MASAK (the Financial Crimes Investigation Board) is the authority that administratively reviews financial activity reported through suspicious transaction notifications and, where warranted, refers the file to the public prosecutor’s office. This process is governed by Law No. 5549 on the Prevention of Laundering Proceeds of Crime and is an administrative stage that precedes any criminal investigation. MASAK itself does not impose penalties; it forwards its findings to the relevant authorities.
What This Area Covers
Suspicious transaction reporting
The obligation of banks and financial institutions to report transactions they consider suspicious to MASAK.
MASAK's preliminary review
Examination of the reported transaction using financial analysis methods.
Requests for information and documents
MASAK requesting account records and documents from the relevant person or institution.
Assessment of a laundering suspicion
Evaluating whether the transaction shows signs of an attempt to present proceeds of crime as legitimate.
Referral to the public prosecutor's office
MASAK forwarding the file for a criminal investigation if its review finds sufficient grounds.
Process Steps
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01
Receipt of the notification
The process begins when a financial institution reports a transaction it considers suspicious to MASAK.
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02
Administrative preliminary review
MASAK evaluates the notification using its own analytical methods; this stage is administrative, not a criminal investigation.
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03
In-depth review (if needed)
Files found to warrant it at the preliminary stage undergo more detailed financial analysis.
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04
Conclusion
MASAK closes the file if no grounds are found; if grounds are found, it forwards the file to the public prosecutor's office for a criminal investigation.
MASAK versus the Financial Crimes Bureau
These two bodies are often confused, but they operate at different stages. MASAK is an administrative board under the Ministry of Treasury and Finance; it has no law-enforcement powers and cannot directly detain or search anyone. The Financial Crimes Bureau, by contrast, is a law-enforcement unit that carries out classic criminal-investigation procedures — taking statements, conducting searches, and seizing assets — on the instructions of the public prosecutor's office. MASAK's administrative review generally comes before the Bureau's investigation; once MASAK identifies grounds and refers a file to the prosecutor's office, the prosecutor's office often conducts the resulting investigation through the Financial Crimes Bureau.
| MASAK | Financial Crimes Bureau | |
|---|---|---|
| Nature | Administrative board | Law-enforcement unit |
| Powers | Financial analysis, requests for information/documents | Taking statements, searches, seizure |
| Reports to | Ministry of Treasury and Finance | Instructions of the public prosecutor's office |
| Nature of the process | Not a criminal investigation | Part of a criminal investigation |
The Lawyer's Role
During the MASAK stage, the lawyer's work generally involves assessing how to respond to a request for information or documents and organizing the financial justification for the transactions in question; at this stage there is not yet a "suspect," so what takes place is an administrative explanation process rather than a defense in the criminal-procedure sense. Once the file reaches the prosecutor's office, the process turns into a criminal investigation, and from that point the general framework described on the Criminal Proceedings page applies.
A situation often encountered in practice is a single large transfer arriving from abroad becoming subject to a report; even if the source of the transfer is legitimate, this can still lead MASAK to examine the transaction. Supporting the source with documents — such as a sale agreement, inheritance documents, or a commercial invoice — helps the review conclude more quickly.
- Suspicious transaction report
- A notification a financial institution files with MASAK when it has reasonable grounds to suspect a transaction may be linked to proceeds of crime.
- Laundering
- An attempt to present assets obtained from an offense as though they came from a legitimate source.
Situations Frequently Encountered
A single large transfer from abroad
Large transfers with an undocumented source can become subject to a report.
Heavy cash activity through company accounts
Cash volume that appears inconsistent with the nature of a business's commercial activity can trigger a review.
Buying and selling crypto assets
Transactions involving crypto assets can also fall within MASAK's area of review.
Not responding to a request for information
Failing to provide the information and documents MASAK requests affects the administrative dimension of the process.
Transactions carried out on behalf of a third party
An account being used on behalf of, or for the benefit of, someone else can become a separate subject of review.
Legal Basis
Law No. 5549 on the Prevention of Laundering Proceeds of Crime
Sets out MASAK's duties and powers and the suspicious transaction reporting obligation.
Frequently Asked Questions
No, MASAK is an administrative board and does not impose penalties directly; it forwards its findings to the relevant authorities.
The reporting process is confidential; the person usually becomes aware of it through a request for information or documents.
No, if the review does not find sufficient grounds, the file can be closed at this stage.
Yes, crypto asset service providers are also among the institutions subject to the reporting obligation.
No, but a large, seemingly undocumented transfer can become subject to review; documenting the source makes the process easier.
Banks, financial institutions, and other obliged parties listed in the law are responsible for filing these reports.
No, MASAK's administrative review and the criminal investigation carried out by the Financial Crimes Bureau are separate processes; the latter can begin once MASAK refers the file.
Summary of This Page
- MASAK is an administrative board with no law-enforcement powers and does not impose penalties directly.
- Suspicious transaction reporting is a legal obligation for banks and financial institutions.
- MASAK's review and a Financial Crimes Bureau investigation are different stages; if MASAK finds grounds, the file goes to the prosecutor's office and typically on to the Bureau.
- Large transfers with an undocumented source carry a higher risk of being reviewed.
Related Topics
Last updated: 14.08.2026
Legal processes are carried out by independent lawyers. This page is for informational purposes and does not constitute legal advice.