Bangladesh AML/CFT Guide

Bangladesh’s regime is built around BFIU, which sits within Bangladesh Bank but operates as a separate agency. BFIU receives reports, issues the AML/CFT circulars for each sector, supervises designated non-financial businesses and professions (DNFBPs) directly, and can freeze accounts. Sector regulators supervise banks, insurers, the capital market, microfinance and NGOs.

Bangladesh’s exposure comes from corruption, trade-based money laundering through over- and under-invoicing, hundi (informal value transfer) linked to one of the world’s largest remittance flows, and smuggling of gold and goods. An official White Paper in December 2024 estimated that about USD 16 billion a year left the country illegally between 2009 and 2023.

How the regime fits together

• Policy and co-ordination. The National Coordination Committee on AML/CFT is chaired by the Finance Minister, with the Head of BFIU as member secretary. A Working Committee, convened by the Secretary of the Financial Institutions Division, follows up its decisions.
• Financial intelligence. BFIU receives suspicious transaction, suspicious activity and cash transaction reports and sends intelligence to investigators.
• Supervision. Bangladesh Bank, the Bangladesh Securities and Exchange Commission (BSEC), the Insurance Development and Regulatory Authority (IDRA), the Microcredit Regulatory Authority, the NGO Affairs Bureau and others supervise their sectors; BFIU supervises DNFBPs.
• Enforcement. The Anti-Corruption Commission (ACC), the Criminal Investigation Department (CID) of the police and other agencies investigate money laundering linked to their predicate offences.

Key milestones

1. 1997

   Bangladesh is a founder member of the Asia/Pacific Group on Money Laundering (APG).

2. 2002

   The first money laundering law is passed, and Bangladesh Bank sets up an anti-money laundering department.

3. 2009

   The Anti-Terrorism Act 2009 is passed, and the APG publishes its second evaluation of Bangladesh.

4. 2010–2014

   The FATF names Bangladesh in its monitoring process in October 2010 and removes it in February 2014.

5. 2012

   The Money Laundering Prevention Act 2012 is passed and BFIU is established. BFIU joins the Egmont Group in July 2013.

6. November 2016

   The APG publishes its third evaluation of Bangladesh, followed by follow-up reports up to 2020.

7. 2024–2026

   A Bangladesh Bank-led task force pursues stolen assets at home and abroad, and the Anti-Terrorism Act is amended.

What has changed recently

• Asset recovery. In September 2024 a task force under the Bangladesh Bank Governor was restructured, with joint investigation teams for 11 priority cases. BFIU set up a Stolen Asset Recovery Division in February 2026.
• Anti-terrorism law. An ordinance of 11 May 2025 gave the government power to ban all activities of an entity; Parliament replaced it with the Anti-Terrorism (Amendment) Act 2026 in April 2026.
• New BFIU circulars in 2026. New instructions for money changers, capital market intermediaries, payment service providers and NGOs, and e-KYC guidelines for insurers and capital market firms.
• Reporting volumes. Suspicious transaction and activity reports rose 74% to 30,199 in FY2024-25.
• Planned reforms. The government plans to amend the MLPA and the Companies Act to create a beneficial ownership register; neither had been enacted by October 2026.

Bangladesh has two main statutes, one for money laundering and one for terrorism and its financing, each with rules underneath. Most practical requirements are set in BFIU circulars and guidelines for each sector. The Bangla texts of the laws are authoritative.

Primary laws

Rules and BFIU instructions

BFIU is at the centre of the system, with sector regulators supervising their institutions and BFIU itself supervising DNFBPs. Several agencies can investigate money laundering, each for its own predicate offences.

Supervisors

The financial intelligence unit: BFIU

• Role. Receives suspicious transaction and activity reports and cash transaction reports, analyses them and sends financial intelligence to investigators. It also issues the AML/CFT circulars for each sector.
• Status. Grew out of Bangladesh Bank’s anti-money laundering department, set up in 2002, and became BFIU in January 2012. Since 2015 it has been a separate agency within Bangladesh Bank, led by a head of Deputy Governor rank appointed by the government.
• Powers. Can freeze an account for 30 days, renewable up to a maximum of six months, and fine reporting organisations.
• Activity. Received 30,199 suspicious transaction and activity reports in FY2024-25, and sent 199 intelligence reports to law enforcement.
• International. A member of the Egmont Group since July 2013.

Who investigates and prosecutes

The Anti-Corruption Commission investigates money laundering linked to corruption, and the police Criminal Investigation Department investigates most other cases. The Department of Narcotics Control, the National Board of Revenue, BSEC and the Department of Environment investigate laundering linked to their own offences.

• Asset recovery task force. Led by the Bangladesh Bank Governor, with BFIU as secretariat and joint investigation teams of the ACC, CID and the National Board of Revenue.
• International co-operation. Bangladesh has sent requests for mutual legal assistance abroad, and in 2025 the UK National Crime Agency obtained freezing orders over London properties linked to Bangladeshi politically exposed persons.

Targeted financial sanctions

• Screen. Keep the lists electronically and screen customers and transactions regularly.
• Stop. On a match, stop the payment or transaction immediately.
• Report. Report to BFIU within the next working day. CID verifies within five working days, and BFIU then issues a freezing order within one working day.

The MLPA calls the businesses it covers “reporting organisations” and lists them in section 2. The Anti-Terrorism Act uses the term “reporting agencies” for the same institutions.

Financial institutions

• Banking and finance. Banks, financial institutions, insurers and money changers.
• Money transfer. Any company or institution that remits or transfers money or money value, and any other institution operating with Bangladesh Bank’s approval. Mobile financial services providers and payment service providers fall here and have their own BFIU circulars.
• Capital market. Stock dealers and brokers, portfolio managers and merchant bankers, securities custodians and asset managers.

Bangladesh Bank can add other institutions by notification, with the government’s approval.

Non-profit organisations and DNFBPs

Casinos and virtual asset service providers are not listed in the MLPA. BFIU is assessing virtual asset and digital transaction risks as part of the 2026 national risk assessments.

Quick check: are you a reporting organisation?

1. Are you licensed or approved by Bangladesh Bank, BSEC or IDRA? If yes, you are a reporting organisation and your sector’s BFIU circular applies.
2. Are you an NGO, non-profit or cooperative? If yes, you are a reporting organisation, and the September 2026 BFIU circular for NGOs applies.
3. Are you a real estate developer, jeweller, lawyer, notary, accountant or company service provider? If yes, check whether your activity or the cash amount brings you in scope, and follow BFIU’s DNFBP circulars.

The obligations come from section 25 of the MLPA, the Money Laundering Prevention Rules 2019, the Anti-Terrorism Rules 2013 and BFIU’s sector circulars. The figures below are mostly from the circular for banks.

Key numbers

Check your own sector’s BFIU circular, because some figures differ.

What you must do

Penalties

• Money laundering by an individual (section 4). Four to 12 years’ prison and a fine of twice the value of the property or Tk 10 lakh, whichever is greater, plus possible forfeiture.
• Money laundering by an entity. A fine of at least twice the value or Tk 20 lakh, whichever is greater, and possible cancellation of registration.
• Breach of reporting duties (section 25). A fine of Tk 50,000 to Tk 25 lakh imposed by BFIU or the regulator, and possible suspension of the licence of the organisation, branch or agent.
• Breach of a freezing order. A fine of at least the account balance and up to twice the balance.
• Tipping off. Up to two years’ prison, a fine of up to Tk 50,000, or both.
• Terrorist financing. Rigorous imprisonment of four to 20 years and a fine of twice the value or Tk 10 lakh, whichever is greater.

In November 2025 BFIU fined Premier Bank and its officials a total of Tk 3.44 crore for card misuse, irregular accounts and unreported suspicious transactions, after an earlier fine in April 2025 for allowing withdrawals from a frozen account.

Bangladesh is not a member of the FATF. It is a founder member of the Asia/Pacific Group on Money Laundering (APG), which carries out its mutual evaluations. Its latest evaluation was published in 2016, and the next is planned for 2027.

Current status

The 2016 mutual evaluation

• Process. The on-site visit ran from 11 to 22 October 2015. The APG adopted the report at its annual meeting in September 2016, and it was published on 22 November 2016.
• Technical compliance. 6 compliant, 22 largely compliant and 12 partially compliant, with no non-compliant ratings.
• Substantial effectiveness. International co-operation (IO.2), terrorist financing investigation and prosecution (IO.9) and proliferation financing sanctions (IO.11).
• Moderate effectiveness. Risk and co-ordination (IO.1), supervision (IO.3), financial intelligence (IO.6) and terrorist financing preventive measures and sanctions (IO.10).
• Low effectiveness. Preventive measures (IO.4), legal persons and arrangements (IO.5), money laundering investigation and prosecution (IO.7) and confiscation (IO.8).
• Follow-up. Bangladesh was placed in enhanced follow-up and reported back four times, up to 2020.

How the ratings changed

1. July 2009

   Second APG evaluation, under the older 40+9 Recommendations.

2. October 2010

   The FATF names Bangladesh in its monitoring process, after a high-level political commitment to an action plan.

3. February 2014

   The FATF ends monitoring after Bangladesh completes its action plan.

4. November 2016

   Third APG evaluation: 6 compliant, 22 largely compliant and 12 partially compliant.

5. 2018–2019

   Follow-up reports upgrade R.19, then R.9, R.16, R.18, R.26 and R.34: 8 compliant, 26 largely compliant and 6 partially compliant.

6. 2020

   Fourth follow-up report upgrades R.28 and R.33 but downgrades R.15 (new technologies) after the virtual asset standards changed: 8 compliant, 27 largely compliant and 5 partially compliant (R.1, R.15, R.24, R.25 and R.35).

Grey list history

Bangladesh was under FATF monitoring from October 2010 until 14 February 2014, when the FATF found it had largely addressed its action plan. It has not been listed since, and was not among the 22 jurisdictions listed after the June 2026 plenary.

What comes next

• Next evaluation. The APG made a pre-evaluation visit on 11–13 August 2026. Bangladesh’s submissions are due by March 2027, with the on-site visit reported for October 2027.
• Preparation. Five national risk assessments, covering money laundering, terrorist financing, proliferation financing, NGOs and virtual assets, are due by December 2026.
• Concerns. The visiting APG delegation warned that past looting of banks and the stock market could weigh on the result.

The latest published national risk assessment dates from 2015. It named corruption, fraud and forgery, human trafficking and smuggling of gold and drugs as the highest-risk crimes, and banks, financial institutions, real estate and jewellery as the most vulnerable sectors. New assessments are due by December 2026.

Money laundering threats

Illicit outflows are the dominant concern. The White Paper on the economy, handed to the interim government in December 2024, estimated that about USD 16 billion a year left the country illegally from 2009 to 2023, as reported in the press. Global Financial Integrity estimated a trade misinvoicing gap of about USD 68.3 billion over 2013–2022, a risk indicator rather than a measure of laundering.

Remittances reached a record USD 30.04 billion in FY2024-25. Bankers linked part of the rise to action against hundi, the informal transfer system that bypasses the banking channel.

Most vulnerable sectors

The 2015 assessment is old, so treat its sector ratings as a starting point. BFIU’s 2026 circulars for capital market firms, payment service providers and NGOs, and its 2026 instructions on transaction monitoring for banks and mobile financial services, show where attention has moved.

Terrorist and proliferation financing

• Terrorist financing. The 2016 evaluation described mainly small-scale funding of domestic groups. Bangladesh’s terrorist financing investigation and prosecution was rated substantial.
• Sanctions. BFIU publishes a domestic list of proscribed entities for screening alongside UN lists.
• Proliferation financing. A separate national assessment is part of the 2026 round.

Recent asset recovery

• Freezes. From August to December 2024 BFIU froze the accounts of 366 individuals and entities holding about Tk 15,000 crore. By July 2026, BFIU’s head said about Tk 76,000 crore had been frozen in 11 priority cases, Tk 57,000 crore at home and Tk 19,000 crore abroad.
• Priority cases. They concern the family of former prime minister Sheikh Hasina and ten business groups. Investigations and court proceedings are continuing, and allegations remain to be tested in court.
• Abroad. Banks have hired international firms on a “no recovery, no fee” basis, and UK freezing orders cover London property linked to some of the cases.

Common typologies

Illustrative patterns linked to the threats above.

• Trade misinvoicing. Over-invoiced imports or under-invoiced exports used to move value abroad.
• Hundi. Remittances settled informally, with money paid out locally while the matching funds stay abroad.
• Loans and related parties. Bank loans channelled to connected companies and moved offshore.
• Real estate and gold. Cash proceeds of corruption or smuggling invested in property, flats or gold.

Red flags to watch for

These examples draw on the risks above. They are not an official list; BFIU publishes red flags in its sector guidance and trade-based money laundering guidelines.

Eight scenario questions on the main points in this guide. Choose an answer, then open it to check. The answers use only the facts set out above.

1. Question 1. A customer deposits Tk 6 lakh in cash in the morning and Tk 5 lakh in the afternoon into the same bank account. What must the bank do?

   1. Nothing, because each deposit is below Tk 10 lakh
   2. Include the deposits in its cash transaction report, because they total Tk 10 lakh or more in a day
   3. Refuse the second deposit
   4. Report only to Bangladesh Bank’s foreign exchange department
   Show answer

   Answer: B. Cash deposits or withdrawals of Tk 10 lakh or more in a day in an account, in one or more transactions, must be reported. Banks submit cash transaction reports monthly through goAML.

2. Question 2. A company is owned by four shareholders with 45%, 30%, 15% and 10%. Who are beneficial owners by ownership under BFIU’s guidelines?

   1. All four
   2. Only the 45% shareholder
   3. None, because no one owns more than 50%
   4. The 45% and 30% shareholders, because each owns 20% or more
   Show answer

   Answer: D. BFIU’s guidelines treat a natural person owning 20% or more, or with effective control, as a beneficial owner.

3. Question 3. A bank officer spots a suspicious transaction. How quickly should the report reach BFIU?

   1. Without delay, on the bank’s own initiative, through goAML
   2. Within 30 days
   3. At the next half-yearly self-assessment
   4. Only after the customer explains the transaction
   Show answer

   Answer: A. The MLPA requires reports without delay, and BFIU’s guidance says report immediately. There is no fixed number of days. Asking the customer to explain could amount to tipping off.

4. Question 4. A payment matches a name on the UN sanctions list. What should the bank do?

   1. Process it and review it at month end
   2. Return the funds to the sender
   3. Stop the payment immediately and report to BFIU within the next working day
   4. Wait for the customer’s explanation
   Show answer

   Answer: C. The Anti-Terrorism Rules 2013 require reporting agencies to stop the transaction immediately and report to BFIU within the next working day. BFIU issues the freezing order after CID verifies the match.

5. Question 5. A customer closed her account in March 2024. Until when must the bank keep her records at least?

   1. March 2029, five years after the account closed
   2. March 2025
   3. Indefinitely
   4. Until BFIU’s next annual report
   Show answer

   Answer: A. Section 25 of the MLPA requires records to be kept for at least five years from the date the account is closed.

6. Question 6. A traveller arrives in Dhaka with USD 15,000 in cash. What applies?

   1. Nothing, there is no limit
   2. The cash must be surrendered at the airport
   3. The amount above USD 10,000 must be declared to Customs on the FMJ form
   4. Only amounts above USD 50,000 need declaring
   Show answer

   Answer: C. Foreign currency can be brought in without limit, but amounts above USD 10,000 must be declared to Customs on Form FMJ under Bangladesh Bank’s 2020 rules.

7. Question 7. A colleague says Bangladesh is on the FATF grey list. Is that right?

   1. Yes, it has been listed since 2016
   2. Yes, it was added in June 2026
   3. Bangladesh has never been monitored by the FATF
   4. No. It was under FATF monitoring from 2010 to February 2014 and is not listed now
   Show answer

   Answer: D. Bangladesh was named in October 2010 and removed in February 2014. It was not on the June 2026 list.

8. Question 8. A bank onboards a senior foreign government minister. How should it treat the customer?

   1. As standard risk, because the person is not Bangladeshi
   2. As high risk automatically, with senior management approval, source of wealth and funds checks and closer monitoring
   3. As low risk, because ministers are well known
   4. The bank cannot open the account
   Show answer

   Answer: B. BFIU’s guidance treats foreign politically exposed persons as automatically high risk. Domestic influential persons are assessed case by case.