Turkish authorities have identified 1,070 more people they say acquired citizenship through fictitious real estate purchases, and have opened administrative proceedings to revoke it, Justice Minister Akın Gürlek announced on Monday.
The second wave of an Istanbul-centered investigation into sham sales under the country’s citizenship by investment (CBI) program produced 72 detentions and placed 30 companies under court-appointed trustees.
Police examined sales by three developers, Gül İnşaat, Beyaz İnşaat, and LİV İnşaat, reviewing purchases by 734 foreign nationals and classifying 274 of the transactions as collusive.
Those sales made citizens of 1,070 people once family members were counted, while 11 applicants were still in the pipeline when officers moved.
Gürlek put the value of the collusive transactions at more than TL 3.5 billion (approximately $72 million). Prosecutors opened proceedings against 88 suspects, and precautionary measures now cover 2,011 properties, a hotel, 86 vehicles, two yachts, and 42 bank accounts.
He framed the raid as part of a continuing campaign, pledged under President Recep Tayyip Erdoğan’s leadership, against structures that abuse citizenship law and mislead public institutions through forgery.
Second Wave of the Same File
The first wave, carried out in August, targeted transactions linked to developer Babacan İnşaat, in which low-value properties were dressed up with inflated appraisal reports, and found that 687 people had gained citizenship as a result. It also produced 72 detentions across 16 provinces.
At the time, Gürlek estimated that approximately TL 2.5 billion (approximately $52.6 million) that should have entered Turkey through the investment process never arrived.
Seizures ran to 1,045 properties, a hotel in Bodrum, 15 vehicles, a yacht, and 10 bank accounts, with seven companies handed to trustees. On nearly every measure, the second wave outstrips the first.
The same day as that first raid, the Interior Ministry disclosed that it had cancelled or withdrawn the citizenship of 6,134 people program-wide. That figure combined 5,391 people tied to 1,150 investors who completed collusive transactions with 743 people tied to 263 investors flagged on public order and national security grounds after naturalization.
The thread runs back to September 2025, when police dismantled a network that had arranged fictitious sales for 451 investors, arresting 106 suspects across 19 provinces.
The two prosecutor-led waves alone now cover 1,757 people, on top of the 6,134 citizenships the ministry had already cancelled by early August; how far those sets overlap has not been clarified.
274 Sales, 1,070 Citizens
Güvenç Ketenci, managing partner at Istanbul-based Ketenci & Ketenci, cautions against reading the headline figure as more than a thousand separate fraudulent investments.
Probes of this kind, he tells IMI, tend to involve “organized structures in which the same developers, intermediaries, valuation practices or transaction mechanisms are used repeatedly,” while a single qualifying purchase can naturalize an entire family.
He reads the crackdown as good news for the program rather than a threat to it. Authorities are pursuing manipulated transactions, not the program’s legitimacy, and their readiness to revisit historical files shows “that compliance does not necessarily end when citizenship is granted.”
Enforcement of this nature, he argues, should ultimately leave the program “stronger, more transparent and more credible internationally.”
Investors who made their investments through genuine, properly valued, and fully documented transactions should see no cause for concern in the investigations, in his assessment.
Separating them from those who tried to circumvent the rules is, in his words, “essential to the sustainability of the program.”
Fraud Is Not the Only Ground
Not every revocation on the books stems from sham sales. Among August’s cumulative figures were 263 principal applicants flagged by police and the National Intelligence Organization (MİT) on public order and national security grounds after naturalization, with no fraud alleged against their investments.
Files of that nature, reasons Aran Hawker, co-founder at CIP Turkey, come down to national security concerns or to external regulators, such as the Financial Action Task Force (FATF), raising issues with Ankara down the line.
Even then, Turkey gives those investors “the opportunity to exit their investment and not lose their money,” which he sees as “a lot better than circumstances on other programs.”
His advice to applicants is to be forthcoming with their lawyers from the start. “Honesty is the best policy,” in his telling, because counsel who know the full picture can flag a refusal or revocation risk before a file is ever submitted.
Filling the Due Diligence Gap
Hawker explains that unlike the private firms that dominate compliance practice in the market, the Turkish government “doesn’t use any external third-party due diligence providers.”
His firm is preparing to close that gap from the client side, partnering with an external provider to commission independent due diligence reports on its own applicants and file them with the government, “so that no one can come to you later and say that you didn’t provide all of the information.”
Ketenci’s prescription operates further upstream. A citizenship-linked purchase “should be approached first and foremost as a substantial cross-border investment,” with due diligence on the property, the seller, the valuation, and the transaction structure.
Above all, he urges applicants to appoint independent Turkish counsel “who represents the investor alone,” rather than relying on the developer, sales intermediary, or citizenship agent to arrange the deal.
The Program Today
Turkey launched CBI in 2017 with a $1 million real estate threshold, cut it to $250,000 in September 2018, and raised it to $400,000 in June 2022, where it remains.
Real estate dominates uptake, though a $500,000 bank deposit, fixed-capital investment, or fund subscription also qualifies, each held for at least three years.
The valuation loopholes these networks exploited have since been sealed. Citizenship appraisals moved to a single state-owned valuation company in March 2024, and since December 2024, the document certifying a property’s investment value is generated by the land registry’s own system and recorded directly, with paper versions no longer accepted.
