Enforcing a Foreign Judgment Against Assets in Türkiye

You won abroad. Now you need that win to actually count in Türkiye (Turkey) — against real bank accounts, receivables, and property. A foreign judgment is not automatically valid here: first a Turkish court must enforce it (a step called tenfizTenfizEnforcement of a foreign judgment in TürkiyeThe Turkish court decision that makes a foreign judgment enforceable in Türkiye — the step that lets you actually collect.Glossary → ), and only then can the enforcement offices seize assets under the Enforcement and Bankruptcy Act. This guide walks the whole arc: foreign judgment → tenfiz → İİKİİKEnforcement and Bankruptcy Law No. 2004The Turkish statute governing how debts are collected by force — enforcement proceedings, attachment, sale and bankruptcy.Glossary → execution → collection. It also shows how an early precautionary attachment can freeze assets before the debtor moves them out of reach.

You won your case abroad — what happens next in Türkiye?

Your foreign win does not cross the border on its own. To reach assets in Türkiye you take two steps. First, you ask a Turkish court to enforce the judgment — a proceeding called enforcement (tenfiz). Once that succeeds, the judgment counts like a Turkish one. Second, you hand it to the enforcement offices (the icra dairesi), which issue a payment order and, if the debtor does not pay, seize bank accounts, receivables, and property.

Think of it as one continuous arc:

• Foreign judgment — a final decision from a court abroad.
• Tenfiz — a Turkish court makes that decision executable in Türkiye.
• İİK execution — the enforcement offices act on it under the Enforcement and Bankruptcy Act (İİK, Law No. 2004).
• Collection — attached assets are turned into money paid to you.

What is tenfiz, and does a foreign judgment work automatically here?

No — nothing about a foreign judgment is automatic in Türkiye. You need a Turkish court to act on it first, in one of two ways.

• Enforcement (tenfiz) makes a foreign judgment executable in Türkiye, exactly like a judgment handed down by a Turkish court. This is the route you need to collect money or take assets.
• Recognition (tanıma) gives a foreign judgment res judicata and evidentiary effect — it is treated as settled and can be relied on as proof — but it does not, by itself, let you seize anything (MÖHUK Arts 58–59).

The difference matters because reciprocity — whether Türkiye and the country of origin honour each other's judgments — is required for enforcement but not for recognition.

For a closer look at how the two routes differ, see our guide on recognition vs enforcement (tanıma vs tenfiz).

How are assets actually seized once you have the tenfiz judgment?

Once the tenfiz judgment is final, you collect the same way a domestic creditor does — through the enforcement offices under the Enforcement and Bankruptcy Act (İİK, Law No. 2004). The steps are concrete and follow a set order.

1. You open enforcement proceedings at the enforcement office and present your enforceable tenfiz judgment.
2. A payment order (ödeme emri) is served on the debtor, demanding payment within the statutory period.
3. If the debtor does not pay, you apply for attachment (haciz) — the seizure of the debtor's assets.
4. Assets are attached and, where needed, sold, and the proceeds are paid toward your claim.

What can be reached is broad: bank accounts, receivables owed to the debtor by third parties, vehicles, shares, and real property (tapuTapuTitle deed / land registry recordThe official title deed and the state land-registry record behind it — the only thing that proves who owns real estate in Türkiye.Glossary →) registered in the debtor's name. The office can send attachment notices to banks and registries directly.

How do you stop the debtor moving assets while the tenfiz runs?

You ask for a precautionary attachment (ihtiyati hacizİhtiyati hacizPrecautionary attachment (asset freeze)A court-ordered freeze on a debtor's assets granted early — before the case ends — to stop them being moved out of reach.Glossary →) — an early, protective freeze on the debtor's assets, available under the Enforcement and Bankruptcy Act. This is often one of the most valuable moves in a cross-border collection.

A tenfiz action and the execution that follows take time. A debtor who sees enforcement coming may empty a Turkish bank account, transfer a property, or route receivables elsewhere. A precautionary attachment locks specified assets in place before the debtor can act, so that when your tenfiz judgment is ready there is still something to collect against.

Which court decides the tenfiz, and where do you file?

You file at the civil court of first instance (asliye hukuk mahkemesiAsliye hukuk mahkemesiCivil court of first instanceThe general civil court that hears most disputes not assigned to a specialised court.Glossary →) where the party you are enforcing against has their Turkish domicile or residence. If that party has no domicile or residence in Türkiye, you may file at one of the courts in Ankara, İstanbul, or İzmir (MÖHUKMÖHUKTurkish Private International Law Act No. 5718The Turkish statute that decides which country's law applies to a cross-border matter, and how foreign judgments are recognised and enforced here.Glossary → Art. 51).

If the underlying dispute is a commercial matter, the case is heard by the commercial court of first instance instead of the general civil court. Choosing the right court and venue at the outset avoids a jurisdiction objection that can cost months.

For the full breakdown of venue rules and how they play out in practice, see which court and where (jurisdiction for tenfiz).

What must the foreign judgment satisfy to be enforced?

A Turkish court will enforce a foreign judgment when a defined set of conditions is met (MÖHUK Art. 54). It does not re-hear the dispute. The conditions are:

• (a) Reciprocity — Türkiye and the state of origin recognise each other's judgments, whether by treaty, by statute, or by de facto practice.
• (b) No exclusive Turkish jurisdiction — the judgment is not on a matter reserved to the exclusive jurisdiction of the Turkish courts.
• (c) No conflict with public policy — the judgment is not manifestly contrary to Turkish public policy (kamu düzeni), meaning fundamental principles of the Turkish legal order.
• (ç) Proper defence — the defendant's right to a proper defence and due service was respected in the original proceedings.

Two of these deserve their own read: the full checklist in the conditions to enforce a foreign judgment, and the most argued-over ground in public policy (kamu düzeni) and refusal.

Is an arbitral award enforced the same way as a court judgment?

No — a foreign arbitral award follows a different regime, and it is important not to confuse the two. Do not apply the court-judgment articles (MÖHUK 50–59) to an award.

The primary route is the 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards, to which Türkiye is a party. Turkish law also governs the enforcement of foreign arbitral awards (MÖHUK Arts 60–63). You file at the asliye court the parties agreed on; failing that, at the debtor's Turkish domicile or residence; failing that, where the enforceable assets are (MÖHUK Arts 60–61).

Crucially, the grounds to refuse an award are narrower than for a court judgment. They track New York Convention Article V — for example an invalid arbitration agreement or a party's incapacity, improper notice or inability to present the case, an award beyond what was submitted, an irregular tribunal or procedure, an award set aside at the seat, a non-arbitrable subject, or enforcement contrary to public policy. MÖHUK Art. 62 lists the corresponding grounds, including the public-policy ground at Art. 62/1-b.

Once enforced, the award is collected against Turkish assets through the same İİK execution described above. For detail, see enforcing a foreign arbitral award under the New York Convention and our arbitration and dispute resolution practice.

What about a foreign divorce or personal-status ruling?

A foreign divorce does not need enforcement against assets, only recognition — so the path is lighter, and there are two ways to have it take effect in Türkiye.

• Recognition (tanıma) before a family court under MÖHUK Art. 58, which gives the foreign divorce legal effect in Türkiye.
• The administrative route under the Population Services Act (Law No. 5490), Art. 27/A. Since 2017, a foreign divorce can be registered directly in the Turkish population register through the civil registry or a Turkish consulate when the conditions are met — without a court case.

Which route fits depends on your documents and circumstances. This is a family-law matter rather than an asset-collection one; our divorce and family law team handles both paths.

How long does it take, and what should you prepare?

Honest answer: it varies, and no lawyer can promise a result or a fixed date. As rough estimates only, an uncontested tenfiz action often takes around 6–10 months at first instance; a contested one can run 12–24 months; administrative divorce registration under Art. 27/A tends to take weeks to a few months. An appeal or a hard-fought defence can extend any of these.

You give your case the best chance by having the paperwork right from day one. The judgment or award must be:

• Final (kesinleşmiş), carrying a finality annotation from the origin court;
• Apostilled under the 1961 Hague Apostille Convention, or consular-legalised if the country is not a party; and
• accompanied by a sworn Turkish translation.

A power of attorney (vekâletname) lets a Türkiye-bar lawyer run the entire case remotely, so you do not have to travel. Note too that a foreign claimant may have to post security for costs (yabancılık teminatı) under the Code of Civil Procedure (HMK, Art. 84), unless a treaty or a reciprocity exemption applies.

This article is general information about Turkish law and is not legal advice; for advice on your specific situation, consult a qualified lawyer.

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