Validity and Deadline Control — Foreign Exchange Purchase Document (DAB)
What this control verifies
Döviz Alım Belgesi, commonly shortened to DAB, is a transaction document used in the current TKGM foreign natural-person acquisition workflow. TKGM’s official notice explains that, for covered purchases, foreign currency is sold through a bank within the Central Bank framework and the DAB is submitted for the title transaction. Validity and deadline control is therefore not a generic “does the PDF look recent?” check. It verifies whether the document belongs to the correct buyer and transaction, contains the required transaction information, reached the title process through the required channel, and still corresponds to the payment and filing facts at the moment it is relied upon.
Start with transaction applicability
Before asking whether a DAB is valid, establish whether the current transaction falls within the rule. Record buyer status, acquisition type, filing date and the official instruction checked. Do not copy an old assumption from another file. TKGM introduced the DAB requirement for relevant foreign natural-person purchases from 24 January 2022, with specific treatment for certain earlier payments. A historical exception should be supported by the applicable official rule and evidence of the payment date, not by a broker’s recollection.
Check core document identity
Match the buyer name or identifying information, currency sold, Turkish-lira amount, bank, date and any transaction reference against the title and payment file. The document must be tied to this acquisition, not merely to the same person. If the bank produced a corrected DAB, preserve both versions and mark which one is operative. Any mismatch in names, amounts or transaction references should be resolved before filing or payment release.
Control the delivery channel
TKGM later instructed that DAB documents in the relevant workflow be received through KEP. The file should therefore record how the title office receives or verifies the document, not only store a screenshot sent by the buyer. A copy can be useful for internal review, but internal possession is different from official receipt. Where the applicable procedure calls for bank-originated or KEP transmission, confirm that event independently.
Separate DAB from payment evidence
A DAB proves the foreign-exchange conversion event defined by the procedure; it is not the same document as proof that the buyer paid the seller. TKGM’s notice specifically distinguishes citizenship-related acquisitions by requiring bank evidence of transfer from buyer to seller in addition to the DAB. Keep these two evidentiary questions separate. A perfect DAB does not prove the seller received the contractual price, and a bank transfer receipt does not replace a required DAB.
Use actual deadlines, not invented expiry
Do not invent a universal “DAB expires after X days” rule unless the current official instruction expressly provides one for the relevant case. Deadline control should instead follow the real sequence: currency conversion, issuance, official transmission, application, fee/value processing and title transfer. Set file deadlines backward from the booked or expected closing date and leave enough time to correct bank errors. If the transaction changes materially before filing, revalidate the DAB rather than assuming age alone determines usability.
Reopen control after material changes
A new buyer, changed transaction amount, changed acquisition structure, corrected identity, cancelled transaction, or replacement payment arrangement can affect whether the existing DAB still maps to the file. Record the event and recheck with the bank or current TKGM procedure. Do not amend the DAB manually. If the bank issues a replacement, preserve the audit trail and ensure the official channel receives the operative version.
Decision record
The control closes only when applicability is established, the DAB matches the buyer and transaction, the amount and bank data reconcile, official receipt requirements are satisfied, and any special evidence required by the transaction purpose is separately complete. Record the source checked, check date, responsible reviewer and next procedural deadline. If one of these elements is missing, the status remains open and the title or payment step that depends on it should not be treated as ready.
