşaat and LİV İnşaat.

    The authorities reported examining sales to 734 foreign purchasers, of which 274 were alleged to involve sham transactions.

    The investigation concerned citizenship acquisitions involving 1,070 people, including investors and their family members.

    The reported transaction volume exceeded TRY 3.5 billion. Various properties and corporate assets were reportedly subjected to protective measures, including seizure and the appointment of trustees.

    Nevertheless, the presumption of innocence continues to apply to the companies and individuals under investigation. Whether the allegations are established must be determined through the applicable criminal proceedings.

    The fact that a development project is mentioned in a criminal investigation does not establish that every purchaser within that project participated in unlawful conduct.

    Source:
    Anadolu Agency, September 21, 2026.

    2.4. September 21, 2026: Ministry of Interior Figures Concerning 6,134 People

    The Ministry of Interior’s public statement reported on September 21, 2026, revealed that the administrative dimension of the citizenship reviews extended considerably beyond the latest criminal investigation.

    The Ministry reported that citizenship acquisition decisions involving 6,134 individuals had been cancelled or withdrawn in connection with investment eligibility reviews and public-order or national-security assessments.

    This total must not be confused with the 1,070 people referred to in the second-wave investigation.

    International investment-migration publications had also reported the broader figure in August 2026. Accordingly, the publication date of a news article must be distinguished from the period covered by the underlying administrative statistics.

    Sources:
    TRT Haber, September 21, 2026;
    IMI Daily, August 6, 2026.

    2.5. September 24–25, 2026: Detention and Judicial Supervision Measures

    Following the second-wave operation, further information became available concerning the criminal procedural measures imposed on suspects.

    An Anadolu Agency report dated September 25, 2026, stated that 33 suspects had been remanded in custody, 20 were subjected to house-arrest measures, and 21 were placed under other forms of judicial supervision.

    Some earlier reports had cited different detention figures. Reports issued at different times may reflect successive stages of the same investigation rather than contradictory final outcomes.

    Pretrial detention and judicial supervision are preventive procedural measures. Neither constitutes a final criminal conviction.

    2.6. October 2026: Outstanding Uncertainty Regarding Individual Files

    As of October 22, 2026, the publicly verifiable information examined in this study demonstrated the existence of extensive criminal investigations and administrative reviews.

    However, public sources did not establish that all individual citizenship files within the announced groups had been concluded or that final criminal judgments had been delivered in every related investigation.

    The absence of new press announcements does not mean that no administrative or investigative actions are taking place. Criminal investigation confidentiality and personal-data protection rules may prevent individual developments from becoming publicly known.

    3. What Do the Figures 6,134, 1,070 and 687 Actually Mean?

    A major source of misunderstanding is the combination of figures originating from separate administrative reviews, criminal investigations and official announcements.

    3.1. The Reported Administrative Total of 6,134

    The Ministry of Interior’s publicly reported breakdown was as follows:

    Category Principal Investors Total Including Family
    Cancellation linked to certificates of conformity 1,150 5,391
    Withdrawal connected to public-order and national-security reviews 263 743
    Reported Total 1,413 6,134

    The Ministry also reported that, since February 11, 2026, certificates of conformity involving 458 principal investors had been cancelled, affecting 1,393 individuals including family members. It separately referred to seven individuals whose citizenship had been withdrawn on public-order or national-security grounds.

    These sub-period figures should not automatically be added to the general total as if they were entirely separate populations.

    For each affected individual, the relevant legal facts remain the date of the administrative decision, the date and manner of notification, its statutory grounds and any available judicial remedy.

    3.2. The 1,070 Individuals Were Not All Principal Investors

    Category Persons
    Principal investors 263
    Family members 807
    Total 1,070
    Persons obtaining citizenship at the time of the original decision 1,015
    Children obtaining citizenship subsequently 55

    Calling all 1,070 people foreign investors would be legally inaccurate.

    The citizenship status of spouses and children may be connected to the principal investor’s acquisition, but the legal consequences must be examined with reference to the grounds and date of each person’s acquisition.

    The fact that 55 children reportedly acquired citizenship after the original citizenship decision does not establish that all of those children necessarily face identical consequences.

    3.3. Can the Figures 687 and 1,070 Be Added Together?

    The August 4 and September 21 announcements concerned different investigative stages. Adding their figures may produce a rough count of the individuals mentioned in those announcements, but it does not establish a new official total of final citizenship cancellations.

    Nor can it safely be assumed, without examining the underlying datasets, that the figures are entirely independent of the reported total of 6,134.

    Official statistics must be interpreted according to their precise scope, reporting period and legal classification.

    4. The Positions of the Ministry of Interior, Ministry of Justice, Police and Prosecutors

    4.1. Ministry of Interior: Administrative Supervision

    The Ministry of Interior has emphasised the supervision of certificates of conformity and the review of previously issued citizenship decisions.

    According to its publicly reported explanation, investment applications undergo checks concerning compliance with the statutory requirements, security screening and archival investigations.

    The Ministry has also stated that the irregularities under investigation concerned documents prepared before the citizenship application stage and that no institutional failure or negligence had been identified within the Directorate General of Population and Citizenship Affairs.

    This represents the Ministry’s stated position. Whether particular administrative officials relied on specific documents lawfully remains a matter requiring examination of the individual case file and, where necessary, judicial scrutiny.

    4.2. Ministry of Justice: Alleged Fraud and Organised Misconduct

    The Ministry of Justice has presented the criminal investigations as measures against the misuse of citizenship legislation through fraudulent property transactions and documents.

    Depending on the investigation, publicly reported allegations have included establishing organisations for criminal purposes, migrant smuggling, document forgery and false declarations during the preparation of official documents.

    Nevertheless, the appearance of a particular offence in an investigation does not establish that every person connected to the investigation committed that offence.

    Criminal liability depends on the alleged conduct, individual participation, the relevant mental element and the admissibility and sufficiency of the evidence.

    4.3. Istanbul Chief Public Prosecutor’s Office: Financial and Documentary Evidence

    The investigations have reportedly involved land registry records, valuation reports, banking transactions, expert assessments and analyses conducted by the Financial Crimes Investigation Board, known as MASAK.

    The central issue therefore extends beyond whether title to a property was formally transferred.

    The authorities may also examine the genuine economic nature of the transaction, the origin and destination of funds, the authenticity of payment and whether the required investment was actually completed.

    4.4. Police Authorities: Criminal Investigation Functions

    The Istanbul Police Department’s Anti-Migrant Smuggling and Border Gates Branch has participated in the publicly announced operations under prosecutorial coordination.

    Judicial police authorities collect evidence and carry out investigative measures under the applicable criminal procedure framework.

    They do not, merely by interviewing a person or recording a statement, exercise the authority to issue a final administrative decision terminating Turkish citizenship.

    A summons for questioning and a citizenship cancellation decision must therefore be treated as legally distinct events.

    4.5. Land Registry and Tax Audit Authorities

    The General Directorate of Land Registry and Cadastre and the Tax Inspection Board have also been identified as participants in technical and financial review processes.

    Relevant issues include the reliability of valuation reports, the nature of real estate transfers, declared purchase prices, tax-related financial information and the consistency of supporting documents.

    Technical findings may provide grounds for subsequent administrative action, but the legality of such action remains subject to applicable judicial review.

    5. What Transactions Are Being Investigated?

    5.1. False or Inflated Property Valuation Reports

    An allegation that a property’s value was artificially increased raises the question of whether the investment genuinely met the statutory minimum required at the relevant time.

    However, it is not always legally appropriate to determine the historical validity of an investment solely by reference to its present market value.

    The governing legislation, market conditions, valuation methodology and transactional circumstances at the time of investment are essential considerations.

    5.2. Sham Property Sales

    A sham transaction generally involves a discrepancy between the parties’ apparent legal act and their genuine intention or economic arrangement.

    The appearance of a development or construction company’s name in an investigation is insufficient, by itself, to establish that every individual sale carried out by that company was fictitious.

    Each transaction requires its own examination.

    5.3. Artificial Financial Transactions and Missing Currency Inflows

    One recurring allegation is that funds ostensibly transferred for a qualifying investment did not genuinely originate from the investor or were circulated through intermediary accounts to simulate compliance.

    Relevant evidence may include foreign-bank statements, SWIFT records, currency purchase documents, seller account statements, payment instructions, tax records and any subsequent repayment or circular movement of funds.

    The economic reality of the payment should be established through a coherent documentary chain rather than an isolated banking entry.

    5.4. Distinguishing the Investor’s Conduct from Third-Party Misconduct

    The preparation of an inaccurate valuation report by an appraisal company, the submission of a false document by a seller and a knowingly false declaration by an investor are not legally identical acts.

    At the same time, the investor’s good faith does not automatically resolve every administrative problem if a mandatory objective condition for the acquisition of citizenship was not actually fulfilled.

    Both questions therefore require examination: whether the statutory requirements were satisfied and whether any alleged misconduct is attributable to the investor.

    For further analysis, see our earlier publication:
    Cancellation and Withdrawal of Turkish Citizenship Acquired Through Investment: False Valuation Reports, Sham Transactions and the Protection of Genuine Investors.

    7. How Has the Arabic-Language Media Covered Turkish Citizenship Revocations?

    Turkish citizenship through investment has long attracted attention in Arabic-speaking countries because of its relationship with real estate investment, family relocation, business opportunities and international mobility.

    The investigations reported in 2026 introduced an additional dimension to this discussion: the possibility that nationality granted in previous years may subsequently become the subject of administrative and judicial review.

    7.1. Anadolu Agency’s Arabic Coverage

    On September 21, 2026, Anadolu Agency published an Arabic-language report concerning the proceedings involving 1,070 individuals and the alleged property irregularities under investigation.

    The publication is useful for understanding how Turkish official statements were communicated to Arabic-speaking audiences.

    Nevertheless, translating an official announcement into another language does not transform ongoing proceedings into final judicial findings.

    Anadolu Agency, Arabic Edition, September 21, 2026.

    7.2. Regional Arabic Publications

    Ammon News, based in Jordan, also reported the developments concerning the 1,070 individuals and the alleged irregularities in property transactions.

    This illustrates how the Turkish citizenship investigations became part of the wider Arabic-language regional news cycle.

    However, republication of information initially reported by Anadolu Agency does not necessarily constitute independent verification of the underlying allegations.

    Ammon News, September 21, 2026.

    7.3. Terminological Problems in Arabic Reporting

    Arabic expressions commonly translated as cancellation, withdrawal or revocation may not accurately reproduce the distinctions contained in Articles 31 and 40 of Turkish Citizenship Law.

    A definitive headline declaring that 1,070 people had lost citizenship may therefore overstate what the underlying announcement actually established.

    For investors and their families, the relevant questions concern the existence of an individual administrative decision, its legal grounds, notification, passport status and possible legal remedies.

    The implications for spouses and children deserve particularly careful consideration.

    8. European and English-Language International Media Coverage

    International coverage has approached the Turkish citizenship issue not only as a criminal investigation but also as a question concerning the governance, credibility and long-term stability of citizenship-by-investment programmes.

    8.1. Deutsche Welle: The Broader Public-Policy Debate

    A Deutsche Welle report published on August 8, 2026, considered the investigations in the context of the wider Turkish investment-naturalisation framework.

    Such reporting raises institutional questions extending beyond individual criminal liability: How should qualifying investments be verified? Which public institutions should review valuation and banking evidence? What safeguards are required to prevent abuse without undermining lawful investment?

    Deutsche Welle, August 8, 2026.

    8.2. IMI Daily and Comparative Investment Migration

    IMI Daily, a publication specialising in investment migration, reported on the Turkish citizenship developments during August and September 2026.

    Its September 21 coverage addressed the investigation concerning 1,070 individuals. A separate analysis published on October 8 discussed citizenship revocation risks across different international investment programmes.

    These publications show that the Turkish controversy forms part of a broader discussion about the legal durability of citizenship acquired through investment.

    However, specialist commercial publications should not be treated as equivalent to official administrative documents or binding court decisions.

    Sources:
    IMI Daily, September 21, 2026;
    IMI Daily, October 8, 2026.

    8.3. The Ambiguity of the Word “Revocation”

    English-language reporting often uses “revocation”, “cancellation”, “withdrawal” and “annulment” interchangeably.

    These terms may not accurately identify the precise administrative mechanism applied under Turkish law.

    Accurate reporting therefore requires more than identifying the number of affected persons. It should distinguish decisions already issued from procedures merely initiated, identify the relevant legal grounds and clarify whether individual decisions have been notified or judicially challenged.

    9. Russian-Language Reporting and Investment Security

    Russian-speaking investors have shown sustained interest in Turkish real estate and citizenship acquisition. Consequently, reports concerning retrospective reviews of citizenship decisions have also appeared in Russian-language publications.

    9.1. Kazinform and the 2025 Investigations

    Kazinform, a Kazakhstan-based news agency, published a Russian-language report on October 4, 2025, concerning the investigation into allegedly fictitious Turkish property transactions and citizenship acquisitions.

    The report illustrates that concerns about fraudulent investment-based citizenship applications were already circulating in Russian-language media before the larger developments of 2026.

    Kazinform, October 4, 2025.

    9.2. Property Investment Platforms

    Russian-language commercial publications addressing the Turkish property market have also discussed appraisal requirements, documentary safeguards and the possibility of reviewing past citizenship acquisitions.

    These publications may assist in identifying practical investor concerns, such as the preservation of historical banking documents and verification of property valuations.

    However, real estate marketing materials should not be treated as independent legal scholarship or authoritative regulatory statements.

    Property Turkey, Russian-language publication, September 30, 2026.

    10. Chinese-Language Publications and the Position of Chinese Investors

    Developments concerning Turkish citizenship revocations have also been discussed in Simplified Chinese-language investment and migration publications.

    The principal subjects include historical property valuations, documentation of genuine payments and the possibility of administrative review after a citizenship decision has already been granted.

    10.1. Chinese Migration and Investment Commentary

    A Chinese-language publication dated September 28, 2026, addressed the Turkish investigation involving 1,070 individuals and discussed the risk that citizenship previously acquired through investment might later be reviewed because of alleged irregularities in the underlying property transactions.

    This demonstrates that the issue has attracted attention outside Turkish and English-language reporting.

    Skymigration, September 28, 2026.

    10.2. Reporting on the Figure of 6,134

    Chinese-language commercial investment publications have also referred to the reported cancellation or withdrawal of citizenship decisions involving 6,134 individuals.

    Some have presented the developments as evidence of stronger compliance requirements while emphasising that lawful new applications remain possible.

    Such commentary should be assessed in light of the publisher’s commercial interests. A company marketing Turkish property may minimise perceived legal risks, whereas a company promoting competing investment destinations may emphasise those risks.

    The legal assessment must be based on Turkish law, official decisions and the documents of the individual transaction.

    Property Turkey, Chinese-language publication, September 30, 2026.

    10.3. Can the Investigations Be Attributed to a Particular Nationality?

    The official figures examined for this article do not provide a comprehensive, independently verified public breakdown of all affected individuals by nationality.

    Accordingly, it would be inappropriate to suggest, without reliable evidence, that Chinese, Arab, Russian or other national groups account for particular proportions of the cases.

    For legal purposes, the determining considerations are the conditions under which citizenship was acquired, the authenticity of the supporting transactions and the precise legal grounds of any subsequent administrative decision.

    11. Social Media, Internet Forums and Misleading Claims

    The investigations have generated discussion on Reddit and other online platforms concerning intermediaries, real estate developers, valuation companies and the reliability of citizenship-by-investment programmes.

    11.1. Criticism of Intermediaries

    A Reddit discussion published on September 23, 2026, questioned reliance on intermediaries and argued in favour of independent verification of the underlying investment documents.

    Such commentary may identify practical concerns, but it remains an individual opinion rather than representative evidence of investor sentiment.

    Reddit, r/CitizenshipInvestment, September 23, 2026.

    11.2. Claim: “Everyone Who Obtained Citizenship Through Investment Is at Risk”

    This is an unjustified legal generalisation.

    Acquisition of Turkish citizenship through a lawful investment does not itself constitute misconduct.

    The existence and degree of risk depend on the investment’s nature, the applicable legislation at the time, the supporting documents and the specific administrative findings concerning the individual.

    11.3. Claim: “All 1,070 Turkish Passports Have Been Cancelled”

    The September 21 announcements referred to the initiation of relevant administrative procedures. They did not establish that every person in the group had already received a final individual citizenship cancellation decision and that every passport had been cancelled on the same date.

    A citizenship decision, passport validity and the physical surrender of a passport may involve distinct legal and practical procedures.

    11.4. Claim: “All Foreign Investors Will Be Detained at Turkish Borders”

    No publicly verified general official measure establishing such treatment for all foreign investors was identified in the research underlying this article.

    The position of a particular traveller depends on the person’s current nationality status, travel documents, any criminal investigation and applicable individual judicial or administrative measures.

    Neither unconditional assurances of safe entry nor general predictions of detention can properly be made without examining the specific legal circumstances.

    11.5. Are There Reliable International Opinion Surveys?

    This study did not identify a representative international scientific survey, with a disclosed methodology and sample, measuring attitudes towards Turkish citizenship revocations by nationality or investor group.

    Social media posts, online comments and search-engine trends should not be presented as scientifically established public opinion findings.

    12. How Might Citizenship Revocations Affect International Investor Confidence?

    Citizenship through investment is not merely a passport acquisition mechanism. For many individuals and families, nationality forms part of long-term legal, residential, educational and commercial planning.

    Re-examining citizenship decisions issued several years earlier may therefore produce different effects on investor confidence.

    12.1. Stronger Enforcement May Improve Programme Credibility

    A state’s willingness to detect fraudulent valuations, fictitious transactions and fabricated documents may strengthen the legal integrity of its citizenship regime.

    Distinguishing genuine investors from those involved in artificial arrangements could enhance public confidence in the programme over time.

    12.2. Retrospective Reviews May Raise Questions About Legal Stability

    Conversely, an investor who genuinely paid the legally required amount, acquired the property and obtained official approval may reasonably question the consequences of irregularities allegedly committed by third parties.

    This does not mean that administrative authorities are categorically prohibited from reviewing earlier decisions.

    The essential question is whether the alleged failure to satisfy statutory requirements has been established through sufficiently specific evidence and properly connected to the grounds of the administrative measure.

    12.3. Legitimate Expectations and Individual Responsibility

    Legal certainty requires individuals to be able to foresee, within reasonable limits, the legal consequences of state action and to organise their affairs accordingly.

    Nevertheless, legal certainty does not automatically protect every decision that is subsequently shown to be unlawful.

    Accordingly, the proper analysis must determine both whether the legal requirements for citizenship existed at the date of acquisition and whether the administration has justified the particular measure taken against the individual.

    This distinction is especially important where the investor is not personally accused of fraud but the relevant developer, appraisal company or intermediary is under investigation.

    12.4. The International Dimension of Legal Protection

    For foreign investors, a credible legal system is not one in which administrative review is impossible. Rather, it is one in which review is conducted on foreseeable legal grounds, allegations and evidence can be examined, decisions are reasoned and effective judicial remedies remain available.

    The long-term international credibility of Türkiye’s citizenship-by-investment framework may therefore depend not only on how many decisions are cancelled, but also on how those decisions are justified and reviewed by independent courts.

    13. Are New Turkish Citizenship-by-Investment Applications Still Possible?

    As of October 22, 2026, the official investment and citizenship information reviewed for this study did not establish that the Turkish citizenship-by-investment mechanism had been abolished in its entirety.

    The official investment information published by Invest in Türkiye continued to describe exceptional citizenship acquisition through qualifying real estate investment of at least USD 400,000, subject to the applicable legal conditions.

    The General Directorate of Land Registry and Cadastre also continued to provide information concerning citizenship acquisition through property investment via its Your Key Türkiye platform.

    Official resources:
    Invest in Türkiye;
    Your Key Türkiye.

    Two distinctions are essential.

    First, the continued legal availability of the programme does not guarantee that any particular application will be approved.

    Second, administrative review of citizenship decisions granted in previous years does not establish that all lawful new applications have automatically been suspended.

    For prospective applicants, the type and actual value of the investment, the payment documents, the certificate of conformity, the security screening and the legislation applicable at the relevant date remain material.

    The General Directorate of Land Registry and Cadastre also published an announcement on September 29, 2026, concerning the procedures and principles governing valuation reports used in certain property transactions involving foreigners.

    Land Registry and Cadastre – September 29, 2026 Announcement.

    The presence of application information on official websites does not, however, provide sufficient statistical evidence about actual processing times or approval rates.

    14. Outstanding Questions Concerning Turkish Citizenship Revocations

    Despite the information contained in official announcements, several important legal and empirical questions require further clarification.

    1. What is the complete distribution of the 6,134 reported cases by original citizenship acquisition year and date of the administrative measure?
    2. How many individuals within the group of 1,070 had received individual and reasoned citizenship decisions by October 22, 2026?
    3. Which specific provisions of Turkish Citizenship Law No. 5901 are applied in each category of cancellation or withdrawal?
    4. How are genuinely compliant investors distinguished from individuals knowingly participating in fraudulent transactions?
    5. Is there a publicly available, verified list identifying the precise property transactions affected by the investigations?
    6. How are the rights of spouses and children assessed where citizenship was acquired at different times or under different legal grounds?
    7. What information is publicly available concerning the outcomes of administrative lawsuits and applications for suspension of execution?
    8. Have independent researchers conducted representative studies measuring the effects of these developments on international investor confidence?

    These questions cannot all be conclusively answered through news coverage. Many require access to individual administrative files, primary institutional records and court decisions.

    15. Conclusion: Fraud Prevention and Legal Certainty Must Be Protected Together

    The investigations conducted during 2025 and 2026 constitute an important phase in the application and supervision of Turkish citizenship law.

    Allegations involving false appraisal reports, fictitious property sales, artificial banking transactions and misleading documentation raise serious questions of both criminal and administrative law.

    However, legal analysis cannot be founded exclusively on the scale of the figures announced or on the identity of a construction company associated with an investigation.

    The administrative statistics concerning 6,134 individuals, the September investigation involving 1,070 people and the earlier proceedings concerning 687 people must be understood within their respective legal and factual contexts.

    Similarly, involvement in a criminal investigation does not automatically establish a final conviction or the termination of citizenship.

    Under Article 66 of the Turkish Constitution, nationality is a legal status acquired and lost in accordance with statutory conditions.

    Every administrative measure affecting that status must be examined according to its legal grounds, evidentiary basis and consequences for the individual.

    The central conclusion of this research is that preventing fraud in citizenship procedures and protecting the legal security of genuine, good-faith investors are not mutually exclusive objectives.

    The state’s responsibility to safeguard the integrity of its nationality regime must operate alongside the individual’s entitlement to lawful administrative decision-making and effective judicial protection.

    In the longer term, the international credibility of Turkish citizenship through investment will depend not merely on investment thresholds or the number of approved applications, but also on transparency, legal foreseeability, reasoned decisions and effective judicial oversight.

    Accordingly, the appropriate legal starting point is not a general media headline, but the applicable statute, the actual administrative decision, the underlying evidence and the circumstances of the individual citizenship file.

    17. Legislation, Official Statements and International References

    A. Legislation and Official Sources

    1. Constitution of the Republic of Türkiye, Article 66. Constitutional Court – Constitutional Text.
    2. Turkish Citizenship Law No. 5901, particularly Articles 12, 31, 32 and 40. Turkish Grand National Assembly.
    3. Turkish Ministry of Justice, August 4, 2026. Official Statement on Proceedings Concerning 687 Individuals.
    4. Ministry of Interior, September 21, 2026. Statement Reported by TRT Haber.
    5. Invest in Türkiye. Acquiring Property and Citizenship.
    6. General Directorate of Land Registry and Cadastre. Your Key Türkiye – Citizenship Acquisition.
    7. General Directorate of Land Registry and Cadastre, September 29, 2026. Valuation Report Procedures.

    B. Turkish News Sources

    1. Anadolu Agency, September 24, 2025. Investigation Into Sham Property Transactions.
    2. Anadolu Agency, September 21, 2026. Second-Wave Investigation.
    3. Anadolu Agency, September 25, 2026. Reporting on detention and judicial supervision measures.
    4. Deutsche Welle Turkish, August 8, 2026. Research on Turkish Citizenship Through Investment.

    C. Arabic-Language Publications

    1. Anadolu Agency Arabic, September 21, 2026. Coverage of Proceedings Involving 1,070 Individuals.
    2. Ammon News, Jordan, September 21, 2026. Arabic-Language Coverage.

    D. English-Language International Publications

    1. IMI Daily, August 6, 2026. Turkey Revokes 6,134 CBI Citizenships in Program-Wide Sweep.
    2. IMI Daily, September 21, 2026. Turkey to Revoke 1,070 More Citizenships.
    3. Turkish Minute, September 21, 2026. Citizenship Decisions Involving 6,134 People.
    4. IMI Daily, October 8, 2026. Comparative Citizenship Revocation Risks.

    E. Russian-Language Publications

    1. Kazinform, October 4, 2025. Russian-Language Report on Turkish Citizenship Investigations.
    2. Property Turkey, September 30, 2026. Russian-Language Investment Commentary.

    F. Chinese-Language Publications

    1. Skymigration, September 28, 2026. Chinese-Language Commentary on the 1,070-Person Investigation.
    2. Property Turkey, September 30, 2026. Chinese-Language Investment Commentary.

    G. Online Discussion

    Reddit, r/CitizenshipInvestment, September 23, 2026.
    Individual Discussion of Citizenship-by-Investment Intermediaries. This is an individual user opinion, not official evidence.

    Source methodology: Reporting based on the same official announcement is not counted as independent verification. Commercial publications, anonymous commentary and official legal records are distinguished throughout this research.

    Author and Contact Information

    Attorney Murat Can Dolğun
    Istanbul Bar Association – Registration No. 75860
    TD Law Firm & Legal Consultancy
    Lecturer in Law – Istanbul University-Cerrahpaşa

    Practice Areas: Turkish Citizenship Law, Immigration Law, Administrative Law, Criminal Law, Private International Law, Real Estate Law and Foreign Investment Disputes.

    Office: Istanbul World Trade Center (IDTM), Block A2, Office 206, Yeşilköy, Bakırköy, Istanbul, Türkiye.

    Telephone: +90 212 299 44 22
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    Email: av.muratcandolgun@gmail.com
    Website: dolgun.av.tr

    Read in Turkish:
    Click here for the original Turkish article.

    Legal Disclaimer: This article has been prepared for general legal, academic and informational purposes. It does not constitute individual legal advice, a determination of the validity of any particular citizenship decision or a guarantee of any outcome in criminal or administrative proceedings. Applicable legislation, judicial practice and administrative procedures may change. Individual matters must be assessed on the basis of the legislation applicable at the relevant time and the documents contained in the relevant official files.

    © 2026 DOLĞUN AKADEMİ – ATTORNEY MURAT CAN DOLĞUN

  • 1,070 PEOPLE FACING TURKISH CITIZENSHIP CANCELLATION PROCEEDINGS IN 2026:A COMPREHENSIVE LEGAL GUIDE FOR REAL ESTATE INVESTORS

    1,070 PEOPLE FACING TURKISH CITIZENSHIP CANCELLATION PROCEEDINGS IN 2026:A COMPREHENSIVE LEGAL GUIDE FOR REAL ESTATE INVESTORS

    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.

    Source:
    https://www.aa.com.tr/tr/gundem/istanbul-merkezli-usulsuz-vatandaslik-operasyonunda-73-zanli-yakalandi/4062988

    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.

    Source:
    https://www.aa.com.tr/tr/gundem/istanbul-merkezli-usulsuz-vatandaslik-operasyonunda-73-zanli-yakalandi/4062988

    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.

    Source:
    https://www.aa.com.tr/tr/gundem/istanbul-merkezli-usulsuz-vatandaslik-operasyonunda-73-zanli-yakalandi/4062988

    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.

    Source:
    https://www.aa.com.tr/tr/gundem/istanbul-merkezli-usulsuz-vatandaslik-operasyonunda-73-zanli-yakalandi/4062988

    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.

    Source:
    https://www.aa.com.tr/tr/gundem/istanbul-merkezli-usulsuz-vatandaslik-operasyonunda-73-zanli-yakalandi/4062988

    This distinction should not be treated as a technicality.

    There may be several separate stages:

    1. Identification in the investigation.
    2. Administrative examination of the investment.
    3. Examination of the Certificate of Conformity.
    4. Examination of the citizenship file.
    5. Issuance of an individual administrative decision.
    6. Notification of that decision.
    7. 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.

    Source:
    https://www.aa.com.tr/tr/gundem/istanbul-merkezli-usulsuz-vatandaslik-operasyonunda-73-zanli-yakalandi/4062988

    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:

    1. Did the investor personally participate in any false statement, concealment or irregularity?
    2. 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.

    Official source:
    https://nvi.gov.tr/kurumlar/nvi.gov.tr/mevzuat/nufusmevzuat/talimat/yabanci-yatirimcilarin-istisnai-olarak-turk-vatandasligini-kazanmalarina-iliskin-usul-ve-esaslar.pdf

    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.

    Source:
    https://www.aa.com.tr/tr/gundem/istanbul-merkezli-usulsuz-vatandaslik-operasyonunda-73-zanli-yakalandi/4062988

    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.

    Source:
    https://www.aa.com.tr/tr/gundem/istanbul-merkezli-usulsuz-vatandaslik-operasyonunda-73-zanli-yakalandi/4062988

    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.

    Source:
    https://www.aa.com.tr/tr/gundem/istanbul-merkezli-usulsuz-vatandaslik-operasyonunda-73-zanli-yakalandi/4062988

    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

    1. 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
    2. 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
    3. 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
    4. 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
    5. Previous detailed legal analysis – Av. Murat Can Dolğun
      https://dolgun.av.tr/2026/09/19/yatirim-yoluyla-turk-vatandasliginin-iptali-geri-alinmasi/