What DAB is and why it should not be treated as a formality
The Döviz Alım Belgesi (DAB) is a bank-issued foreign-exchange purchase document used in the Turkish rules applying to foreign natural persons acquiring real estate. TKGM states that, for transactions within the rule, the foreign currency is sold through a bank in the prescribed framework and the bank issues the DAB needed for the title-deed process. TKGM also publishes instructions requiring the document to be transmitted through the bank’s KEP channel. The DAB should therefore be treated as part of a transaction-specific official payment evidence chain, not as a detachable piece of paperwork.
Match the core fields before releasing non-refundable funds
Check the buyer’s identity details, foreign currency amount, currency type, Turkish-lira equivalent, bank, date and any transaction reference linking the DAB to the acquisition. The values should be reconcilable with the contractual sale price and the bank transfers shown elsewhere in the file. A difference in amount, party or timing does not automatically prove an error, but it must be explained and documented before the payment trail is treated as complete.
Separate the DAB from proof of paying the seller
A DAB evidences the foreign-exchange conversion required by the applicable procedure; it does not always prove by itself that the purchase price reached the seller. TKGM explains that citizenship-by-investment property files additionally require a bank-approved receipt for the transfer from buyer to seller. TKGM also notes that relevant values in those files must align across the DAB, declared sale price, valuation and total transfers/payments. Even outside a citizenship case, complete bank transfer evidence is good practice because it establishes who paid, who received the funds, when, and under which payment reference.
Build a reconciliation schedule for every payment
If the transaction contains a reservation deposit, contractual deposit, instalments and a final balance, list each movement separately. Record date, currency, sending account, receiving account, purpose, contractual treatment and whether the amount is credited against the price. This prevents double counting and makes it easier to reconcile the contract with bank records. Where exchange rates differ between stages, use the actual bank documents for each stage rather than reconstructing the transaction from an estimated rate after the event.
Create a payment-release gate
Adopt a clear control: the next material payment is not released until the prior evidence set is complete and consistent. Before a large or final payment, confirm the beneficiary identity, account number, account-holder relationship to the seller, DAB where required, current contract, and closure of legal or technical conditions that the parties agreed must be satisfied. If bank instructions change at the last moment, independently re-verify them rather than relying on a single email or messaging account.
Third-party payments and fraud risk
A request to transfer the purchase price to an employee’s personal account, an unrelated company or a newly introduced account without explanation is a stop event. Legitimate collection agents, escrow structures or group-company arrangements may exist, but the written documents must show why payment to that party validly discharges the buyer’s obligation to the seller. A tight title-deed appointment should never be used as a reason to bypass beneficiary verification.
How to handle a discrepancy
Record the exception precisely instead of hiding it. Examples include a DAB amount lower than expected, a different beneficiary name, a missing payment reference, a historical advance payment, or a receipt that does not identify the purpose. Assign a closure document such as a bank confirmation, bank-stamped receipt, contractual amendment, account statement or written seller explanation supported by the records. Close the exception only when another reviewer can reconstruct the flow of funds without relying on assumptions.
Archive for later audit
Keep the DAB, available KEP transmission reference, bank receipts, payment instructions, contract, reconciliation schedule and correspondence explaining exceptions. This package can matter for the title process, accounting review, a later dispute, resale due diligence or a citizenship file where relevant. Use file names and dates that preserve the sequence of the payment trail.
Current official sources
TKGM publishes Circular 2022/1 on the DAB and related instructions, its foreign-buyer document checklist, and the KEP transmission instruction. For citizenship-related acquisitions it also publishes guidance on the relationship among DAB value, declared consideration, valuation and transferred funds. Because banking and title procedures can be updated, check the latest TKGM and bank instructions for the live transaction.
Additional questions and context
Is a DAB the same as a seller payment receipt?
No. The DAB evidences the relevant foreign-exchange conversion; the transfer receipt evidences movement of money to the beneficiary.
Who sends the DAB into the title-deed process?
TKGM guidance states that the bank transmits it through KEP under the prescribed process.
Should bank receipts still be retained?
Yes. They are essential to reconstruct the payment trail and are expressly required in some procedures such as citizenship files.
What if the seller changes its bank account just before payment?
Stop and independently verify the new instructions using updated documentary evidence.
When can an amount discrepancy be closed?
When the contract, DAB and bank evidence can be reconciled with a documented explanation and no assumptions.