Updated: 28 September 2026

In recent months, the questions most frequently raised by foreign nationals who acquired Turkish citizenship through real estate investment have changed significantly.

Investors are no longer asking only:

“Can my Turkish citizenship be revoked?”

They are now asking:

“Has my Turkish citizenship already been cancelled?”

“Am I involved in a criminal investigation?”

“Could I be detained if I enter Türkiye?”

“My e-devlet account still works. Does that mean I am still a Turkish citizen?”

“I did not prepare the valuation report. Can I still face consequences?”

“Can a Turkish lawyer investigate my case before I issue a power of attorney?”

“I live abroad and have received no notice at all. How can I find out what has happened to my citizenship?”

These questions have become particularly important because of the criminal investigations and administrative reviews concerning citizenship-by-investment files that began attracting significant public attention in 2025 and expanded considerably during 2026.

We previously examined the legal framework in detail in our article dated 19 September 2026, titled:

“Revocation and Withdrawal of Turkish Citizenship Acquired Through Investment: False Valuation Reports, Sham Transactions, Good-Faith Investors and Judicial Protection.”

In that article, we addressed in particular the distinction between revocation under Article 31 of Turkish Citizenship Law No. 5901 and withdrawal under Article 40, as well as property valuation reports, good faith of the investor, genuine financial transfers and relevant Council of State case law.

Following the second major investigation announced on 21 September 2026, we also published a separate article on 26 September 2026 titled:

“The 2026 Turkish Citizenship Cancellation Process Affecting 1,070 Persons.”

That article examined the investigation concerning 263 principal investors and 807 family members in greater detail.

This article complements those two studies and provides an updated guide to the questions that should be asked immediately by any person whose Turkish citizenship has been revoked, whose investment is under investigation, or who suspects that his or her citizenship may be at risk.

WHAT CHANGED IN 2026 AND WHY ARE SO MANY CITIZENSHIP FILES BEING REVIEWED?

Large-scale reviews of Turkish citizenship acquired through investment began receiving significant public attention in 2025.

In an investigation announced on 24 September 2025, transactions involving 451 foreign investors and citizenship acquisitions covering 1,198 persons together with their family members were examined.

Authorities alleged, among other matters, that the required foreign currency had not actually entered Türkiye, fictitious financial transactions had been created, certain real estate sales were sham transactions and some properties had been shown at values exceeding their actual market value.

Publicly announced allegations in that investigation included offences such as establishing an organisation for the purpose of committing crimes, migrant smuggling, laundering of assets derived from crime, aggravated fraud and forgery of private documents.

A further investigation was announced on 4 August 2026 under the coordination of the Organised Crime Investigation Bureau of the Istanbul Chief Public Prosecutor’s Office.

The Ministry of Justice stated that legal proceedings had been initiated concerning the citizenship status of 687 persons in connection with allegations that low-value properties had been shown at substantially higher values through false valuation reports and that Turkish citizenship had been obtained through sham real estate transactions.

Authorities also alleged that approximately TRY 2.5 billion that should have entered Türkiye in connection with these investment transactions had not in fact entered the country.

A second major operation was announced on 21 September 2026.

Authorities stated that real estate sales to 734 foreign nationals had been examined, that 274 sales were considered to be sham transactions, and that 1,070 persons had acquired citizenship when family members were included.

Of these individuals, 263 were principal investors and 807 were family members.

It was also reported that 1,015 persons acquired citizenship at the time of the principal citizenship decisions, while 55 children acquired Turkish citizenship subsequently.

According to the investigating authorities, transactions amounting to USD 72.25 million were considered to involve sham arrangements.

By 25 September 2026, 33 suspects detained in connection with this second investigation had been remanded in custody, while 20 persons were reportedly subjected to judicial control measures requiring them to remain at their residences.

During the same period, the Ministry of Interior announced considerably broader figures.

According to the Ministry, investment eligibility certificates of 1,150 investors had been cancelled in connection with false or irregular valuation reports, and the citizenship decisions concerning those investors and their family members, totalling 5,391 persons, had been cancelled.

In addition, citizenship decisions concerning 263 investors and their family members, totalling 743 persons, were reportedly withdrawn following assessments relating to public order and national security.

The total number announced was therefore 6,134 persons.

It is essential to understand that these figures do not necessarily relate to one investigation, one legal ground, one developer or one group of investors.

Each investor’s individual file must be examined separately.

1. CAN TURKISH CITIZENSHIP BE REVOKED AFTER IT HAS BEEN GRANTED?

Yes.

The fact that Turkish citizenship has already been acquired does not mean that the citizenship decision can never subsequently be reviewed.

Article 31 of Turkish Citizenship Law No. 5901 provides for revocation where citizenship was acquired as a result of a false declaration by the person concerned or the concealment of important matters affecting the acquisition of citizenship.

Article 40 regulates withdrawal of a citizenship decision where it is subsequently established that the legal requirements for acquisition were not actually satisfied or that the decision was issued repetitively.

Revocation and withdrawal are not the same legal mechanism.

One of the first matters that must therefore be determined in a citizenship case is the precise legal basis relied upon by the administration.

2. WHAT IS THE DIFFERENCE BETWEEN REVOCATION OF CITIZENSHIP AND WITHDRAWAL OF THE CITIZENSHIP DECISION?

This distinction is central to the case.

Under Article 31, the principal question is:

Was Turkish citizenship acquired because of the investor’s own false declaration or concealment of an important fact?

Under Article 40, a different question arises:

Were the objective legal conditions for the acquisition of citizenship actually satisfied at the time the citizenship decision was issued?

Accordingly, the absence of fraudulent conduct by the investor does not necessarily resolve every issue that may arise under Article 40.

Conversely, the fact that the objective investment criteria appear to have been satisfied does not necessarily eliminate an Article 31 issue where the investor knowingly relied upon false documentation or misleading declarations.

We discussed this distinction in greater detail in our previous article dated 19 September 2026.

3. HAVE THE CITIZENSHIPS OF ALL 1,070 PERSONS ALREADY BEEN CANCELLED?

The publicly available information should not be interpreted in that manner.

The announcement made on 21 September 2026 stated that 1,070 persons had been identified within the scope of the investigation and that the necessary administrative process concerning their citizenship status had been initiated.

Several stages must therefore be distinguished.

Identification of a person or transaction in a criminal investigation is one stage.

Cancellation of the investment eligibility certificate is another administrative measure.

Revocation or withdrawal of the citizenship decision is a separate administrative act.

Notification of that act to the person concerned is another stage.

Judicial proceedings challenging the administrative measure constitute a further stage.

Therefore, merely learning that an investor may be included among the group of 1,070 persons is not sufficient to determine his or her current legal status.

4. WHAT DOES THE ANNOUNCEMENT CONCERNING 6,134 PERSONS MEAN?

The Ministry of Interior announced that citizenship acquisition decisions concerning a total of 6,134 persons, including investors and their family members, had been cancelled or withdrawn.

Different legal grounds were involved within that overall figure.

According to the publicly announced information, 5,391 persons were affected by cancellation measures associated with investment eligibility certificates and irregularities in the investment process.

A further 743 persons were affected by withdrawal decisions connected with assessments relating to public order and national security.

The figure of 6,134 therefore does not represent one criminal investigation or the customers of one developer.

5. DOES THE EXISTENCE OF A CRIMINAL INVESTIGATION MEAN THAT MY CITIZENSHIP HAS ALREADY BEEN REVOKED?

No.

A criminal investigation and an administrative decision concerning Turkish citizenship are legally separate processes.

However, given the structure of the investigations conducted in 2025 and 2026, learning that an investor or the transaction through which citizenship was obtained is being investigated may be a significant indication that the citizenship file is also being reviewed.

For example, where investigating authorities allege that a particular sale was fictitious, that the investment amount was never genuinely paid, or that the valuation report was inaccurate, those same facts may also become relevant to an administrative citizenship review.

Nevertheless, the existence of a criminal investigation and the existence of an individual administrative decision terminating citizenship must not be treated as the same thing.

Both files should be checked separately.

6. I LIVE ABROAD AND KNOW NOTHING ABOUT THE CASE. COULD THE EXISTENCE OF AN INVESTIGATION INDICATE THAT MY CITIZENSHIP MAY ALREADY HAVE BEEN CANCELLED?

Yes. In the current environment, that possibility should be taken seriously.

A person who has lived abroad for several years, no longer communicates with the former developer or real estate company in Türkiye, and does not actively monitor his or her Turkish address records may remain unaware of administrative and criminal proceedings for a considerable period.

This is particularly relevant where the property, developer, intermediary company or valuation report used in the citizenship application is connected with one of the investigations currently being conducted.

The existence of such a criminal investigation may indicate that an administrative review, revocation procedure or withdrawal procedure has also been initiated in relation to the citizenship file.

However, a possible risk must be distinguished from an actual citizenship decision already issued against the individual.

For a person living abroad, it may therefore be necessary to examine separately:

whether a criminal investigation exists;

the person’s procedural status in that investigation;

the current status of the citizenship file;

the status of the investment eligibility certificate;

whether an individual revocation or withdrawal decision has been issued;

whether such a decision has been served;

and whether there is any arrest warrant, summons, judicial control measure or other restriction relevant to entry into Türkiye.

These checks may be particularly important before booking travel to Türkiye.

7. COULD I BE DETAINED AT THE AIRPORT IF I RETURN TO TÜRKİYE?

The answer cannot be determined from citizenship status alone.

If a criminal investigation exists, it is also necessary to determine whether there is an arrest warrant, detention order, instruction to obtain a statement, judicial control measure, travel restriction or another criminal procedural measure.

If Turkish citizenship has already ceased, the conditions applicable to the individual’s entry into Türkiye as a foreign national may also need to be examined.

Accordingly, at least three separate matters should be reviewed before travel:

the person’s citizenship status;

the criminal investigation and any procedural measures;

and the conditions applicable to entry into Türkiye as a foreign national.

A person living abroad should not rely solely on the fact that a Turkish passport remains physically in his or her possession.

8. WHY CAN A CITIZENSHIP FILE LEAD TO A CRIMINAL INVESTIGATION?

Because the allegations raised in the current investigations are not limited to whether the administrative requirements for citizenship were satisfied.

Investigating authorities have alleged in various files that fictitious financial movements were created, real estate transactions were structured as sham transactions, property values were misrepresented and false or misleading documents were used.

Where authorities allege that a person knowingly participated in such conduct, a criminal investigation may arise independently of the citizenship proceedings.

9. WHICH CRIMINAL OFFENCES MAY BE INVESTIGATED IN CONNECTION WITH CITIZENSHIP-BY-INVESTMENT CASES?

Different criminal allegations have appeared in publicly announced investigations conducted during 2025 and 2026.

Depending on the facts of the individual file, the offences under investigation may include:

establishing, managing or participating in a criminal organisation;

migrant smuggling;

fraud or aggravated fraud, including allegations involving public authorities;

forgery of official documents;

forgery of private documents;

false declaration in the preparation of an official document;

and laundering of assets derived from criminal activity.

The fact that such offences appear in a criminal investigation does not mean that every foreign investor is suspected of all or any of these offences.

Criminal responsibility is personal.

A person who merely purchased a property from a particular developer is not in the same legal position as a person alleged to have knowingly participated in the preparation of false valuation reports or fictitious financial transfers.

The precise conduct attributed to the individual investor must therefore be identified.

10. IF THE DEVELOPER IS UNDER CRIMINAL INVESTIGATION, AM I ALSO A SUSPECT?

That conclusion cannot be drawn merely from the commercial relationship.

A company may have sold properties to hundreds of foreign nationals.

Certain transactions may be alleged to have been irregular while other investors may have genuinely paid the full investment amount.

Indeed, in the second investigation announced on 21 September 2026, authorities stated that 734 foreign purchasers had been examined but referred to 274 sales as allegedly involving sham transactions.

This itself demonstrates that each transaction must be assessed individually.

11. I DID NOT PREPARE THE VALUATION REPORT. CAN MY CITIZENSHIP STILL BE AFFECTED?

The distinction between Articles 31 and 40 is again important.

For Article 31 purposes, the investor’s own false declaration or concealment of important information is highly relevant.

If a valuation report was prepared by an authorised valuation professional and the investor had no knowledge that the report was inaccurate, this may be significant when assessing the investor’s personal conduct.

However, under Article 40, the administration may argue that the objective investment criteria were never actually satisfied when citizenship was granted.

Accordingly, “I did not prepare the valuation report” may be an important part of the defence, but it should not be treated as the entire defence.

The actual historical value of the property must also be examined.

12. CAN THE ACTUAL VALUE OF THE PROPERTY HELP PROTECT MY CITIZENSHIP?

Depending on the facts, it may be extremely important.

Assume, for example, that the applicable citizenship threshold at the time of investment was USD 250,000.

An old valuation report may have stated that the property was worth USD 400,000, but authorities may now allege that the report was inaccurate.

The relevant economic question is then:

What was the real market value of the property on the relevant historical date?

Was it USD 150,000?

USD 280,000?

USD 400,000?

If the genuine historical value exceeded the legal investment threshold applicable at the time, that fact may be important to the legal defence.

For this reason, an independent retrospective valuation may be appropriate in certain cases.

13. DOES TODAY’S USD 400,000 INVESTMENT REQUIREMENT APPLY TO MY OLD CITIZENSHIP APPLICATION?

An old investment file must be examined under the legislation applicable at the time of the investment.

The required investment amount has changed over the years.

A person who acquired citizenship during a period in which the applicable threshold was USD 250,000 should not have the historical investment tested against the present USD 400,000 threshold.

The investment date, title deed date, eligibility certificate date, citizenship application date and citizenship decision date must all be identified.

14. I REALLY SENT THE MONEY THROUGH THE BANK. DOES THIS PROTECT ME?

A genuine bank transfer may be one of the most important pieces of evidence in the investor’s file.

However, one payment receipt may not be sufficient.

The current investigations frequently focus on the economic reality of the entire money flow.

It may therefore be necessary to examine:

the source of the funds;

the transfer from the investor’s account;

the entry of the funds into Türkiye;

payment to the seller;

the date and currency of the transfer;

and whether any part of the funds was subsequently returned directly or indirectly to the investor or a related person.

The legal position of an investor who genuinely paid the investment amount is materially different from that of a person alleged to have knowingly participated in a merely apparent transfer.

15. WHAT IF PART OF THE PURCHASE PRICE WAS LATER RETURNED TO ME?

This may constitute one of the most sensitive issues in the case.

If authorities allege that the required investment amount was transferred only for appearance and that a significant part of the money was subsequently returned pursuant to a prior arrangement, the genuine economic nature of the investment may be questioned.

However, not every repayment has the same legal significance.

The date, amount, purpose, contractual basis and parties involved in any repayment must be examined carefully.

Investors should therefore retain complete bank statements and supporting documentation.

16. I ACTED IN GOOD FAITH. IS THAT ENOUGH?

Good faith may be highly significant, particularly under Article 31.

An investor may have genuinely paid the full investment amount, received no concealed refund, completed the official title deed transaction, relied on a valuation report prepared within the authorised system, obtained an investment eligibility certificate and submitted no false document or false declaration.

That investor is not in the same legal position as a person alleged to have knowingly participated in an artificial citizenship scheme.

Nevertheless, where authorities argue that the objective statutory requirements were never satisfied, Article 40 must also be considered.

17. DOES THE FACT THAT I RECEIVED AN INVESTMENT ELIGIBILITY CERTIFICATE PROTECT ME?

The investment eligibility certificate is an important administrative document.

A foreign investor does not obtain citizenship simply on the basis of his or her own statement.

The investment is examined through official administrative procedures and an eligibility certificate is issued if the competent authority concludes that the statutory investment conditions have been satisfied.

The fact that the investor relied upon an official state-supervised process may therefore be relevant to legal certainty, administrative stability and good faith.

However, the previous issuance of an eligibility certificate does not prevent later administrative review.

It is therefore important to determine whether the eligibility certificate has subsequently been cancelled.

18. IF MY INVESTMENT ELIGIBILITY CERTIFICATE WAS CANCELLED, DOES THAT MEAN MY CITIZENSHIP HAS ALSO BEEN CANCELLED?

The cancellation of an investment eligibility certificate and the revocation or withdrawal of a citizenship decision are legally separate administrative acts.

They may be closely connected, but they are not identical.

The precise sequence of the administrative measures must therefore be established.

19. MY E-GOVERNMENT ACCOUNT STILL WORKS. DOES THAT PROVE THAT I AM STILL A TURKISH CITIZEN?

Not by itself.

Different government databases may not necessarily be updated at precisely the same time.

Access to an e-Government account should therefore not be treated as the sole method of determining current citizenship status.

A person who becomes aware that his or her investment project or developer is involved in a current investigation should consider having the official citizenship status checked separately.

20. I STILL PHYSICALLY HAVE MY TURKISH PASSPORT. DOES THAT MEAN I AM STILL A TURKISH CITIZEN?

The physical possession of a Turkish passport is not, by itself, conclusive evidence of current citizenship status.

This is especially important for investors living abroad.

Before travelling, it may be appropriate to verify both current citizenship status and the status of the passport.

21. WHAT HAPPENS TO MY SPOUSE AND CHILDREN IF MY CITIZENSHIP IS REVOKED?

Article 32 of Turkish Citizenship Law provides that a revocation decision may also affect a spouse and children who acquired Turkish citizenship in connection with the person concerned.

However, the legal basis and date on which each family member acquired citizenship should be examined separately.

The investigation announced on 21 September 2026 involved 263 principal investors and 807 family members.

It was also reported that 55 children acquired citizenship after the original citizenship decisions had already been issued.

The legal position of children born or registered subsequently may therefore require separate analysis.

22. IF MY CITIZENSHIP IS REVOKED, WILL I LOSE MY PROPERTY IN TÜRKİYE?

Loss of citizenship and loss of ownership of real estate are not the same legal event.

Article 33 of Turkish Citizenship Law contains special provisions concerning the liquidation of property belonging to persons whose citizenship has been revoked.

Where liquidation of assets is considered necessary, this is required to be stated in the relevant decision.

The law also provides that where the person challenges the revocation decision before the courts, liquidation of the assets is postponed until the conclusion of the proceedings.

Accordingly, no reliable conclusion concerning the property should be reached without examining the full wording of the administrative decision.

23. CAN I FILE A LAWSUIT AGAINST THE REVOCATION OR WITHDRAWAL OF MY TURKISH CITIZENSHIP?

Yes.

A decision revoking citizenship or withdrawing the citizenship acquisition decision is an administrative act and is subject to judicial review.

The competent court depends on the authority that issued the challenged decision.

Certain citizenship decisions issued by the President may fall within the jurisdiction of the Council of State acting as the court of first instance.

It should also be remembered that cancellation of an investment eligibility certificate and termination of citizenship may constitute separate administrative measures.

In some cases, more than one administrative act therefore needs to be examined.

24. HOW LONG DO I HAVE TO FILE A CITIZENSHIP CANCELLATION CASE?

Where no special period is prescribed, the general time limit for administrative proceedings before administrative courts and the Council of State is ordinarily 60 days.

The period generally begins on the day following written notification.

However, the method of service, the authority issuing the decision, any prior administrative application and the specific administrative act being challenged may affect the calculation.

A person who has received a citizenship decision should therefore not calculate the litigation deadline on assumptions.

25. CAN I REQUEST A STAY OF EXECUTION IN A CITIZENSHIP CASE?

Yes, where the statutory requirements are satisfied.

Loss of citizenship may affect the person’s passport, ability to enter Türkiye, family life, companies, bank relationships, real estate and other legal interests.

For that reason, an application for a stay of execution should identify the concrete consequences that the administrative act creates for the individual concerned.

Filing a lawsuit does not by itself suspend the implementation of the administrative decision.

26. CAN A LAWYER CHECK WHETHER THERE IS A CRIMINAL INVESTIGATION AGAINST ME?

Yes, although the criminal investigation and the citizenship file must be examined through different channels.

In relation to the criminal file, it may first be necessary to determine:

the competent Chief Public Prosecutor’s Office;

the investigation number;

the person’s procedural status;

the offences under investigation;

and whether any criminal procedural measure exists.

The citizenship file should separately be examined through the Directorate General of Population and Citizenship Affairs and other relevant administrative records.

Information found in one file does not necessarily establish the status of the other.

27. CAN A LAWYER INSPECT A CRIMINAL INVESTIGATION FILE WITHOUT A POWER OF ATTORNEY?

This question is particularly important for persons living abroad who have not yet issued a Turkish power of attorney.

Article 2 of the Attorneys’ Act No. 1136 provides that judicial authorities, law-enforcement authorities and other public institutions are, subject to specific statutory restrictions, required to make available to lawyers the information and documents needed for the performance of their professional duties.

Obtaining copies of documents may require presentation of a power of attorney.

Article 46 of the Attorneys’ Act also provides that a lawyer or trainee lawyer may inspect court and enforcement files without submitting a power of attorney, while copies of documents are not provided to a lawyer who has not produced the relevant authority.

In the context of criminal investigations, the Union of Turkish Bar Associations published Notice No. 2019/32 dated 10 April 2019 referring to a judicial decision confirming that a lawyer may inspect an investigation file without a power of attorney, formal appointment document or written or oral consent from a party to the investigation.

An earlier Notice No. 2019/23 also addressed procedures applicable where a lawyer does not yet have a power of attorney or UYAP registration and seeks to inspect an investigation file after identifying the party concerned and presenting professional identification.

Accordingly, the fact that a person living abroad has not yet issued a power of attorney does not necessarily mean that no preliminary investigation of the criminal file can be undertaken.

However, full and continuing access to the file, obtaining copies, making applications on behalf of the person, accessing the file continuously through UYAP and performing comprehensive defence work may require the establishment of a formal attorney-client representation.

28. IF THERE IS A RESTRICTION ORDER IN THE CRIMINAL FILE, DOES THAT MEAN THE LAWYER CANNOT SEE ANYTHING?

No.

Under Article 153 of the Turkish Code of Criminal Procedure, where access to the investigation file would jeopardise the purpose of the investigation, a judge may restrict file inspection upon the request of the public prosecutor in cases permitted by law.

However, even where such a restriction exists, certain materials remain outside the restriction, including the statement of the arrested person or suspect, expert reports and records of judicial acts at which the suspect is entitled to be present.

This distinction may be particularly important in citizenship-related investigations because expert reports may contain key findings concerning property valuations and financial transactions.

29. CAN A LAWYER INSPECT MY CITIZENSHIP FILE WITHOUT A POWER OF ATTORNEY?

The criminal investigation and the administrative citizenship file must again be distinguished.

Article 2 of the Attorneys’ Act provides a general basis for lawyers to request access to information and documents needed for professional duties, subject to special statutory restrictions.

Obtaining copies generally requires presentation of authority.

Citizenship files, however, may contain personal data, security assessments and information specific to the individual.

For this reason, special legislation and the practice of the relevant administrative authority must also be considered.

In practice, certain information may potentially be reviewed or preliminary enquiries may be made without a power of attorney.

However, obtaining complete copies of the individual’s citizenship file, making formal applications on behalf of the person, requesting official records or performing transactions concerning population registers may require a valid power of attorney.

Accordingly, a power of attorney becomes particularly important where an official confirmation of citizenship status or formal action before the Population and Citizenship authorities is required.

30. I AM ABROAD. WHAT CAN A LAWYER CHECK BEFORE I ISSUE A POWER OF ATTORNEY?

The answer depends on the type of case.

In relation to a criminal investigation, it may be possible to identify the relevant investigation and inspect accessible portions of the file within the limits of Turkish law.

Under Article 2 of the Attorneys’ Act, access to information and documents held by public institutions may also be requested where legally permissible.

Existing court or enforcement files may be physically inspected without a power of attorney.

Publicly available information concerning investigations, companies and projects may be examined.

It may also be possible to determine whether the person’s transaction appears to be connected with a publicly announced investigation.

However, making formal applications on behalf of the client, obtaining official copies, filing an administrative case, conducting formal transactions before population authorities or undertaking comprehensive defence work in a criminal investigation may require a power of attorney.

For a client living abroad, the work may therefore proceed in two stages:

first, preliminary identification of the investigation and the immediate legal risks;

second, full representation under a power of attorney where required.

31. CAN A STATEMENT TO THE PROSECUTOR OR POLICE BE ARRANGED BEFORE I TRAVEL TO TÜRKİYE?

Depending on the stage of the investigation, contact may be established with the public prosecutor or the law-enforcement unit conducting the investigation in order to clarify or plan the taking of a statement.

However, the position is different where an arrest warrant or another coercive measure has already been issued.

The current procedural status should therefore be checked before travel arrangements are finalised.

32. CAN I FIND OUT IN ADVANCE WHETHER THERE IS AN ARREST WARRANT AGAINST ME?

Depending on the accessible portions of the investigation file and the nature of the proceedings, relevant information may be investigated.

However, the confidentiality of criminal investigations, access restrictions and the nature of law-enforcement measures may mean that not every piece of information is available at every stage.

For this reason, reliance solely on an e-Government screen may be insufficient.

The criminal investigation should be examined separately by a lawyer.

33. WHAT IF MY CITIZENSHIP WAS CANCELLED BUT I NEVER RECEIVED ANY NOTIFICATION?

The first issue is to determine whether an individual decision actually exists.

If a decision has been issued, the following questions become important:

when was it issued;

to which address was it sent;

how was service attempted;

what procedure was followed for a person living abroad;

and when did the person actually become aware of the decision?

These issues may directly affect the calculation of the litigation period.

In such cases, the service documents may be as important as the citizenship decision itself.

34. WHAT SHOULD I DO IF THE AUTHORITIES SAY MY CITIZENSHIP HAS BEEN CANCELLED BUT E-GOVERNMENT STILL SHOWS ME AS A TURKISH CITIZEN?

Where there is a conflict between different sources of information, the formal administrative decision and official population records should be examined together.

A person should not rely solely upon a digital screenshot before undertaking important legal actions such as international travel, passport renewal, title deed transactions or entry into Türkiye.

35. I GAVE UP MY PREVIOUS NATIONALITY. COULD I BECOME STATELESS IF TURKISH CITIZENSHIP IS REVOKED?

This question must be examined not only under Turkish citizenship law but also under the nationality law of the person’s former country.

Some investors relinquished their previous citizenship after acquiring Turkish citizenship, while others may have lost their former citizenship under the law of their country of origin.

If Turkish citizenship is subsequently terminated, it is necessary to determine whether the person currently possesses another nationality.

The possibility of statelessness may make the case more complex from the perspective of both immigration law and international law.

36. IF MY TURKISH CITIZENSHIP IS TERMINATED, CAN I REMAIN IN TÜRKİYE?

If citizenship ceases, the legal basis for the person’s continued presence in Türkiye must be examined separately.

Relevant factors may include the person’s previous nationality, passport status, residence rights, family connections, employment, property ownership and other legal ties with Türkiye.

The citizenship proceedings and immigration-law consequences should therefore be assessed together.

37. CAN I SUE THE DEVELOPER OR INTERMEDIARY IF MY CITIZENSHIP IS CANCELLED?

Depending on the circumstances, yes.

If the seller, developer or intermediary expressly represented that the property qualified for Turkish citizenship, the investor relied upon that representation, and it later emerges that the property or supporting documents did not satisfy the relevant requirements, contractual and compensation claims may arise.

A citizenship cancellation case and a private-law claim against the developer, seller, intermediary or other responsible party are separate proceedings.

38. WHAT ARE THE MOST IMPORTANT DOCUMENTS IN A CITIZENSHIP REVOCATION CASE?

A citizenship case should not be analysed solely by looking at the citizenship decision.

The initial review may require, among other documents:

citizenship acquisition documents and subsequent administrative decisions;

Turkish identity and passport records;

title deeds;

real estate sale agreements;

property valuation reports;

the investment eligibility certificate;

bank payment receipts;

SWIFT records and account statements;

foreign currency purchase or transfer documents;

communications with the seller, developer or intermediaries;

invoices and payment receipts;

citizenship application documents;

citizenship records of the spouse and children;

and any document received from the police, public prosecutor or court.

In many cases, a complete legal assessment cannot be made by examining only the title deed or only the valuation report.

39. MY CITIZENSHIP HAS NOT BEEN CANCELLED, BUT MY PROJECT IS UNDER INVESTIGATION. WHAT SHOULD I DO NOW?

Evidence should be preserved before any decision is issued.

Old bank statements, SWIFT records, valuation reports, sale agreements, eligibility certificates and communications with the developer may become more difficult to obtain as time passes.

A person who believes that a genuine investment was made should therefore consider creating a complete personal citizenship file in advance.

Where appropriate, the historical market value of the property may also be examined before any litigation begins.

40. I SAW MY NAME ON A SOCIAL-MEDIA LIST. DOES THAT MEAN MY CITIZENSHIP HAS BEEN CANCELLED?

A social-media list does not, by itself, establish the person’s legal status.

There is no publicly released official list containing the names of all 1,070 persons referred to in the investigation announced on 21 September 2026.

A person should therefore not rely upon an unofficial internet list.

The individual citizenship file and any criminal investigation should be checked through official channels.

41. CAN I WIN A TURKISH CITIZENSHIP REVOCATION CASE?

A reliable legal assessment cannot be made without reviewing the individual file.

However, there can be substantial differences between cases.

An investor who genuinely paid the full investment amount from his or her own funds, received no concealed refund, acquired the property through a real transaction, purchased a property whose actual value met the investment threshold applicable at the time, relied on the official valuation system, obtained an eligibility certificate, submitted no false documents and made no false declarations is not in the same legal position as a person alleged to have knowingly participated in a sham arrangement.

The purpose of the legal defence should therefore not be limited to making a general statement of “good faith.”

The investor’s own transaction, own money flow, own property and own conduct should be documented and analysed individually.

42. HOW DO WE REVIEW A TURKISH CITIZENSHIP REVOCATION CASE?

A proper citizenship review requires more than examining a single administrative decision.

First, the date and legal basis on which citizenship was acquired must be established.

The legislation applicable at the time of investment must then be identified.

The title deed, sale agreement, valuation report, eligibility certificate and citizenship application documents should be examined.

The genuine money flow from the investor’s source account to the seller should be reconstructed.

It should be determined whether any part of the money returned directly or indirectly to the investor after the sale.

Where necessary, the actual historical value of the property should be reassessed.

If the developer, seller, valuation company or intermediary is involved in a criminal investigation, the investor’s individual position in that investigation should be determined.

If the investor personally appears in a criminal investigation, the alleged offence and the evidence relating specifically to that investor should be examined.

The status of the investment eligibility certificate and citizenship decision should then be established.

Where a revocation or withdrawal decision exists, its legal basis, date, service and litigation deadline should be checked.

For clients living abroad, possible risks relating to entry into Türkiye, criminal procedure and immigration law should also be assessed.

Until this analysis has been completed, it is difficult to provide a reliable legal opinion on the appropriate litigation strategy or the legal position of the individual investor.

CRIMINAL INVESTIGATION AND CITIZENSHIP PROCEEDINGS MAY NEED TO BE REVIEWED TOGETHER

The files emerging in 2026 should no longer be viewed solely as conventional citizenship-law disputes.

Current investigations may involve expert reports, MASAK financial analyses, banking records, title deed records, valuation reports and corporate relationships.

For some investors, two separate questions therefore need to be answered:

First:

Does the person’s Turkish citizenship legally continue, and what administrative action has been taken in the citizenship file?

Second:

In the criminal investigation, is the person merely an investor whose transaction is being reviewed, a witness or person with information, an alleged victim, or a suspect?

These are separate questions and neither can replace the other.

SPECIAL WARNING FOR INVESTORS LIVING OUTSIDE TÜRKİYE

The position may be particularly sensitive for investors who live abroad and have not travelled to Türkiye for several years.

The individual may never have seen a notification.

The Turkish telephone number previously used may no longer be active.

The registered address may be outdated.

The person may not have communicated with the developer or intermediary company for years.

The person may have no knowledge of a criminal investigation.

The person may not know that the citizenship file has been reopened for administrative review.

In such circumstances, it may be appropriate to examine both the citizenship status and the criminal investigation before travelling to Türkiye.

This is particularly important for persons who purchased real estate from projects, companies or intermediaries now appearing in current investigations.

TD LAW FIRM – TURKISH CITIZENSHIP REVOCATION AND CRIMINAL INVESTIGATION FILE REVIEW

TD Law Firm advises on matters involving revocation and withdrawal of Turkish citizenship acquired through investment, cancellation of investment eligibility certificates, allegations concerning false or inaccurate valuation reports, sham transactions and financial transfers, criminal investigations involving foreign investors and legal risks associated with entry into Türkiye.

For clients living abroad, where legally possible, an initial review may be conducted to identify the relevant investigation and the immediate legal position before determining which documents or formal power of attorney arrangements are required for the next stage.

For an initial assessment, it is useful to provide:

the year in which Turkish citizenship was acquired;

the project or company through which the investment was made;

property information;

any available citizenship documents;

the valuation report;

the investment eligibility certificate;

and bank payment records.

Av. Murat Can Dolğun
Istanbul Bar Association – Registration No. 75860
TD Law Firm

Office: +90 212 299 44 22
WhatsApp / Mobile: +90 507 475 44 22
Email: av.muratcandolgun@gmail.com
Website: dolgun.av.tr

Address: Istanbul World Trade Center (IDTM), A2 Block, Floor 5, No. 206, Yeşilköy Mah., Atatürk Cad., Bakırköy / Istanbul, Türkiye

OUR PREVIOUS ARTICLES

19 September 2026

“Revocation and Withdrawal of Turkish Citizenship Acquired Through Investment: False Valuation Reports, Sham Transactions, Good-Faith Investors and Judicial Protection.”

This article examines in detail the distinction between Articles 31 and 40 of Turkish Citizenship Law, good-faith investors, retrospective property valuation, administrative stability, legal certainty and relevant Council of State case law.

Available on dolgun.av.tr.

26 September 2026

“The 2026 Turkish Citizenship Cancellation Process Affecting 1,070 Persons.”

This article examines the investigation announced on 21 September 2026, including 263 investors, 807 family members, 274 allegedly sham property sales, valuation issues and financial transactions.

Available on dolgun.av.tr.

LEGAL NOTICE

This article has been prepared for general legal information purposes based on publicly available official announcements, legislation, accessible judicial decisions and publicly reported developments as of 28 September 2026.

References to “false valuation reports,” “sham transactions,” “irregular citizenship,” “criminal organisation,” “fraud,” “forgery” or similar expressions in relation to ongoing criminal investigations refer to allegations and assessments publicly attributed to the investigating authorities.

The existence of a criminal investigation, detention or remand decision does not constitute a final criminal conviction.

The presumption of innocence applies unless and until a final judgment of conviction is rendered.

The existence of a criminal investigation concerning a company, developer or valuation professional does not mean that every investor who dealt with that person or company is in the same legal position.

Similarly, the fact that an investor is not a criminal suspect does not by itself establish that all objective statutory requirements for the acquisition of Turkish citizenship were satisfied.

Every citizenship case should be examined individually by reference to the date of investment, the legislation applicable at that time, the genuine value of the property, financial transfers, the investor’s personal conduct, the investment eligibility certificate, the citizenship file, any related criminal investigation and the individual administrative decision issued in respect of the person concerned.

This article does not constitute a guarantee of outcome or an individual legal opinion concerning any particular person or dispute.