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Payment and E-Money Institution Liability in Investment Fraud

Savun Law & Consultancy · Updated 30 October 2026

Payment and E-Money Institution Liability in Investment Fraud

In investment fraud, the money is often transferred through payment and electronic money institutions. The obligations of these institutions are an important part of the process. The subject is covered below for information purposes.

⚖️ Obligations

Payment and electronic money institutions are subject, under the legislation, to obligations such as know-your-customer (KYC) checks, suspicious transaction reporting and record keeping. A breach of these obligations may bring up a liability assessment, depending on each case.

Summary: Payment intermediaries are subject to KYC, suspicious transaction reporting and record keeping obligations.

🔍 Tracing the Money

For the victim, establishing which accounts the money was transferred to, and requests for a MASAK report and account freezeTR, are important.

🛡️ From the Victim's Perspective

Preserving the transfer records and running the process quickly matter for the prospects of a refund.

❓ Frequently Asked Questions

What are the obligations of a payment institution?

They have legal obligations such as KYC, suspicious transaction reporting and record keeping.

Can the institution be held liable?

Where an obligation has been breached, liability is assessed according to each case.

How is the money trail followed?

The accounts are identified from the transfer records; a MASAK report or an account freeze may be requested.

What should I do?

The transfer records are preserved and the process is started quickly.

For detailed information and legal support, you can contact Savun Law & Consultancy.

The information in this article is for general information purposes only and may vary according to current legislation. Every case is unique.

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This page is an English adaptation of our Turkish article Ödeme ve Elektronik Para Kuruluşunun Sorumluluğu.

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