Risk review of bank payment evidence in a property purchase
Payment evidence is not strong merely because a bank receipt exists. The file should prove a complete chain: who paid, who received, how much was paid, in which currency, on what date, and for which property or contractual obligation. A receipt can be authentic but still fail to prove the transaction if the beneficiary is different, the amount belongs to another instalment or the reference cannot be tied to the property. Bank evidence should therefore be read together with the contract, property identity and verified account instructions rather than as a detached screenshot.
Start with payer and beneficiary
Match the payer name and account to the party responsible for payment under the contract. Then match the beneficiary to the seller or to a recipient expressly and validly authorised by the transaction documents. If the beneficiary is another company, an individual or a central collection account for a corporate group, require a written and verifiable explanation linking that recipient to the seller and this sale. A statement that the account belongs to the developer is not enough. If the IBAN changes shortly before completion, treat the change as a new fact requiring independent verification through a trusted channel. Last-minute beneficiary changes are a significant fraud risk.
Reconcile amount, currency and date
The file should state whether each transfer is a reservation deposit, advance payment, instalment or final price payment. Compare the amount with the contractual schedule and document any difference caused by a fee, commission or exchange calculation. Record both the transfer instruction date and final settlement status where relevant because creation of a transfer order does not always prove receipt. If the contract and payment use different currencies, preserve the agreed conversion basis rather than leaving a later reviewer to guess how the numbers relate.
Tie every payment to the exact property
Where practical, the transfer reference should identify the contract, project and unit, or the relevant ada and parsel. If the bank reference itself is short, build a manual transaction-file reconciliation linking the receipt to the contract and the payment obligation with clear dates and references. Do not reuse evidence from another unit or an earlier transaction merely because the same parties were involved. The evidence must prove the obligation that is actually under review.
DAB is not the same as proof that the sale price reached the seller
For purchases by foreign natural persons, TKGM explains that a Döviz Alım Belgesi, or DAB, has been required under the applicable purchase process since 24 January 2022. A bank prepares the DAB after the regulated foreign-currency sale process and sends it to the land-registry authority. The DAB proves the required currency-conversion step. It does not by itself prove that the buyer transferred the sale price to the seller. TKGM expressly states that in real-estate citizenship transactions a bank receipt for the transfer from buyer to seller is required in addition to the DAB. The two documents therefore perform different evidential functions.
Citizenship files require tighter reconciliation
Under TKGM Circular 2024/4, the total price transfers or payments form part of the investment-amount test in citizenship transactions, alongside the price declared in the official deed or preliminary sale agreement and the amount confirmed through TTB. For acquisitions after 19 September 2018 the current real-estate route uses the USD 400,000 threshold. Every transfer relied upon should therefore be traced individually and excluded if it cannot be linked to the seller, property and qualifying payment. In a multi-property file, the allocation must be understandable and a payment must not be counted twice.
Safe Payment System: the date matters
The Ministry of Trade announced on 29 April 2026 a regulatory change making a Safe Payment System mandatory for property sales where some or all of the price is paid in cash, by bank transfer or electronic funds transfer, with the purpose of allowing title and price to change hands in a coordinated manner. The original start date was 1 July 2026. On 26 June 2026, the Ministry exercised the permitted three-month extension and moved the start date to 1 October 2026. As of the review date of this record, 20 August 2026, it is therefore inaccurate to state that the system is already mandatory. The correct position is that mandatory operation is scheduled for 1 October 2026 unless a later official change is issued. Transactions after that date should be checked again against the implementation rules then in force.
Risk decision
Use three outcomes. Accept when payer, beneficiary, amount, currency, date and property all reconcile and there is no conflict with the contract. Hold when the bank evidence is genuine but a curable gap remains, such as an absent property reference or an unexplained corporate collection account. Stop when there is an unjustified beneficiary, material amount mismatch, unverified new account or an attempt to rely on evidence from another transaction. Do not close a conflict with a general note. Name the evidence required to resolve it.
Red flags
- An IBAN or beneficiary change immediately before payment.
- A request to pay a staff member, broker or private account without documented authority.
- A receipt with no usable link to the property or instalment.
- A screenshot that does not show final transfer status.
- Treating DAB alone as proof of buyer-to-seller payment in a citizenship file.
- Pooling payments across several properties without a traceable allocation.
- Claiming the property Safe Payment System is already mandatory before 1 October 2026 without a newer official rule.
Frequently asked questions
Does a bank receipt always prove the seller received the price? No. The beneficiary, transfer status and contractual linkage must be verified.
Can DAB replace the buyer-to-seller transfer receipt? No, particularly in citizenship files; TKGM distinguishes the documents.
Is the property Safe Payment System mandatory on 20 August 2026? No under the latest official announcement. The mandatory start was postponed to 1 October 2026.