Technology, IP & DataPractice areaBangladesh · Cross-border
Digital Assets, Cryptocurrency and
Blockchain
Blockchain-enabled products can raise regulatory and contractual questions that depend on the digital item, the activity, the participants, the allocation of control and the jurisdictions involved. In Bangladesh-facing arrangements, official materials and the particular facts should be checked before a decision is made.
FocusTechnology, IP & Data
Page typePractice
information
information
Initial routeStart with
context
context
The starting point
Questions to frame before the arrangement
takes shape
A technical label alone may not answer the legal question. Early analysis can begin with the actual activity, the powers held by participants and the jurisdictions connected to the arrangement, while keeping distinct the treatment of a blockchain system from the treatment of a virtual-asset activity.
Define the activity before naming the technology
Consider whether the proposal is an internal or permissioned recordkeeping workflow, or whether it could involve obtaining, transferring, exchanging, facilitating or trading a digital item within the language used in relevant official materials. Start with the activity, the digital item and the Bangladesh connection, rather than the label “blockchain”.Decide who controls system and asset-facing functions
Identify who may validate, change, pause, instruct, access or exit the arrangement. Written governance and custody terms can then address authority, operational control and contingency before the parties rely on code or platform rules alone.Place the legal map beside the technical map
Consider the locations of participants, custodians and infrastructure, together with governing-law, forum and dispute-route questions. The location of a server, wallet or counterparty may not answer every legal question in a decentralised or cross-border arrangement.A focused conversation
Scope-bounded areas for
consideration
Depending on the facts and the applicable legal framework, regulatory and contractual questions may be organised under the following workstreams. They are issue-framing categories, not assurances about classification, permission, licensing, enforceability or outcome.
01 · Potential question
Bangladesh regulatory-perimeter assessment
Frame the proposed activity, product functions and Bangladesh touchpoints against the wording of current official materials, including questions that may need further verification before a decision is taken.02 · Potential question
Blockchain-enabled product and token terms
Consider terms that describe the ledger function, the digital item, participant roles, permitted actions, governance arrangements and agreed limitations with sufficient clarity for the proposed model.03 · Potential question
Permissioned-network or consortium governance
Consider allocation of validator or node roles, voting and change procedures, admission and exit, audit records, responsibility boundaries and shutdown contingencies in a private or permissioned arrangement.04 · Potential question
Digital-asset control and custody documentation
Distinguish contractual authority, key or access-control arrangements, instruction pathways, segregation concepts and contingency terms, while reserving proprietary and insolvency conclusions for a current review of applicable law and facts.05 · Potential question
Smart-contract alignment
Align code-driven steps with readable terms on performance, testing, version changes, error correction, pause rights, dispute handling and evidence, including the relationship between automated and human actions.06 · Potential question
Cross-border contract and conflicts mapping
Identify potentially relevant jurisdictions and map governing-law, forum, custody, infrastructure and participant-location questions. International principles and model materials can assist issue spotting but do not themselves determine Bangladesh law.07 · Potential question
Regulatory change and launch-readiness review
Before a launch, material redesign or public communication, consider re-checking official legal and regulatory materials and recording unresolved classification or contractual assumptions. This does not predict a licence, permission or other outcome.Bangladesh context
Bangladesh and cross-border public
context
The following public materials provide a limited context for issue spotting. They should be read with their stated scope and date, and should not be treated as a complete or current legal position for a particular product, transaction or participant.
Bangladesh Bank FE Circular No. 24
The circular dated 15 September 2022 states that certain transactions made in, from or to Bangladesh for obtaining virtual assets or virtual currencies, and specified facilitation of exchange, transfer or trading activity, are not permitted by Bangladesh Bank. The circular is a central official reference point, but later materials and the proposed facts should be checked before treating it as determinative for any arrangement.Read sourceVirtual-asset risk in official financial-crime context
The Bangladesh Financial Intelligence Unit’s 2024–2025 Annual Report identifies misuse of virtual assets as an emerging risk and discusses cryptocurrency-related activity in Bangladesh. The report is public-risk context only; it does not determine the legal obligations, status or exposure of an individual organisation or arrangement.Read sourceInternational virtual-asset implementation context
FATF’s July 2026 targeted update records progress and continuing gaps in the implementation of its virtual-asset standards, including emerging risks. This is international comparative context; it does not itself establish a Bangladesh legal requirement, licence status or enforcement outcome.Read sourceQuestions, not prescriptions
What may
matter.
These answers are general information. The applicable route always depends on the facts, documents and current legal position.
What does Bangladesh Bank’s 2022 circular say about virtual assets and virtual currencies?
Bangladesh Bank’s FE Circular No. 24, dated 15 September 2022, states that virtual currencies are not recognised as currency under the cited definition in the Foreign Exchange Regulation Act, 1947. It also states that transactions made in, from or to Bangladesh for obtaining virtual assets or virtual currencies, and facilitation of business, activities or operations associated with exchange, transfer or trading, are not permitted by Bangladesh Bank. This describes the circular rather than determining the position of a specific product. The current official record and relevant facts should be checked at the relevant time.
Does a blockchain-enabled system necessarily involve cryptocurrency?
No. The ICT Division’s National Blockchain Strategy describes blockchain or distributed-ledger technology more broadly and identifies use cases beyond cryptocurrency. That policy discussion does not determine the legal treatment of any particular blockchain implementation, token, record or transaction.
Why do control and custody arise in cross-border digital-asset discussions?
UNIDROIT’s Principles on Digital Assets and Private Law address private-law topics including control, transfer, custody, security and insolvency. They illustrate questions that can arise where access, instructions or custody are distributed. The Principles were adopted in 2023 and are not, without more, Bangladesh law.
Begin with context
Start with a non-confidential
outline
For a Bangladesh-related or cross-border blockchain-enabled arrangement, contact TRW & Co with a non-confidential outline of the business context, the decision to be made and the relevant jurisdictions. Please do not send confidential, privileged or time-sensitive information through an initial enquiry.
Legal information only. This page provides general information about regulatory and contractual issues that may arise in blockchain-enabled and digital-asset arrangements. It is not legal, financial, investment, tax, accounting or other professional advice, and it is not a statement that any activity, product, token, platform or arrangement is permitted, prohibited, licensed or suitable. Laws, regulatory materials and facts can change and may apply differently depending on the jurisdiction, activity and participants. Do not act or refrain from acting on this information without obtaining advice on the current facts and applicable law. An initial enquiry does not create an attorney-client relationship. Please do not send confidential, privileged or time-sensitive information through the initial contact route.
Publication candidate prepared from the supplied Batch 04 research pack and source log. It remains subject to authorised legal and editorial review, including a current check of official Bangladesh materials, the final page facts, source dates, links and metadata before staging or release.
Selected source material
- Bangladesh Bank — FE Circular No. 24: Prohibition regarding virtual assets, virtual currencies and facilitating their exchange/transfer/trading
- Information and Communication Technology Division, Government of Bangladesh — National Blockchain Strategy: Bangladesh
- Bangladesh Financial Intelligence Unit — Annual Report 2024–2025
- UNIDROIT — Principles on Digital Assets and Private Law
- UNCITRAL — Model Law on Electronic Transferable Records (2017)