Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved.

Financial Integrity Monitor

Bangladesh BD

Domains covered
7 of 8
Sources
172
Role actions
8
Horizon <90d
1
Jurisdiction profile
FATF status: Clean Tier: B Risk direction: Increasing Enablement vs enforcement: Mixed

Bangladesh operates under the Money Laundering Prevention Act 2012 and Anti-Terrorism Act, supervised by the Bangladesh Financial Intelligence Unit (BFIU) under Bangladesh Bank.

MoreBangladesh exited the FATF ICRG monitoring process in 2014 but remains in APG enhanced follow-up on technical-compliance deficiencies, including partial compliance on virtual-asset provider (R.15) obligations. Post-2024 interim government has intensified corruption enforcement against the former ruling elite.

Key deficiencies
  • No licensed or regulated virtual asset service provider framework despite documented underground crypto adoption
  • No centralized, verified beneficial ownership registry; company registry (RJSC) lacks BO verification capacity
  • Weak asset recovery infrastructure relative to scale of alleged embezzlement ($17-30bn estimated under prior administration)
  • Politically selective enforcement pattern raising durability and even-handedness concerns
  • Banking-sector supervisory capture demonstrated by emergency board dissolutions at systemically important banks
Recent developments (18m)
  • Anti-Corruption Commission corruption trials against Sheikh Hasina, her son and daughter opened August 2025 over Purbachal land allocations
  • International Crimes Tribunal sentenced Hasina to death in absentia for crimes against humanity, November 2025
  • Dhaka court sentenced Hasina to 10 years and UK MP Tulip Siddiq to 4 years in absentia for land-corruption scheme, February 2026
  • UK National Crime Agency froze 342 properties worth approximately £185 million linked to a former Bangladeshi land minister's family, June 2025
  • Bangladesh Bank dissolved the entire board of Islami Bank Bangladesh, the country's largest Islamic lender, June 2026
  • IMF continuing conditional negotiations on remaining tranches of $5.5bn loan tied to banking-sector and fiscal reforms, 2026
Brief

Lead signal

Lead Signal

Bangladesh produced two compliance-architecture developments this cycle that, read together, describe a regulator consolidating and extending its anti-money-laundering perimeter rather than responding to a single incident. The Bangladesh Financial Intelligence Unit issued a 20 October 2026 circular extending a formal AML/CFT compliance architecture to life and non-life insurance companies for the first time at this level of specificity, requiring a central compliance unit, a named Chief Anti-Money Laundering Compliance Officer, screening against United Nations Security Council and domestic sanctions lists, enhanced due diligence for politically exposed persons and customers linked to high-risk jurisdictions, and reporting of large cash transactions. This is a structural extension of supervisory reach into a sector that had not previously carried obligations of this specificity, and it is corroborated across three independent Bangladeshi business-press outlets, though the primary circular text itself has not yet been retrieved.

Read full brief

Lead Signal

Bangladesh produced two compliance-architecture developments this cycle that, read together, describe a regulator consolidating and extending its anti-money-laundering perimeter rather than responding to a single incident. The Bangladesh Financial Intelligence Unit issued a 20 October 2026 circular extending a formal AML/CFT compliance architecture to life and non-life insurance companies for the first time at this level of specificity, requiring a central compliance unit, a named Chief Anti-Money Laundering Compliance Officer, screening against United Nations Security Council and domestic sanctions lists, enhanced due diligence for politically exposed persons and customers linked to high-risk jurisdictions, and reporting of large cash transactions. This is a structural extension of supervisory reach into a sector that had not previously carried obligations of this specificity, and it is corroborated across three independent Bangladeshi business-press outlets, though the primary circular text itself has not yet been retrieved.

Separately, Bangladesh Bank issued a unified foreign-exchange circular, reported between 29 and 31 October 2026, that supersedes Volume I of the 2018 foreign-exchange guidelines and explicitly reiterates the prohibition on exchanging, transferring and transacting virtual assets and virtual currencies. This is consolidation of an existing prohibition rather than a substantive change to Bangladesh's stance on virtual assets, which has stood since 2022.

Other Developments

Insurance-sector AML mandate. The BFIU circular is the more structurally significant of the two developments: it is the first time the insurance sector in Bangladesh has been brought under an AML/CFT compliance architecture of comparable specificity to that already applied to banks, requiring governance infrastructure (a central compliance unit and named compliance officer) rather than only transaction-level controls. The obligation is grounded in the Money Laundering Prevention Act 2012 and the Anti-Terrorism Act 2009, as applied through the insurer-specific circular.

Foreign-exchange consolidation and the standing crypto prohibition. Bangladesh Bank's unified circular folds prior fragmented foreign-exchange directives into a single instrument under the Foreign Exchange Regulation Act 1947, and in doing so restates rather than revises the prohibition on virtual-asset transacting. The practical effect for crypto-asset operators and banks is continuity: the compliance posture required of regulated entities toward virtual-asset activity is unchanged, but it is now stated within a consolidated rather than a fragmented regulatory text.

FATF standing position. Bangladesh remains off both the FATF grey list and blacklist following the 30 October 2026 plenary outcome, at which Bulgaria, Cote d'Ivoire, the Democratic Republic of the Congo and Monaco were removed from the grey list. This is continuity rather than a Bangladesh-specific development, tracked here for standing-tracker purposes.

Cross-Monitor Connections

The unified foreign-exchange circular's reaffirmation of the virtual-asset prohibition is the same underlying development that informs the digital-asset reading of this cycle's signal, since the same instrument speaks to both the AML/CTF compliance dimension and the digital-asset regulatory-architecture dimension of Bangladesh's posture. The insurance-sector mandate, by contrast, sits more squarely within the architecture of obliged-entity expansion and has less direct bearing on digital-asset or sanctions-architecture questions, though its reporting and screening requirements track typologies common to conflict-finance and sanctions-evasion typologies elsewhere in the fleet's coverage.

Outlook

The near-term question is verification rather than direction: both developments are reported by business-press corroboration rather than primary-source circular text, and confirming the precise scope and citation of the insurer mandate, along with resolving the crypto-gains tax treatment question that remains unverified, are the open items most likely to sharpen next cycle's picture. Absent a reversal, the structural direction in Bangladesh is toward broader obliged-entity coverage and consolidated rather than fragmented regulatory texts, which is itself a durable signal independent of any single enforcement action.

Earlier periodic briefs (8)
4 Nov 2026 · fim-2026-11-04

Lead Signal

Bangladesh produced two compliance-architecture developments that, read together, describe a regulator consolidating and extending its anti-money-laundering perimeter rather than responding to a single incident. The Bangladesh Financial Intelligence Unit issued a 20 October 2026 circular extending a formal AML/CFT compliance architecture to life and non-life insurance companies for the first time at this level of specificity, requiring a central compliance unit, a named Chief Anti-Money Laundering Compliance Officer, screening against United Nations Security Council and domestic sanctions lists, enhanced due diligence for politically exposed persons and customers linked to high-risk jurisdictions, and reporting of large cash transactions. This is a structural extension of supervisory reach into a sector that had not previously carried obligations of this specificity, and it is corroborated across three independent Bangladeshi business-press outlets, though the primary circular text itself has not yet been retrieved.

Separately, Bangladesh Bank issued a unified foreign-exchange circular, reported between 29 and 31 October 2026, that supersedes Volume I of the 2018 foreign-exchange guidelines and explicitly reiterates the prohibition on exchanging, transferring and transacting virtual assets and virtual currencies. This is consolidation of an existing prohibition rather than a substantive change to Bangladesh's stance on virtual assets, which has stood since 2022.

Other Developments

Insurance-sector AML mandate. The BFIU circular is the more structurally significant of the two developments: it is the first time the insurance sector in Bangladesh has been brought under an AML/CFT compliance architecture of comparable specificity to that already applied to banks, requiring governance infrastructure (a central compliance unit and named compliance officer) rather than only transaction-level controls. The obligation is grounded in the Money Laundering Prevention Act 2012 and the Anti-Terrorism Act 2009, as applied through the insurer-specific circular.

Foreign-exchange consolidation and the standing crypto prohibition. Bangladesh Bank's unified circular folds prior fragmented foreign-exchange directives into a single instrument under the Foreign Exchange Regulation Act 1947, and in doing so restates rather than revises the prohibition on virtual-asset transacting. The practical effect for crypto-asset operators and banks is continuity: the compliance posture required of regulated entities toward virtual-asset activity is unchanged, but it is now stated within a consolidated rather than a fragmented regulatory text.

FATF standing position. Bangladesh remains off both the FATF grey list and blacklist following the 30 October 2026 plenary outcome, at which Bulgaria, Cote d'Ivoire, the Democratic Republic of the Congo and Monaco were removed from the grey list. This is continuity rather than a Bangladesh-specific development, tracked here for standing-tracker purposes.

Cross-Monitor Connections

The unified foreign-exchange circular's reaffirmation of the virtual-asset prohibition is the same underlying development that informs the digital-asset reading of the signal, since the same instrument speaks to both the AML/CTF compliance dimension and the digital-asset regulatory-architecture dimension of Bangladesh's posture. The insurance-sector mandate, by contrast, sits more squarely within the architecture of obliged-entity expansion and has less direct bearing on digital-asset or sanctions-architecture questions, though its reporting and screening requirements track typologies common to conflict-finance and sanctions-evasion typologies elsewhere in the fleet's coverage.

Outlook

The near-term question is verification rather than direction: both developments are reported by business-press corroboration rather than primary-source circular text, and confirming the precise scope and citation of the insurer mandate, along with resolving the crypto-gains tax treatment question that remains unverified, are the open items most likely to sharpen the next picture. Absent a reversal, the structural direction in Bangladesh is toward broader obliged-entity coverage and consolidated rather than fragmented regulatory texts, which is itself a durable signal independent of any single enforcement action.

3 Nov 2026 · fim-2026-11-01

Lead Signal

Bangladesh has moved to extend formal anti-money-laundering architecture into a sector that had previously sat largely outside it. The Bangladesh Financial Intelligence Unit directed every insurance company in the country to form a central compliance unit, appoint a Chief Anti-Money Laundering Compliance Officer, screen customers against United Nations Security Council and domestic proscription lists, apply enhanced due diligence to politically exposed persons and to customers linked to high-risk jurisdictions, and report large cash transactions and suspicious activity. The requirement, dated 20 October 2026, brings the insurance sector into line with the compliance infrastructure banks and mobile financial service providers have operated under for some time. The underlying statutory basis is the Money Laundering Prevention Act 2012 together with the Anti-Terrorism Act 2009, applied through a sector-specific circular rather than new primary legislation.

The significance here is architectural rather than incident-driven. No enforcement action or specific case triggered this expansion; instead it reflects a deliberate closing of a perimeter gap. Industry practice among Bangladeshi insurers has not previously required a dedicated compliance-unit and CAMLCO structure, and implementation lag should be expected, particularly among smaller non-life insurers without existing compliance capacity. The primary circular text itself has not been independently retrieved; the finding rests on corroborating coverage from Bangladeshi business press rather than the regulator's own document, a gap worth noting for anyone relying on this for precise provision-level compliance mapping.

Other Developments

Consolidation, not expansion, of the crypto prohibition. Bangladesh Bank issued a unified circular for foreign exchange that supersedes Volume I of the 2018 FX guidelines, folding prior directives into a single instrument. Within that consolidation, the circular explicitly reiterates the existing prohibition on exchanging, transferring, and transacting in virtual assets and virtual currencies, a prohibition that traces to the Foreign Exchange Regulation Act 1947 framework. The substantive policy is unchanged from the position Bangladesh has held since 2022; what has changed is the administrative tidying of the instrument that states it. Two independent Bangladeshi business-press sources describe the same consolidation exercise, which supports the finding, though again the primary circular has not been directly retrieved.

No change in Bangladesh's FATF standing. The Financial Action Task Force's late-October plenary removed Bulgaria, Cote d'Ivoire, the Democratic Republic of the Congo, and Monaco from increased monitoring, taking the global grey list to eighteen jurisdictions. Bangladesh was not part of this action in either direction: it remains off both the grey list and the blacklist, with no Bangladesh-specific action recorded at this plenary. This is reported through a lower-tier secondary source and should be read as directional context rather than a load-bearing finding on its own.

Cross-Monitor Connections

The insurance-sector compliance mandate and the FX circular's crypto-prohibition language both sit on the regulatory-architecture side of the ledger rather than the enforcement-incident side, and that distinction matters for anyone tracking conflict-finance or state-capture exposure through adjacent monitors: a jurisdiction building out sanctions-screening infrastructure across a wider set of obliged entities is not the same signal as a jurisdiction acting against a live violation. The reiterated prohibition on virtual-asset transacting is also relevant to any monitor tracking digital-asset infrastructure or evasion routing through markets with outright bans, since a consolidated and restated prohibition narrows (on paper) the space available for crypto-denominated layering through formally licensed Bangladeshi channels, even though restatement of an existing rule is a weaker signal than a new one.

Outlook

The near-term question for the insurance-sector mandate is implementation capacity: whether non-life insurers, in particular, stand up the required compliance-unit and CAMLCO structure within the window regulators expect, or whether a visible lag develops that invites a follow-up circular or supervisory action. Because the primary circular text was not independently retrieved, the precise deadline and penalty architecture attached to non-compliance remain to be confirmed against the regulator's own document rather than press summaries. On the crypto side, the consolidation exercise suggests Bangladesh Bank is tidying its regulatory stack rather than signalling any near-term move toward a licensed virtual-asset regime; the prohibition should be read as stable rather than as a precursor to liberalisation. Bangladesh's unchanged FATF status offers a steady baseline against which both developments can be read as routine architecture-building rather than a response to external listing pressure.

25 Oct 2026 · fim-2026-10-25

Lead Signal

Bangladesh Bank issued a consolidated circular on 17-18 October 2026 that unifies the licensing and renewal rules previously scattered across separate instructions for authorised dealers, money changers, limited money changers, authorised gold dealers, and authorised importers of gold ore and dore. Issued under Section 20(3) of the Foreign Exchange Regulation Act 1947, the circular brings five categories of regulated entity under a single administrative instrument, folding in AML/CFT compliance expectations, reporting duties, and Bangladesh Bank's inspection and cancellation powers. The finding rests on two independent Tier-3 quality-press accounts, as the underlying Bangladesh Bank primary text was not retrievable, reportedly due to a bot-wall on the central bank's own site. This is an architecture-level development rather than an enforcement incident: it does not alter the substantive AML/CTF regime itself, but it does consolidate the supervisory perimeter around foreign-exchange and gold-trading intermediaries that sit adjacent to classic trade-based laundering and gold-smuggling typologies in the region.

The circular supersedes prior individual instructions and runs for one year, suggesting Bangladesh Bank intends this as a living administrative baseline subject to renewal or further consolidation rather than a one-off tidying exercise. Because gold and foreign-exchange dealer networks are a recurring enabler layer in regional illicit-finance typologies, a single licensing and inspection instrument covering all five entity categories is a structural tightening of the supervisory surface, even absent a change to the underlying statute.

Other Developments

Standing AML/CTF architecture unchanged. Bangladesh's core AML/CFT framework continues to rest on the Money Laundering Prevention Act 2012 (as amended 2015) and the Anti-Terrorism Act 2009, with the Bangladesh Financial Intelligence Unit supervising within Bangladesh Bank. FATF's own Asia/Pacific Group country page records the last mutual evaluation as 2016, with the next possible on-site period in November 2027, indicating no fresh multilateral assessment has intervened.

Reporting-failure penalty confirmed at source. BFIU's own guidance document confirms that failure by a reporting organisation to file a suspicious transaction or suspicious activity report under Section 25(2) of the Money Laundering Prevention Act attracts a fine of not less than Tk 50,000 and not exceeding Tk 25 lakh. This is a standing feature of the regime rather than a new development, but it is directly sourced to the regulator's own primary document.

FATF list status. Secondary reporting states Bangladesh is not currently on the FATF list of jurisdictions with strategic AML deficiencies, a status corroborated by FATF's own country page, which records no grey-list flag against Bangladesh.

Cross-Monitor Connections

The consolidated FX and gold-dealer licensing circular is also material to the World Payments Monitor's licensing and market-access tracking, since authorised dealers and money changers sit within the broader foreign-exchange services perimeter that payments-focused oversight also tracks. No sanctions nexus, beneficial-ownership development, or conflict-finance signal was identified that would route to those adjacent trackers.

Outlook

Whether this administrative consolidation is followed by gazetted regulation, a published Bangladesh Bank primary text, or further sector-specific instructions is the open question carried. The absence of a retrievable primary document is itself a gap worth closing before the finding can be treated as more than probable; until a Tier-1 Bangladesh Bank source is obtained, confidence in the precise scope of the consolidated rules should remain qualified.

18 Oct 2026 · fim-2026-10-18

Lead Signal

Bangladesh Bank issued a consolidated circular on 17-18 October 2026 that unifies the licensing and renewal rules previously scattered across separate instructions for authorised dealers, money changers, limited money changers, authorised gold dealers, and authorised importers of gold ore and dore. Issued under Section 20(3) of the Foreign Exchange Regulation Act 1947, the circular brings five categories of regulated entity under a single administrative instrument, folding in AML/CFT compliance expectations, reporting duties, and Bangladesh Bank's inspection and cancellation powers. The finding rests on two independent Tier-3 quality-press accounts, as the underlying Bangladesh Bank primary text was not retrievable this cycle, reportedly due to a bot-wall on the central bank's own site. This is an architecture-level development rather than an enforcement incident: it does not alter the substantive AML/CTF regime itself, but it does consolidate the supervisory perimeter around foreign-exchange and gold-trading intermediaries that sit adjacent to classic trade-based laundering and gold-smuggling typologies in the region.

The circular supersedes prior individual instructions and runs for one year, suggesting Bangladesh Bank intends this as a living administrative baseline subject to renewal or further consolidation rather than a one-off tidying exercise. Because gold and foreign-exchange dealer networks are a recurring enabler layer in regional illicit-finance typologies, a single licensing and inspection instrument covering all five entity categories is a structural tightening of the supervisory surface, even absent a change to the underlying statute.

Other Developments

Standing AML/CTF architecture unchanged. Bangladesh's core AML/CFT framework continues to rest on the Money Laundering Prevention Act 2012 (as amended 2015) and the Anti-Terrorism Act 2009, with the Bangladesh Financial Intelligence Unit supervising within Bangladesh Bank. FATF's own Asia/Pacific Group country page records the last mutual evaluation as 2016, with the next possible on-site period in November 2027, indicating no fresh multilateral assessment has intervened this cycle.

Reporting-failure penalty confirmed at source. BFIU's own guidance document confirms that failure by a reporting organisation to file a suspicious transaction or suspicious activity report under Section 25(2) of the Money Laundering Prevention Act attracts a fine of not less than Tk 50,000 and not exceeding Tk 25 lakh. This is a standing feature of the regime rather than a new development, but it is directly sourced to the regulator's own primary document.

FATF list status. Secondary reporting states Bangladesh is not currently on the FATF list of jurisdictions with strategic AML deficiencies, a status corroborated by FATF's own country page, which records no grey-list flag against Bangladesh.

Cross-Monitor Connections

The consolidated FX and gold-dealer licensing circular is also material to the World Payments Monitor's licensing and market-access tracking, since authorised dealers and money changers sit within the broader foreign-exchange services perimeter that payments-focused oversight also tracks. No sanctions nexus, beneficial-ownership development, or conflict-finance signal was identified this cycle that would route to those adjacent trackers.

Outlook

Whether this administrative consolidation is followed by gazetted regulation, a published Bangladesh Bank primary text, or further sector-specific instructions is the open question carried into the next cycle. The absence of a retrievable primary document is itself a gap worth closing before the finding can be treated as more than probable; until a Tier-1 Bangladesh Bank source is obtained, confidence in the precise scope of the consolidated rules should remain qualified.

11 Oct 2026 · fim-2026-10-11

Lead Signal

Bangladesh widened its anti-money-laundering predicate-offence perimeter this cycle through the Gambling Prevention Act, 2026 (Act No. 98 of 2026). Two independent legal-commentary sources report that Section 25 of the Act designates the transfer, concealment or conversion of gambling proceeds through financial institutions, hundi, hawala, cryptocurrencies or digital assets as a predicate offence under the Money Laundering Prevention Act, 2012. The characterisation is probable rather than confirmed: no primary gazette text of the Act has been retrieved to date, and the finding rests on Tier-3 commentary corroborated across two independent outlets rather than on the statute itself.

The development sits alongside continuing documentary activity from the Bangladesh Financial Intelligence Unit (BFIU), which issued Circular No. 32 on 24 September 2026 addressed to Payment Service Providers and Payment System Operators, and Circular No. 33 on 30 September 2026 addressed to NGOs and NPOs, both on the prevention of money laundering, terrorist financing and proliferation financing. Both circulars are confirmed from BFIU's own official circular index, a Tier-1 primary source, though the substantive English-language text of either circular was not retrievable this cycle.

Other Developments

Crypto-gambling enforcement nexus reported. Secondary reporting describes crypto tools, wallets and VPN software seized in raids alongside gambling evidence, consistent with the broader pattern of gambling-linked laundering typologies the new predicate offence is designed to address. This finding rests on a single Tier-3 source and is assessed as probable; no Tier-1 enforcement record was located this cycle.

FATF standing unchanged. Bangladesh remains confirmed absent from both the February 2026 and the 19 June 2026 FATF increased-monitoring lists, a standing position dating to its removal from FATF monitoring in 2014. This is not a new development but provides context for reading the domestic predicate-offence expansion: it is an architecture change driven by domestic policy on gambling, not a response to deteriorating FATF standing.

Cross-Monitor Connections

The gambling-proceeds predicate-offence expansion names cryptocurrencies and digital assets explicitly as a laundering vector, which intersects with ongoing monitoring of Bangladesh's standing prohibition on virtual-asset transactions. Any crypto-settled gambling proceeds now fall within two separate domestic legal perimeters: the foreign-exchange control prohibition on crypto transactions, and the new money-laundering predicate offence under the Gambling Prevention Act. The BFIU circulars addressed to payment service providers and NGOs/NPOs also intersect with payments-sector AML/CFT supervisory architecture, where sector-specific instruction documents of this kind are a recurring feature of BFIU's supervisory approach.

Outlook

The gazette text of the Gambling Prevention Act, 2026 has not yet been retrieved in primary form, and confirming the exact wording and scope of Section 25 against the official statute remains an open item. Should the predicate-offence characterisation be confirmed against primary text, it would represent a durable widening of Bangladesh's AML perimeter rather than an isolated enforcement episode. The substantive content of BFIU Circulars No. 32 and No. 33 also remains to be confirmed in English-language detail; until then, only the existence, numbering and addressee category of each circular can be stated with confidence.

4 Oct 2026 · fim-2026-10-04

Lead Signal

Bangladesh has widened its anti-money-laundering predicate-offence architecture through the Gambling Prevention Act, 2026 (Act No. 98 of 2026), which took effect on 1 July 2026. The Act designates the transfer, concealment or legitimisation of gambling proceeds routed through banks, mobile financial services (MFS) accounts, digital wallets, hawala or hundi networks, or cryptocurrency as an offence under the Money Laundering Prevention Act, 2012. This is a structural widening rather than an incident: reporting entities across banking, payments and crypto-adjacent sectors now screen against a broader predicate-offence universe than before, with Bangladesh Bank and its Financial Intelligence Unit, BFIU, named among the implementing agencies tasked with enforcement.

The gazette text locating the precise predicate-offence clause has not been retrieved this cycle; the finding rests on tier-3 legal commentary rather than a primary statutory citation, which caps confidence at probable rather than confirmed. The underlying AML/CTF architecture against which this change sits is otherwise stable: Bangladesh's regime continues to rest on the Money Laundering Prevention Act, 2012 and the Anti-Terrorism Act, 2009, administered through BFIU, a member of the Egmont Group, with obliged entities filing suspicious transaction and cash transaction reports to that unit. Bangladesh is confirmed off the FATF grey list as of the 19 June 2026 plenary, among 22 jurisdictions that remained under increased monitoring at that sitting.

Other Developments

Standing AML/CTF baseline reaffirmed. Separate from the gambling-proceeds widening, this cycle corroborates the durable architecture of the Bangladeshi regime: statutory basis in the 2012 and 2009 Acts, supervisory and financial-intelligence functions concentrated in BFIU under Bangladesh Bank, and continued non-listing on the FATF grey list following the June 2026 plenary. This baseline record carries no new development in itself but anchors the predicate-offence widening against a stable institutional backdrop rather than a shifting one.

A compliance-technology gap surfaces alongside the new predicate offence. The Gambling Prevention Act, 2026 commits government agencies to artificial-intelligence and deep-packet-inspection-based detection methods for enforcement purposes, yet no corresponding BFIU supervisory guidance on AI or machine-learning transaction-monitoring model risk for obliged financial entities has been located this cycle. The result is a documented asymmetry: the state is instructed to deploy automated detection against gambling-related flows, while the private-sector reporting entities expected to screen the same flows for the new predicate offence have no published supervisory expectations for the technology that would do so. This is noted as an enforcement-gap observation rather than a settled finding, and confidence in the gap itself is uncertain since it is inferred from the absence of guidance rather than from a stated BFIU position.

Crypto posture unchanged. Bangladesh Bank continues to treat cryptocurrency dealing as prohibited, relying on section 23(1) of the Foreign Exchange Regulation Act 1947 together with the Anti-Terrorism Act 2009 and the Money Laundering Prevention Act 2012, rather than on a dedicated crypto statute. The 2026 National Blockchain Policy expressly excludes cryptocurrency trading and exchange activity from its scope, leaving the prohibition-by-reliance posture intact. This is relevant context for the gambling-proceeds widening, since cryptocurrency is explicitly named as one of the channels through which gambling proceeds may now constitute a predicate-offence laundering act, even though no licensed domestic crypto exchange sector exists to apply enhanced due diligence at that channel.

Cross-Monitor Connections

The gambling-proceeds predicate-offence designation touches payment rails that the World Payments Monitor tracks independently this cycle, including mobile financial services and digital wallets, though the illicit-finance use of those rails is a financial-integrity question and not a payments-conduct one. The compliance-technology gap identified here, concerning AI-driven detection obligations without matching private-sector model-risk guidance, is a signal worth routing to any monitor tracking financial-sector technology adoption, since the asymmetry between state detection ambition and industry practice guidance is a structural compliance-technology question rather than a single-institution failing.

Outlook

The interagency task force and expanded financial-surveillance powers contemplated under the Gambling Prevention Act, 2026 are expected to be operationalised further through the fourth quarter of 2026, as named agencies, including the Ministry of Home Affairs, Bangladesh Bank, BFIU, the Bangladesh Telecommunication Regulatory Commission, the Criminal Investigation Department and the National Cyber Security Agency, build out implementing practice. Whether BFIU issues parallel guidance to obliged entities on AI-driven transaction monitoring, closing the gap identified this cycle between state detection ambition and documented industry practice, is the item to watch. Confirmation of the precise gazetted predicate-offence clause, currently resting on tier-3 commentary, would allow this finding to move from probable toward confirmed.

21 Sep 2026 · fim-2026-09-21

Lead Signal

Bangladesh enacted the Gambling Prevention Act, 2026 (Act No. 98 of 2026), repealing the Public Gambling Act, 1867 and criminalising online gambling, crypto-denominated wagering, and VPN-based circumvention, effective 1 July 2026. The architecturally significant element for this monitor is not the gambling prohibition itself but what it wires into the anti-money-laundering system: the Act designates gambling-linked money laundering conducted via fake SIMs, fraudulent Mobile Financial Services (MFS) accounts, or cryptocurrency settlement as a predicate offence under the Money Laundering Prevention Act, 2012, carrying penalties of up to ten years' imprisonment. This closes a previously identified structural gap between Bangladesh's gambling-prohibition regime and its digital-payments AML architecture, formalising a laundering typology that MFS-sector supervisors had already been confronting operationally, and it does so through the enabler-channel mechanics of ghost SIMs and fraudulent mobile accounts rather than through a conventional financial-institution vector.

Other Developments

Crypto prohibition reaffirmed, not altered. Bangladesh Bank's long-standing posture that virtual-currency transactions are not recognised as approved foreign exchange under the Foreign Exchange Regulation Act, 1947 remains structurally unchanged this cycle, but it has been freshly reaffirmed through the 2026 National Blockchain Policy's explicit exclusion of cryptocurrency trading from its scope. This is a confirmed finding, sourced directly from Bangladesh Bank's Foreign Exchange Policy Department circular text, and it reasserts the central bank's exclusive jurisdiction over crypto activity via foreign-exchange and AML law rather than through any dedicated licensing framework.

MFS ghost-account channel formalised as an enabler pathway. Fake SIMs and fraudulent MFS accounts are identified, at a probable confidence tier, as the primary enabler channel through which gambling-linked laundering proceeds are moved. This is not a new phenomenon in isolation - Bangladesh's Financial Intelligence Unit has previously suspended tens of thousands of MFS accounts on similar grounds - but its formal capture as an MLPA predicate-offence pathway under the new Gambling Prevention Act represents a structural tightening of the enabler-jurisdiction picture for Bangladesh's mobile-money sector specifically.

FATF standing unaffected. Bangladesh remains outside the FATF list of jurisdictions under increased monitoring as of the June 2026 plenary, which added Bosnia and Herzegovina and Iraq and removed Algeria and Namibia, leaving 22 jurisdictions listed. This is a probable-confidence corroboration of the jurisdiction risk tracker's standing FATF-status line rather than a new development in itself.

Cross-Monitor Connections

The gambling-linked AML predicate-offence designation connects directly to the World Payments Monitor's tracking of Bangladesh Bank's new card-to-MFS cash-out linkage security rules, which independently tighten conduct requirements for the same mobile-financial-services rails now implicated in gambling-laundering typologies; the two developments describe complementary tightening across payments conduct and AML predicate-offence architecture within the same MFS ecosystem, though this brief does not re-analyse the payments-conduct dimension, which belongs to World Payments. The gambling-prohibition statute itself, and its consumer-facing and platform-enforcement provisions, are the primary subject matter of the Advennt gambling-regulatory monitor and are not re-analysed here beyond their AML predicate-offence dimension.

Outlook

The near-term watch item is implementation: a Ministry of Home Affairs-led task force, working with Bangladesh Bank, the Bangladesh Telecommunication Regulatory Commission, BFIU, the Criminal Investigation Department and the National Cyber Security Agency, is expected to operationalise the Act's enforcement provisions in the 2026 Q4 window, with an explicit gap noted between the new predicate-offence characterisation and current transaction-monitoring rule sets, which have not yet incorporated gambling-linked typologies into standard MFS monitoring practice. The gambling-linked predicate-offence finding itself rests on a single Tier 3/4 secondary source without independent primary confirmation this cycle, so continued monitoring for a corroborating primary-source publication - a BFIU circular or gazette notification specifically implementing the predicate-offence designation - would materially strengthen confidence in this finding going into the next cycle.

14 Sep 2026 · fim-2026-08-21

Lead Signal

Bangladesh's anti-money-laundering architecture was materially operationalised this cycle. The Cyber Security Act 2026, in force from 10 April 2026, criminalised online gambling under its Section 20, and in its wake the Bangladesh Financial Intelligence Unit suspended or froze transactions on roughly 55,000 mobile financial service accounts, predominantly on the bKash, Nagad, and Rocket platforms, linked to online gambling and informal digital hundi remittance. BFIU submitted an intelligence report to the Criminal Investigation Department in May 2026, which has since filed a case. This is the largest such account-freeze action on record for Bangladesh, and it demonstrates that the standing AML/CTF regime of record — the Money Laundering Prevention Act 2012, its 2013 Rules, and the Anti-Terrorism Act 2009/2013 Rules architecture administered by BFIU within Bangladesh Bank — has translated rapidly from statutory text into large-scale operational enforcement capacity. High confidence attaches to this finding, drawn from a direct Tier 1 state news agency report of a parliamentary ministerial statement. The architecture-over-incident read is that this is not an isolated enforcement action but evidence of a materially strengthened operational capability sitting behind an otherwise familiar legal framework, and that capability is the more consequential structural finding than the freeze event itself.

Other Developments

Digital hundi as the dominant enabler channel. BFIU's gambling-linked account-freeze programme is consistently co-labelled with digital hundi, an unlicensed informal remittance channel, indicating that hundi networks function as Bangladesh's principal professional-facilitator and enabler-adjacent channel rather than as a separate typology running in parallel to gambling-linked laundering. This finding rests on a single trade-press corroboration of a government-sourced statement, and no dedicated structural investigation of the hundi networks themselves was located this cycle. The three-pillar balance point here is that this is an AML finding with enabler-jurisdiction characteristics rather than a distinct enabler-jurisdiction finding in its own right; the analytical significance lies in the co-mingling rather than in either channel considered alone.

Myanmar border conflict finance escalating. The Arakan Army's territorial consolidation across Rakhine State has opened a security vacuum exploited by transnational criminal networks for arms and drug smuggling and human trafficking across the Bangladesh-Myanmar border, with reporting alleging collusion between elements of Border Guard Bangladesh and armed Rohingya groups. This assessment is capped at Assessed confidence pending primary-source corroboration beyond the trade-press reporting relied upon this cycle, but the trajectory is worsening and the finding is structural rather than episodic. The CPF-pillar significance of this development should not be under-weighted relative to the AML volume generated by the gambling-account-freeze programme: proliferation-finance-adjacent smuggling routes across an active security vacuum represent a structurally distinct risk from consumer-facing gambling laundering, even though both surfaced from Bangladesh-focused research this cycle.

Crypto ambiguity converging rather than resolving. Bangladesh Bank maintains an outright prohibition on cryptocurrency transactions under the Foreign Exchange Regulation Act 1947 and the Money Laundering Prevention Act 2012, yet the new Gambling Prevention Act 2026 and Cyber Security Act 2026 now explicitly name cryptocurrency as a money-laundering vector within their own provisions. The coexistence of an outright transaction prohibition with statutory recognition of crypto as a laundering vector signals unresolved regulatory ambiguity that is more likely to generate further enforcement or clarification activity than to resolve on its own. This is a jurisdiction where enablement and enforcement now point in different statutory directions simultaneously, and that internal contradiction is itself the signal worth tracking, independent of which direction ultimately prevails.

Cross-Monitor Connections

The gambling-linked laundering typology surfaced this cycle sits directly at the intersection of retail payments-rail infrastructure and consumer-facing gambling-regulatory enforcement, both of which are being tracked in parallel research streams within this fleet. The scale of the BFIU account-freeze action is payments-infrastructure-relevant in its own right, since it reaches directly into the mobile-financial-service rails that underpin much of Bangladesh's retail payments ecosystem, independent of the AML/CTF analysis proper. Equally, the underlying statutory driver — the criminalisation of online gambling itself — is a gambling-regulatory development with laundering-typology consequences rather than the reverse, meaning enforcement-capacity findings recorded here should be read alongside, not instead of, the gambling-regulatory record of the same underlying statute.

Outlook

The near-term horizon is implementation-focused: a Ministry of Home Affairs-led interagency task force, together with Bangladesh Bank, BFIU, BTRC, CID, and the National Cyber Security Agency, is being stood up this quarter to formalise the BFIU-to-CID intelligence pipeline for gambling-linked financial crime, an improving-direction development given the surveillance-capacity gap that general reporting-entity practice still shows relative to the Act's continuous-monitoring expectation. What would most change this picture next cycle is either a dedicated structural investigation into the digital hundi networks themselves, which remains a gap in the evidentiary record, or primary-source corroboration of the Myanmar border conflict-finance reporting, which currently rests entirely on secondary trade-press sourcing. Absent either development, expect continued escalation on the D3/D4/D5 fronts alongside sustained enforcement momentum on D7.

Domain intelligence (D1–D8)

D1 Sanctions

no_changestanding position

Sanctions

This cycle's only sanctions-architecture signal for Bangladesh is a single Tier 4 op-ed reporting a Reciprocal Trade Agreement between Bangladesh and the United States, said to have been concluded in February 2026, under which Bangladesh would take on an obligation (reportedly Articles 4.1 through 4.3) to align its export controls and restrict transactions that would violate US sanctions, with explicit reference to the US Entity List and OFAC designation lists. No primary treaty text has been located, and no Tier 1 or Tier 2 government source, from either Washington or Dhaka, has corroborated the existence or terms of this clause this cycle. Read through an enablement-as-signal lens, the absence of primary confirmation is itself notable: a bilateral mechanism that would pull a non-US jurisdiction toward US designation-list alignment outside the multilateral sanctions architecture would ordinarily generate government-level commentary or trade-press confirmation, and none has surfaced. This is treated as a Low-confidence, single-source signal pending corroboration rather than a structural finding about Bangladesh's sanctions posture.

Continue reading

Outlook

The operative question for this domain is corroboration, not trajectory: whether primary treaty text, a USTR or Bangladesh Ministry of Commerce statement, or independent trade-press reporting surfaces to confirm or disconfirm the alignment clause. Until that happens, this item remains a watch item rather than an assessed development, and no downstream sanctions-exposure judgment should be drawn from it.

D2 Beneficial Ownership

no_change

BD not on FATF grey/black list as of 30 Oct 2026 plenary; no change.

D3 Enabler Jurisdictions

no_changestanding position

Enabler Jurisdictions and Professional Facilitators

The defining development in this domain, and arguably in the cycle overall, is the Gambling Prevention Act, 2026's explicit statutory naming of hawala and hundi networks -- Bangladesh's dominant informal value-transfer systems -- as channels through which gambling proceeds can be laundered, alongside banks, mobile financial services accounts, digital wallets, and cryptocurrency. This is a structural rather than incidental change: for the first time, Bangladesh's primary money-laundering statute, the Money Laundering Prevention Act, 2012, has a gambling-specific predicate-offence hook that reaches directly into the informal value-transfer system that has historically sat outside formal AML supervision. The designation is corroborated across multiple Tier 2 and Tier 3 press sources -- BSS News, GGRAsia, and others -- though the verbatim gazetted statutory language has not been independently retrieved, and this gap is logged rather than assumed away.

Continue reading

The enabler-jurisdiction reading of this development treats Bangladesh not as a passive victim of external laundering flows but as a jurisdiction whose own informal-finance architecture has now been formally recognised, in statute, as a laundering vector requiring active enforcement attention. That recognition is reinforced by enforcement volume rather than left as an abstract legal designation: the Bangladesh Financial Intelligence Unit has frozen or suspended approximately 55,000 mobile financial services accounts linked to online gambling and digital hundi activity, a figure disclosed on 24 June 2026, followed by a further approximately 24,000 accounts through early August 2026, for a cumulative total exceeding 79,000 accounts. This is a High-confidence, Tier 3-corroborated enforcement figure, and its scale -- tens of thousands of accounts across a period of roughly six weeks -- indicates a systemic sweep rather than a small number of targeted investigations.

Architecture-over-incident framing is warranted here: the account freezes are the incident, but the statutory predicate-offence designation is the architecture that will outlast this particular enforcement wave and shape how future hundi/hawala-linked flows, gambling-related or otherwise, are treated by Bangladeshi financial institutions and their compliance functions. A persistent structural enabler risk sits alongside this development and is independent of it: Bangladesh's company registry continues to lack a centralised, publicly accessible beneficial-ownership layer, a gap that predates and is unaffected by this cycle's gambling-law developments and that continues to concentrate ownership opacity in one-person-company structures. This structural gap is noted here only as context for the enabler-jurisdiction picture and is not itself a cycle development.

Outlook

The key question for this domain going forward is implementation depth: whether Bangladesh Bank and the BFIU issue guidance that operationalises the new predicate-offence designation into concrete reporting obligations for MFS providers and hundi/hawala-adjacent financial channels, or whether the designation remains primarily a criminal-law hook exercised through account freezes without a parallel supervisory-reporting regime. A second thing to watch is whether the account-freeze campaign, now exceeding 79,000 accounts, produces any formal typology report or FIU publication that would allow this monitor to assess false-positive rates and the proportion of frozen accounts tied to confirmed gambling activity versus adjacent informal-finance use.

D7 AML/CTF Regime

stable

AML/CTF Regime

The defining development in Bangladesh's AML/CTF regime this cycle is the Bangladesh Financial Intelligence Unit's 20 October 2026 circular bringing life and non-life insurance companies under a formal compliance architecture for the first time at this level of specificity. Where prior obligations on the sector were comparatively general, the new circular requires each insurer to stand up a central compliance unit and name a Chief Anti-Money Laundering Compliance Officer, to screen customers against United Nations Security Council and domestic sanctions lists, to apply enhanced due diligence to politically exposed persons and to customers connected to high-risk jurisdictions, and to report large cash transactions. This is architecture, not incident: the circular does not respond to a specific enforcement failure in the insurance sector but instead extends to it the governance infrastructure already expected of banks, closing a gap in obliged-entity coverage that had persisted even as banks were held to materially stricter standards.

Continue reading

The obligation traces to the Money Laundering Prevention Act 2012 and the Anti-Terrorism Act 2009, applied through the insurer-specific circular, and is corroborated by three independent Bangladeshi business-press outlets reporting consistently on the same instrument, though the primary BFIU circular text has not itself been retrieved this cycle, leaving the precise scope and citation of the mandate to be confirmed against the primary source. The practical significance is in the structural message it sends about supervisory ambition: insurance intermediaries, underwriters and brokers now sit inside a sanctions-screening and enhanced-due-diligence perimeter they did not previously occupy with this degree of specificity, and the cash-transaction reporting requirement gives the regime a monitoring channel into a sector that has historically generated comparatively little AML enforcement volume relative to banking.

Alongside the insurance-sector extension, Bangladesh Bank's unified foreign-exchange circular, consolidating prior fragmented foreign-exchange directives under the Foreign Exchange Regulation Act 1947, explicitly reiterates the prohibition on exchanging, transferring and transacting virtual assets and virtual currencies. Within the AML/CTF frame, this restates rather than revises the compliance obligation already resting on regulated entities with respect to virtual-asset activity; its significance here lies in consolidation of the regulatory text rather than in any change of substantive duty.

Outlook

The principal open item is verification: confirming the exact scope, obliged-entity definitions and statutory citation of the insurer mandate against the primary BFIU circular, rather than relying solely on press corroboration, is the most consequential unresolved question carried into the next cycle. A secondary open item is the crypto-gains tax treatment question, which remains unverified and sits adjacent to, but distinct from, the AML/CTF compliance question addressed by this cycle's developments. Absent a primary-source correction, the structural trajectory is toward broader obliged-entity coverage of the insurance sector, which should be expected to generate downstream guidance, implementation timelines, or sector commentary in subsequent cycles.

Cumulative analysis

AML/CTF Regime

Bangladesh's standing AML/CTF regime — the Money Laundering Prevention Act 2012, its 2013 Rules, and the Anti-Terrorism Act 2009 and its 2013 Rules, administered by the Bangladesh Financial Intelligence Unit within Bangladesh Bank — has been materially operationalised this cycle through its intersection with the new Gambling Prevention Act 2026 and Section 20 of the Cyber Security Act 2026, in force from 10 April 2026, which criminalises online gambling directly. In the wake of that criminalisation, BFIU suspended or froze transactions on approximately 55,000 mobile financial service accounts — predominantly on the bKash, Nagad, and Rocket platforms — linked to online gambling and informal digital hundi remittance. This is a High-confidence finding, drawn directly from a Tier 1 state news agency report of a parliamentary ministerial statement, and it represents the largest single account-freeze action on record for this jurisdiction.

The significance of this development is architectural rather than episodic. A regime that, on paper, looks similar to many other developing-market AML/CTF frameworks — a primary statute, implementing rules, a financial intelligence unit housed within the central bank — has now demonstrated an operational capacity to act at genuine scale against a specific typology within months of a triggering statutory change. BFIU submitted an intelligence report to the Criminal Investigation Department in May 2026, and CID has since filed a case, evidencing a functioning intelligence-to-prosecution pipeline rather than a purely administrative freeze action that terminates at the financial institution.

Confidence in this reading is reinforced by source diversity: the core freeze-and-referral chain is confirmed by a Tier 1 state news agency account of a parliamentary ministerial statement, while the specific institutional composition of the frozen accounts is corroborated by Tier 3 business-press reporting citing the BFIU official responsible. Where those two source tiers converge on the same operational chain, the overall finding is stronger than either tier would support alone.

The finding should also be weighted against what it does not yet demonstrate. The account freezes reach the payments layer; they do not, on the evidence available this cycle, demonstrate equivalent capacity against the digital hundi networks' own organisational structure, nor against the offshore-hosted gambling platforms that the frozen accounts were ultimately funding. The AML/CTF regime has shown it can act decisively against domestic financial rails; it has not yet shown, on this cycle's evidence, that it can reach the underlying illicit infrastructure those rails were serving. On the three-pillar balance this analytical register requires, this cycle's signal is overwhelmingly AML in character; no CTF- or CPF-specific development attaches to the gambling-enforcement action itself.

Outlook

The near-term horizon for Bangladesh's AML/CTF regime is implementation-focused: a Ministry of Home Affairs-led interagency task force, working with Bangladesh Bank, BFIU, the Bangladesh Telecommunication Regulatory Commission, CID, and the National Cyber Security Agency, is being stood up this quarter to formalise the BFIU-to-CID intelligence pipeline for gambling-linked financial crime specifically. This is assessed as an improving-direction development, though general reporting-entity practice for gambling-linked mobile-financial-service surveillance is still maturing relative to the Act's mandatory continuous-monitoring expectation, meaning the task force's near-term work is likely to surface further compliance gaps at the reporting-entity level even as the BFIU-to-CID pipeline itself strengthens. The practical burden implied by the Act's continuous-monitoring expectation is non-trivial for mobile-financial-service and payment-company reporting entities specifically, and it is this bar — not the freeze action itself — that the interagency task force's near-term work is most likely to test.

domain_sub_briefs · D7 · Cumulative analysis
Standing baseline position

BFIU mandates a central compliance unit, a named CAMLCO, UNSC/domestic sanctions screening and EDD for PEPs/high-risk customers across all life and non-life insurers (circular reported 20 Oct 2026).

Periodic updates (5)
3 Nov 2026 · fim-2026-11-01

AML/CTF Regime

The defining development is the extension of formal AML/CTF compliance architecture to the insurance sector in Bangladesh. The Bangladesh Financial Intelligence Unit directed every insurance company to form a central compliance unit, appoint a Chief Anti-Money Laundering Compliance Officer, screen customers against United Nations Security Council and domestic proscription lists, apply enhanced due diligence to politically exposed persons and to customers connected to high-risk jurisdictions, and report large cash transactions and suspicious activity. The circular is dated 20 October 2026 and rests on the Money Laundering Prevention Act 2012 and the Anti-Terrorism Act 2009, applied through sector-specific guidance rather than new primary legislation.

Read against the three-pillar balance that AML, CTF, and CPF findings deserve, this is squarely an AML-architecture finding: the obligations set out are classic customer due diligence, screening, and reporting controls rather than anything specific to terrorist financing or proliferation financing typologies. That said, the screening-against-UNSC-lists component does carry CTF and sanctions-implementation weight, since UNSC lists capture both terrorism and proliferation designees, so the insurance sector's new screening obligation is not purely an AML matter even though it is framed that way administratively.

The structural significance of bringing insurers into a compliance framework previously centred on banks and mobile financial service providers should not be understated. Insurance products, particularly those with cash-value or investment components, have historically been a comparatively under-monitored channel relative to deposit-taking institutions in many markets, and Bangladesh's move closes a perimeter gap rather than responding to a specific enforcement incident. This is architecture-over-incident in its purest form: no reported case or sanction triggered the circular; instead, the regulator appears to have assessed the sector as a residual gap and acted pre-emptively.

Implementation is the open question. General industry practice among Bangladeshi insurers has not previously required a dedicated compliance-unit and CAMLCO structure equivalent to what banks operate, and a lag in implementation should be anticipated, particularly among smaller non-life insurers that may lack existing compliance capacity or budget to build it out quickly. The underlying circular text has not been independently retrieved; the finding is corroborated by business-press reporting rather than the regulator's own published document, which means provision-level details, including any formal deadline or penalty schedule for non-compliance, remain to be confirmed against the primary source.

Separately, but within the same AML/CTF regime frame, Bangladesh's position on the FATF grey list is unchanged following the late-October 2026 plenary. The Financial Action Task Force removed Bulgaria, Cote d'Ivoire, the Democratic Republic of the Congo, and Monaco from increased monitoring at that sitting, bringing the global grey list to eighteen jurisdictions, but Bangladesh featured in neither the additions nor removals. This is a stability signal rather than a development, and it is worth stating because the absence of FATF action is itself informative: it suggests Bangladesh's underlying AML/CTF regime, at FATF's current assessment, is not viewed as requiring the kind of international pressure that grey-listing represents, even as the country continues domestic architecture-building of its own initiative.

Outlook

The insurance-sector mandate will be worth tracking for whether implementation proceeds on the timeline regulators expect, or whether a visible compliance gap emerges among smaller insurers that prompts a follow-up supervisory circular, inspection programme, or enforcement signal. Because the primary circular was not retrieved directly, confirming the precise compliance deadline, penalty structure, and any phase-in provisions against the regulator's own text would sharpen the picture considerably; until then, this remains a probable-confidence finding resting on consistent but secondary reporting. Bangladesh's steady, off-list FATF status provides a stable backdrop against which this sector-specific tightening should be read as self-directed architecture-building rather than externally compelled remediation, and nothing in the current evidence suggests Bangladesh anticipates near-term FATF scrutiny that would change that posture.

Baseline-Tracked Domains with No Current-Cycle Escalation (1 of 8)
  • D8 Commercial Activity: Standing coverage — no activity this cycle.
Regulatory horizon
Consultation2028-Q3 · ±year

APG Fourth/Fifth-Round Mutual Evaluation of Bangladesh

Bangladesh is compiling national risk assessments and a national AML/CFT strategy ahead of the APG's onsite visit (possible 2027-11) and plenary discussion (possible 2028-07).
2 dated · 3 pending date · baseline fim-2026-07-09
Role action cards
MLRO

BFIU extends formal AML/CFT compliance architecture to the insurance sector for the first time at this level of specificity.

The insurer circular introduces sanctions screening, enhanced due diligence for PEPs and high-risk-jurisdiction customers, and large cash-transaction reporting as governance-level obligations rather than general exhortations, which materially changes the baseline against which SAR-adjacent triggers in the insurance sector will be assessed.

1 evidence refs
Compliance

Insurance sector brought under a named-officer, screened-customer compliance architecture; FX circular consolidated without substantive crypto change.

Insurers now face a governance-infrastructure requirement (central compliance unit, named compliance officer) that did not previously exist at this specificity, while banks and crypto-asset operators see their existing virtual-asset compliance posture restated rather than altered within a consolidated FX text.

2 evidence refs
Board

Regulatory architecture is broadening to a previously under-covered sector, and the FATF position remains unchanged.

The insurance-sector mandate signals continuing supervisory ambition to close obliged-entity gaps, while Bangladesh's standing off the FATF grey and black lists as of the 30 October 2026 plenary provides continuity rather than new reputational exposure.

2 evidence refs
CTO

Virtual-asset transaction prohibition restated within a consolidated foreign-exchange circular, with no change to the underlying rule.

Systems and controls built around the existing prohibition on exchanging, transferring or transacting virtual assets do not require amendment; the change is one of regulatory-text consolidation rather than substantive rule.

1 evidence refs
Risk

Sectoral AML tightening in insurance and a reiterated crypto prohibition are architecture consolidations, not signals of deteriorating underlying risk.

Both developments are structural and enforcement-oriented rather than episodic, and should be read as consolidation of compliance architecture rather than as evidence that underlying money-laundering or virtual-asset risk in Bangladesh is worsening or improving this cycle.

2 evidence refs
Operations

Insurers face new screening and reporting workflow requirements; no new transaction-monitoring threshold change for other sectors.

Operational workflows at insurance firms will need to accommodate sanctions-list screening, PEP and high-risk-jurisdiction enhanced due diligence, and large cash-transaction reporting; no equivalent new processing requirement arises from the FX circular consolidation.

1 evidence refs
Audit

New governance-control requirements at insurers create a fresh control-testing scope once the primary circular text is confirmed.

The central compliance unit and named compliance officer requirement for insurers will need to be reflected in control-testing scope, though the precise audit criteria cannot be finalised until the primary BFIU circular text, rather than press reporting alone, is available.

1 evidence refs
Standing trackers (T1–T6)
TrackerStatusNote
T1 · Russian Sanctions-Evasion Architectureno_change
T2 · EU AML Package / AMLAno_change
T3 · FATF Grey Listno_change
T4 · Beneficial-Ownership Register Statusno_change
T5 · Crypto & Digital-Asset Integritystable
T6 · Sanctions Regime Divergenceno_change
Registers

Enforcement actions

  • 11 Aug 2025
  • 1 Dec 2025
  • 2 Feb 2026
  • 14 Jun 2026
  • 17 Nov 2025
  • 24 Jun 2026
  • 4 Aug 2026
  • In-absentia corruption trials opened over unlawful allocation of state-owned Purbachal New Town Project land to individuals with personal or political ties to the former prime minister's family, part of a wider set of prosecutions targeting the ousted administration. 11 Aug 2025
  • Court convicted and sentenced former PM Sheikh Hasina to 10 years, and UK MP Tulip Siddiq and two siblings to 4-7 years each, in absentia, for abuse of office in allocating Purbachal New Town government land plots to family members. 2 Feb 2026
  • Central bank invoked emergency powers under the Bank Company Act 1991 to dissolve the entire board of the country's largest Islamic lender by assets, citing depositor and public interest, amid long-running allegations of related-party lending capture by a politically connected conglomerate. 14 Jun 2026
  • Tribunal sentenced the former prime minister to death in absentia for crimes against humanity over the deadly crackdown on protesters during the July-August 2024 uprising that ended her 15-year rule, a case intertwined with parallel financial-crime and asset-recovery proceedings against her network. 17 Nov 2025

Sanctions changes

  • 10 Dec 2021
  • UK National Crime Agency obtained account/property freezing orders covering 342 UK properties worth approximately £185 million ($252 million) linked to the family of a former Bangladeshi land minister, as part of a broader crackdown on assets held by members of the ousted Awami League government. 12 Jun 2025
  • OFAC's December 2021 designation of the Rapid Action Battalion (RAB) and associated officials for serious human rights abuse remains in force with no delisting or modification identified during the 18-month window; no equivalent EU or UK (OFSI) designation of RAB exists, leaving a persistent cross-regime divergence in how Bangladesh security-sector risk is treated for sanctions-screening purposes. 10 Dec 2021
  • Bangladesh's Anti-Corruption Commission pursued domestic asset-freeze and confiscation proceedings against Hasina-era officials and their relatives, including the Purbachal land-allocation defendants, as part of prosecutions running in parallel with international asset-recovery requests. 11 Aug 2025

Regulatory horizon (register)

  • Gambling Prevention Act 2026 implementation task force
  • Gambling Prevention Act 2026 implementation task force
  • Gambling Prevention Act 2026 implementation task force
  • Gambling Prevention Act, 2026 implementing rules / interagency task force formation
  • APG Fourth/Fifth-Round Mutual Evaluation of Bangladesh
  • BFIU insurer AML/CFT circular implementation
  • IMF loan tranche conditions on banking-sector and NPL reform
  • Bangladesh Bank independence and governance reform legislation
  • Next FATF/APG follow-up report on Bangladesh technical compliance

Active schemes

  • [HIGH] Bank-board capture enabling large-scale asset stripping
  • [HIGH] Political-elite offshore layering via UK and US real estate
  • Armed-group extortion and hawala financing in Rohingya camps
  • Underground crypto adoption despite central-bank ban
  • Export under-invoicing capital flight in garment sector
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  114. 07 September 2025 1
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  117. Report: Rohingya Refugees Exposed to Violence in Bangladesh Camps | OCCRP
  118. 2025-26 Joint Response Plan: Rohingya Humanitarian Crisis in Bangladesh | United Nations in Bangladesh
  119. UNHCR / BANGLADESH ROHYNGYA REFUGEES | UNifeed
  120. General Assembly Urges Protection, Justice, Lasting Solutions for Rohingya as Crisis Deepens | UN Meetings Coverage and Press Releases
  121. Recalibrating the Rohingya Response: 2025-26 Joint Response Plan | United Nations in Bangladesh
  122. Bangladesh Removes Entire Board of Its Largest Islamic Bank, Islami - Bloomberg
  123. bangladesh annual country report 2024
  124. CALL DOWN CONTRACT Framework Agreement with: Pegasys Limited
  125. Technical Assistance for the Independence and Reorganisation of the Central Bank of Bangladesh - Contracts Finder
  126. Bangladesh Voluntary National Review (VNR) 2025 - HLPF
  127. Technical Assistance on Bank Recovery, Resolution and Financial Stability for Bangladesh Bank - Contracts Finder
  128. Bangladesh Development Update April 2024 - Knowledge for policy - European Commission
  129. Md Mahbub-Ul-Alam, Islami Bank Bangladesh Ltd: Profile and Biography - Bloomberg Markets
  130. Bangladesh Continues Talks with IMF on Key Reforms Tied to Loan - Bloomberg
  131. Global Crypto Policy Review Outlook 2025/26 Report | TRM Labs
  132. FATF urges stronger global action to address Illicit Finance Risks in Virtual Assets
  133. From trading bans to total embrace, a global guide to crypto regulation
  134. Quick guide on assessing the Money Laundering risks of virtual assets (VA) and virtual asset service providers (VASP)
  135. What Is a VASP? Virtual Asset Service Provider - Chainalysis
  136. Elliptic's 2026 regulatory and policy outlook: 5 crypto trends to expect in 2026
  137. Virtual Asset Service Provider (VASP): Definition, Compliance & Examples
  138. Virtual Assets
  139. Crypto Sanctions: 2026 Crypto Crime Report
  140. 2025 Crypto Adoption and Stablecoin Usage Report | TRM Labs
  141. Nigeria Slaps Strict Rules on Banks After Lifting Cryptocurrency Ban - Bloomberg
  142. Nigeria Central Bank Orders Cryptocurrency Accounts to Close - Bloomberg
  143. Is Crypto Trading Legal in India? Reserve Bank India Clarifies 2018 Rule - Bloomberg
  144. Nigeria Central Bank Fines Lenders for Shielding Cryptocurrency Transactions - Bloomberg
  145. Nigeria to Ban Person-to-Person Crypto Trade in Dented Naira (NGN/USD) - Bloomberg
  146. Crypto compliance
  147. Trade-Based Money Laundering (TBML) handbook - Common techniques of trade-based money laundering - Guidance - GOV.UK
  148. APG Typology Report on Trade Based Money Laundering
  149. Financing Costs, Per-Shipment Costs and Shipping Frequency: Firm-Level Evidence from Bangladesh
  150. Trade-Based Money Laundering
  151. Money Laundering vulnerabilities of Free Trade Zones
  152. WHAT IS TRADE-BASED MONEY LAUNDERING?
  153. Illicit Financial Flows iff Report of the High Level Panel
  154. Trade-Based Money Laundering Trends and Developments December 2020
  155. Opening remarks at Trade-Based Money Laundering Press Conference
  156. UK Freezes 342 Properties Linked to Ex-Bangladesh Minister - Bloomberg
  157. Joint Evaluation of Support to Anti-Corruption Efforts ...
  158. DFID's Anti-Corruption Strategy for Bangladesh
  159. Bangladesh MP Faces Scrutiny Following OCCRP Investigation | OCCRP
  160. Organized Crime and Corruption Reporting Project | OCCRP
  161. UNODC Corruption and Financial Crime Branch
  162. Overseas business risk: Bangladesh - GOV.UK
  163. Financial Action Task Force / Asia Pacific Group on Money Laundering
  164. Financial Action Task Force / Asia Pacific Group on Money Laundering
  165. Financial Action Task Force
  166. UNODC / Government of Bangladesh
  167. OCCRP
  168. ICIJ
  169. Bloomberg
  170. Bloomberg
  171. TRM Labs
  172. UK Government (FCDO)
Coverage gaps
fim-int-2026-07-07-G001: No current FATF or APG substantive …
fim-int-2026-07-07-G001: No current FATF or APG substantive follow-up report on Bangladesh exists since 2020 despite a December 2025 page update, weakening confidence in effectiveness ratings during a period of major political transition. [resolved]
fim-int-2026-07-07-G002: The 17 to 30 billion dollar corrupt…
fim-int-2026-07-07-G002: The 17 to 30 billion dollar corruption-loss estimate lacks a documented primary source or methodology and should be independently verified before being treated as a firm baseline figure. [resolved]
fim-int-2026-07-07-G003: No independent forensic audit or pr…
fim-int-2026-07-07-G003: No independent forensic audit or primary-source documentation establishes the full ultimate-beneficial-ownership chain behind the Islami Bank related-party lending, limiting confirmation of the severity and scope of the capture scheme. [resolved]
fim-int-2026-07-07-G004: Primary court-record verification o…
fim-int-2026-07-07-G004: Primary court-record verification of the exact dates and sentencing lengths in the December 2025 Purbachal verdict and the February 2026 Rajuk-case verdict would resolve the conflation identified in challenge review and is currently sourced only via quality-journalism reporting. [resolved]
fim-int-2026-07-07-G005: No primary regulatory documentation…
fim-int-2026-07-07-G005: No primary regulatory documentation establishes whether Bangladesh cryptocurrency ownership is formally criminalized under existing statute or remains an enforcement gray area, a distinction material to assessing the Recommendation 15 compliance gap. [resolved]
fim-int-2026-08-05-G001: Primary treaty text of the US-Bangl…
fim-int-2026-08-05-G001: Primary treaty text of the US-Bangladesh Reciprocal Trade Agreement sanctions-alignment clause not retrieved; single Tier-4 op-ed source only. [resolved]
fim-int-2026-08-05-G002: APG mutual evaluation (Tier-1) UBO …
fim-int-2026-08-05-G002: APG mutual evaluation (Tier-1) UBO finding for Bangladesh not directly quoted this cycle. [resolved]
fim-int-2026-08-05-G003: Tier-D watch jurisdictions (KH, LA,…
fim-int-2026-08-05-G003: Tier-D watch jurisdictions (KH, LA, MX, CO) not independently searched this cycle; research budget concentrated on the BD dispatch. [resolved]
fim-int-2026-08-05-G004: No formal financial-flow data or FI…
fim-int-2026-08-05-G004: No formal financial-flow data or FIU-specific typology report located confirming terrorist-financing infrastructure inside Bangladesh Rohingya camps. [resolved]
fim-int-2026-08-21-G001 ({'scheme': 'financial_integrity', '…
fim-int-2026-08-21-G001 ({'scheme': 'financial_integrity', 'value': 'D3'}): No dedicated hundi-network structural investigation located this cycle; D3 enabler-jurisdiction analysis rests on single T3 corroboration of a T1-sourced government statement. [resolved]
fim-int-2026-08-21-G002 ({'scheme': 'financial_integrity', '…
fim-int-2026-08-21-G002 ({'scheme': 'financial_integrity', 'value': 'D4'}): No T1/T2 primary-source confirmation located for the Bangladesh-Myanmar border conflict-finance reporting; capped at Assessed confidence. [resolved]
fim-int-2026-08-21-G003: Tier-D watch list (KH/LA/MX/CO) was…
fim-int-2026-08-21-G003: Tier-D watch list (KH/LA/MX/CO) was not actively searched this cycle given the BD-scoped single-jurisdiction dispatch. [resolved]
fim-int-2026-08-21-G004 ({'scheme': 'financial_integrity', '…
fim-int-2026-08-21-G004 ({'scheme': 'financial_integrity', 'value': 'D6'}): No material RegTech/AI transaction-monitoring development for BD located this cycle (D6). [resolved]
fim-int-2026-09-21-G001 ({'scheme': 'financial_integrity', '…
fim-int-2026-09-21-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): No BD-specific D1 (Sanctions) finding identified this cycle; no primary source located. [resolved]
fim-int-2026-09-21-G002 ({'scheme': 'financial_integrity', '…
fim-int-2026-09-21-G002 ({'scheme': 'financial_integrity', 'value': 'D2'}): No BD-specific D2 (Beneficial Ownership) development identified this cycle; awaiting primary source. [resolved]
fim-int-2026-09-21-G003: Tier D watch jurisdictions (Cambodi…
fim-int-2026-09-21-G003: Tier D watch jurisdictions (Cambodia, Laos, Mexico, Colombia) were not actively re-swept this cycle given budget concentration on the bound jurisdiction's own delta. [resolved]
fim-int-2026-09-21-G004 ({'scheme': 'financial_integrity', '…
fim-int-2026-09-21-G004 ({'scheme': 'financial_integrity', 'value': 'D7'}): The gambling-linked laundering predicate-offence characterisation rests on a single T3/T4 secondary source (ZIGRAM); no independent second primary confirmation was located this cycle. [resolved]
fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): Official gazette text of the Gambling Prevention Act, 2026 (predicate-offence clause pinpoint section) was not retrieved; finding rests on T3 legal commentary. [resolved]
fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', 'value': 'D6'}): No BFIU-specific AI/ML transaction-monitoring model-risk guidance was located this cycle, leaving a documented gap between the Act's state-side AI ambition and private-sector practice guidance. [resolved]
fim-int-2026-10-04-G003: D1-D4 showed thin coverage for Bang…
fim-int-2026-10-04-G003: D1-D4 showed thin coverage for Bangladesh this cycle; Tier D watch jurisdictions (KH, LA, MX, CO) were out of scope for this single-JID-bound dispatch. [resolved]
fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): No Tier-1 gazette text of the Gambling Prevention Act 2026 (bdlaws.minlaw.gov.bd) was retrieved this cycle; the predicate-offence characterisation under s.25 rests on two independent Tier-3 sources only. [resolved]
fim-int-2026-10-11-G002: D1-D4 and D6 yielded no BD-specific…
fim-int-2026-10-11-G002: D1-D4 and D6 yielded no BD-specific substantive finding this cycle despite targeted searching; Tier D jurisdiction watch (KH, LA, MX, CO) was not separately actively searched owing to pooled search budget concentration on BD. [resolved]
fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', 'value': 'D7'}): BFIU Circular No. 32/33 English-language substantive text was not retrievable this cycle (Bangla-only download); only title, number and date are confirmed. [resolved]
fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): No official Bangladesh Bank primary-source PDF of the 17-18 Oct 2026 consolidated FX/gold licensing circular was retrievable this cycle (bb.org.bd reported to sit behind a bot-wall); finding rests on two independent Tier-3 press reports. [resolved]
fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', 'value': 'D1'}): No Bangladesh-specific sanctions designation, beneficial-ownership registry development, or enabler-jurisdiction finding was located this cycle (D1, D2, D3 thin coverage). [resolved]
fim-int-2026-10-25-G001: Tier-D jurisdictions (KH, LA, MX, C…
fim-int-2026-10-25-G001: Tier-D jurisdictions (KH, LA, MX, CO) were not separately re-searched this cycle given the pooled budget was concentrated on the bound jurisdiction (BD); this is logged as a coverage gap rather than an asserted no-change for those four. [resolved]
fim-int-2026-10-25-G002: No BD beneficial-ownership registry…
fim-int-2026-10-25-G002: No BD beneficial-ownership registry development or crypto-specific regulatory instrument change was located this cycle; source coverage for D2 and D5 remains thin for Bangladesh. [resolved]
fim-int-2026-11-01-G001: No primary BFIU circular text was r…
fim-int-2026-11-01-G001: No primary BFIU circular text was retrieved to confirm the exact scope and citation of the insurer AML/CFT mandate reported 20 October 2026. [open]
fim-int-2026-11-01-G002: Tier D watch jurisdictions (KH, LA,…
fim-int-2026-11-01-G002: Tier D watch jurisdictions (KH, LA, MX, CO) could not be resolved within this single-jurisdiction search budget. [open]
fim-int-2026-11-01-G003 ({'scheme': 'financial_integrity', '…
fim-int-2026-11-01-G003 ({'scheme': 'financial_integrity', 'value': 'D7'}): No primary NBR circular confirming crypto-gains tax treatment in Bangladesh was retrieved this cycle, leaving the tax dimension of crypto enforcement unverified. [open]
FIM-GAP-001 (D3): Primary FATF/APG documentation specific to…
FIM-GAP-001 (D3): Primary FATF/APG documentation specific to Bangladesh is dated: the last full Mutual Evaluation Report is from 2016 and the last FATF-endorsed Follow-Up Report from 2020, despite a page update noted for December 2025. No new substantive FATF/APG assessment document covering the post-2024 interim-government period was located during this baseline.
FIM-GAP-002 (D2): Estimates of public funds lost to corrupti…
FIM-GAP-002 (D2): Estimates of public funds lost to corruption under the prior administration range from $17 billion to $30 billion, yet identified international asset-freeze actions (e.g., the UK's ~$252 million property freeze) capture only a small fraction of the alleged total, and domestic conviction-based confiscation cannot be enforced while principal defendants remain abroad.
FIM-GAP-003 (D5): Bangladesh has no licensed virtual asset s…
FIM-GAP-003 (D5): Bangladesh has no licensed virtual asset service provider regime; the central bank's approach remains a blanket informal prohibition rather than a risk-based licensing and AML/CFT supervisory framework, even as grassroots crypto adoption is independently estimated to rank among the higher tiers globally.
FIM-GAP-004 (D3): Post-2024 anti-corruption and asset-recove…
FIM-GAP-004 (D3): Post-2024 anti-corruption and asset-recovery enforcement in Bangladesh has been concentrated almost exclusively on the ousted Awami League administration and its network, raising questions about the durability and even-handedness of the enforcement regime across future political transitions.

Evidence

Confidence-tiered claims

Gambling-proceeds laundering via banks, MFS accounts, digital wallets, hawala/hundi or cryptocurrency designated a Money Laundering Prevention Act 2012 predicate offence [Source 1]
Probable · 1 source
Money Laundering Prevention Act, 2012 and Anti-Terrorism Act, 2009, administered via Bangladesh Bank's BFIU (Egmont Group member) [Source 1]
Probable · 1 source
Not on FATF grey list or blacklist as of the 30 October 2026 plenary outcome (18 grey-list jurisdictions; blacklist unchanged at Iran/DPRK/Myanmar). [Source 1]
Probable · 1 source
Prohibited, via Foreign Exchange Regulation Act 1947 s.23(1), Anti-Terrorism Act 2009 and Money Laundering Prevention Act 2012; no dedicated crypto statute [Source 1]
Probable · 1 source
No AI/ML transaction-monitoring model-risk guidance for obliged financial entities, despite the Gambling Prevention Act 2026 committing the state to AI/DPI-based detection [Source 1]
Uncertain · 1 source
Money Laundering Prevention Act, 2012 [Source 1]
Probable · 1 source
BFIU Circular No. 32 (24 Sep 2026) addressed to PSP/PSO on AML/CFT/CPF prevention [Source 1]
Probable · 1 source
not on FATF increased-monitoring list [Source 1]
Probable · 1 source
crypto tools, wallets, and VPN software seized alongside gambling evidence in CID/police raids [Source 1]
Probable · 1 source
BFIU Circular No. 33 (30 Sep 2026) addressed to NGO/NPO on AML/CFT/CPF prevention [Source 1]
Probable · 1 source
Bangladesh Bank issued a single consolidated circular (17-18 Oct 2026) under FERA 1947 s.20(3) unifying licensing/renewal rules for authorised dealers, money changers, limited money changers, authorised gold dealers and gold-ore/dore importers, including AML/CFT compliance, reporting, and BB's inspection/cancellation powers; it supersedes prior individual instructions and runs for one year. [Source 1]
Probable · 1 source
Bangladesh's standing AML/CFT regime continues to rest on the Money Laundering Prevention Act 2012 (as amended 2015) and Anti-Terrorism Act 2009, supervised by BFIU within Bangladesh Bank. Last FATF/APG mutual evaluation on record is 2016, with next possible on-site period 2027-11. [Source 1]
Probable · 1 source
Failure by a reporting organization to file an STR/SAR under s.25(2) MLPA attracts a fine of at least Tk 50,000 and not exceeding Tk 25 lakh. [Source 1]
Probable · 1 source
Bangladesh Bank's long-standing posture that crypto transactions are prohibited under FERA 1947/MLPA 2012 continues; BB has separately told CID that mere ownership is not itself punishable absent an FX/AML/terror-financing nexus, creating a documented enforcement grey area. [Source 1]
Probable · 1 source
Bangladesh is not currently on the FATF grey or black list. [Source 1]
Probable · 1 source
Technical-compliance submission due 31 March 2027; possible onsite 2027-11; possible plenary discussion 2028-07 [Source 1]
Probable · 1 source
APG P-MEP delegation visited 11-13 Aug 2026 and flagged that financial irregularities under the previous regime could hurt the upcoming evaluation [Source 1]
Probable · 1 source
Approximately 55,000 MFS accounts frozen/suspended by June 2026 over online-gambling and digital-hundi links, with a further approximately 14,000 frozen in August 2026 [Source 1]
Probable · 1 source
Restrictive posture under FERA 1947 and MLPA 2012 unchanged; new Bangladesh Bank governor has not signalled a review [Source 1]
Probable · 1 source
BFIU directed every insurance company to form a central compliance unit, appoint a CAMLCO, screen customers against UN Security Council and domestic proscription lists, apply EDD to PEPs and high-risk-jurisdiction customers, and report large cash transactions and suspicious activity. [Source 1]
Probable · 1 source
Bangladesh Bank consolidated prior FX directives into a unified circular, superseding Volume I of the 2018 FX guidelines, reiterating the prohibition on exchanging, transferring and transacting in virtual assets/virtual currencies. [Source 1]
Probable · 1 source
BD is not on the FATF grey list or blacklist as of the 30 October 2026 plenary outcome; no BD-specific FATF action this cycle. [Source 1]
Probable · 1 source
all life and non-life insurance companies via a 20 October 2026 circular requiring a central compliance unit, a named CAMLCO, UNSC/domestic sanctions screening, EDD for PEPs and high-risk-jurisdiction customers, and large cash-transaction reporting. [Source 1]
Probable · 1 source
Prohibition on exchanging, transferring or transacting virtual assets/virtual currencies via a unified FX circular superseding Volume I of the 2018 FX guidelines, reported ~29-31 October 2026. [Source 1]
Probable · 1 source