Your Account Has Been Frozen: A Legal Roadmap for P2P and MASAK Blocks

"I sold USDT on P2P, and the next day my bank account was frozen." As crypto transactions have increased in Turkey in 2026, this sentence is heard ever more frequently. Even when you have conducted a legitimate transaction, your account may be blocked under MASAK due to the counterparty's suspicious history. In this article, we examine the legal roadmap to follow in such a situation and the critically important "what not to do" points.

Why Does a P2P Transaction Lead to an Account Block?

In P2P (peer-to-peer) crypto trading, if the source of funds of the person who transfers money to you in exchange for USDT is suspicious, the problem can spread directly to you. The typical scenario: a fraudster transfers money obtained from a victim to your IBAN and receives USDT in return. When the victim files a complaint, your account — as the last stop the money passed through — becomes part of the investigation and may be blocked.

A block can come through various channels:

• MASAK notification: Under Law No. 5549 Article 19/A, accounts may be frozen for up to six months.
• Bank-initiated suspicious transaction report: High-value and frequently recurring TL withdrawals from crypto exchanges can prompt banks to file automatic suspicious transaction reports.
• Prosecutorial instruction: Within an investigation, the prosecutor's office may request a measure on the account.

The Good News: Legitimate P2P Trading Is Not a Crime

Crypto trading and P2P transactions are legal activities in Turkey. Court of Cassation precedents accept that crypto asset trading does not, on its own, constitute money laundering, and that P2P trading can be a legitimate commercial activity. What constitutes a crime is knowingly facilitating proceeds of crime or turning a blind eye to it.

The First 24 Hours: What to Do When Your Account Is Frozen

• Find out the source of the block: Request from the bank, in writing, on whose instruction and within which case file the block was imposed.
• Secure the evidence: P2P order screenshots, the counterparty's KYC information, the USDT transaction ID (TxID), the bank transfer receipt, any chat records and the reference code in the description field. This evidence shifts the burden of proof to the other side.
• Digital evidence preservation: Recording digital evidence through notary determination under CMK Article 134 creates a strong basis for later.
• Consult an expert lawyer: Early contact with a lawyer experienced in crypto law is critical to managing the process correctly.

What You Must Absolutely Not Do

• Do not delete evidence or reset devices
• Do not try to close the matter by "settling" with the counterparty and sending the money back — this may be interpreted as an admission of guilt
• If summoned by the prosecutor's office, do not give a statement without your lawyer

Lifting the Block: The Legal Process

The path to follow depends on the source of the block:

• MASAK/prosecutor-initiated block: A petition demonstrating that you have no organic connection to the source of funds, together with an on-chain analysis report, can be submitted to the prosecutor's office. An appeal to the Criminal Judgeship of Peace is available.
• Bank-initiated block: If the bank does not respond positively to your objection within the statutory waiting period, a negative declaratory / objection action may be filed at the Commercial Court of First Instance. A request for an interim injunction can prevent the block period from being extended.
• Documentary support: Bank account statements for the last 1–3 years should be submitted to demonstrate your income-expenditure balance and the legitimacy of your transactions.

The Constitutional Court's Approach to Property Rights

The Constitutional Court has held that disproportionate and prolonged account freezing measures may infringe the right to property. This approach provides an important basis for objecting to blocks that exceed a reasonable period. A block is a precautionary measure; sustaining it indefinitely and disproportionately is legally questionable.

Preventive Measures: When Doing P2P

• Only transact through licensed platforms that apply KYC
• Use the description/reference code in full in every transaction
• Keep the counterparty's KYC information and all correspondence
• Be wary of counterparties offering unusually high prices
• Keep your transaction volume and frequency at a level explainable by your income profile