A Turkish legal problem can reach someone in the United States from many directions. A distributor in Mersin stops paying a Houston LLC. A Turkish-American family in New Jersey finds that the grandparents’ apartment in Bursa is still registered to a grandfather who died years ago. A plaintiff with a judgment from a California court learns that the defendant’s assets are in Türkiye. A Chicago law firm needs a summons served on a company in İzmir. A patient back home in Arizona discovers that a hair transplant done in Istanbul has failed.
All of these are dealt with in Türkiye, before a Turkish court, enforcement office, land registry or civil registry, and Turkish law sets the procedure. Few of them require the client to travel. This page explains how a Turkish matter is run from the United States, which US documents Türkiye accepts and in what form, and what each of the seven guides in the US series covers.
Who writes to a Turkish lawyer from the United States
The starting point depends on who you are, because it decides which documents you already hold and where you can sign them.
- US citizens with no Turkish background. They meet Turkish law through a purchase, a contract, a medical treatment or a relative’s estate. They want the work done in English and need to know which of their US papers Türkiye will accept, and in what form.
- Turkish-Americans and Turkish citizens living in the US. A Turkish citizen’s marriage, divorce and family ties sit in the Turkish civil registry (nüfus), and a divorce decree from a US state court or a death in the US does not reach that record by itself. Turkish citizens can have notarial acts done at the Turkish Consulates General.
- Arabic-speaking residents and citizens of the US. Their matters typically concern property in Türkiye, family there or trade with Turkish companies. Lex Lata corresponds in English or Turkish; when someone writes in Arabic, an interpreter is brought in where needed.
- US companies and US law firms. Exporters, licensors and service providers with Turkish customers, and attorneys who need Turkish counsel to serve papers, obtain evidence or enforce a US judgment in Türkiye.
Signing a power of attorney without leaving the US
Everything a Turkish lawyer does for you rests on a power of attorney (vekâletname). From the United States there are two ways to sign one, and the choice affects what happens next.
At a Turkish Consulate General
Türkiye has an Embassy in Washington, D.C. and Consulates General in Boston, Chicago, Houston, Los Angeles, Miami and New York. Under Article 191 of the Notaries Law (No. 1512), notarial work abroad is carried out by consuls. A power of attorney drawn up at a Consulate General is therefore a Turkish notarial act, written in Turkish. Because Article 1 of the Apostille Convention excludes documents executed by diplomatic or consular agents, this power of attorney carries no apostille. Many Turkish and dual citizens living in the US sign this way.
Before a notary public in your state, then the apostille
The Apostille Convention has been in force for the United States since 15 October 1981 and for Türkiye since 29 September 1985, and neither state has objected to the other. Notarial acts and official certificates on privately signed documents count as public documents under Article 1. To certify the signature, the signer’s capacity and the seal on such a document, Türkiye may not ask for anything beyond the apostille issued by the competent authority of the state the document comes from (Articles 2 and 3); a Turkish translation is a separate matter. For a document notarized in a US state, that authority is the one the state designates, generally the Secretary of State’s office.
What the text has to say
How the document is signed matters less than what it authorizes. Under HMK Article 74 (Code of Civil Procedure, Law No. 6100), a lawyer needs express authority for a list of acts, among them settling, waiving the claim or an appeal, accepting the other side’s claim, releasing the other side, entering into an arbitration agreement, applying to alternative dispute resolution, lifting an attachment and appointing another lawyer. Actions about rights strictly personal to the client also need the power of attorney to say which ones are covered. If a power the matter later needs is missing, a new power of attorney has to be signed.
Getting US documents ready for Türkiye
Most matters rely on a few US documents: a death certificate, a marriage or divorce record, a court judgment, company papers or invoices. Each needs to reach Türkiye in a form a Turkish court or registry will accept.
| Document from the US | Typical example | Apostille issued by |
|---|---|---|
| Signed and notarized in a state | Power of attorney, affidavit, heir’s declaration | The authority that state designates, generally the Secretary of State (Alaska: Lieutenant Governor) |
| Issued by a state court or state agency | State court judgment, death certificate | The authority designated by the same state |
| Issued by a federal agency | Federal agency records | US Department of State, Office of Authentications |
| Issued by a federal court | Federal district court judgment | The clerks and deputy clerks of that federal court |
| Consular record issued abroad | Consular Report of Birth Abroad | Passport Services, Vital Records Section |
Turkish courts and registries work in Turkish, so every foreign document needs a Turkish translation. For the enforcement of a judgment, the law names the papers itself: the certified judgment with a certified translation, and the certified document showing that the judgment is final, also with a certified translation (MÖHUK, Law No. 5718, Article 53(1)(a) and (b)). In practice the apostille is added in the US first and the whole set, apostille included, is then translated in Türkiye by a sworn translator and certified by a Turkish notary. Copies are enough to assess a matter; the apostilled originals are needed once it is clear which ones the court or office will ask for.
Hearings, UYAP and the time difference
Where a court step in Türkiye is taken electronically, it runs through UYAP, the National Judiciary Informatics System (HMK Article 445(1)). Under Article 445(2), a secure electronic signature can be used to file an action, pay court fees and advances, and examine case files. Your lawyer files and follows the case in UYAP and attends hearings in person in Türkiye, so you are not asked to log in to anything or appear in court unless the matter specifically requires it.
Türkiye stays on UTC+3 all year and does not change its clocks. US daylight saving time runs from 2 a.m. on the second Sunday in March to 2 a.m. on the first Sunday in November (49 CFR 71.2), so for the cities below the gap with Istanbul changes twice a year, on the US dates.
| US city | Hours behind Istanbul, March to November | Hours behind Istanbul, November to March |
|---|---|---|
| New York | 7 | 8 |
| Chicago | 8 | 9 |
| Denver | 9 | 10 |
| Los Angeles | 10 | 11 |
In the US summer, a 10 a.m. hearing in Istanbul starts at 3 a.m. in New York and at midnight in Los Angeles. That is why the work runs in writing: after each step you receive a dated note in English saying what happened, what was filed or obtained, the next date and whether a decision is needed from you.
The seven guides in the US series
Each guide below takes one kind of matter from the American side and sets out the Turkish law that decides it. The summaries show where each one begins.
Power of attorney and apostille from the US
Nearly every file starts with this document. The guide compares the consulate route with the notary and apostille route, explains which special powers HMK Article 74 requires to be written in, and sets the order in which the apostille and the Turkish translation are prepared so that nothing has to be redone. Read power of attorney and apostille from the US for Türkiye.
Enforcing a US court judgment
A judgment from a US court, state or federal, cannot be enforced in Türkiye as it stands. If it was given in a civil matter and is final under the law of the place where it was given, it can be executed only after a Turkish court grants an enforcement decision, tenfiz (MÖHUK Article 50(1)). The petition is filed at the civil court of first instance (asliye mahkemesi) for the debtor’s Turkish domicile; if there is none, for the place where the debtor resides; and if neither exists, in Ankara, Istanbul or İzmir (Article 51). Article 54 sets what the court reviews: reciprocity, jurisdiction, public policy and, on the debtor’s objection, whether the debtor was duly summoned or represented in the US proceedings. Reciprocity under Article 54(1)(a) means an agreement based on reciprocity, or a statutory rule or actual practice in the state of the judgment that makes Turkish judgments enforceable there. Neither the United States nor Türkiye is a party to the HCCH 2005 Choice of Court Convention or the 2019 Judgments Convention. In the United States, recognition of foreign-country money judgments is a matter of state law, and each state sets its own rules; the enforcement guide explains what this means for a US creditor. See enforcing a US court judgment in Türkiye.
Serving US court papers and taking evidence in Türkiye
This guide is written mainly for US attorneys. The Hague Service Convention has been in force for the United States since 10 February 1969 and for Türkiye since 28 April 1972. Türkiye has declared its opposition to the Article 10 methods, so papers cannot be served on a defendant in Türkiye by mail or directly through judicial officers or other competent persons; the main channel is a request to the Turkish Central Authority at the Ministry of Justice. The Hague Evidence Convention has applied to Türkiye since 12 October 2004. Letters of request must be in Turkish or come with a Turkish translation, and Türkiye has declared that it will not execute letters of request issued for pre-trial discovery of documents as known in common law countries. See serving US court papers and taking evidence in Türkiye.
Recognition of a US divorce
A divorce decree from a US court does not change the Turkish civil registry on its own: an administrative act in Türkiye based on a foreign decision follows the recognition procedure (MÖHUK Article 58(3)). A registration route exists under Article 27/A of the Civil Registry Services Law (No. 5490). A final foreign divorce given by an authority competent under the law of the place where it was given, and not manifestly contrary to Turkish public policy, is registered when both spouses apply, in person or through representatives, or when the Turkish spouse applies alone because the other spouse is a foreigner or has died. For a decree from a US court, the application abroad goes to the Turkish missions in the United States, because registration outside Türkiye is made by the missions in the country where the decision was given; inside Türkiye, it goes to the civil registry offices the Ministry designates (Article 27/A(2)). If registration is refused, recognition is sought from a Turkish court (Article 27/A(3)), and reciprocity is not required for recognition (MÖHUK Article 58(1)). Article 4 of Law No. 4787 assigns the recognition and enforcement of foreign family-law judgments to the family courts. See recognition of a US divorce in Türkiye.
Inheriting property in Türkiye as a US heir
MÖHUK Article 20(1) splits the question: succession in general follows the deceased’s national law, while immovable property located in Türkiye is governed by Turkish law. An apartment in Antalya owned by a US citizen therefore passes under Turkish rules, even when the rest of the estate is administered in a probate proceeding in the US. On the heirs’ application, a civil court of peace or a notary issues the certificate of inheritance (mirasçılık belgesi) (Turkish Civil Code Article 598(1)), and the transfer is then registered at the land registry. If a US probate order or letters testamentary are to be relied on in Türkiye, the recognition rules apply: they extend to non-contentious foreign decisions and to administrative acts carried out in Türkiye on the basis of a foreign court decision (MÖHUK Article 58(2) and (3)). Heirs who cannot agree on the property can ask the civil court of peace to end the co-ownership (HMK Article 4(1)(b)). See inheriting property in Türkiye as a US heir.
American patients harmed after treatment in Türkiye
Hair transplants, dental implants and veneers, cosmetic surgery and eye surgery are among the treatments Americans travel to Türkiye for. Claims against a private clinic or doctor go to the civil courts. A claim in tort becomes time-barred two years after the injured person learns of the damage and of the person liable, and in any case ten years after the act; where the claim arises from an act punishable under criminal law with a longer limitation period, that period applies (Turkish Code of Obligations Article 72(1)). A claim founded on the treatment contract has its own limitation rules. If the treatment took place in a state hospital, the claim lies against the administration: it is a full remedy action (tam yargı davası) before the administrative courts (Administrative Procedure Law No. 2577, Article 2(1)(b)). Before suing, the patient must apply to the administration within one year of learning of the administrative action and in any case within five years of the action (Article 13(1)). See American patients harmed after treatment in Türkiye.
US exporters recovering unpaid invoices from Turkish buyers
A US seller holding unpaid USD invoices first chooses between enforcement proceedings without a judgment (ilamsız takip) and a court action. The proceedings start with a payment order telling the buyer to pay within seven days and to state any objection within the same seven days (Enforcement and Bankruptcy Law No. 2004, Article 60); a timely objection halts them (Article 66(1)). Unless otherwise provided, commercial cases go to the commercial court of first instance (Turkish Commercial Code Article 5(1)), and for commercial claims for a sum of money, including the action to set aside the buyer’s objection, applying to a mediator before filing is a condition of the action (Article 5/A(1)). A foreign claimant must give the security the court sets for costs and the other side’s possible loss, and the court exempts claimants on the basis of reciprocity (MÖHUK Article 48). Both states apply the UN Convention on Contracts for the International Sale of Goods, which covers sales between parties whose places of business are in different contracting states unless the contract excludes it (Articles 1(1)(a) and 6). Where the contract has an arbitration clause, both states are parties to the New York Convention of 1958, each applying it to awards made in another contracting state and to commercial matters. See US exporters recovering unpaid invoices from Turkish buyers.
Which Turkish office decides what
| Matter | Decided in Türkiye by | Turkish rule to know first | Usually needed from the US | Guide |
|---|---|---|---|---|
| Power of attorney | Used before every court, office and registry | HMK Art. 74: special powers must be written in | Signature at a Consulate General, or US notary plus apostille | Power of attorney |
| US judgment | Civil court of first instance (asliye mahkemesi) | MÖHUK Art. 54: reciprocity, jurisdiction, public policy, due summons | Certified judgment, proof of finality, apostilles, translations | Judgment enforcement |
| Service and evidence for a US case | Turkish Ministry of Justice as Central Authority, then the local court | No service by mail; Turkish translations | Request, papers to be served, Turkish translation | Service and evidence |
| US divorce | Turkish missions in the US or designated registry offices; family court if refused | Law No. 5490 Art. 27/A; MÖHUK Art. 58 | Final decree, proof of finality, apostille, translation | Divorce recognition |
| Inherited property | Civil court of peace or notary, then the land registry | MÖHUK Art. 20(1); Civil Code Art. 598 | Death certificate, proof of family ties, apostilles | Inheritance |
| Medical treatment | Civil courts (private clinic) or administrative courts (state hospital) | TBK Art. 72; Law No. 2577 Art. 13 | Records from Türkiye and the US, invoices, messages | Medical claims |
| Unpaid invoices | Enforcement office; mediation, then the commercial court | İİK Art. 60 and 66; TTK Art. 5/A | Contract, USD invoices, shipping papers, company documents | Debt recovery |
Where Turkish counsel stops and US counsel starts
Lex Lata is a law office in Istanbul. Its side of a US client’s file is the Turkish one: reading the US papers against Turkish law, giving written advice, preparing the wording of the power of attorney, opening and running court cases and enforcement proceedings in Türkiye, going to the hearings and sending a note in English after each step.
US law is outside that work. Whether a state court in Texas or New York would recognize a Turkish judgment, the US tax treatment of an inheritance, a sale or a settlement, and any question of federal or state procedure belong to an attorney or adviser qualified in the United States. When a file has a US side as well, your US attorney and Lex Lata can each handle their own part, with your agreement. Lex Lata does not issue apostilles or sworn translations, and it does not forecast the outcome of a case or the time a Turkish court will take.
A US law firm looking for Turkish counsel for its client can write in the same way. A written engagement letter then fixes the Turkish steps, the reporting line and the language of the reports.
Your first message from the US
A few paragraphs are enough for a first message: the facts, the city or district in Türkiye, the papers in your hands and the result you are after. Scans or phone photos of the documents will do for now. Has a Turkish court paper, payment order or land registry notice been delivered to you in the US? Then say on which date, since time limits under Turkish law often start on service.
Write in English or Turkish; for messages in Arabic an interpreter is used where needed. The answer comes in writing and says whether Lex Lata can act and how; scope and fees are agreed in an engagement letter before any step is taken. Use the contact page to write. For the law behind each kind of matter, see the seven guides above.
