Corruption and Anti-Bribery Laws in Bangladesh: The 2026 Framework for Business

by Barrister Tahmidur Rahman | Oct 20, 2026 | Criminal Law, Insights | 0 comments

TRW Insight / Bangladesh

Bangladesh punishes both sides of a bribe, presumes guilt from unexplained wealth and routes every scheduled offence through one commission and one set of courts. The 2025 reform ordinance lapsed, so the 2004 framework still governs every inquiry.

Updated 20 October 2026Legal insightBangladesh23 min read

Corruption laws Bangladesh enforces in 2026: the framework at a glance

The corruption laws Bangladesh enforces are older, broader and more aggressive than many foreign businesses assume. A bribe paid to a customs officer, a "speed payment" to a utility clerk, an unexplained flat in Gulshan or a commission routed through a consultant can each trigger an inquiry by the Anti-Corruption Commission, a trial before a special court, asset freezing and a parallel laundering case. The statutes date from 1860, 1947, 1958, 2004 and 2012, but they are used hard: the Commission filed 874 cases in 2025, almost double the year before.[11]

This guide explains the whole framework as it stands on 20 October 2026: the Anti-Corruption Commission Act 2004 and its schedule, the bribery offences in the Penal Code, criminal misconduct under the Prevention of Corruption Act 1947, the Special Judge courts created by the Criminal Law Amendment Act 1958, and the corruption predicate in the Money Laundering Prevention Act 2012. It then covers how ACC inquiries and investigations run, asset statements, the exposure of companies and directors, what an effective anti-bribery programme looks like in Bangladesh, and the reform story of 2025 and 2026, including the amendment ordinance that lapsed in April 2026.

Corruption laws Bangladesh — counsel reviewing an Anti-Corruption Commission notice with a client
Most corruption exposure is decided at the notice and inquiry stage

Summary: Bangladesh criminalises the taking and giving of bribes involving public servants, criminal misconduct by officials, possession of assets disproportionate to known income and laundering of corruption proceeds. The Anti-Corruption Commission alone inquires into and investigates scheduled offences, needs its own sanction before a court takes cognizance, and prosecutes before special courts. Companies are exposed as "persons" under the Penal Code and as entities under the money laundering law, and their directors can be treated as offenders unless they show lack of knowledge or due diligence.

Key point: The Anti-Corruption Commission (Amendment) Ordinance 2025 was not enacted. The elected government chose not to place it before Parliament, it lapsed after 11 April 2026, and the Anti-Corruption Commission Act 2004 continues to apply in its pre-ordinance form. A new chairman and two commissioners were appointed under the 2004 Act in August 2026, and a fresh ACC bill has been promised but not passed.

At a glance

01

One investigator

Section 20 of the ACC Act 2004 makes scheduled corruption offences inquirable and investigable only by the Anti-Corruption Commission.

02

Bribery offences

Penal Code sections 161 to 165A punish officials who take gratification and anyone who abets them, including the giver.

03

Unexplained wealth

Section 27 of the ACC Act punishes possession of property disproportionate to known income with three to ten years' imprisonment.

04

Special Judges

Scheduled offences are tried exclusively by Special Judges under the Criminal Law Amendment Act 1958, with appeals to the High Court Division.

05

Money laundering

Corruption and bribery are predicate offences under the Money Laundering Prevention Act 2012, carrying four to twelve years and heavy fines.

Table of Contents

How the corruption laws Bangladesh applies fit together

There is no single anti-bribery code in Bangladesh. The corruption laws Bangladesh relies on are a layered set of statutes, each doing a different job. The Penal Code 1860 defines the core bribery offences. The Prevention of Corruption Act 1947 adds the broader offence of criminal misconduct by a public servant and evidential presumptions. The Criminal Law Amendment Act 1958 creates the Special Judge courts and their procedure. The Anti-Corruption Commission Act 2004 creates the investigating and prosecuting body and adds its own offences. The Money Laundering Prevention Act 2012 reaches the proceeds.

The glue is the schedule to the ACC Act. As substituted in 2016, it lists the offences that only the Commission may handle: the ACC Act's own offences; Penal Code sections 161 to 169, 217, 218 and 409; sections 420, 467, 468, 471 and 477A where they relate to government property or are committed in official duty by a government employee or a bank or financial institution officer; offences under the Prevention of Corruption Act 1947; bribery and corruption offences under the Money Laundering Prevention Act 2012; and abetment, conspiracy and attempt to commit any of them under sections 109, 120B and 511 of the Penal Code.[2]

Who counts as a public servant

Most offences turn on the involvement of a public servant. Section 21 of the Penal Code defines the term, including judges and anyone exercising adjudicatory functions, court officers and officers of the state.[4] The Prevention of Corruption Act 1947 widens it to include employees of corporations and bodies set up by the government, and chairmen, directors, managing directors, members, officers and employees of local authorities and of any corporation or body established under any law.[3] The Criminal Law Amendment Act 1958 uses a similar wide definition covering statutory corporations and bodies corporate established under law.[5] In practice, staff of state-owned banks, utilities, port authorities and regulatory bodies are all within reach.

The international layer

Bangladesh is a party to the United Nations Convention against Corruption, and the reform debate of 2025 and 2026 has been framed partly around closing gaps between domestic law and that Convention. Foreign investors should also remember that their home laws, such as the US Foreign Corrupt Practices Act and the UK Bribery Act 2010, can apply to conduct in Bangladesh. A payment that is "only" a local risk for a Bangladeshi company can be a headquarters-level enforcement event for a listed multinational.

Bribery offences under the Penal Code 1860

Chapter IX of the Penal Code contains the bribery offences that sit at the centre of the corruption laws Bangladesh prosecutes most often.[4]

Taking gratification: sections 161 to 165

Section 161 punishes a public servant, or a person expecting to become one, who accepts, obtains, agrees to accept or attempts to obtain any gratification other than legal remuneration as a motive or reward for doing or forbearing an official act, showing favour or disfavour, or rendering a service or disservice. The penalty is imprisonment of up to three years, a fine, or both. The explanations make clear that "gratification" is not limited to money or anything measurable in money, and that a reward for something the official never intended to do still counts.[4]

Section 162 catches the intermediary who takes gratification to induce a public servant by corrupt or illegal means, and section 163 the person who takes it for exercising personal influence over a public servant; both carry up to three years.[4] Section 165 targets the official who obtains a valuable thing for no or inadequate consideration from someone with business before him. The illustrations are instructive: below-market rent from a litigant, or shares sold at a premium to the brother of an accused.[4] For businesses, this is the section that turns discounted property deals, free use of a company car or sponsored travel into criminal exposure.

Giving a bribe: section 165A and the coercion exception

Bangladesh punishes the giver. Section 165A makes anyone who abets an offence under section 161 or 165 liable to the punishment for the offence, whether or not the bribe achieves its purpose.[4] Offering, promising or paying a bribe is therefore a crime in its own right, and the Prevention of Corruption Act presumes, once a payment is proved, that it was given as a motive or reward unless the contrary is shown.[3]

Section 165B contains an exception that matters in practice. A person is deemed not to abet the offence if induced, compelled, coerced or intimidated into offering or giving the gratification.[4] This is not a licence to pay whenever an official delays a file. It is a defence for genuine extortion, and it will only be credible if the company can prove the demand, the pressure and its own reluctance, ideally through contemporaneous records and prompt escalation.

Many corruption cases are charged alongside property offences. Criminal breach of trust by a public servant or by a banker, merchant or agent under section 409 carries imprisonment for life or up to ten years, and a fine.[4] Cheating and forgery offences in sections 420, 467, 468, 471 and 477A come within the Commission's exclusive remit when they concern government property or are committed in official duty by government, bank or financial institution staff.[2] Loan fraud involving bank officers can therefore be an ACC matter rather than an ordinary police case.

Criminal misconduct under the Prevention of Corruption Act 1947

The Prevention of Corruption Act 1947 is short but powerful. It applies to all citizens of Bangladesh and to persons in the service of the Republic wherever they may be, and it makes the Penal Code bribery offences cognizable.[3]

The five forms of criminal misconduct

Under section 5(1), a public servant commits criminal misconduct if he: accepts gratification as a motive or reward of the kind described in section 161; obtains a valuable thing without adequate consideration from a person concerned in his official business; dishonestly misappropriates property entrusted to him; obtains a valuable thing or pecuniary advantage by corrupt or illegal means or by abusing his position; or, with his dependants, possesses pecuniary resources or property disproportionate to his known sources of income for which he cannot reasonably account.[3] The punishment is imprisonment of up to seven years, a fine or both, and the resources or property involved may be confiscated to the State.[3]

Presumptions that shift the burden

The Act's real force lies in its presumptions. Once the prosecution proves that a public servant accepted gratification, the court presumes it was taken as a corrupt motive or reward unless the contrary is proved; the same applies to a giver once a payment is proved. Where disproportionate assets are proved, the court presumes criminal misconduct, and a conviction based solely on that presumption is not invalid. The court may decline to draw the presumption only where the gratification is so trivial that no inference of corruption can fairly be drawn.[3] The practical lesson for anyone facing these allegations is that documentary evidence of lawful income and legitimate transactions must be assembled early.

The Anti-Corruption Commission Act 2004

The Anti-Corruption Commission Act 2004 replaced the Bureau of Anti-Corruption with an independent and impartial commission, and gives the Act overriding effect over other laws.[1] It is the institutional core of the corruption laws Bangladesh has built since 2004.

Structure and independence

The Commission consists of three commissioners, one of whom the President appoints as chairman, on the recommendation of a five-member selection committee chaired by an Appellate Division judge nominated by the Chief Justice. Commissioners serve five years and cannot be reappointed, and they may be removed only on the grounds and by the procedure that apply to a Supreme Court judge.[1] The Commission has its own prosecution unit, whose prosecutors are deemed public prosecutors.[1]

Functions and powers

Section 17 empowers the Commission to inquire into and investigate scheduled offences, file and conduct cases, act on its own initiative or on complaints, review anti-corruption safeguards, carry out research and promote integrity.[1] Under section 19 it may issue notices to witnesses and examine them, require discovery and production of documents, take evidence and call for public records. It can direct any person to supply information in their custody, and that person is bound to comply.[1] Section 23 obliges government bodies to cooperate.

Offences created by the Act

Two offences in the Act itself drive many high-profile cases. Section 26 allows the Commission, after an inquiry, to order a person it believes holds property inconsistent with lawful sources to submit a statement of assets and liabilities; failing to comply, or submitting a statement with reason to believe it is baseless or false, is punishable with up to three years' imprisonment, a fine or both.[1] Section 27 punishes possession of property acquired by dishonest means and inconsistent with known income, where the accused cannot satisfactorily explain it at trial, with three to ten years' imprisonment, a fine and confiscation; once disproportion is proved, the court shall presume guilt unless the accused rebuts it.[1]

The Act also protects informants. Section 28B bars disclosure of an informant's identity in civil or criminal proceedings, while section 28C punishes knowingly false information that could trigger an investigation or trial with two to five years' rigorous imprisonment, a fine or both.[1]

Corruption laws Bangladesh — investigator examining financial records during an ACC inquiry
ACC inquiries begin with documents, bank records and asset statements

ACC inquiry and investigation procedure

Understanding the Commission's procedure is the most practical part of the corruption laws Bangladesh imposes on businesses, because the critical decisions are taken long before any trial.

Complaint and inquiry

A matter usually begins with a complaint, a media report, an audit finding or a referral. The Act distinguishes an anusandhan (inquiry), defined as the steps taken to establish the prima facie truth of an allegation before it is recorded for investigation, from the investigation that follows the recording of a case.[1] The Anti-Corruption Commission Rules 2007, made under section 34 of the Act, regulate how complaints, inquiries, investigations and sanctions are handled.[1] During either stage, the Commission must give a person whose statement it considers necessary a reasonable opportunity of hearing.[1]

Recording the case and investigation deadlines

If the inquiry supports the allegation, the Commission files a case and authorises an investigating officer, who has the powers of an officer in charge of a police station.[1] Section 20A requires the investigation to be completed within 120 working days of authorisation, extendable by the Commission by up to 60 working days for reasonable cause; if the officer still fails, the investigation must be reassigned for completion within 90 working days and departmental action taken against the officer.[1] The deadlines discipline the Commission, and the defence can legitimately press for progress when they are missed.

Arrest, travel restrictions and asset freezing

Section 21 lets an authorised officer arrest, with the court's permission, a person reasonably believed to own or possess property inconsistent with declared income.[1] The Commission also routinely applies to court for travel bans and for the freezing or attachment of assets. In 2025 it reported Tk 30,352.75 crore of assets frozen or seized, against Tk 361.45 crore in 2024.[11] For directors of foreign-owned companies, the risk of a travel restriction is often the most immediate commercial consequence; our analysis of travel restrictions on foreign directors in Bangladesh explains how these orders work.

Sanction, charge sheet and cognizance

No court may take cognizance of a scheduled offence without the Commission's sanction given in the prescribed manner, and a copy of the sanction must be filed with the case.[1] Section 32A, inserted in 2013, required prior government sanction under section 197 of the Code of Criminal Procedure before cases against judges, magistrates and public servants. The High Court Division declared it without lawful authority and of no legal effect on 30 January 2014, holding it discriminatory and an obstacle to the Commission's independent work.[8]

The steps below set out how a company should respond once an ACC matter surfaces.

Step 01

Log the trigger

Record when and how the complaint, notice, media report or audit finding arrived, and calendar every response date.

Step 02

Preserve the record

Issue a document hold covering emails, payment files, agent contracts and devices before anything is deleted or altered.

Step 03

Take privileged advice

Instruct Bangladeshi counsel before staff attend the ACC, and agree how communications with foreign parents are handled.

Step 04

Investigate internally

Establish the facts on payments, intermediaries and approvals so the company knows its position before the Commission does.

Step 05

Respond to notices

Answer section 19 information requests and section 26 asset notices accurately, completely and on time.

Step 06

Protect people and assets

Prepare for bail, travel-restriction and freezing applications, and keep operating accounts and licences functioning.

Step 07

Test the sanction

Check that any charge sheet carries a valid Commission sanction and that the offence is properly scheduled.

Step 08

Remediate

Discipline those responsible, fix control gaps and record the remediation for courts, auditors and counterparties.

Special Judges under the Criminal Law Amendment Act 1958

Every scheduled offence is tried exclusively by a Special Judge, and the Criminal Law Amendment Act 1958 governs the trial and appeal unless it conflicts with the ACC Act, in which case the ACC Act prevails.[1] [5]

Who sits and where

The Government appoints Special Judges by gazette from among serving or former Sessions, Additional Sessions and Assistant Sessions Judges, fixes their territorial limits and, where several sit in the same area, designates a Senior Special Judge with exclusive power to take cognizance and transfer cases.[5] An offence committed outside Bangladesh is deemed committed where the accused is found or last ordinarily resided.[5]

Procedure that favours the prosecution

The 1958 Act contains several features that distinguish a Special Judge trial from an ordinary Sessions trial. An absconding accused may be tried in absentia after a gazetted direction to appear. The Special Judge may tender a pardon to an accomplice at any stage to secure evidence. Disproportionate assets or an unexplained accretion of wealth around the time of the offence are relevant facts. On conviction, the court must impose a fine of at least the gain derived and may confiscate the accused's property.[5] No prosecution may be withdrawn except under the Commission's written order.[5]

Bail and appeals

Bail in corruption cases is contested territory. The 1958 Act deems offences triable by a Special Judge non-bailable, but section 28A of the ACC Act applies the Second Schedule to the Code of Criminal Procedure to determine whether ACC Act offences are cognizable and bailable, and the ACC Act prevails over any inconsistent provision.[1] [5] Appeals lie to the High Court Division, which also has revisional and transfer powers, and the Commission may direct an appeal against an acquittal.[5] Our guide to bail law and criminal defence in Bangladesh covers bail strategy, and challenges to an abusive proceeding can be brought through our section 561A criminal quashment practice.

Money laundering of corruption proceeds

Under the corruption laws Bangladesh has enacted, a corruption case rarely ends with the bribe. The Money Laundering Prevention Act 2012 lists corruption and bribery first among its predicate offences, alongside fraud, forgery, smuggling, tax and customs offences, insider trading and others.[6] The Commission investigates laundering linked to bribery and corruption, while other predicates go to the agency competent for that offence, with police-investigable predicates handled by the Criminal Investigation Department.[6] [2]

Penalties for individuals and entities

An individual who commits, attempts, abets or conspires in money laundering faces four to twelve years' imprisonment and a fine of twice the value of the property involved or Tk 10 lakh, whichever is greater, and the court may confiscate property linked to the offence.[6] An entity faces a fine of not less than twice the value or Tk 20 lakh, whichever is greater, and its registration is liable to cancellation; if it fails to pay, the court can order imprisonment of its owner, chairman or director.[6] A conviction for the predicate offence is not a precondition for a money laundering charge.[6]

Procedure: non-bailable, frozen and tried by Special Judges

Money laundering offences are cognizable, non-compoundable and non-bailable, and are tried by Special Judges. Bail may be granted only after the complainant is heard and the court is not satisfied that there are reasonable grounds to believe the accused is guilty, or where the accused is a woman, child or physically disabled person and justice will not be impeded.[6] Courts may freeze or attach property in Bangladesh or abroad, and where the tainted property cannot be identified, assets of equivalent value.[6] For banks and other reporting organisations, our analysis of banking regulations in Bangladesh sets out the compliance obligations that sit alongside these offences.

Corruption laws Bangladesh — tracing corruption proceeds under the Money Laundering Prevention Act 2012
Corruption is a predicate offence for money laundering

Asset statements and wealth scrutiny

Unexplained wealth is the single most common theme in the corruption laws Bangladesh enforces against officials and politically exposed persons. Three regimes interact.

ACC asset statement notices

A section 26 notice is a formal step, not a request. It requires a statement of assets and liabilities, together with any other information the order specifies, in the manner the Commission prescribes. Non-compliance or a false statement is itself an offence, and the statement becomes the baseline against which the Commission measures disproportion for section 27.[1] Recipients should reconcile the statement with tax returns, bank records, title documents and inheritance papers before filing, because an inconsistency is far harder to explain afterwards.

Annual declarations by public servants

Separately, the Government Servants (Conduct) Rules 1979 require government employees to declare their assets. In September 2024 the government announced the restoration of annual declarations, covering the employee, spouse, children and dependants, after a 2002 change had reduced the frequency to every five years, and treats non-compliance as misconduct.[7] These declarations are not public, but a court or authorised body can call for them, and they are a ready source of evidence in ACC inquiries.

What this means for counterparties

For companies, wealth scrutiny of officials has knock-on effects. Transactions with officials or their relatives, such as property sales, loans, employment of family members or shareholdings, will be examined for disguised gratification under section 165 of the Penal Code and section 5 of the 1947 Act.[3] [4] Related-party screening should therefore cover public officials and their families, not only shareholders and directors.

Corporate exposure under the corruption laws Bangladesh enforces

Bangladesh has no stand-alone corporate "failure to prevent bribery" offence, and the reform commission itself has recommended a law criminalising private-sector bribery, which confirms that purely private commercial bribery is not comprehensively covered today.[9] That does not make companies safe.

Companies as offenders

Section 11 of the Penal Code provides that "person" includes any company or association, whether incorporated or not.[4] A company that pays or offers a bribe to a public servant can therefore be charged with abetment under section 165A, and the ACC Act offences under sections 26 and 27 are framed by reference to "any person".[1] [4] In practice, prosecutions usually name the individuals who authorised or made the payment, but corporate assets, bank accounts and licences are drawn into the case.

Directors and officers

The 2012 Act goes further. Where an entity commits an offence, every owner, director, manager, secretary, officer, employee or representative directly connected with it is deemed to have committed it, unless they prove that it happened without their knowledge or that they used their best efforts to prevent it.[6] That defence turns directly on evidence of a functioning compliance programme. Our guide to corporate governance and directors' duties in Bangladesh explains the wider board obligations.

Where companies typically get caught

  • Public procurement: tender manipulation, kickbacks on contract awards and inflated variations. Our analysis of the 2026 public procurement amendments covers the procurement-side controls.
  • Customs, VAT and tax: payments to clear goods, reduce assessments or settle disputes.
  • Licences and utilities: payments for trade licences, environmental clearances, connections and inspections.
  • Banking: loan approvals and rescheduling obtained through collusion with bank officers, which can bring forgery and breach of trust charges within the Commission's remit.[2]
  • Third parties: agents, clearing and forwarding firms and consultants who pass on part of their fees to officials.

Building an anti-bribery compliance programme for Bangladesh

Because Bangladeshi law offers no statutory "adequate procedures" defence, a compliance programme serves three practical purposes: preventing the payment, supporting the coercion defence under section 165B, and supporting the lack-of-knowledge or best-efforts defence for directors under the 2012 Act.[4] [6] It also satisfies the expectations of foreign parents subject to the FCPA or the UK Bribery Act.

Core elements

  • A clear policy in Bangla and English prohibiting bribes and facilitation payments. Bangladeshi law contains no exception for small "speed" payments, so a policy that permits them invites liability.
  • Gifts, hospitality and sponsorship rules with value thresholds, pre-approval and a register, reflecting section 165's reach to any valuable thing given for inadequate consideration.[4]
  • Third-party due diligence on agents, consultants, distributors and joint-venture partners, with audit rights and termination clauses for corruption.
  • Accurate books and records so that every payment to a government-facing intermediary can be traced to a documented service.
  • An extortion protocol instructing staff to refuse, record and escalate any demand, so that a genuine coercion defence can be evidenced.
  • Training and certification for staff and intermediaries who deal with officials.
  • Speak-up channels and a non-retaliation policy, recognising that the ACC Act protects informants' identities.[1]
  • An investigations and response plan covering ACC notices, document preservation, privilege and communications with foreign parents and regulators.

Programmes for non-profit and donor-funded organisations need additional controls over grant flows; see our guidance on due diligence for foreign-funded NGOs in Bangladesh. TRW's corporate governance and compliance practice designs and tests these programmes.

Comparing the main offences

The table below summarises the principal offences in the corruption laws Bangladesh applies. On a phone, scroll it sideways.

Principal corruption offences in Bangladesh
OffenceLawWho is liableMaximum penaltyKey feature
Taking gratificationPenal Code, s 161Public servant or person expecting to be one3 years, fine or bothGratification need not be monetary
Giving or abetting a bribePenal Code, s 165AAny person, including a companySame as the offence abettedCoercion exception in s 165B
Criminal misconductPrevention of Corruption Act 1947, s 5Public servant, widely defined7 years, fine and confiscationPresumption from disproportionate assets
Disproportionate assetsACC Act 2004, s 27Any person10 years (minimum 3), fine and confiscationCourt presumes guilt once disproportion proved
Asset statement defaultACC Act 2004, s 26Recipient of an ACC notice3 years, fine or bothApplies to false as well as missing statements
Laundering corruption proceedsMoney Laundering Prevention Act 2012, s 4Individuals and entities12 years (minimum 4) and fine of twice the valueEntity fine of at least twice the value or Tk 20 lakh
Corruption laws Bangladesh — board reviewing an anti-bribery compliance programme
A documented compliance programme supports directors' defences

Reform in 2025 and 2026: what changed and what did not

The interim government that took office in August 2024 made anti-corruption reform a priority, and the result has been two years of proposals, one ordinance and very little enacted change to the corruption laws Bangladesh applies.

The ACC Reform Commission

The ACC Reform Commission, chaired by Dr Iftekharuzzaman of Transparency International Bangladesh, delivered its final report in February 2025.[13] Its recommendations included constitutional status for the Commission; five commissioners including a woman, with four-year terms; a seven-member selection and review committee assessing performance twice a year; repeal of section 32A; scrapping the mandatory pre-investigation inquiry; ACC access to tax records without a court order; a permanent prosecution unit and Special Judge courts in every district with an ACC office; and new laws on conflicts of interest, beneficial ownership, political finance and private-sector bribery.[9]

The 2025 amendment ordinance

The interim government promulgated the Anti-Corruption Commission (Amendment) Ordinance 2025 in December 2025.[13] It adopted part of the package: up to five commissioners, including at least one woman and one ICT expert, and a seven-member selection committee led by an Appellate Division judge that would include one member of Parliament each from the ruling party and the opposition.[11] Transparency International Bangladesh criticised it for dropping the review function, the publication of shortlists and multi-stakeholder oversight.[10] The ordinance also repealed section 32A, extended the Commission's reach to corruption committed from abroad, and required Special Judge courts wherever the Commission has a district office.[13]

The ordinance lapsed in April 2026

After the February 2026 elections, the elected government decided not to convert the ordinance into law, and it lapsed after midnight on 11 April 2026.[11] The Anti-Corruption Commission Act 2004 therefore remains in force in its earlier form, with a three-member commission and the original selection committee.[13] The chairman and both commissioners had resigned on 3 March 2026, leaving the Commission unable to authorise new investigations, cases, charge sheets or travel-ban applications for several months, although investigations already approved continued.[11]

In Parliament on 15 June 2026, Home Minister Salahuddin Ahmed said the government had chosen not to proceed with the ordinance in order to build a stronger Commission, that a new ACC bill would be placed before Parliament for full debate, and that a search committee under the existing law would keep the Commission running in the meantime.[12] On 17 August 2026 the government appointed Justice AKM Asaduzzaman as chairman, with Dr Jahangir Alam Khan and Dr Md Sazzad Hossain Bhuiyan as commissioners, under sections 5 and 6 of the 2004 Act.[14]

The draft replacement law

In June 2026 the Commission was preparing a preliminary draft combining the 2004 Act, parts of the ordinance and new proposals. As reported, it would revert largely to the 2004 structure, drop the ordinance's gender and ICT requirements and its parliamentary members on the search committee, and remove the investigation deadline, while keeping the repeal of section 32A, a four-year term, bars on candidates with foreign citizenship or overseas assets, jurisdiction over corruption committed from abroad and Special Judge courts at every district office. It would also extend the Commission's remit to money laundering, insider trading, tax and customs offences.[13] The ACC Secretary described the draft as very preliminary.[13] Until a bill is passed, none of these changes is law.

Practical guidance: what to do and what to avoid

The corruption laws Bangladesh enforces reward early, disciplined action and punish improvisation. Five points cover most situations we see.

  • Treat every ACC notice as a legal event. Calendar the response date, preserve documents and take advice before attending or filing anything.
  • Do not volunteer an asset statement without reconciliation. Every figure should tie to tax returns and bank records, because a false statement is a separate offence.[1]
  • Never pay to make a problem go away. A payment to settle an inquiry is a fresh offence under section 165A.[4]
  • Plan for the laundering case. Asset freezing and non-bailable charges can follow the corruption case, so map exposure across group accounts early.[6]
  • Use the courts where the process is abused. Defective sanction, lack of jurisdiction or a proceeding that discloses no offence can support a quashing application or writ; our constitutional and writ litigation practice handles these challenges.

For a broader view of criminal process in Bangladesh, see our overview of criminal law in Bangladesh. If your company or an executive has received an ACC notice, or you want your anti-bribery programme tested against Bangladeshi law, contact TRW.

Frequently asked questions

Which law governs corruption in Bangladesh?

The corruption laws Bangladesh applies are spread across several statutes: the Penal Code 1860 bribery offences, the Prevention of Corruption Act 1947, the Criminal Law Amendment Act 1958, the Anti-Corruption Commission Act 2004 and the Money Laundering Prevention Act 2012. The schedule to the ACC Act lists the offences the Commission handles.[2]

Is giving a bribe a crime in Bangladesh, or only taking one?

Both. Section 165A of the Penal Code makes anyone who abets an offence under section 161 or 165 liable to the same punishment, whether or not the bribe achieves its purpose. Section 165B excuses a person who was genuinely compelled, coerced or intimidated into paying.[4]

Are facilitation payments allowed under Bangladeshi law?

No. There is no exception for small or routine payments. Any gratification other than legal remuneration given to a public servant for an official act falls within section 161, and the giver is exposed under section 165A.[4]

What is the punishment for possessing disproportionate assets?

Under section 27 of the ACC Act, three to ten years' imprisonment, a fine and confiscation of the property. Once disproportion is proved, the court presumes guilt unless the accused rebuts it.[1]

What happens if I ignore an ACC asset statement notice?

Failing to submit the statement, or submitting one with reason to believe it is false or baseless, is an offence under section 26 of the ACC Act punishable with up to three years' imprisonment, a fine or both.[1]

How long does an ACC investigation take?

Section 20A requires completion within 120 working days of authorisation, extendable by up to 60 working days, after which the case must be reassigned for completion within 90 working days. In practice timelines often run longer.[1]

Which court tries corruption cases?

A Special Judge appointed under the Criminal Law Amendment Act 1958 tries scheduled offences exclusively, with appeals to the High Court Division.[1] [5]

Can a company be prosecuted for corruption in Bangladesh?

Yes. "Person" in the Penal Code includes a company, and under the Money Laundering Prevention Act 2012 an entity faces fines of at least twice the value involved or Tk 20 lakh and cancellation of registration, while its directors and officers are deemed liable unless they prove lack of knowledge or best efforts to prevent the offence.[4] [6]

Was the ACC (Amendment) Ordinance 2025 enacted?

No. The elected government did not place it before Parliament and it lapsed after 11 April 2026. The 2004 Act continues to apply, and a new ACC bill has been promised but not passed.[11] [12]

Does the ACC need government permission to prosecute public servants?

The ACC must give its own sanction before a court takes cognizance. The 2013 requirement for prior government sanction in section 32A was declared of no legal effect by the High Court Division in January 2014.[1] [8]

Source register

Primary legal and regulatory sources

Materials checked on 20 October 2026. Confirm the current official text before relying on any provision.

  1. Anti-Corruption Commission Act 2004 (Act No V of 2004) — Laws of Bangladesh
  2. Anti-Corruption Commission Act 2004, Schedule (as substituted by Act No 25 of 2016) — Laws of Bangladesh
  3. Prevention of Corruption Act 1947 (Act No II of 1947) — Laws of Bangladesh
  4. Penal Code 1860 (Act No XLV of 1860), sections 11, 21, 161 to 165B and 409 — Laws of Bangladesh
  5. Criminal Law Amendment Act 1958 (Act No XL of 1958) — Laws of Bangladesh
  6. Money Laundering Prevention Act 2012 (Act No 5 of 2012) — Laws of Bangladesh
  7. The Daily Star, 22 September 2024 — Govt employees, families must file wealth info annually
  8. The Daily Star, April 2015 — HC decries scrapped section of ACC law
  9. Dhaka Tribune, 5 August 2025 — ACC Reform Commission charts roadmap for anti-graft overhaul
  10. The Business Standard, 26 December 2025 — ACC reform drive stalls as key proposals dropped from ordinance
  11. The Business Standard, 10 April 2026 — ACC grounds to a halt as govt waits for ordinance to elapse
  12. The Business Standard (Bangla), 15 June 2026 — Parliament debate on the ACC and the new ACC bill
  13. The Daily Star, 23 June 2026 — ACC working on draft law rolling back key reforms
  14. Dhaka Tribune, 18 August 2026 — Justice AKM Asaduzzaman made ACC chairman

Related TRW assistance

Move from information to a defined next step

TRW advises companies, boards and individuals on ACC inquiries and investigations, asset statement notices, Special Judge trials, bail, quashing applications and anti-bribery compliance programmes. Explore our criminal quashment practice and corporate governance and compliance practice, or contact TRW to discuss your matter in confidence.

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