Anti Money Laundering Law in Bangladesh: MLPA 2012, BFIU Reporting and Compliance in 2026

Anti money laundering law Bangladesh in 2026: the framework at a glance

Anti money laundering law Bangladesh enforces in 2026 rests on two statutes, one set of rules and a steady stream of instructions from the Bangladesh Financial Intelligence Unit (BFIU). The Money Laundering Prevention Act 2012 creates the offence, names the businesses that must report and gives the BFIU power to freeze accounts and fine non-compliant institutions. The Anti-Terrorism Act 2009 adds terrorist financing, proliferation financing and United Nations sanctions. Since August 2024 the same machinery has been turned towards recovering assets moved abroad, and the Asia/Pacific Group on Money Laundering (APG) has begun preparing its next evaluation of the country.

This guide is for the institutions that carry the compliance burden, from banks and insurers to real estate developers, jewellers, company service providers, lawyers and accountants. It explains who must report, what due diligence and reporting require, how sanctions screening works, the penalties, and how the asset recovery drive changes the risk for companies and their directors.

Summary: The Money Laundering Prevention Act 2012, as amended in 2015, requires every reporting organisation to identify its customers, keep records for at least five years and report suspicious transactions to the BFIU immediately and on its own initiative. Banks and financial institutions must also file cash transaction reports for cash deposits or withdrawals of Tk 10 lakh or more in a day. Failures attract regulatory fines of up to Tk 25 lakh, licence action and personal fines on directors and officers, alongside criminal liability of four to twelve years' imprisonment for laundering itself.

Key point: The regulatory risk in 2026 is not only the offence of money laundering. It is a missed freeze, a late report or a weak due diligence file. The BFIU can freeze an account for thirty days and extend the freeze to six months, and reporting organisations that let money leave a frozen account can be fined between one and two times the balance held when the order was made.

At a glance

Swipe or scroll →

Table of Contents

How anti money laundering law Bangladesh enforces is structured

Anti money laundering law Bangladesh applies has four layers. At the top sit the Money Laundering Prevention Act 2012 (Act No. 5 of 2012) and the Anti-Terrorism Act 2009 (Act No. 16 of 2009).[1] [2] Beneath them are the Money Laundering Prevention Rules 2019, published in the Gazette in February 2019.[3] The third layer is the BFIU's sector circulars and circular letters.[7] The fourth is supervision by sector regulators, which the 2015 amendments made jointly responsible for compliance.[1]

The Money Laundering Prevention Act 2012

The 2012 Act was deemed to come into force on 16 January 2012.[1] It was substantially amended by the Money Laundering Prevention (Amendment) Act 2015 (Act No. 25 of 2015). That amendment transferred to the BFIU the powers previously exercised by Bangladesh Bank, widened the list of investigating agencies, allowed courts to freeze property of equivalent value where tainted property cannot be traced, and made regulators answerable for the compliance of the institutions they supervise.[1] The consolidated text on the official Laws of Bangladesh portal shows no amendment to the Act after 2015.[1]

What counts as money laundering

The statutory definition is wide. It covers knowingly converting or transferring proceeds of crime to conceal their origin; smuggling money or property abroad; remitting proceeds across the border to disguise their source; structuring transactions to avoid reporting; knowingly acquiring or using proceeds of a predicate offence; and abetting or conspiring in any of these.[1] "Smuggling of money or property" includes failing to repatriate money due to Bangladesh and paying more abroad, or bringing back less, than the real amount due, which is how over-invoicing and under-invoicing are captured.[1]

The Act lists twenty-eight categories of predicate offence, from corruption and bribery through fraud, narcotics, human trafficking, customs and tax offences, insider trading and organised crime. The last category allows the BFIU, with Government approval, to declare further predicate offences by Gazette notification.[1] A conviction for the predicate offence is not a precondition for prosecuting money laundering.[1]

The Anti-Terrorism Act 2009 and its 2026 amendment

Section 7 of the Anti-Terrorism Act 2009 makes terrorist financing an offence whether the funds are lawful or not and whether or not they are used in a terrorist act; section 16 imposes reporting duties; and section 20A gives effect to UN Security Council sanctions.[2] In May 2025 the interim government amended the Act by ordinance to allow the Government to prohibit all activities of a listed entity. Parliament passed the Anti-Terrorism (Amendment) Bill on 8 April 2026 without changes, and the official text records the change as made by the Anti-Terrorism (Amendment) Act 2026 (Act No. 28 of 2026).[2] [13]

The BFIU: powers, reporting lines and enforcement

Section 24 of the 2012 Act establishes the BFIU as the national financial intelligence unit, and section 23 gives it the operational powers.[1] It analyses cash transaction reports and suspicious transaction reports, collects further information notwithstanding any other law, issues directions, inspects and supervises reporting organisations, and may share intelligence with foreign financial intelligence units.[1]

Administrative freezing of accounts

Where there are reasonable grounds to suspect that an account holds proceeds of an offence, or funds that have been or may be used to commit one, the BFIU may direct a reporting organisation to suspend or freeze transactions for up to thirty days. It may extend the freeze by thirty days at a time, to a maximum of six months.[1] No court order is needed. In August 2026 the BFIU instructed every reporting organisation that, on receiving a freeze order, it must immediately inform the BFIU of the balance in the account and of other accounts connected with it, citing rule 26(4) of the 2019 Rules.[6]

Investigation and prosecution

Money laundering is investigated by the agency empowered to investigate the relevant predicate offence. Predicates within police jurisdiction go to the Criminal Investigation Department, the Anti-Corruption Commission handles corruption-linked cases, and the BFIU may form joint investigation teams with officers from more than one agency in consultation with the Government.[1] Offences are tried by a Special Judge appointed under the Criminal Law Amendment Act 1958, and are cognisable, non-compoundable and non-bailable.[1]

In 2024–25 the BFIU received 30,199 suspicious reports, 20,524 suspicious transaction reports and 9,675 suspicious activity reports, a 74 per cent increase on the previous year. Banks filed 95 per cent of them. Requests for financial intelligence from law enforcement agencies rose to 1,329, led by the CID and the Anti-Corruption Commission.[11]

Reporting organisations under the Money Laundering Prevention Act

Every obligation in the framework attaches to a "reporting organisation". Section 2 lists banks; financial institutions; insurers; money changers; companies that remit or transfer money or money value; other institutions operating with Bangladesh Bank approval; stock dealers and brokers, portfolio managers, merchant bankers, securities custodians and asset managers; non-profit organisations, non-government organisations and cooperative societies; real estate developers; dealers in precious metals or stones; trust and company service providers; and lawyers, notaries, other legal professionals and accountants. Further categories may be added by notification with Government approval.[1]

Designated non-financial businesses and professions

For non-financial businesses the obligations are triggered by specific activities. Under rule 14 of the 2019 Rules, real estate developers must apply customer due diligence when they buy or sell real estate for clients, and dealers in precious metals or stones when they engage in a cash transaction with a customer of Tk 10 lakh or more, or such other amount as the BFIU sets.[3] Lawyers, notaries and chartered accountants are caught when they carry out or prepare transactions for a client in buying or selling real estate, managing client money, securities, assets or accounts, forming or managing companies and other legal entities, or buying and selling businesses.[3]

Trust and company service providers are caught when they act as formation agents, nominee directors, secretaries, trustees or shareholders, or provide a registered office.[3] Corporate service businesses should map each service line against this list. Our guide to corporate secretarial compliance in Bangladesh covers the company-law side of the same services.

Sector instructions issued in 2026

The BFIU refreshed most of its sector instructions in 2026: an e-KYC guideline for insurers and capital market intermediaries on 30 March, and new instructions for money changers (18 August), capital market intermediaries (15 September), payment service providers and operators (24 September), NGOs and NPOs (30 September) and insurance companies (19 October).[7] The banks' master instructions remain BFIU Circular No. 26 of 16 June 2020, and financial institutions follow Circular No. 28 of 30 May 2023.[7] The table below summarises where each sector sits. On a phone, scroll it sideways.

Customer due diligence and KYC under anti money laundering law Bangladesh

Section 25(1) of the 2012 Act requires reporting organisations to maintain complete and correct customer identification information while an account is operated.[1] The 2019 Rules turn that duty into a full customer due diligence regime. A reporting organisation may not open or maintain anonymous accounts, accounts in fictitious names or numbered accounts.[3] Rules 7 to 13 are framed for financial institutions; rule 14 applies the due diligence rules to designated non-financial businesses and professions in the circumstances described above.[3]

When due diligence is required

Rule 7(2) requires customer due diligence when a business relationship begins; for transactions above a threshold the BFIU sets, whether single or linked; for occasional wire transfers; on any suspicion of money laundering or terrorist financing; and when earlier identification data is in doubt.[3] Identity must normally be verified before or while the relationship is established.[3]

What due diligence involves

Under rule 7(3) the institution must identify every customer, individual, legal person or legal arrangement, and verify identity from reliable, independent sources. It must identify and verify the beneficial owner, understand the ownership and control structure of corporate and trust customers, understand the purpose of the relationship, monitor transactions against the customer's business, risk profile and source of funds, and keep high-risk customer data under regular review.[3] A corporate file that records directors but not the natural persons who ultimately own or control the company does not meet that standard.

Risk-based approach, PEPs and influential persons

Rule 10 requires a periodic risk assessment covering customers, products, delivery channels and geography. Where risk is high, enhanced due diligence is mandatory; simplified due diligence is allowed only where low risk has been identified and never where there is suspicion.[3] Designated non-financial businesses must apply the BFIU's requirements for domestic influential persons and foreign politically exposed persons.[3]

Electronic KYC in 2026

The BFIU's March 2026 e-KYC guideline for insurers and capital market intermediaries sets two tracks. Simplified e-KYC applies to proven lower-risk products and requires no risk grading, but still requires sanctions screening. Regular e-KYC requires screening against UN Security Council lists and for influential persons, beneficial ownership identification, adverse media screening, risk grading, a due diligence template and enhanced due diligence where needed.[8] KYC must be refreshed at least annually for high-risk customers, every two years for medium-risk and every five years for low-risk customers, and the guideline must be implemented by 31 December 2026.[8]

When due diligence cannot be completed

Rule 11 is short and strict. If an institution cannot complete the required due diligence, it must not open the account, begin the relationship or carry out the transaction, or must end the relationship, and it must consider filing a suspicious transaction or activity report.[3] Onboarding a valuable client while documents are "on their way" is a common source of later findings under anti money laundering law Bangladesh regulators enforce.

BFIU reporting obligations: STRs, CTRs and records

Reporting is the core of anti money laundering law Bangladesh imposes on the private sector. Three obligations matter most: suspicious transaction reports, cash transaction reports and record keeping.

Suspicious transaction reports

Section 25(1)(d) of the 2012 Act requires a reporting organisation that observes a suspicious transaction, or an attempted one, to report it to the BFIU immediately and on its own initiative.[1] A transaction is suspicious if it deviates from the usual pattern, if there are grounds to suspect that the property is proceeds of an offence or is financing terrorism, or if it falls within instructions issued by the BFIU.[1] Section 16(1) of the Anti-Terrorism Act imposes the same duty, without delay, for transactions connected with terrorist financing.[2]

The threshold is suspicion, not proof, and the predicate offence need not be identified. Section 28 protects a reporting organisation, its board and staff from proceedings for anything done in good faith under the Act.[1]

Tipping off

Rule 12 deals with the conflict between due diligence and secrecy. Where an institution suspects money laundering or terrorist financing and reasonably believes that pursuing due diligence would alert the customer, it should not pursue the process and should file a suspicious transaction report instead.[3] Separately, section 6 of the Act makes it an offence to disclose information about an investigation with ill motive to any person, organisation or the media, punishable by up to two years' imprisonment, a fine of up to Tk 50,000, or both.[1]

Cash transaction reports and the Tk 10 lakh threshold

Under paragraph 6 of BFIU Circular No. 26 of 16 June 2020, banks must report every case in which cash of Tk 10 lakh or more, or the equivalent in foreign currency, is deposited into or withdrawn from a single account on a single day, whether in one transaction or several, including online and ATM transactions.[4] In January 2026 the BFIU required banks to file these reports weekly, within three working days after each week, from 11 January 2026.[4] Six weeks later it cancelled that instruction with effect from 1 March 2026 and directed banks to file cash transaction reports from March 2026 under the Circular No. 26 arrangements.[5]

Both letters warned that late, incorrect, incomplete or false reporting can lead to action under section 23 of the 2012 Act.[4] In 2024–25 banks and financial institutions reported 31.25 million cash transactions involving Tk 19,452 billion; the BFIU attributes the year-on-year decline in CTRs to Bangladesh Bank's push towards digital payments.[11]

Record keeping

Section 25(1)(b) requires records of accounts and transactions to be kept for at least five years after an account closes.[1] Rule 13 adds that records must be usable as evidence in a criminal trial, that due diligence files, correspondence and analysis must also be kept for five years, and that records linked to an investigation must be kept until the case is finally disposed of.[3]

Sanctions screening and targeted financial sanctions

Under anti money laundering law Bangladesh enforces, United Nations sanctions are implemented through section 20A of the Anti-Terrorism Act 2009, inserted in 2013. It covers UN Security Council Resolution 1267 and its successors, Resolution 1373, and the resolutions on proliferation of weapons of mass destruction and its financing.[2]

Freeze without delay and without notice

Section 20A(1) requires property, funds and other financial assets of listed persons and entities, and of entities they own or control directly or indirectly, to be frozen, seized or attached immediately and without prior notice. It prohibits making funds or financial services available, directly or indirectly, to listed persons and those acting for them, and lets the BFIU issue implementing instructions.[2] A person who breaches a freeze or attachment under section 20A faces up to four years' imprisonment, a fine of twice the value of the property, or both. Making funds available to a listed person is treated as terrorist financing.[2]

A reporting organisation that fails to follow BFIU instructions under section 20A, or fails to freeze without delay, is liable to a fine of not less than Tk 5 lakh and not more than Tk 25 lakh, or twice the suspected funds, whichever is greater. Bangladesh Bank may also suspend its registration or licence, or that of its branches, service centres, booths or agents.[2]

Domestic listing and the 2026 amendment

Alongside UN listings, section 18 lets the Government list a person in the Act's schedule, or proscribe and list an entity, by Gazette notification where there are reasonable grounds to believe it is involved in terrorist activity. Since the 2026 amendment it may also prohibit all activities of an entity.[2] The amending bill also prohibits press releases, propaganda in mass and social media, processions, meetings and public speeches by or in support of a prohibited entity.[13] Sanctions screening systems should therefore cover both UN lists and domestic listings under section 18, and should flag payments to or from prohibited entities as well as listed individuals.

Building the screening process

Sanctions screening should run at onboarding, on changes to customer data, on each list update and on each cross-border payment. The 2026 e-KYC guideline requires UN list screening for every customer, even on the simplified track.[8] Each potential match should be resolved and documented: true matches frozen and reported to the BFIU, false positives cleared with reasons.

Penalties under anti money laundering law Bangladesh

The penalty regime has a criminal side and a regulatory side, and companies should plan for both. The criminal provisions for corruption-linked laundering are explained in our guide to corruption laws in Bangladesh; the summary here concentrates on what matters for compliance.

Criminal liability

A person 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. An entity faces a fine of at least twice the value or Tk 20 lakh, whichever is greater, and its registration is liable to cancellation.[1]

Terrorist financing carries four to twenty years' rigorous imprisonment for individuals. An entity faces a fine of three times the value of the property or Tk 50 lakh, whichever is greater, and its head faces imprisonment unless he or she proves the offence was committed without knowledge or despite every effort to prevent it.[2]

For compliance staff, the lesser offences matter: breaching a freeze order carries up to three years' imprisonment; refusing without reasonable cause to supply a requested report, up to one year or Tk 25,000; and knowingly giving false information about the source of funds or an account holder's identity, up to three years or Tk 50,000.[1]

Regulatory fines on reporting organisations

For breach of the identification, record keeping or reporting duties in section 25(1), the BFIU or the sector regulator may impose a fine of Tk 50,000 to Tk 25 lakh and cancel the licence of the organisation or any branch, booth or agent.[1]

Under section 23, the BFIU may fine an organisation Tk 10,000 a day, up to Tk 5 lakh, for failing to provide requested information on time or for each instruction not complied with; between Tk 20,000 and Tk 5 lakh for false or misleading information; and between one and two times the account balance for breaching a freeze order. An organisation fined more than three times in a financial year may have its registration or licence suspended.[1] Unpaid fines can be recovered by debiting the organisation's accounts.[1]

Personal exposure of directors and officers

Where the BFIU fines a reporting organisation under section 23, it may also fine the responsible owners, directors, officers, employees or contractual staff between Tk 10,000 and Tk 5 lakh and direct administrative action against them.[1]

Under section 27, where an entity commits an offence, every owner, director, manager, secretary or other officer directly involved is deemed guilty unless he or she proves lack of knowledge or best efforts to prevent it.[1] Under section 16 of the Anti-Terrorism Act, the board must approve and issue instructions on officers' duties and ensure BFIU directions are followed; if it fails, the chairman or chief executive may be fined up to Tk 25 lakh and removed from office.[2]

Freezing, confiscation and asset recovery in court

BFIU freezes are short-term. Longer restraint requires a court order under section 14 of the 2012 Act, made by the Special Judge on the investigating agency's written application.[1]

Court freezing and attachment

The court may freeze or attach property, inside or outside Bangladesh, connected with money laundering or representing proceeds of crime. Where that property cannot be identified, it may freeze money or property of equivalent value from the accused's other assets.[1] The order is published in the Gazette and in two national dailies, one Bangla and one English.[1]

Two remedies are available to those affected. A third party with an interest in frozen property may apply for its return within thirty days of the published notice, showing that it is not involved and is not the accused's nominee. Any aggrieved person may appeal to the High Court Division within thirty days, but the order stays in force pending the appeal unless the appellate court directs otherwise.[1] Thirty days is short, so affected businesses should diarise the deadline from publication.

Confiscation

On conviction the court may confiscate property in or outside the country involved directly or indirectly in money laundering or a predicate offence. It may also order confiscation during an inquiry, investigation or trial, and where the accused absconds for six months after an arrest warrant or dies after a charge sheet.[1] If tainted property cannot be found, the court may confiscate untainted property of equivalent value or impose a fine equal to the shortfall.[1]

Cross-border cooperation

Section 26 allows the Government to enter into agreements with foreign states, lets the BFIU sign memoranda of understanding with foreign financial intelligence units, and authorises courts, on the application of the Attorney General's Office, to give effect to foreign confiscation or return orders. Documents received through mutual legal assistance are admissible in evidence.[1]

The stolen asset recovery task force, 2024 to 2026

After the change of government in August 2024, asset recovery became the headline application of the framework. On 29 September 2024 the Financial Institutions Division of the Ministry of Finance restructured the Inter-Agency Task Force on Stolen Asset Recovery and Management, with the Governor of Bangladesh Bank as chairman and the BFIU as secretariat.[9] Its members are the Ministries of Home Affairs and Foreign Affairs, the Financial Institutions Division, the Law and Justice Division, the Anti-Corruption Commission, the CID, the Attorney General's Office, the NBR's Customs Intelligence and Investigation Directorate and Central Intelligence Cell, and the BFIU.[9]

Its mandate is to identify siphoned assets, remove obstacles to legal proceedings, recover, repatriate and manage assets, and coordinate with foreign authorities.[9]

Where recovery stood in October 2026

Figures presented to Parliament's Standing Committee on Estimates and reported on 2 October 2026 put assets under court seizure, attachment or freezing orders at about Tk 769.84 billion, of which Tk 573.26 billion is in Bangladesh and Tk 196.58 billion abroad.[10] As of August 2026, 142 cases had been filed, charge sheets submitted in 16 and verdicts delivered in six; travel bans had been imposed on 158 people; ten Interpol red notice requests had been made; and 30 mutual legal assistance requests had gone to 16 jurisdictions. Mutual legal assistance treaties had been concluded with Malaysia and Hong Kong, China.[10]

Among 11 priority groups, the six initial targets account for loans of about USD 12 billion; a second phase targets civil proceedings against 40 further borrowers with loans of about USD 2 billion. Eight lead banks are organising six consortia, and ten international firms have expressed interest in acting on recovery.[10] The World Bank–UNODC StAR Initiative, UNODC and the US Department of Justice are named partners.[10]

Proposed amendments to the 2012 Act

In January 2026 the Financial Express reported that the interim government planned to amend the 2012 Act to allow proceedings against property itself where the owner cannot show a lawful source, to expand the predicate offences to target trade-based laundering, to fast-track mutual legal assistance and to set tighter timelines for charge sheets and trials.[14] As noted above, no such amendment appears in the official consolidated text as of October 2026.[1] Companies should treat these proposals as a statement of direction, not current law, and watch for a bill in the new Parliament.

What the recovery drive means for companies

The effect reaches beyond the named groups. Suppliers, lenders, landlords and minority shareholders of a targeted group may find accounts frozen or payments held while funds are traced. A business in that position should identify the authority and legal basis behind each order and the deadline for a third-party claim or appeal, and be ready to document the source of its own funds. Our analysis of banking law in Bangladesh explains how the parallel bank resolution process interacts with recovery.

APG mutual evaluation: where Bangladesh stands

Bangladesh's record with the international standard-setters is mixed. The country was placed on the high-risk jurisdiction list in 2009 and exited in February 2014 after targeted reforms; its last full mutual evaluation was in 2016.[12]

The next full evaluation is scheduled for 2027–28. An APG delegation made a Preliminary Mutual Evaluation Planning visit from 11 to 13 August 2026, meeting regulators, investigators and ministries, with separate sessions for banks, insurers, capital market intermediaries and NGOs.[12] The delegation expressed concern about looting and illicit capital flight from banks and the stock market under the previous government, warned that these risks could affect the 2027–28 rating, and urged "verifiable, real-world results" before the main assessment. It told reporting entities to strengthen customer due diligence, transaction monitoring and suspicious transaction reporting.[12]

The evaluation will test how anti money laundering law Bangladesh has on paper works in practice. Reporting organisations should expect more inspections and data calls in the run-up, and should be able to produce their risk assessments, training records and reporting statistics on request.

Building a corporate AML compliance programme

Rule 6 of the 2019 Rules makes the compliance programme a legal requirement. Every reporting organisation must have its own policy, consistent with international standards, Bangladeshi law and BFIU instructions, approved by its board or highest management committee and reviewed from time to time.[3]

To implement the policy, each reporting organisation must have a compliance programme that includes nomination of a compliance officer in line with BFIU instructions, screening procedures when hiring staff, training of officers, and an independent and impartial audit function.[3] Financial groups must apply it across branches and subsidiaries, including abroad.[3] The sequence below is how we build or remediate a programme.

Swipe or scroll →

For companies outside the regulated sectors

Exporters, manufacturers and other businesses outside the reporting list still need an anti money laundering law Bangladesh compliance position. Their banks must apply due diligence to them, and over-invoicing, under-invoicing or failure to repatriate export proceeds falls within the statutory definition of smuggling money.[1] A proportionate programme covers beneficial ownership records, due diligence on distributors and agents, controls on cash and related-party payments, and a route for escalating red flags. TRW's corporate governance and compliance practice designs these programmes.

Governance points the board should own

The board, not the compliance department, owns the policy, and the minutes should show it. The compliance officer needs direct access to the board or audit committee and the independence to file a suspicious transaction report without business-line approval. And the board should receive regular data on alerts, reports, freezes and training, because that is what an inspector or APG assessor will ask for.

AML advisory: when to bring in counsel

Most anti money laundering law Bangladesh issues are handled in-house. External advice adds most value at five points. The first is design: a policy, risk assessment and procedures for a new licence, product or market entry. The second is the request: a BFIU data call, inspection report or show-cause notice, where the record created now shapes any later penalty.

The third is the freeze, whether by the BFIU, a court or as a section 20A sanctions measure, where deadlines run from publication. The fourth is the investigation: internal inquiries, decisions on whether to file a suspicious transaction report, and ACC or CID proceedings, including applications to quash under section 561A of the Code of Criminal Procedure where they are an abuse of process. The fifth is the transaction: acquisitions or lending where the counterparty is linked to a group under investigation.

For banks and finance companies, our banking and finance practice works with compliance teams on Circular No. 26, reporting processes and regulator engagement. Our overview of banking regulations in Bangladesh sets out the prudential framework that AML compliance sits within.

What to watch in 2026 and 2027

Four developments will shape anti money laundering law Bangladesh applies over the next eighteen months. First, whether the new Parliament passes amendments to the 2012 Act on non-conviction-based recovery, trade-based laundering and mutual legal assistance.[14] Second, the bedding-in of the BFIU's 2026 sector instructions and the 31 December 2026 e-KYC deadline for insurers and capital market intermediaries.[7] [8] Third, whether asset recovery moves from freezing orders to actual repatriation through foreign courts and recovery firms.[10] Fourth, the APG's 2027–28 mutual evaluation, which will judge results rather than rules.[12]

Organisations that come through scrutiny well can show a reasoned risk assessment, consistent due diligence, prompt reporting and an informed board. TRW advises on each of these, from programme design to freeze orders and investigations. Contact TRW to discuss your position.

Frequently asked questions

What is the main anti-money laundering law in Bangladesh?

The Money Laundering Prevention Act 2012, as amended in 2015, supported by the Money Laundering Prevention Rules 2019. Terrorist financing and UN sanctions are covered by the Anti-Terrorism Act 2009.[1] [2] [3]

Which reporting organisations must comply?

Banks, financial institutions, insurers, money changers, remittance businesses, capital market intermediaries, NGOs, NPOs, cooperatives, real estate developers, dealers in precious metals or stones, trust and company service providers, lawyers, notaries and accountants, and any other category notified under the Act.[1]

What is the cash transaction reporting threshold?

Banks must report cash deposits or withdrawals of Tk 10 lakh or more, or the foreign currency equivalent, in a single account on a single day, whether in one or several transactions.[4]

When must a suspicious transaction report be filed?

Immediately and on the organisation's own initiative once a suspicious transaction or attempted transaction is observed. Suspicion, not proof, is the trigger for a suspicious transaction report.[1]

How long must AML records be kept?

At least five years after an account closes or an occasional transaction is carried out, and until final disposal of any related investigation or case.[1] [3]

Can the BFIU freeze an account without a court order?

Yes. It may direct a reporting organisation to suspend or freeze an account for up to thirty days, extendable by thirty days at a time to a maximum of six months. Longer restraint requires a court order under section 14.[1]

What are the penalties for money laundering?

For individuals, four to twelve years' imprisonment and a fine of twice the value involved or Tk 10 lakh, whichever is greater. For entities, a fine of at least twice the value or Tk 20 lakh, and possible cancellation of registration.[1]

Can directors be personally liable?

Yes. Directly involved directors and officers are deemed guilty of an entity's offence unless they prove lack of knowledge or best efforts to prevent it, and the BFIU can fine responsible individuals up to Tk 5 lakh.[1]

How does Bangladesh implement UN sanctions?

Through section 20A of the Anti-Terrorism Act 2009, which requires assets of persons listed under UN Security Council resolutions to be frozen immediately and without prior notice, with fines of up to Tk 25 lakh or twice the funds for reporting organisations that fail to act.[2]

When is Bangladesh's next APG mutual evaluation?

The next full evaluation is scheduled for 2027–28. An APG planning visit took place from 11 to 13 August 2026.[12]