Regulatory Investigations and Financial Crime in Bangladesh

by Barrister Tahmidur Rahman | Sep 10, 2026

Trade, Competition & RegulationMeasured responses under scrutiny9 min read

Regulatory Investigations and Financial Crime in Bangladesh

Financial crime and regulatory investigations advice for companies, banks, boards and individuals in Bangladesh: Anti-Corruption Commission notices, money laundering inquiries, BFIU account freezes, Bangladesh Bank, BSEC, NBR and Competition Commission investigations, internal investigations, asset restraint and cross-border requests for evidence and asset recovery.

Overview

How financial crime investigations work in Bangladesh

Businesses in Bangladesh face investigation from more agencies, and with more intensity, than at any point in recent memory. Since 2024 the authorities have pursued corruption, money laundering, loan fraud and illicit capital flight with new energy, including high-profile cases against business groups, bank sponsors and former officials, and efforts to trace and recover assets moved abroad. Many companies with no connection to those cases still find themselves receiving notices, account freezes or information requests. We advise companies, boards and individuals on financial crime and regulatory investigations as part of our regulatory practice in Bangladesh.

Several agencies have overlapping powers. The Anti-Corruption Commission investigates corruption and related offences, including certain money laundering predicates, under the Anti-Corruption Commission Act 2004. The Bangladesh Financial Intelligence Unit receives suspicious transaction reports under the Money Laundering Prevention Act 2012 and can suspend or freeze accounts for limited periods. The police Criminal Investigation Department investigates many money laundering cases. Bangladesh Bank, the Bangladesh Securities and Exchange Commission, the National Board of Revenue and its intelligence units, customs and the Competition Commission each run their own inquiries. One set of facts can therefore attract several financial crime investigations at once.

The first response often determines the outcome. A notice to appear, a demand for documents or a sudden account freeze creates pressure to act quickly, but an unplanned interview, an incomplete production or an inconsistent explanation can do lasting damage. Before engaging, the company or individual needs to understand which agency is acting, under what power, on what allegation and with what deadline. We help clients answer those questions, preserve relevant records, decide what to produce and how, prepare witnesses for interviews, and manage communications with banks, auditors, counterparties and staff while the financial crime inquiry proceeds.

Internal investigations into suspected financial crime are frequently needed alongside the official process. Boards must understand what happened, whether employees or managers acted improperly, and whether disclosure, remediation or disciplinary action is required. A well-scoped internal investigation protects the company's position, while a poorly run one can generate documents that harm it. We design and conduct investigations with forensic accountants and technical specialists where necessary, and report to boards or special committees. Where an investigation leads to criminal proceedings, our dispute resolution lawyers handle bail, quashing applications, trial defence and appeals in coordination with the regulatory team.

Financial crime matters are increasingly cross-border. Bangladesh uses mutual legal assistance and the Egmont network of financial intelligence units to request information from abroad, and foreign authorities make requests in the other direction. Foreign banks and counterparties apply their own know-your-customer and sanctions reviews when a Bangladeshi client is under investigation, and may close accounts or freeze funds. Asset recovery efforts can lead to proceedings in the UK, UAE, Singapore and elsewhere. Barrister Tahmidur Rahman and Barrister Remura Meheruba Mahbub advise on the cross-border dimension, working with counsel in the UK, US, UAE, China, India and Singapore.

01 · What we handle

Core workstreams

  • Notices, interviews and productions
  • Account freezes and asset restraint
  • Internal investigations
  • Regulator inquiries and enforcement
02 · How it runs

Four clear stages

  1. 01Immediate assessment
  2. 02Fact-finding
  3. 03Engagement with authorities
  4. 04Resolution and remediation
03 · Start here

Talk to a partner

Consultations in Dhaka or by video. Scope, team and fees are agreed in writing first.

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How we help

What we do in investigations and financial crime matters

Workstream 01Trade, Competition & Regulation

Notices, interviews and productions

  • Immediate assessment
  • Fact-finding
  • Engagement with authorities
  • Resolution and remediation
Workstream 02Trade, Competition & Regulation

Account freezes and asset restraint

  • Immediate assessment
  • Fact-finding
  • Engagement with authorities
  • Resolution and remediation
Workstream 03Trade, Competition & Regulation

Internal investigations

  • Immediate assessment
  • Fact-finding
  • Engagement with authorities
  • Resolution and remediation
Workstream 04Trade, Competition & Regulation

Regulator inquiries and enforcement

  • Immediate assessment
  • Fact-finding
  • Engagement with authorities
  • Resolution and remediation
Workstream 05Trade, Competition & Regulation

AML and sanctions compliance remediation

  • Immediate assessment
  • Fact-finding
  • Engagement with authorities
  • Resolution and remediation
Workstream 06Trade, Competition & Regulation

Cross-border requests and asset recovery

  • Immediate assessment
  • Fact-finding
  • Engagement with authorities
  • Resolution and remediation
01

Notices, interviews and productions

We review notices from the ACC, police, BFIU, Bangladesh Bank, BSEC, NBR or other agencies, confirm the legal power being used and the deadline, and advise on the response. We prepare clients for interviews, attend where permitted, manage document productions with proper indexing and privilege review, and keep a complete record of everything provided in the financial crime inquiry for later use.

02

Account freezes and asset restraint

When a bank account is suspended by the BFIU, frozen by court order or restricted at the request of an investigating agency, we establish the legal basis, the duration and the procedure for review. We make representations to the agency and the bank, apply to court where appropriate, and seek arrangements that allow payroll, taxes and essential operating payments to continue while the financial crime investigation proceeds.

03

Internal investigations

We design and run internal investigations into suspected financial crime, including fraud, corruption, money laundering, accounting irregularities or misconduct, with clear scope, document preservation, interviews and forensic support. We report findings to the board or a special committee with practical recommendations on remediation, disclosure, disciplinary action and recovery, structured so that the work product supports, rather than undermines, the company's position. We also advise on whistleblower reports.

04

Regulator inquiries and enforcement

We act for banks, finance companies, listed companies, insurers and other regulated businesses in inquiries and enforcement proceedings by Bangladesh Bank, the BSEC, the Insurance Development and Regulatory Authority and the Competition Commission. Our work includes responses to show cause notices, negotiations on corrective plans and penalties, hearings, and challenges to unlawful decisions before the High Court Division. Findings are often shared between regulators.

05

AML and sanctions compliance remediation

Financial crime investigations frequently expose weaknesses in anti-money laundering and sanctions controls. We help institutions and corporates review customer due diligence, beneficial ownership verification, transaction monitoring and suspicious transaction reporting against the Money Laundering Prevention Act 2012 and BFIU guidance, and build remediation plans that regulators, auditors and foreign correspondent banks can rely on in later reviews. We also train compliance teams.

06

Cross-border requests and asset recovery

We advise on mutual legal assistance requests, foreign production orders and information requests from foreign banks and regulators, and on proceedings abroad to trace, freeze or recover assets. For clients facing financial crime allegations, we coordinate defence strategy across jurisdictions; for victims of fraud, we pursue recovery in Bangladesh and through counsel in the jurisdictions where assets are held. Timing is coordinated across jurisdictions.

RecognitionThe Legal 500Asia Pacific ranks Tahmidur Remura Wahid (TRW) Law Firm for dispute resolution in Bangladesh.
Cross-border reach6 jurisdictionsMatters coordinated with counsel in the UK, US, UAE, China, India and Singapore.
Bar and admissionsDhaka and LondonBarristers and advocates in Bangladesh, with a solicitor of England and Wales (non-practising).
HeadquartersDhakaHouse 410, Road 29, Mohakhali DOHS. Consultations in person or by video.
Who leads this work

Partner-led, on every matter.

Trade, Competition & Regulation matters at TRW are led by partners, supported by associates, with one responsible lawyer from first advice to final outcome.

Meet the firm →
01

We have received an Anti-Corruption Commission notice. What should we do first?

Read the notice carefully to identify the allegation, the legal power used, the person or documents sought and the deadline. Do not ignore it, and do not respond informally or in haste. Secure the documents the notice refers to and suspend routine deletion of relevant records. Then take advice before anyone attends or produces material, because what is said or provided at this stage can shape the entire financial crime inquiry. We review the notice, contact the investigating officer where appropriate, prepare the client and any witnesses, and attend to support them where the procedure allows legal representation.

02

The BFIU has frozen our bank account. How can the freeze be lifted?

The BFIU can suspend or freeze accounts for limited periods under the Money Laundering Prevention Act 2012, and longer restraints usually require a court order obtained by an investigating agency. The first step is to confirm who imposed the freeze, under which power and for how long. We then make representations to the BFIU or the investigating agency, provide documents that explain the transactions, and where appropriate apply to court for release or variation. In many cases the immediate goal is a partial release for salaries, taxes and essential payments while the financial crime investigation continues.

03

Can several agencies investigate the same financial crime matter at once?

Yes, and it is common. The ACC, the police, the BFIU, Bangladesh Bank, the BSEC and the tax authorities may each have an interest in the same transactions, from different legal angles. They can share information, and statements or documents given to one agency may reach another. We map the agencies involved and their powers, coordinate responses so that the company's explanation is accurate and consistent across them, and advise on the order in which matters should be addressed, so that resolving one inquiry does not create new exposure in another.

04

Should a company conduct an internal investigation into suspected financial crime?

Usually, yes, but it should be planned carefully. An internal investigation helps the board understand the facts, decide on remediation and disciplinary action, and respond credibly to regulators. It should have a clear scope and terms of reference, a reporting line to the board or an independent committee, proper document preservation and careful interview procedures. Findings and drafts can later be sought by investigating agencies, so the structure of the work matters. We design investigations with these risks in mind, work with forensic accountants, and advise on how and when findings should be shared with the authorities.

05

Can company directors be prosecuted personally for financial crime?

Yes. Many Bangladeshi statutes, including the Money Laundering Prevention Act 2012, contain provisions under which offences committed by a company can be attributed to its directors, officers and managers, unless they show that the offence occurred without their knowledge or that they exercised due diligence. Directors of banks and finance companies face particular scrutiny over loan approvals and related party exposures. Travel restrictions and asset restraints may also be sought against individuals. We advise directors on their personal position, separate representation where interests diverge from the company's, and steps that support a due diligence defence. Records of board deliberations help.

06

What happens if a regulatory or police investigation leads to a criminal case in court?

If the investigating agency files a charge sheet and the court takes cognisance, the matter proceeds to trial, usually before a Special Judge's court for money laundering and corruption offences. Bail, interim relief and challenges to the proceedings become central. In appropriate cases, the High Court Division can quash proceedings that are an abuse of process or disclose no offence. We handle bail applications, quashing petitions, trial defence and appeals, and coordinate the criminal case with any parallel regulatory proceedings, civil claims and financial crime remediation steps. Witness lists and document sets should be prepared well before trial dates.

07

How do foreign banks react when a Bangladeshi client is under investigation?

Foreign banks often review relationships when they learn of an investigation, whether through media coverage, information requests or their own screening. They may request explanations, restrict transactions, close accounts or file reports with their own authorities. Their decisions are governed by their own law and policies, not Bangladeshi procedure. A clear, accurate and consistent explanation, supported by documents, can sometimes preserve the relationship. We help clients prepare those explanations and coordinate with counsel abroad, so that what is said to foreign banks matches what is said in the Bangladeshi financial crime proceedings.

08

Can victims of fraud use these processes to recover money?

Yes. Victims of financial crime, such as fraud, embezzlement or loan fraud, can file complaints that lead to investigation, and investigating agencies and courts can freeze and confiscate assets. Criminal proceedings alone, however, rarely return money quickly, so victims usually combine them with civil claims, attachment orders and, where assets are abroad, proceedings in foreign courts. The Commercial Courts Act 2026 may also affect how some commercial recovery claims are heard. We design recovery strategies that use criminal, civil and cross-border tools together, and coordinate with forensic accountants to trace funds through Bangladeshi and foreign accounts.

How a matter runs

From first call to resolution.

  1. 01

    Immediate assessment

    We review the notice, freeze or allegation, identify the agency, power and deadline, secure relevant documents and advise on the first response, including who should speak for the company and what must not be done.

  2. 02

    Fact-finding

    We gather and review the documents, interview key people and, where needed, engage forensic accountants, so that the client understands the facts before giving explanations to any agency, bank, auditor or counterparty. We keep the findings under review as evidence emerges.

  3. 03

    Engagement with authorities

    We prepare written responses, document productions and interview preparation, attend meetings where permitted, negotiate the scope of requests and freezes, and keep the client's position consistent across every agency involved in the financial crime matter.

  4. 04

    Resolution and remediation

    We work towards closure of the inquiry, defend any proceedings that follow, seek release of restrained assets, and implement remediation of controls and governance so that the client is better placed if questions arise again.

“Demonstrates an extraordinary command over both domestic litigation and international arbitration.”

The Legal 500 Asia Pacific, Bangladesh: Dispute resolution, client feedback

FAQ

Questions, answered.

Still unsure? Email info@trw.co with a short outline of the matter.

Which agencies investigate financial crime in Bangladesh?
The main agencies are the Anti-Corruption Commission, the Criminal Investigation Department of the police, the Bangladesh Financial Intelligence Unit, Bangladesh Bank, the Bangladesh Securities and Exchange Commission, and the National Board of Revenue with its intelligence and customs units. Other bodies, such as the Competition Commission and sector regulators, run inquiries within their own fields. Which agency leads depends on the alleged offence, and responsibilities sometimes overlap or shift as an investigation develops. We identify the lead agency at the outset and track any change.
Do we have to answer every question a financial crime investigator asks?
Obligations to provide information and documents depend on the statute and the notice. Some powers compel production or attendance, and failing to comply can itself be an offence, while individuals retain certain protections, particularly in criminal matters. Answers should be accurate and considered, never speculative or guessed. We advise on what must be provided, what can properly be clarified or narrowed, and how to make sure that the record of any interview is complete and correct. Written answers are often preferable.
Can we tell our customers or staff about a financial crime investigation?
Sometimes, but with care. Anti-money laundering law prohibits tipping off a person that a suspicious transaction report has been made or that an investigation is underway in certain circumstances, and statements to staff or the market can be used as evidence. Listed companies may also have disclosure obligations to the BSEC and the stock exchanges. We help clients decide what to say, to whom and when, and prepare internal and external communications that are accurate without creating new legal exposure. Employees should be told only what they need to know.
Are travel bans imposed on individuals in financial crime cases?
Courts have restricted the foreign travel of individuals under investigation in a number of high-profile financial crime matters, usually on the application of an investigating agency. Such orders can be challenged or varied, for example for medical treatment or business needs, on proper application. Individuals who expect scrutiny should take advice early, because the timing and terms of any application can affect the court's approach and the practical consequences for their work and family. Documents supporting any variation request should be prepared early.
Is legal advice to a company protected from financial crime investigators?
Bangladeshi law recognises protection for confidential communications between a client and its advocate, but the scope of that protection, particularly for in-house lawyers, internal investigation reports and documents shared with third parties, is less settled than in some other jurisdictions. Investigations should therefore be structured with that uncertainty in mind. We advise on how to organise legal and forensic work so that confidentiality is preserved as far as the law allows. Board reports should be drafted with care.
How long do financial crime investigations usually take in Bangladesh?
There is no single timetable. Some inquiries close within months after documents are produced and explanations accepted, while complex money laundering or corruption investigations can run for years, especially where evidence is needed from abroad. Account freezes and travel restrictions may continue in the meantime. We help clients plan for the realistic duration, seek interim relief where the impact is severe, and press for progress where an inquiry has stalled without justification. We review progress with the client at regular intervals and record each agency's requests and deadlines.
Can a company settle a financial crime or regulatory matter in Bangladesh?
Regulators such as Bangladesh Bank, the BSEC and the Competition Commission can resolve some matters through penalties, corrective action plans, undertakings or negotiated outcomes within their statutory powers. Criminal offences investigated by the ACC or the police are not usually settled in the same way, though cooperation, restitution and remediation can still be relevant to how a case proceeds. We advise on the options available in each forum and on whether and how to pursue a negotiated resolution. Any settlement terms should be reviewed for consequences in other forums.
How do we contact TRW & Co urgently about an investigation?
Call +880 1708 000660 or use our Dhaka contact page, and share the notice, the deadline and a brief description of the situation. We treat financial crime matters as urgent, advise on immediate steps, and confirm scope and fees in writing. Individuals and companies whose interests may differ should tell us at the outset so that conflicts can be checked and separate representation arranged if needed. Please also send the notice by email so that we can review it promptly.

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