LC Fraud in Bangladesh 2026: Criminal Liability, Asset Tracing and Joint Agency Inquiries

LC fraud Bangladesh law in 2026: crime, remedy and recovery

LC fraud Bangladesh cases sit where trade finance, criminal law and asset recovery meet. A forged bill of lading, a shipment that never left port, an invoice priced at twice the market rate or a back-to-back credit opened for a factory that does not exist can each trigger a payment dispute, a money laundering case, a customs claim and an Anti-Corruption Commission investigation at the same time. The party that understands how those tracks interact, and moves first, usually controls the outcome.

This guide is for banks, importers, exporters, foreign suppliers and their executives. It explains how the fraud exception to letter of credit autonomy works, how Bangladesh Bank and the BFIU police mispriced trade, which offences are charged, how asset tracing works through criminal freezing and civil attachment, and how to respond when the ACC, the NBR's Central Intelligence Cell and the BFIU ask about your wealth. It closes with an overview of the financial crime laws that matter in 2026.

Summary: A letter of credit in Bangladesh is paid against documents, and courts will restrain payment only for established fraud of which the bank has notice. Most LC fraud is therefore fought elsewhere: through criminal complaints for cheating, forgery and money laundering, through BFIU and court freezing orders, through civil attachment before judgment, and through regulatory action by Bangladesh Bank, customs and the NBR. Since late 2024, joint teams led by the ACC and including the NBR's intelligence units have made wealth inquiries multi-agency by default.

Key point: Speed decides LC fraud cases. A beneficiary is paid within days of a complying presentation, a BFIU freeze can last up to six months, and an NBR freezing order under section 223 of the Income Tax Act 2023 can be set aside if the authority lacked specific information when it was made. Evidence gathered and filed in the first week is worth more than any argument made later.

At a glance

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Table of Contents

What LC fraud Bangladesh law recognises

A documentary credit, or letter of credit, is a bank's promise to pay against documents. Article 4(a) of UCP 600 states that a credit "by its nature is a separate transaction from the sale or other contract on which it may be based", and Article 5 that banks "deal with documents and not with goods".[1] That separation is what makes the instrument valuable, and it is also what fraudsters exploit. If the documents look right, the bank pays, and Article 34 disclaims the bank's responsibility for the genuineness of the documents themselves.[1]

LC fraud Bangladesh banks encounter takes a small number of recurring forms. The BFIU's guidelines on trade-based money laundering list over-invoicing, under-invoicing, multiple invoicing, short shipment, over-shipment, phantom shipment, complicated payment structures and manipulation of discounts, freight and price changes.[4] In practice we see four patterns most often: forged transport and export documents presented under a genuine credit; credits opened for fictitious or connected suppliers; mispriced trade used to move money across the border; and insider collusion that lets documents through without scrutiny.

Forged documents under a genuine credit

The classic case is a beneficiary that presents forged bills of lading or export bills to obtain payment or discounting. In a case filed by the ACC in December 2018, the managing director and a director of a leather exporter were accused of submitting 26 forged export bills, including bills of export and bills of lading worth about Tk 48.78 crore, against 19 credits from three foreign buyers between July and November 2017; bank officials allegedly approved 17 bills without scrutiny.[7] In December 2019 a Senior Special Judge cancelled the couple's bail on the ACC's revision.[7]

Phantom shipments and fictitious counterparties

A phantom shipment is a credit honoured against documents for goods that never move. One of the case studies in the BFIU guidelines describes a small fruit importer that suddenly opened accounts at three more banks and opened 21 credits worth about USD 9.1 million; payment was made on shipping documents, no shipment was ever made and nothing was refunded.[4] The red flags the guidelines identify are familiar: weak customer due diligence, untracked vessels and credit volumes out of line with the customer's business.[4]

Mispriced trade

Over-invoicing and under-invoicing need no forged documents. The goods are real and the letter of credit paperwork is consistent; only the price is false. These cases are usually prosecuted as money laundering, customs or tax offences, and are discussed separately below.

The fraud exception to UCP 600 autonomy in Bangladesh courts

The fraud exception is the only recognised route to stopping payment under a credit, and Bangladeshi courts apply it narrowly. The governing statement, repeated in the High Court Division's 2024 judgment in Meejab Ltd v AA Knitspin Ltd, comes from the Appellate Division in 33 DLR (AD) 298: the obligation to pay is "absolutely obligatory", no direction to withhold payment can be passed, and the "only exception is in case of fraud of which the bank has notice".[2] Our LC dispute guide analyses the full line of Appellate Division and High Court Division authority; this section focuses on what that law means when fraud is genuinely in play.

Allegation is not enough

In Meejab the court refused to restrain an issuing bank even though fraud had been alleged and the bank put on notice, because no fraud had been established and the bank was not aware of any.[2] The court also held that the principles developed for international credits apply equally to back-to-back credits opened in favour of local suppliers.[2] The practical lesson is that a buyer who suspects letter of credit fraud must arrive at court with evidence, not suspicion: a carrier's confirmation that no bill of lading was issued, port records showing no loading, a registry search showing the beneficiary does not exist, or forensic evidence of forgery.

Injunctions against payment

An application to restrain payment under a letter of credit is made in a suit, usually now a commercial suit. The Commercial Courts Act 2026, Act No. 23 of 2026, covers the ordinary dealings of traders, bankers and merchants and disputes over the export or import of goods, and its pre-suit mediation requirement in section 7(1) does not apply where urgent interim relief is involved.[10] That exception matters in LC fraud: the applicant can go straight to court. Interim relief itself is governed by the Code of Civil Procedure, which the Act applies unless it provides otherwise.[10] Our note on temporary injunctions in Bangladesh sets out the general tests.

Targeting the credit itself

Claimants sometimes try to reach the letter of credit by another route, such as an order aimed at its proceeds. Expect the same resistance. In Meejab the respondents relied on Gooryonly (BD) Textile Ltd v Chartkar Information Holding Ltd, 54 DLR (AD) 70, and Zyta Garments v Union Bank, 55 DLR (AD) 56, to resist any interference with payment, and the appeal failed.[2] Where LC fraud is proved, the better targets are the fraudster's other receivables and accounts, discussed in the asset tracing section below.

When the bank is the victim

Many LC fraud Bangladesh cases have no buyer-seller dispute at all. The bank has paid against forged documents and is now an unsecured creditor of its own customer. Its remedies are a criminal complaint, a freezing application, an Artha Rin suit and a claim against any negotiating bank that failed to examine the documents.

Over-invoicing, under-invoicing and trade-based money laundering

Trade-based money laundering is the largest category of LC fraud Bangladesh regulators deal with, because it hides inside legitimate trade. The BFIU guidelines explain the mechanics: under-invoicing an import evades duty and taxes, with the balance usually paid through hundi or hawala, while over-invoicing capital machinery and raw materials, which carry lower duties, moves value abroad.[4] The guidelines also flag freight charges inflated to several times the FOB value and the abuse of multiple importer registration certificates held by related parties.[4]

Bangladesh Bank's import pricing rules

The current rules are in FEPD-1 Circular No. 30 of 13 August 2026, the consolidated circular on import transactions, issued under section 20(3) of the Foreign Exchange Regulation Act 1947 and valid for one year.[3] Before opening a credit, the dealer bank must take reasonable measures to ensure that both exporter and importer are bona fide businesses, that the exporting country is a usual exporter of the goods, and that the price is competitive against the international market on the contract date or contemporary imports.[3]

To make price verification possible, the proforma invoice or indent must give a full description of the goods, including quality, brand, production date, packaging and grade, the unit price and quantity for each product, appropriate units of measurement, freight under the stated incoterm, and an eight-digit HS code.[3] Imports of USD 3 million or more must be reported to Bangladesh Bank's Online Import Monitoring System at least 24 hours before the credit is opened, other than government imports.[3]

The importer's declaration

Payment is made against the IMP form, on which the importer declares that the foreign exchange represents the correct prevailing market price on the contract date and that it is not connected with the exporter abroad or financially interested in it. Intercompany imports require instead a declaration that the transaction is at arm's length and complies with transfer pricing and AML rules, and the bank must satisfy itself, on documents, that the relationship is legitimate.[3] A false declaration on the IMP form is therefore direct evidence in any later prosecution, which is why importers should never sign one they cannot support.

Bill of entry matching

The importer must submit the customs-certified bill of entry within four months of remittance. Where the goods received differ materially from those paid for, the bank reports the case to Bangladesh Bank monthly, and an importer whose bill of entry is overdue is barred from opening new credits without Bangladesh Bank's prior permission.[3] Unmatched bills of entry are one of the earliest signals of phantom shipment, and they are where many investigations start.

What the BFIU expects of banks

The BFIU issued its trade-based money laundering guidelines under section 23(d) of the Money Laundering Prevention Act 2012 and section 15(1)(g) of the Anti-Terrorism Act 2009.[4] Banks must build their own price databases and policies, set an acceptable price variance with escalation where a significant difference appears, apply "TBML alerts" across trade transactions and file suspicious transaction reports where the review justifies it.[4] For a customer, an STR is invisible until an account is frozen.

Why mispricing is money laundering

The Money Laundering Prevention Act 2012 defines money laundering to include illegally moving money or property abroad in breach of prevailing rules, whether it was obtained legally or illegally.[5] Its list of predicate offences includes fraud, forgery, forgery of documents, smuggling and customs-related offences, tax offences and smuggling of domestic and foreign currency.[5] An over-invoiced import can therefore be charged as laundering even if every unit of goods arrived. Our customs valuation guide covers the parallel duty assessment.

Criminal liability for letter of credit fraud

A letter of credit fraud case is rarely charged under one statute. Investigators combine Penal Code offences with money laundering and, where public servants or state-owned banks are involved, anti-corruption offences. Our guide to white collar crime in Bangladesh covers the elements of each Penal Code offence in depth; here we map them to the LC fraud patterns.

Penal Code offences

The Penal Code 1860 supplies the core charges: criminal breach of trust, including section 409 on breach of trust by a public servant, banker, merchant or agent; cheating and dishonestly inducing delivery of property under section 420; forgery of a valuable security under section 467; forgery for the purpose of cheating under section 468; and using a forged document as genuine under section 471.[6] Abetment and criminal conspiracy extend liability to the bank officer who passes the documents and the agent who arranges the paperwork.

Forged bills of lading and export bills fit sections 467, 468 and 471, and inducing a bank to pay a letter of credit against them is cheating. A bank officer who releases funds knowing the documents are false is exposed under section 409. Mispriced trade usually involves no forgery, so prosecutors build those LC fraud Bangladesh cases on false declarations and money laundering.

Money laundering

Under section 4 of the Money Laundering Prevention Act, an individual convicted of money laundering faces imprisonment of four to twelve years 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.[5] The court may also order the forfeiture of property connected with the offence, and a person can be charged and punished for laundering without first being charged or convicted of the predicate offence.[5]

Offences under the Act are tried by a Special Judge appointed under the Criminal Law Amendment Act 1958, and the investigating agency must notify the BFIU when it begins an inquiry or investigation.[5] Bail in these cases follows a distinct statutory test, explained in our guide to money laundering case bail in Bangladesh.

Anti-corruption overlay

Where officials of a state-owned bank, customs or another public body are involved, the ACC investigates. The Anti-Corruption Commission Act 2004 gives the Commission exclusive power to inquire into and investigate the offences in its schedule, and its powers include notices under section 19 and asset statement orders under section 26.[8] Our guide to the Anti Corruption Commission in Bangladesh explains the process from inquiry to Special Judge trial.

Tax and customs exposure

Mispriced trade also produces a tax case. Section 312 of the Income Tax Act 2023 punishes wilful attempts to evade tax, including concealing income and furnishing false information about assets, liabilities, expenses or accounts, with imprisonment of six months to five years, a fine or both.[16] Customs authorities pursue misdeclaration and under-valuation separately under the Customs Act 2023. A defence that resolves only the criminal case and ignores the duty and tax assessments leaves the most expensive liabilities in place.

Financial crimes and negligence

Not every failure in an LC fraud Bangladesh case is a crime. A trade officer who misses a discrepancy may have been negligent without any dishonest intention, yet breach of trust, cheating and forgery all require a dishonest or fraudulent state of mind. Investigators often charge bank staff simply because documents passed through their hands. A clear record of what each officer checked, and why, is the best protection against negligence being recharacterised as complicity.

Asset tracing Bangladesh: freezing, attachment and fraud recovery

Recovering money lost to LC fraud Bangladesh schemes is a race against dissipation. Asset tracing in Bangladesh works on two tracks: state powers that freeze accounts during a criminal inquiry, and civil remedies that secure assets for a claimant before judgment. The strongest recovery strategies use both, because the criminal track has more powerful tools but the civil track is controlled by the victim.

BFIU freezing

Under section 23(1)(gha) of the Money Laundering Prevention Act, the BFIU may direct a reporting organisation to suspend or freeze transactions in an account for up to 30 days where there are reasonable grounds to suspect the funds derive from, or may be used in, an offence. It may extend the freeze in further 30-day periods, but the total cannot exceed six months.[5] A bank that breaches a freeze faces a fine of at least the account balance at the time of the order and up to twice that balance.[5]

A victim reaches the BFIU through the bank's suspicious transaction report or a complaint to an investigating agency. For an account holder, the six-month ceiling matters: an administrative freeze that continues beyond it without a court order is open to challenge.

Court freezing and attachment in criminal cases

Section 14 of the Act allows the investigating agency to apply to the court to freeze or attach property in or outside Bangladesh connected with money laundering or the proceeds of crime. If the tainted property cannot be identified, the court may freeze property of equivalent value. The application must give full details of the property, prima facie evidence and the risk of transfer, and any order must be published in the Gazette and in two national dailies.[5] The ACC uses this power routinely, often at the inquiry stage. The 30-day windows for third-party claims and appeals are covered in our bail guide.

Mareva-style attachment before judgment

Bangladesh has no freestanding Mareva injunction, but Order XXXVIII, rule 5 of the Code of Civil Procedure allows a court to attach a defendant's property before judgment so that a future decree is not defeated. In Dird Felt (Pvt) Ltd v M/S Hossain and Sons, decided on 2 December 2024, the High Court Division set aside a Dhaka Joint District Judge's refusal to attach bills payable to the defendants by a third party in a Tk 14.06 crore money suit.[9]

The High Court Division found that the plaint and application specifically described the bill, the defendants' dishonoured cheques showed unfair conduct, the claim appeared genuine and the bill was the defendants' only identifiable asset within the jurisdiction.[9] Those are the elements an applicant should prove: a specific, scheduled asset; a strong prima facie claim; evidence that the defendant is dissipating or has nothing else; and prompt filing. A vague application for "all assets" will fail.

Disclosure after judgment

Section 9(13) of the Commercial Courts Act 2026 allows the court, in execution, to order the judgment debtor to provide information identifying its assets.[10] It is a valuable asset tracing tool for a decree holder and should be sought as soon as the decree is passed.

Tracing tools

Investigating agencies may obtain a customer's bank records by court order or through the BFIU under section 23(7A) of the Act.[5] Private asset tracing relies on lawful material: trade documents, shipping and port records, registry searches and documents produced in civil proceedings. The decisive evidence is usually the beneficiary's account trail, which only an agency or a court can reach, so victims commonly file a criminal complaint alongside the civil suit.

Cross-border recovery and mutual legal assistance

Fraud proceeds rarely stay in Bangladesh, so asset tracing must follow them abroad. By October 2026 Bangladesh had sent 30 mutual legal assistance requests to 16 jurisdictions and concluded treaties with Malaysia and Hong Kong, China.[13] State-to-state assistance is slow, and private victims should consider civil proceedings and disclosure orders in the foreign jurisdiction in parallel. Our white collar crime guide explains how the Mutual Legal Assistance in Criminal Matters Act 2012 works.

The 2026 BFIU Stolen Asset Recovery Division

On 22 April 2026 the Prime Minister told Parliament that a Stolen Asset Recovery Division had been set up within the BFIU on 22 February 2026, and that 11 priority cases were being pursued through 11 joint investigation teams.[12] Figures presented to a parliamentary committee and reported on 2 October 2026 put assets under court seizure, attachment or freezing at about Tk 769.84 billion, of which Tk 573.26 billion was in Bangladesh and Tk 196.58 billion abroad, with 142 cases filed, 16 charge sheets and six verdicts.[13]

The same report described six bank consortia, led by eight of the most affected banks, organised to pursue recovery jointly, and international partners including the StAR Initiative, UNODC and the US Department of Justice.[13] For a bank that lost money to a group within the priority cases, joining the consortium route is usually more efficient than acting alone. Our anti money laundering law guide covers the task force structure.

Joint notices from the ACC, the NBR's CIC and the BFIU

A joint notice is rarely a single document signed by three agencies. More often it is a cluster: an ACC notice to appear or file an asset statement, an NBR intelligence demand to banks for account information, a BFIU freeze and, sometimes, a customs inquiry, all arriving within weeks. Treating each part of a joint notice as a separate problem is the most common mistake recipients make.

The 2024 to 2026 joint task force

The multi-agency model was formalised in December 2024, when ten joint teams were constituted to investigate revenue evasion and money laundering by several business groups and individuals. An officer nominated by the ACC leads each team, the BFIU coordinates, and the members include the NBR's Customs Intelligence and Investigation Department and the police CID.[11] By April 2026 there were 11 joint investigation teams, led by the ACC with the CID, the NBR's Central Intelligence Cell and the Customs Intelligence and Investigation Directorate.[12]

The statutory basis is section 9(1) of the Money Laundering Prevention Act, which allows the BFIU, in consultation with the government, to form a joint investigation team of officials from more than one investigating agency.[5] Information obtained by one agency is shared across the team, so an answer given to the NBR may be read by the ACC.

The NBR's freezing and information powers

Two provisions of the Income Tax Act 2023 drive most NBR intelligence action. Section 200 allows an income tax authority not below the rank of Deputy Commissioner to require information by written notice, but information may be demanded from a bank or financial institution only with the Commissioner's approval. Section 223 allows the Director General of the Central Intelligence Cell or a Commissioner, where they have specific information that a person has concealed income or investment, to order that money, financial assets or other property not be removed or transferred without prior permission.[14]

A section 223 order lapses one year after it is made. It may be extended with the Board's approval, but the extensions cannot exceed one year in total, and any period during which a court stays the order is excluded.[14] Section 8(3) of the Act was relied on as the source of the authority of the officers who issued the orders in the cases discussed below.[14]

What the High Court Division decided in 2026

In Md Sirajul Islam v National Board of Revenue, Writ Petition No. 22265 of 2025, decided on 23 April 2026, the Income Tax Intelligence and Investigation Unit froze the bank accounts and deposits of a taxpayer, his family and businesses under section 223 on the same day it asked banks, under section 200, for their account information since July 2018. The bank's reply arrived later. The High Court Division held that "specific information" of concealment is the precondition for a section 223 order, that it was absent when the order was made, and directed the accounts to be reopened within seven days.[14]

In Sadrul Hasan v Commissioner of Taxes, Writ Petition No. 2364 of 2026, decided on 8 July 2026, the same bench followed that ruling and added that section 223 requires individualised satisfaction against each person whose assets are frozen; a blanket order against unnamed family members could not be cured by naming them later. The court upheld the section 200 information demand as a free-standing power not limited by the assessment time limits.[15] The lesson for recipients is precise: information demands are hard to resist, but freezing orders made before the information exists are vulnerable.

ACC notices within a joint inquiry

When the ACC is part of the team, its notices carry their own consequences. The Commission's section 19 powers to summon, question and require documents, and its power under section 26 to order a statement of assets, operate alongside the NBR and BFIU tools.[8] Our ACC guide sets out how to respond to those notices, how to prepare an asset statement and why non-compliance is itself an offence. Our tax audit guide covers ordinary NBR audit notices, which follow a different procedure.

Legal response procedure to a joint notice

A joint notice should be run as one matter with one file and one narrative. The steps below reflect how we handle these cases for individuals and companies.

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Two principles apply to every joint notice. Do not give a different account of the same asset to different agencies, because the joint team will compare them. And do not move, transfer or encumber assets after a notice arrives, because that is precisely the risk on which freezing orders, travel bans and refusal of bail are based.

Financial crime laws Bangladesh: an overview

The financial crime laws that apply to an LC fraud or a wealth inquiry overlap, and the choice of statute decides which agency investigates, which court tries the case and what penalties follow. The table below summarises the principal laws. On a phone, scroll it sideways.

Three points of practice follow from the table. First, money laundering is the gateway charge, because almost every other offence is a predicate under the 2012 Act.[5] Second, the forum depends on the agency: ACC and money laundering cases go to Special Judges, while ordinary Penal Code complaints start before a magistrate. Third, regulatory sanctions under the Bank Company Act 1991, Bangladesh Bank's foreign exchange circulars and the Customs Act 2023 continue whatever the outcome of the criminal case. Our guide to anti money laundering law covers compliance obligations in detail.

Working with a trade fraud lawyer in LC fraud Bangladesh cases

An LC fraud Bangladesh matter needs commercial, banking and criminal skills in one team, because the decisions interlock: a criminal case affects the civil suit, an injunction affects the bank relationship, and cooperation with a joint team affects tax exposure.

Choosing the forum

A victim can lodge a first information report, file a complaint petition before a magistrate, or complain to the ACC where its schedule applies. Our guide on how to file a criminal case in Bangladesh explains the routes. In Dhaka, fraud case lawyers will most often be before the Chief Metropolitan Magistrate's courts at the complaint stage and the Senior Special Judge and Special Judge courts once money laundering or anti-corruption charges are framed.[5] Civil claims for the credit amount or damages go to the commercial courts, while a bank's claim against its customer goes to the Artha Rin Adalat, which the Commercial Courts Act excludes.[10]

Acting for the accused

For a company or executive accused of letter of credit fraud, the first priorities are bail, the preservation of documents, and a clear position on each freezing order. Where the case is a commercial dispute dressed as a crime, quashing under section 561A of the Code of Criminal Procedure may be available; see our criminal quashment practice. Where an administrative freeze exceeds statutory power, a writ petition is the remedy, as the 2026 section 223 judgments show.[14] [15]

Acting for banks

For banks, the work starts before any fraud. Price-verification files, TBML alert reviews and documented discrepancy decisions protect trade officers when a letter of credit goes wrong, and they are what Bangladesh Bank inspectors ask to see.[4] After a loss, preserve the presentation, report through the AML channel and consider a criminal complaint and an attachment application.

Mistakes to avoid in LC fraud and wealth inquiries

• Calling a quality dispute LC fraud: courts and investigators recognise a contractual quarrel presented as a crime, and the claimant loses credibility for the real case.
• Arriving at court without evidence: an injunction against payment needs established fraud known to the bank, not an allegation in a letter.[2]
• Signing an IMP declaration you cannot support: the price and non-connection declarations become prosecution evidence if the trade is mispriced.[3]
• Applying to attach "all assets": attachment before judgment succeeds against specific, scheduled property.[9]
• Answering agencies separately: joint teams share information, and inconsistent answers become the case.
• Ignoring time limits on freezes: BFIU freezes cannot exceed six months and section 223 orders lapse unless extended within the statutory ceiling.[5] [14]
• Moving assets after a notice: any transfer is treated as evidence of dissipation and invites freezing, travel bans and refusal of bail.

What to watch in 2026 and 2027

Three developments will shape LC fraud Bangladesh enforcement, and asset tracing more generally, over the next year. First, the asset recovery drive is moving from freezing to forfeiture and civil recovery, with bank consortia and foreign proceedings now in play.[13] Second, the High Court Division has begun to police the procedural limits of NBR freezing powers, and further challenges to section 223 orders made without specific information are likely.[14] [15] Third, Bangladesh Bank's annual consolidated circulars continue to tighten price verification and import reporting, and banks should test their trade files against each new version.[3]

In LC fraud Bangladesh matters and joint notice cases alike, the first week decides most of what follows. TRW's banking and finance litigation practice acts on LC fraud, asset tracing and multi-agency inquiries; contact TRW to discuss your position.

Frequently asked questions

Can a court stop payment under a letter of credit for fraud in Bangladesh?

Only for established fraud of which the bank has notice. The Appellate Division treats the bank's obligation as absolute, and the High Court Division has refused injunctions where fraud was merely alleged.[2]

What offences are charged in an LC fraud case?

Usually criminal breach of trust, cheating and forgery under the Penal Code, often combined with money laundering under the 2012 Act and, where public officials are involved, anti-corruption offences.[5] [6]

What is the penalty for money laundering in Bangladesh?

Four to twelve years' imprisonment for an individual and a fine of twice the value of the property or Tk 10 lakh, whichever is greater. Entities face at least twice the value or Tk 20 lakh and possible cancellation of registration.[5]

Is over-invoicing an import a crime?

It can be. Illegally moving money abroad in breach of prevailing rules is money laundering under the 2012 Act, and customs and tax offences are predicate offences. The importer's IMP declaration on market price is also relevant evidence.[3] [5]

How long can the BFIU freeze a bank account?

Up to 30 days at a time, extendable in 30-day periods, but not beyond six months in total. A longer freeze needs a court order.[5]

Is there a Mareva injunction in Bangladesh?

Not as such, but Order XXXVIII, rule 5 of the Code of Civil Procedure allows attachment before judgment of specific property so that a decree is not defeated, as the High Court Division applied in December 2024.[9]

Can the NBR freeze my bank accounts without notice?

Under section 223 of the Income Tax Act 2023, only where the Director General of the Central Intelligence Cell or a Commissioner has specific information of concealment. In 2026 the High Court Division set aside freezes made before that information existed.[14] [15]

Who sits on the joint investigation teams?

Teams are led by the ACC and include the CID, the NBR's Central Intelligence Cell and the Customs Intelligence and Investigation Directorate, with the BFIU coordinating.[11] [12]

What is the BFIU Stolen Asset Recovery Division?

A division set up within the BFIU on 22 February 2026 to support the recovery of laundered assets, alongside the inter-agency task force chaired by the Bangladesh Bank governor.[12] [13]

Should I answer an NBR information notice if I am challenging a freeze?

Usually yes. The High Court Division has upheld section 200 information demands as a lawful, free-standing power even while setting aside the related freezing order, so non-compliance carries risk without strategic gain.[15]