Enforcing a Foreign Money Judgment Against Assets in Türkiye

To enforce a foreign money judgment against assets in Türkiye, the creditor usually needs a Turkish enforcement judgment first. After enforcement is granted, the creditor can proceed through Turkish enforcement offices against attachable assets such as bank accounts, receivables, vehicles, equipment or real estate.

A foreign money judgment is a court decision ordering one party to pay a sum of money. In Türkiye, the judgment does not operate like a domestic enforcement title until it satisfies the recognition and enforcement requirements under Turkish law.

Law No. 5718 governs the enforcement of foreign court judgments. Once enforcement is granted, the Enforcement and Bankruptcy Law No. 2004 governs execution against assets. Depending on the debtor and transaction, the Turkish Commercial Code and Code of Obligations may be relevant to interest, company status and related claims.

Court practice is formal at the enforcement stage and practical at the execution stage. First, the court asks whether the foreign judgment can be enforced. Then the enforcement office asks what assets can be attached. A court victory without asset information may not produce recovery. This section deliberately avoids invented case numbers. Where a case-specific filing relies on precedent, the relevant Court of Cassation, regional appellate court or Constitutional Court materials should be checked against the current file and date of publication.

The tension is between judgment portability and national procedural safeguards. Turkish law does not re-litigate the foreign merits, but it does protect jurisdictional limits, defence rights and public order. Creditors often underestimate this gatekeeping role.

The creditor must produce the judgment, finality proof, required certifications, translations and debtor details. The judgment must be clear enough to identify the amount, parties and obligation. If the judgment includes interest, costs or foreign currency, enforceability and calculation must be handled carefully.

There is no reason to wait after finality if the debtor has assets in Türkiye. Asset dissipation risk is real. Limitation and enforcement periods must be checked under the judgment's law and Turkish rules, especially where years have passed since the foreign decision.

The enforcement action is filed in the competent court under Law No. 5718. After a positive decision, enforcement offices handle execution according to the asset location and enforcement rules.

In addition to the judgment package, useful enforcement evidence includes Turkish company registry data, real estate information, vehicle data, known bank relationships, receivables, contracts with Turkish customers and previous correspondence about assets.

The enforcement claim and the collection strategy should be designed together. If the debtor is a Turkish company with active receivables, bank accounts or machinery, the approach differs from a dormant company with no known operations.

Common mistakes include treating enforcement as a paperwork exercise, failing to investigate assets, omitting interest calculations, filing translations that do not match the judgment and assuming that the Turkish court will correct defects in foreign documents.

Can assets be attached before enforcement is final?

Protective measures may be considered in suitable cases, but the threshold and risks must be assessed separately.

Can a judgment in foreign currency be enforced?

It may be possible, but currency, interest and conversion issues must be reviewed.

Will the debtor be heard?

Yes. The debtor may raise objections permitted under Turkish recognition and enforcement rules.

For creditors, the real question is not 'Can the judgment be recognised?' but 'Can this judgment be turned into money in Türkiye?' Those are connected but not identical questions.

The correct legal route in these matters must be determined by reference to the date of the events, the legal position of the parties, the available evidence and the applicable statutory deadlines. Missing a deadline, applying to the wrong authority or presenting evidence in the wrong procedural form may cause loss of rights. You may contact Günser + Partners for an assessment of your matter under current Turkish legislation and court practice.