Bank Account Freeze Writs in Bangladesh 2026: BFIU, Tax, ACC and Court Freezes

by Barrister Tahmidur Rahman | Oct 23, 2026 | Banking & Finance, Insights | 0 comments

TRW Insight / Bangladesh

Freezes by the BFIU, tax intelligence units and other agencies now reach far beyond their targets. Each power has conditions and time limits, and the High Court Division has set freezes aside where they were missing or had expired.

Updated 23 October 2026Legal insightBangladesh13 min read

Bank account freeze writ: how to unlock accounts in Bangladesh in 2026

A bank account freeze writ is often the fastest way to restore access to money that a Bangladeshi bank has blocked on instructions from the Bangladesh Financial Intelligence Unit, the tax authorities, the Anti-Corruption Commission or another agency. Since August 2024 freezes have become a routine tool of asset recovery and tax enforcement, and many reach far beyond their original targets: spouses, children, employees and companies with no allegation against them. Each freezing power has its own legal conditions and time limits. When those conditions are missing or have expired, Article 102 of the Constitution lets the High Court Division set the freeze aside.

This guide maps the main freezing powers, the 2024 to 2026 surge in freezes, the grounds on which the High Court Division has quashed them, the cases where a writ is the wrong remedy, and the practical steps for getting accounts reopened.

Bank account freeze writ — bank branch in Dhaka where frozen accounts are held
Banks comply with freezing orders immediately and lift them only on clear authority

Summary: Bank accounts in Bangladesh can be frozen by the BFIU for up to 30 days, extendable to six months, under the Money Laundering Prevention Act 2012; by a court on application under the same Act; by tax officials under the Income Tax Act 2023 and the VAT Act 2012; and by a court on the Anti-Corruption Commission's application. The High Court Division has set aside freezes made without statutory authority, after their time limit expired, without specific information against the person affected, or without a lawful underlying demand.

Key point: In June 2026 the High Court Division held that once a BFIU freeze has run its statutory course of 30 days plus six extensions, banks have no authority to keep blocking the account, and must again follow the customer's instructions.

At a glance

01

BFIU freeze

Section 23 of the Money Laundering Prevention Act 2012: 30 days, extendable by 30-day periods to six months.

02

Court freeze

Section 14 of the same Act: a court order on written application, published, with a 30-day appeal to the High Court Division.

03

Tax freezes

Income Tax Act 2023 sections 221 and 223, and VAT Act 2012 section 95, each with their own conditions.

04

ACC freezes

Require a court order; an ACC officer's "no debit" letter to a bank has been held unlawful.

05

Writ grounds

No power, expired period, no specific information, blanket family freezes and no underlying demand.

Table of Contents

Why a bank account freeze writ matters in 2026

The scale of freezing since the 2024 change of government is unprecedented. Figures presented by Bangladesh Bank to Parliament's Standing Committee on Estimates on 2 October 2026 put assets covered by court seizure, attachment or freezing orders at about Tk 769.84 billion, including bank accounts, shares, BO accounts and property, with Tk 573.26 billion in Bangladesh and Tk 196.58 billion abroad. The same briefing named six individuals and business groups selected for civil recovery proceedings in the first phase.[11]

Alongside those court-ordered measures, administrative freezes by the BFIU and the tax intelligence units have reached many people who are not accused of anything: relatives, directors, employees, suppliers and companies in which a target once held shares. A bank account freeze writ is often the only practical remedy for them, because the statutory remedies attached to court orders are not available against administrative letters sent directly to banks.

The freezing powers and their limits

The first step in any bank account freeze writ is to identify which power the authority used. The bank's notice to the customer often does not say, so the order itself must be obtained.

BFIU administrative freezes

Section 23(1)(c) of the Money Laundering Prevention Act 2012 allows Bangladesh Bank, acting through the BFIU, to order a reporting organisation to suspend or freeze transactions on an account for up to 30 days where there are reasonable grounds to suspect that money or property has been deposited by committing an offence. The order may be extended by further periods of 30 days, up to a maximum of six months, if necessary to find out correct information about the account's transactions.[2] A bank that fails to comply may be fined between the balance and twice the balance held when the order was made.[2]

That penalty explains why banks comply instantly and are reluctant to lift a freeze without written clearance.

Court freezes under the Money Laundering Prevention Act

Longer restraint requires a court. Under section 14, the court may freeze or attach property involved in money laundering or another offence on a written application by the Anti-Corruption Commission or an authorised agency, which must describe the property, give grounds and primary evidence, and explain the risk of transfer. The order must be published in the official Gazette and in two national dailies.[2] A third party with an interest in the property may apply for its return within 30 days of the published notice, and any aggrieved person may appeal to the High Court Division within 30 days, although the order stays in force during the appeal unless the appellate court directs otherwise.[2]

Anti-Corruption Commission freezes

The Anti-Corruption Commission Rules 2007 require the Commission, where it is satisfied that property has been acquired through a scheduled offence, to authorise an officer to apply to the Senior Special Judge or Special Judge for a freezing or attachment order, supported by a description of the property, the grounds and primary evidence.[6] An ACC officer has no power to freeze an account by letter.

Tax and VAT freezes

Under the Income Tax Act 2023, section 221(3) lets the Deputy Commissioner of Taxes direct a bank holding the assessee's money to pay tax that is due, and section 214(6) treats an assessee with a pending appeal as not in default. Section 223 separately allows the Director General of the Central Intelligence Cell or a Commissioner, on specific information of concealed income or investment, to order that money or assets not be moved, for one year, extendable with Board approval by no more than one year in total.[3] Under the VAT Act 2012, section 95 allows a freeze only to recover arrear tax.[4]

Bank account freeze writ — freezing order and bank statements under review
The first task is to obtain the freezing order itself

Grounds for a bank account freeze writ

The High Court Division's recent decisions fall into five clear patterns. Each identifies a statutory condition that the authority failed to meet.

The freeze has expired

In Rubayet Hossain v Bangladesh Bank, decided on 15 June 2026, the BFIU wrote to every bank on 4 March 2025 under section 23 of the 2012 Act, directing them to suspend all accounts of the petitioner's father and his family members. The petitioner's own bank and BO accounts were blocked without notice, and his bank refused to give him a copy of the order. The BFIU later told the Court that the order had been extended six times and had expired on 30 September 2025, and that it had referred the matter to the ACC, the CID and the tax Central Intelligence Cell. The banks nevertheless kept refusing payment instructions.[5]

The High Court Division held that the BFIU could impose a 30-day restriction and extend it six times, that there was no scope to extend it further, and that once the period had run, the banks had no authority to keep the account blocked. Their refusal was without lawful authority, and they were under a legal obligation to follow the customer's instructions. The Court disposed of the Rule with a direction to the respondents to perform their duties under the law.[5]

In Belayet Hosen v Anti-Corruption Commission, decided on 27 June 2021, an ACC inquiry officer wrote to a bank asking it to mark the petitioner's fixed deposits "no debit", without any court order. The High Court Division held that, without the permission of the court concerned, no one, not even the Commission, has power to freeze or attach property alleged to be crime-acquired. It found the letter illegal, arbitrary, without jurisdiction and a colourable exercise of power, while leaving the ACC free to act lawfully.[6]

No specific information against the person affected

The tax freezes of late 2025 produced two leading 2026 judgments. In Md Sirajul Islam v National Board of Revenue, decided on 23 April 2026, section 223 notices froze accounts, FDRs and credit facilities of the petitioners, their family and their businesses, even though the petitioners had paid substantial taxes and their returns had been accepted. The Court held that section 223 requires definite information about concealment before the freeze, found that the information was obtained from the banks only afterwards, described the sequence as putting the cart before the horse, and ordered all accounts reopened within seven days.[7]

Blanket freezes on family members

In Sadrul Hasan v Commissioner of Taxes, decided on 8 July 2026, the authority first froze the FDRs of the petitioner's "family members" in general terms and named them only in a later memo. The Court held that section 223 requires individualised satisfaction about each person whose assets are frozen, and that a blanket sweep later regularised by naming individuals cannot meet that requirement. It set the freezes aside and ordered the accounts reopened within seven days.[8] The principle has obvious force against BFIU and other orders that freeze relatives as a class.

No underlying demand

Recovery freezes need a debt. In China Bangladesh Electronics (Pvt) Ltd v National Board of Revenue, decided on 17 December 2023, the Board directed a VAT Commissioner to lock four companies' BINs and freeze their bank accounts. The High Court Division held that the power to freeze for unpaid VAT depended on a pending demand, that none had been shown, and that the Board was not the officer empowered to act, and it declared the order without lawful authority.[9]

Companies, employees and other third parties

Freezes aimed at an individual regularly catch companies in which that person is or was a director or shareholder, and the employees, suppliers and lenders who depend on those companies. A company is a separate legal person, and its accounts can be frozen only if the statutory conditions are met in relation to the company itself. A bank account freeze writ brought by a company should therefore show its own ownership structure, its own tax position and the commercial source of the balances, rather than simply denying the allegations against the individual.

Third parties should also look at the order closely. A BFIU letter that names a person "and family members" or "institutions in which they have interests" may be applied by banks far more widely than intended. The Rubayet Hossain case shows that a person outside the core investigation can obtain relief once the order's terms and duration are tested in court.[5]

Natural justice and the right to know

Freezes are usually imposed without prior notice, because notice could defeat their purpose. That does not make the affected person's rights disappear. In Sirajul Islam the Court observed that a section 223 freeze issued only because the assessee might move funds if warned runs counter to the principle of audi alteram partem.[7] In Rubayet Hossain the petitioner learnt of the BFIU letter only by visiting the BFIU's office after his bank declined to give him a copy.[5]

Articles 31 and 42 of the Constitution protect the right to be treated in accordance with law and the right to hold property, and Article 102(1) lets the High Court Division give directions to enforce fundamental rights.[1] A bank account freeze writ should plead both the statutory defect and the constitutional rights affected, and ask the Court to direct disclosure of the freezing order if it has been withheld.

Bank account freeze writ — calendar tracking the expiry of a BFIU freeze
BFIU freezes cannot run beyond six months

When a writ is not the right remedy

Court orders under the Money Laundering Prevention Act

Where a court has frozen or attached property under section 14, the Act provides its own remedies: an application for return by a third party within 30 days of publication, and an appeal to the High Court Division within 30 days.[2] A writ against a judicial freezing order is unlikely to be entertained while those remedies are available, and the short deadlines make speed essential.

Tax freezes linked to a pending revision or appeal

Where the freeze follows a tax assessment, the Court may prefer to let the statutory process run while protecting the account. In Engineer Md Mohosin v Commissioner of Taxes, decided on 5 July 2026, the High Court Division quashed a revisional order for breach of natural justice, remitted the case, and stayed the freezing of the petitioner's accounts until the revision was decided. Earlier, the Appellate Division had modified the interim stay on the Government's application and directed a prompt hearing.[10] Our guide to tax writ petitions explains those routes in detail.

Choosing the right respondent

Writs lie against statutory authorities such as Bangladesh Bank, the BFIU, the NBR and the ACC. Commercial banks are a different matter. In Md Rokanuzzaman v Bangladesh Bank, decided on 29 July 2026, the High Court Division followed the Appellate Division's holding that actions of Rupali Bank taken after its conversion into a public limited company cannot be challenged under Article 102, while confirming that Bangladesh Bank remains amenable as a statutory authority.[12] In freeze cases, the practical solution is to challenge the authority's order and join the banks so that the Court's direction binds them, as happened in Rubayet Hossain.[5]

How to run a bank account freeze writ

The general procedure for writ petitions is set out in our guide to writ petitions in Bangladesh. Freeze cases have their own rhythm, because every day of a blocked operating account damages the business. The steps below reflect how these petitions are best prepared.

Step 01

Obtain the order

Ask the bank in writing for the freezing letter, its reference and date, and request it from the issuing authority if refused.

Step 02

Identify the power

Establish whether the freeze rests on the 2012 Act, a court order, the Income Tax Act, the VAT Act or nothing at all.

Step 03

Check the clock

Calculate the BFIU six-month limit, the section 223 one-year period and any 30-day court deadlines.

Step 04

Test the conditions

Check for specific information, individual naming, a pending demand or a court order, as the power requires.

Step 05

Gather proof of source

Assemble tax returns, salary records, sale deeds and bank statements showing the legitimate source of balances.

Step 06

Move for a Rule and release

File against the authority, join the banks, and seek release of operating or salary accounts at the motion stage.

Step 07

Defend the interim order

Prepare for a leave petition in the Appellate Division and press for an early final hearing.

Step 08

Serve and follow up

Serve the judgment on every bank and the authority, and track reopening within the time the Court fixes.

Interim relief and the Appellate Division

Interim orders releasing frozen accounts are routinely challenged by the State. In Rubayet Hossain, the High Court Division's interim direction to release the accounts was stayed by the Appellate Division's Chamber Judge, who directed the Rule to be heard quickly.[5] In Mohosin the Appellate Division modified the stay and directed disposal within a fixed time.[10] Article 102(4) also requires notice to the Attorney General before an interim order likely to harm the public interest is made.[1] A realistic request often works better: release of salary and operating accounts, or of balances above a defined sum, while the rest stays frozen pending the hearing.

Comparing the freezing powers

The table below summarises each freezing power and the usual line of attack. On a phone, scroll it sideways.

Freezing powers in Bangladesh and the usual line of challenge
Freezing powerLegal basisDurationUsual remedyCommon defect
BFIU administrative freezeMLPA 2012 s 23(1)(c)30 days, up to 6 monthsWritExpired period; family members frozen as a class
Court freeze or attachmentMLPA 2012 s 14Until court orders otherwiseReturn application or appeal within 30 daysWeak grounds or third-party property
ACC freezeACC Rules 2007 r 18As ordered by Special JudgeWrit if no court order; otherwise court remediesOfficer's letter without court order
Tax interim freezeITA 2023 s 2231 year, plus up to 1 yearWritNo specific prior information; no individual satisfaction
Tax recovery through bankITA 2023 s 221Until tax paidWrit or appealAppeal pending under s 214(6)
VAT recovery freezeVAT Act 2012 s 95Until arrears paidWritNo lawfully determined demand
Bank account freeze writ — lawyers preparing a petition to the High Court Division
A focused petition asks for release of what the business needs most

Bank account freeze writ: practical points for 2026

  • Get the order: ask the bank in writing for the freezing letter and its reference number, and ask the issuing authority directly if the bank refuses.[5]
  • Count the days: a BFIU freeze cannot exceed six months, and a section 223 tax freeze cannot exceed one year plus one year of extensions.[2] [3]
  • Show you are a separate person: independent income, tax returns and the source of each balance answer the blanket family freeze.[8]
  • Watch the 30-day windows: court freezes under the 2012 Act carry 30-day deadlines for third-party claims and appeals.[2]
  • Expect parallel referrals: a BFIU freeze is often followed by referrals to the ACC, CID or tax authorities, so prepare for the next stage.[5]

For the regulatory background, see our guides to anti-money laundering law in Bangladesh and the Anti-Corruption Commission, and for VAT recovery freezes our guide to VAT writ petitions. TRW's constitutional and writ litigation practice and banking and finance litigation team act on bank account freeze writ petitions, court freezing orders, and the investigations that follow them.

Frequently asked questions

Who can freeze a bank account in Bangladesh?

The BFIU under the Money Laundering Prevention Act 2012, courts on application by the ACC or an authorised agency, income tax authorities under the Income Tax Act 2023, and VAT officers recovering arrear tax under the VAT Act 2012.[2] [3] [4]

How long can the BFIU freeze my account?

Thirty days at first, extendable by 30-day periods to a maximum of six months. After that the BFIU order lapses, and the High Court Division has held that banks cannot keep the account blocked on its basis.[2] [5]

Can the ACC freeze my account without a court order?

No. The High Court Division has held that an ACC officer's letter asking a bank to mark accounts "no debit", without a court order, is without lawful authority.[6]

My accounts were frozen because a relative is under investigation. What can I do?

A bank account freeze writ can challenge a blanket freeze on family members. In 2026 the High Court Division required individualised satisfaction about each person whose assets are frozen.[8]

Can the tax office freeze my account on suspicion alone?

Section 223 requires specific information of concealed income or investment before the freeze, and the High Court Division has set aside freezes where that information was gathered only afterwards.[3] [7]

Can VAT officers freeze my bank account?

Only to recover arrear tax under section 95 of the VAT Act 2012. A freeze without a pending, lawfully determined demand has been held unlawful.[4] [9]

How do I challenge a court order freezing my property under the Money Laundering Prevention Act?

By appeal to the High Court Division within 30 days, or, for a third party with an interest in the property, by applying to the court for its return within 30 days of the published notice.[2]

Can I file a writ against my bank?

A commercial bank is generally not amenable to Article 102 in its own right, but it can be joined as a respondent to a writ against the authority's freezing order so that the Court's directions bind it.[5] [12]

Will the court release my accounts immediately?

Sometimes, at the Rule stage, but the State often seeks a stay from the Appellate Division. A limited request, such as release of operating or salary accounts, is more likely to survive.[5] [10]

How much in assets is currently frozen in Bangladesh?

Bangladesh Bank told a parliamentary committee in October 2026 that court orders covered assets worth about Tk 769.84 billion at home and abroad.[11]

Source register

Primary legal and regulatory sources

Materials checked on 23 October 2026. Confirm the current official text before relying on any provision.

  1. Constitution of the People's Republic of Bangladesh (Articles 31, 42 and 102) — Laws of Bangladesh
  2. Money Laundering Prevention Act 2012 (Act No. 5 of 2012), as amended — Laws of Bangladesh
  3. Income Tax Act 2023 — authentic English text (SRO No. 404-Law/2025), National Board of Revenue
  4. Value Added Tax and Supplementary Duty Act 2012 — authentic English text (SRO No. 440-Law/2025/326-Mushak), Laws of Bangladesh
  5. High Court Division, Rubayet Hossain v Bangladesh Bank, Writ Petition No. 18927 of 2025 (15 June 2026)
  6. High Court Division, Belayet Hosen v Anti-Corruption Commission, Writ Petition No. 1539 of 2021 (27 June 2021)
  7. High Court Division, Md Sirajul Islam v National Board of Revenue, Writ Petition No. 22265 of 2025 (23 April 2026)
  8. High Court Division, Sadrul Hasan v Commissioner of Taxes, Income Tax Intelligence and Investigation Unit, Writ Petition No. 2364 of 2026 (8 July 2026)
  9. High Court Division, China Bangladesh Electronics (Pvt) Ltd v National Board of Revenue, Writ Petition No. 4041 of 2017 (17 December 2023)
  10. High Court Division, Engineer Md Mohosin v Commissioner of Taxes, Taxes Zone-1, Chattogram, Writ Petition No. 2508 of 2026 (5 July 2026)
  11. Prothom Alo, 2 October 2026 — Assets worth nearly Tk 770b seized, frozen at home, abroad
  12. High Court Division, Md Rokanuzzaman v Bangladesh Bank, Writ Petition No. 12714 of 2025 (29 July 2026)

Related TRW assistance

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TRW acts on bank account freeze writs against BFIU, tax, VAT and ACC freezes, court freezing orders and the investigations that follow them. Explore our constitutional and writ litigation practice and banking and finance litigation practice, or contact TRW to discuss your matter.

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