Citizenship by Investment for Bangladeshis: Dual Nationality, Foreign Exchange and Tax in 2026

Citizenship by investment for Bangladeshis: the 2026 legal position

Citizenship by investment for Bangladeshis is a legal question long before it is a commercial one. A Caribbean passport, a European residence permit or a UAE golden visa may be available to anyone who can pay, but a Bangladeshi citizen must first answer three questions under Bangladeshi law: will acquiring the new nationality cost them their Bangladeshi citizenship, can the investment lawfully be funded under the Foreign Exchange Regulation Act 1947, and will the new assets be disclosed to the National Board of Revenue? Getting any of these wrong can turn a mobility plan into a criminal investigation.

The stakes rose sharply in 2025, when the NBR's Central Intelligence Cell reported evidence of 352 passports bought by Bangladeshis in nine countries, including the principal Caribbean citizenship programmes, Malta and Turkey, as part of a wider inquiry into laundered assets abroad. This guide explains the dual nationality rules and the approved-country list, the foreign exchange and tax constraints that apply to residents, the anti-money laundering scrutiny on both sides, the programmes themselves as they stand in October 2026, and the lawful steps for those who are eligible.

Summary: A Bangladeshi may keep Bangladeshi citizenship alongside citizenship of a state in Europe or North America or of a state the government has notified, and should obtain a dual nationality certificate. A person resident in Bangladesh cannot, however, send money abroad to buy a passport, property or residence without Bangladesh Bank permission, and no published general permission covers investment migration. Residents must also declare offshore assets in their tax return or face a penalty equal to their value. The lawful route is generally limited to funds earned and held abroad while non-resident.

Key point: Remitting money through hundi or other informal channels to pay for a foreign passport or golden visa is not a grey area. It contravenes the Foreign Exchange Regulation Act 1947, which carries up to seven years' imprisonment and confiscation, and can amount to money laundering, which carries four to twelve years. Investigators in 2025 specifically traced passports bought by Bangladeshis abroad.

At a glance

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Table of Contents

What citizenship by investment for Bangladeshis actually involves

Investment migration covers two different products. Citizenship by investment grants a passport, usually within months, in exchange for a donation to a government fund or a qualifying investment such as real estate. Residence by investment, often called a golden visa, grants a residence permit that may lead to citizenship only after years of lawful residence and a separate naturalisation application. The distinction matters in Bangladeshi law, because only an acquired nationality engages the dual citizenship rules, while both routes engage foreign exchange, tax and anti-money laundering law.

For most applicants, the attraction is mobility: visa-free travel, a base for business, schooling for children or a plan B. Those are legitimate objectives. The legal risk lies almost entirely in how citizenship by investment for Bangladeshis is funded and reported, and in whether the chosen country is one with which Bangladeshi citizenship can lawfully be held.

The people who can approach this with the fewest obstacles are non-resident Bangladeshis who have built their wealth abroad. The people who face the most obstacles are residents of Bangladesh whose wealth is in taka. Most of this guide is about the gap between those two positions.

Bangladesh's dual citizenship rules

The starting point: section 14 of the Citizenship Act 1951

Section 14 of the Citizenship Act 1951 is headed as a prohibition on dual citizenship. It provides that a person who is a citizen of Bangladesh under the Act and is at the same time a citizen or national of another country ceases to be a citizen of Bangladesh unless he makes a declaration under the laws of that other country renouncing it. Sub-section (1A) disapplies the rule for anyone under twenty-one.[1]

The exception: Article 2B of the 1972 Order

The exception lies in Article 2B of the Bangladesh Citizenship (Temporary Provisions) Order 1972. Clause (1) disqualifies a person who owes or acknowledges allegiance to a foreign state, but its proviso states that a citizen of Bangladesh shall not, merely by being or becoming a citizen of a state specified in clause (2), cease to be a citizen of Bangladesh. Clause (2) allows the government to grant Bangladeshi citizenship to a citizen of any state of Europe or North America, or of any other state the government specifies by notification in the official gazette.[1]

Read together, the provisions give a clear practical rule. Acquiring citizenship of a European or North American state, or of a notified state, does not by itself end Bangladeshi citizenship. Acquiring citizenship of a state outside that list leaves the person exposed to the general rule in section 14. The English Court of Appeal, analysing these provisions in 2019, noted that their interaction, including the effect of reaching twenty-one, can be contested, which is why a formal certificate matters.[1]

The approved-country list

The list has grown in stages. On 27 February 2023 the cabinet approved an SRO extending dual citizenship to 44 more countries, taking the total from 57 to 101. The published additions included nineteen African states, eleven South American states, Fiji and twelve Caribbean states: Cuba, the Dominican Republic, Haiti, the Bahamas, Jamaica, Trinidad and Tobago, Dominica, Saint Lucia, Barbados, Saint Vincent and the Grenadines, Grenada and Saint Kitts and Nevis.[2] By January 2026 the list was reported to stand at 103 countries.[3]

For anyone considering citizenship by investment for Bangladeshis, the list is the first filter. Four of the five Eastern Caribbean programme states appear by name in the 2023 additions. Antigua and Barbuda was not among the countries named in the published report of the additions, which listed only 43 of the 44, so its status should be confirmed against the gazetted SRO before any application.[2] European programmes fall within the Europe limb of Article 2B itself.[1]

The dual nationality certificate

A Bangladeshi who acquires an approved second nationality should obtain a dual nationality certificate, the government's formal record that Bangladeshi citizenship continues alongside the foreign one. Since 16 May 2025 applications are made online through the Security Services Division portal of the Ministry of Home Affairs, with documents uploaded and the government fee paid electronically; paper applications at missions and the ministry stopped from 15 May 2025, and approved certificates are issued digitally with a QR code.[4] Our guide to the dual nationality certificate in Bangladesh walks through the documents and common refusals, and our overview of Bangladesh citizenship law covers renunciation and restoration.

Political and public office

Dual nationality carries public-law consequences. Article 66(2) of the Constitution disqualifies a person who acquires the citizenship of a foreign state from election to Parliament. Ahead of the February 2026 election, the Election Commission reviewed dual citizenship objections against 25 candidates, upholding 23 candidacies and cancelling two, and the Appellate Division had in 2024 upheld the cancellation of a nominee's candidacy on the same ground.[3] Anyone with political ambitions, or in a family where they exist, should treat a second passport as a decision with long consequences.

The foreign exchange wall: why residents cannot simply wire the money

The single biggest constraint on citizenship by investment for Bangladeshis is the Foreign Exchange Regulation Act 1947. It applies to every person in or resident in Bangladesh and turns most outward capital movements into permission-based transactions.

Buying and paying foreign exchange

Section 4 confines dealings in foreign exchange to authorised dealers and requires foreign exchange acquired for a stated purpose to be used only for that purpose. Since a 2015 amendment, a resident may buy foreign exchange from an authorised dealer for a current account transaction, but capital account transactions are permissible only in the classes Bangladesh Bank specifies in consultation with the government.[5] Section 5 separately prohibits a person in or resident in Bangladesh from making payments to, or creating rights to payment in favour of, persons resident outside Bangladesh except as Bangladesh Bank permits.[5]

A contribution to a Caribbean sovereign development fund, a deposit on a Lisbon fund subscription or the purchase of a Dubai apartment is a capital transfer to a non-resident. It needs a permission that the published rules do not give to individuals.

The only published outward equity route is for exporters

The Capital Account Transaction (Overseas Equity Investment) Rules 2022, issued on 9 January 2022 under the 1947 Act, allow exporters to invest abroad from their export retention quota accounts, up to 20 per cent of average annual export earnings over the previous five years or 25 per cent of net assets, subject to scrutiny by a committee chaired by the Governor of Bangladesh Bank. Returns must be repatriated within 30 days, and misuse is treated as money laundering.[6] These rules are for business investment by exporting companies. They do not provide a route for an individual to buy citizenship or residence abroad, and diverting company funds to that end would be a misuse.

Penalties and disclosure powers

Contravening the Act, attempting to contravene it or abetting a contravention is punishable by imprisonment of up to seven years, a fine or both, tried by a Sessions Judge sitting as a tribunal, which may also order confiscation of the currency or property involved. Directors and officers knowingly party to a company's offence are liable personally.[5]

Section 19 lets the government or Bangladesh Bank direct any citizen or resident to make a return of foreign exchange, foreign securities and immovable property or businesses held outside Bangladesh, and section 17 restricts residents from settling property on trusts for persons resident abroad without permission.[5] Structures that hold a foreign passport-linked asset through a trust or nominee do not escape the Act. See our guides to foreign exchange regulations in Bangladesh and outward remittance rules.

Lawful funding routes for citizenship by investment for Bangladeshis

Because the restrictions bite on residents and on money in Bangladesh, the lawful routes depend on where the money was earned and where the investor lives.

Earnings abroad while non-resident

Under a 1958 government notification under section 9 of the Act, citizens of Bangladesh and persons residing in Bangladesh continuously for six months or more must sell foreign exchange they acquire, whether held in Bangladesh or abroad, to an authorised dealer within one month. The notification does not apply to foreign exchange held by Bangladesh nationals in accounts abroad that were opened and credited while they were working abroad as residents outside Bangladesh.[5] A non-resident Bangladeshi professional in London or Dubai who funds a programme from salary and savings earned and held there is therefore in a fundamentally different position from a Dhaka resident.

The exemption is specific. It covers foreign exchange in accounts opened and credited while working abroad. It does not cover money remitted from Bangladesh into those accounts, income from businesses in Bangladesh, or new foreign income earned after the person returns and becomes resident again. Keep the employment contracts, salary records and bank statements that prove the source and timing, because programme due diligence and any later Bangladeshi inquiry will ask for them.

Specific permission

A resident can apply to Bangladesh Bank, through an authorised dealer, for specific permission for a capital transaction. Approval is discretionary and the published framework is restrictive, so an applicant should expect scrutiny of purpose and should not commit funds abroad before written approval. An agent who suggests that a programme can be paid for first and regularised later is suggesting a contravention.

What is not a lawful route

Hundi and other informal transfer systems, over-invoicing of imports, under-invoicing of exports, routing through a relative's foreign account, or using an annual travel allocation for an investment are all contraventions of the 1947 Act, and some will also be money laundering. Foreign exchange obtained for one purpose must be used for that purpose only.[5] TRW does not advise on, and will not assist with, any of these arrangements.

Tax residency, wealth statements and offshore assets

Tax law adds a second layer of exposure to citizenship by investment for Bangladeshis. Under the Income Tax Act 2023, an individual is resident in an income year if present in Bangladesh for at least 183 days, or for at least 90 days having been present for 365 days or more in the four preceding years.[7] A resident is taxed on worldwide income, including income that accrues or arises outside Bangladesh.[7]

Declaring assets abroad

Section 165 requires an individual's return to contain a statement of all assets and liabilities located in Bangladesh and outside Bangladesh.[7] A citizenship investment, a foreign property, a fund subscription or a foreign bank balance must therefore appear in a resident's return.

The offshore asset penalty

Section 21 is severe. Where a resident Bangladeshi is found to own an offshore asset not disclosed in the return and cannot satisfactorily explain its nature and source, the Deputy Commissioner of Taxes must impose a penalty equal to its fair market value, after a hearing, and may recover it by confiscating or selling assets held by the taxpayer or by others on the taxpayer's behalf. The penalty is without prejudice to liability under any other law, and tax officers may conduct onshore and offshore investigations.[7]

The interaction with foreign exchange law is the trap. Disclosing an asset bought with money that left Bangladesh unlawfully invites a foreign exchange and money laundering inquiry; failing to disclose it invites the section 21 penalty. The only safe position is an asset acquired lawfully and reported fully. Our private wealth tax practice advises on residence planning and disclosure.

Source of funds and anti-money laundering scrutiny

On the programme side

Programme countries have tightened due diligence under pressure from the United States, the United Kingdom and the European Union. In September 2025 the five Eastern Caribbean programme states, Antigua and Barbuda, Dominica, Grenada, Saint Kitts and Nevis and Saint Lucia, signed an agreement creating a regional regulator, the Eastern Caribbean Citizenship by Investment Regulatory Authority, to oversee their programmes under uniform standards, keep regional registers of applicants, licensees and developers, publish annual compliance reports, fine and revoke non-compliant licensees, and require biometric data from new applicants and from existing passport holders at renewal.[12] Applicants should expect detailed questions on the origin of every amount, including how it left their home country.

On the Bangladeshi side

Under the Money Laundering Prevention Act 2012, money laundering is punishable by four to twelve years' imprisonment and a fine linked to twice the value of the property involved or Tk 20 lakh, and the court may order forfeiture of the property.[8] Banks report suspicious transactions to the Bangladesh Financial Intelligence Unit, and an attempt to move funds in small amounts or through third parties is precisely the pattern they are trained to detect. Our guide to anti-money laundering law in Bangladesh explains reporting and investigation.

Enforcement: what the 2025 investigations show

In August 2025 the NBR's Central Intelligence Cell reported to the Chief Adviser that it had traced nearly Tk 40,000 crore in assets allegedly laundered from Bangladesh, identified 346 properties abroad and found evidence of 352 passports bought by Bangladeshis in nine countries: Antigua and Barbuda, Austria, Dominica, Grenada, Saint Kitts and Nevis, North Macedonia, Malta, Saint Lucia and Turkey. Investigations had begun in January 2025 across seven cities in five countries, and the Anti-Corruption Commission, the CIC and the police Criminal Investigation Department were directed to coordinate.[9]

Three lessons follow. First, a foreign passport is not a shield: the investigators are looking at the passports themselves as evidence of where money went. Second, the list of countries mirrors the main investment migration markets, so the programmes Bangladeshis use are known to the authorities. Third, the investigative effort is multi-agency and international, which means that information disclosed to a programme or to a foreign bank may reach Bangladeshi authorities through cooperation channels. Anyone already holding a second citizenship or foreign asset acquired without proper permission should take advice on their position now, before an inquiry starts. See our page on bail in money laundering cases.

The main programmes in 2026: verified facts

The programme landscape has changed significantly since 2023. The points below are limited to developments we have verified; programme rules change often, and every figure should be checked with the programme authority before commitment.

Eastern Caribbean

The five Eastern Caribbean states operate citizenship programmes and, from 2025, a common regulatory framework. Their heads of government committed to enact enabling legislation for the regional regulator by October 2025, its headquarters will be in Grenada, and it becomes operational thirty days after the fifth ratification.[12] Travel access, the main attraction, is under pressure: the United Kingdom has revoked visa-free entry for Dominica nationals, the United States has considered travel restrictions on four Caribbean programme countries, and the EU has proposed legislation allowing suspension of visa-free travel for countries running citizenship programmes.[12]

Malta

On 29 April 2025, in Commission v Malta (C-181/23), the Court of Justice of the European Union held that Malta's investor citizenship scheme, which granted nationality in exchange for predetermined payments or investments, breached EU law because EU citizenship may not be commodified through financial transactions. The scheme cannot continue in that form.[10] For Bangladeshis, Maltese citizenship by investment should be treated as closed unless and until Malta legislates a compliant replacement.

Portugal

Portugal's golden visa is a residence route, not citizenship by investment. The Mais Habitação reforms of October 2023 removed real estate investment and capital transfer options. Remaining routes include a regulated investment fund of at least EUR 500,000, scientific research of EUR 500,000, a business creating at least five jobs and arts or heritage support of EUR 250,000, with minimum stays of seven days a year.[11]

The path to citizenship has also lengthened: Organic Law No. 1/2026, in force from 19 May 2026, raised the residence period for naturalisation to ten years for nationals of states outside the EU and the Portuguese-speaking community and counts residence only from the first residence permit, although applications filed before that date are assessed under the old law.[13]

United Arab Emirates

The UAE golden visa is a ten-year residence visa. One route requires property worth at least AED 2 million, which may be combined across several properties, but it does not confer citizenship.[14] Because it is residence rather than nationality, it does not engage Bangladesh's dual citizenship rules, but the purchase still engages the foreign exchange, tax and anti-money laundering rules discussed above. For US routes, see our guide to the EB-5 investor visa.

The table below compares these options for Bangladeshi applicants. On a phone, scroll it sideways.

Three common scenarios

The same rules produce very different answers depending on the facts. Three situations account for most of the enquiries we receive about citizenship by investment for Bangladeshis.

The non-resident professional

A Bangladeshi engineer has worked in the Gulf for twelve years, is tax resident there and holds savings in a local bank account opened while employed. She wants a Caribbean passport for travel. Provided the country is on the approved list, she funds the application from those savings and she obtains a dual nationality certificate afterwards, her position is broadly sound. Her main tasks are documentary: proving the source of funds to the programme and keeping records in case she later returns to Bangladesh and becomes resident, when her foreign assets will have to appear in her tax return.[5] [7]

The Dhaka business owner

A resident industrialist with wealth in Bangladesh wants a European residence permit for his family. He has no lawful pool of foreign exchange abroad. Unless Bangladesh Bank grants specific permission, he cannot fund the investment from Bangladesh, and company export earnings may be used abroad only for genuine business investment under the 2022 rules.[6] The realistic options are to seek permission openly, to defer until a lawful source exists, or to pursue a route that does not require an outward capital transfer. Any agent offering to move the money informally is offering him a criminal record.

The existing holder

A returning Bangladeshi already holds a passport bought years ago, funded in ways he cannot now document. The priorities are to confirm whether the country is on the approved list, to assess his exposure under the 1947 Act, the 2012 Act and section 21 of the Income Tax Act, and to plan any disclosure carefully with advice, because each regime interacts with the others.[7] [8] Doing nothing is itself a decision, and the 2025 investigations show it is not a safe one.[9]

The risks in practice

The disputes and investigations we see around citizenship by investment for Bangladeshis tend to fall into five categories.

• Loss of Bangladeshi citizenship: acquiring the nationality of a state outside the approved list engages section 14, with consequences for land ownership, inheritance, voting and public office.[1]
• Criminal exposure for funding: unauthorised outward payments contravene the 1947 Act and may be money laundering.[5] [8]
• Tax penalties: an undisclosed offshore asset attracts a penalty equal to its fair market value.[7]
• Programme risk: schemes close or change, as Malta's did, and visa-free access can be withdrawn, as Dominica's UK access was.[10] [12]
• Agent and fraud risk: unregulated intermediaries sometimes promise passports through unofficial channels or arrange payment routes that are themselves unlawful. Deal only with authorised agents of the programme and insist that every payment goes through regulated banking channels.

The institutions involved on the Bangladeshi side are summarised below.

Step-by-step: a lawful approach

For a Bangladeshi who is genuinely eligible, citizenship by investment for Bangladeshis can be pursued lawfully. The sequence below keeps the process within the law and produces the documents that both the programme and the Bangladeshi authorities will expect.

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Families should also think about the next generation. Children under twenty-one are outside the section 14 rule, but their position on reaching that age deserves attention, and succession and land planning in Bangladesh should anticipate any foreign nationality.[1] Our global mobility and immigration practice coordinates these questions with foreign counsel.

Citizenship by investment for Bangladeshis: what to watch in 2026 and beyond

Four developments will shape the market. First, implementation of the Eastern Caribbean regulator and the response of the United States, United Kingdom and EU to Caribbean programmes, which will decide whether those passports keep their travel value.[12] Second, how EU states respond to the Malta judgment, which casts doubt on any purely payment-based route to EU citizenship.[10] Third, the continuing NBR, ACC and CID work on assets and passports abroad.[9] Fourth, any revision of Bangladesh's approved-country list or citizenship legislation by the elected government.[3]

The safest position for any Bangladeshi considering a second passport or golden visa is straightforward: choose a country on the approved list, fund the investment only from money that can lawfully be used abroad, report the asset, and obtain the dual nationality certificate. TRW advises individuals and families on dual nationality, foreign exchange permissions, tax disclosure and regularisation. Explore our foreign exchange regulation practice or contact TRW in Dhaka.

Frequently asked questions

Can a Bangladeshi hold dual citizenship?

Yes, with a state of Europe or North America or another state notified by the government. Acquiring citizenship of such a state does not by itself end Bangladeshi citizenship.[1]

How many countries are on the dual citizenship list?

The cabinet extended the list to 101 countries in February 2023, and it was reported at 103 in January 2026.[2] [3]

Are Caribbean citizenship by investment countries on the list?

Dominica, Grenada, Saint Kitts and Nevis and Saint Lucia were named in the 2023 additions. Antigua and Barbuda was not named in the published report, so confirm its status first.[2]

How do I apply for a dual nationality certificate?

Online through the Security Services Division portal of the Ministry of Home Affairs, uploading documents and paying the fee electronically. Approved certificates are issued digitally.[4]

Can a resident of Bangladesh send money abroad for a golden visa?

Not without Bangladesh Bank permission. Payments to non-residents and capital transactions require permission under the Foreign Exchange Regulation Act 1947, and the published outward investment rules cover exporters, not individuals.[5] [6]

Can a non-resident Bangladeshi use foreign earnings?

Foreign exchange held in accounts abroad that were opened and credited while working abroad as a non-resident is outside the surrender requirement, which makes such earnings the usual lawful source.[5]

Must I declare a foreign passport investment in my tax return?

If you are resident, yes. The return must list assets outside Bangladesh, and an undisclosed offshore asset can attract a penalty equal to its fair market value.[7]

What are the penalties for using hundi?

Contravening the 1947 Act carries up to seven years' imprisonment and confiscation, and money laundering carries four to twelve years and forfeiture.[5] [8]

Is Malta's citizenship by investment still available?

Not in its previous form. The EU Court of Justice held on 29 April 2025 that Malta's investor citizenship scheme breached EU law.[10]

Can a dual citizen stand for Parliament in Bangladesh?

No. Article 66(2) of the Constitution disqualifies a person who acquires the citizenship of a foreign state, and the Election Commission enforced the rule in the 2026 election.[3]