Financial Integrity Monitor

Bangladesh BD

Domains (D1–D6)

Sources

Role actions

Horizon <90d

Jurisdiction profile

CleanTier BRisk: IncreasingMixed

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

Bangladesh 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

Weekly brief

Lead signal

Lead Signal

Read full brief

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.

weekly_brief_draft · JID BD

Domain intelligence (D1–D6)

D1 Sanctions

Not covered

Sanctions is not yet covered for this jurisdiction in this report.

D2 Beneficial Ownership

Not covered

Beneficial Ownership is not yet covered for this jurisdiction in this report.

D3 Enabler Jurisdictions and Professional Facilitators

Enabler Jurisdictions and Professional Facilitators

Bangladesh's Mobile Financial Services sector this cycle registers a formalised enabler-channel finding: fake SIMs and fraudulent MFS accounts are identified, at a probable confidence tier, as the primary channel through which gambling-linked laundering proceeds are moved. This is not the discovery of a new phenomenon so much as its formal capture in statute - Bangladesh's Financial Intelligence Unit (BFIU) has previously suspended tens of thousands of MFS accounts on grounds consistent with this typology, indicating the enabler pathway was already operationally recognised by the domestic supervisor before this cycle's legislative development gave it a specific predicate-offence anchor.

The newly enacted Gambling Prevention Act, 2026 gives this enabler channel a formal legal hook by designating gambling-linked laundering conducted through fake SIMs, fraudulent MFS accounts, or cryptocurrency settlement as a predicate offence under the Money Laundering Prevention Act, 2012. From an enabler-jurisdiction analytical lens, this matters because it converts what had been an operational enforcement pattern - MFS account suspensions driven by suspicious-activity indicators - into an explicit statutory predicate-offence characterisation, which in principle sharpens the legal basis for cross-referral between gambling enforcement, telecom regulation, and financial-crime prosecution. The professional-facilitator dimension here is not conventional gatekeeper professionals (lawyers, accountants, company-formation agents) but rather SIM-registration and MFS-onboarding intermediaries whose KYC failures create the ghost-account inventory that gambling operators and launderers exploit.

This finding should be read with appropriate caution regarding its sourcing: it traces to a single Tier 3/4 secondary source (ZIGRAM) without independent primary-source confirmation this cycle, meaning no BFIU circular or gazette notification implementing the predicate-offence designation was independently located and verified against the underlying statutory text.

Outlook

The watch item for this domain is whether BFIU or Bangladesh Bank publishes implementing guidance that operationalises the predicate-offence designation into concrete MFS-sector supervisory expectations - for instance, updated suspicious-transaction-reporting triggers specific to gambling-linked ghost-account activity. Absent such guidance, the gap noted in the regulatory horizon persists: general industry AML monitoring practice in this market has not yet incorporated gambling-linked predicate-offence typologies into transaction-monitoring rule sets, leaving a period where the statutory characterisation outpaces operational detection capability.

D4 Conflict Finance

Not covered

Conflict Finance is not yet covered for this jurisdiction in this report.

D5 Crypto, Digital Assets, and Financial Innovation

Crypto, Digital Assets, and Financial Innovation

Bangladesh's crypto-regulatory posture registers a confirmed development this cycle, though one that reaffirms rather than alters the country's long-standing prohibitory stance. Bangladesh Bank's Foreign Exchange Policy Department has directly stated, in Tier 1 primary circular text, that exchange, transfer, or trading of virtual assets or virtual currencies is not permitted by Bangladesh, and that such activity is not recognised as approved foreign exchange or a permitted transaction under the Foreign Exchange Regulation Act, 1947. This posture has now been freshly reaffirmed through the 2026 National Blockchain Policy, which explicitly excludes cryptocurrency trading from its scope even while embracing blockchain technology more broadly - a now-familiar pattern in jurisdictions seeking to capture distributed-ledger innovation while maintaining a hard line against crypto-asset trading itself.

The more analytically significant development for this domain is the newly created statutory nexus between crypto activity and Bangladesh's AML predicate-offence architecture. The Gambling Prevention Act, 2026 criminalises cryptocurrency-based wagering and gambling settlement outright, and separately treats laundering conducted via crypto settlement in connection with gambling as a Money Laundering Prevention Act, 2012 predicate offence. This is the first time crypto-denominated activity has been wired directly into Bangladesh's AML predicate-offence framework in this manner, rather than being addressed solely through the foreign-exchange prohibition route that Bangladesh Bank has maintained since at least 2017. The practical effect is a dual-track exposure for any crypto-adjacent payment rail operating in or toward Bangladesh: foreign-exchange-law exposure under the long-standing FERA prohibition, and now AML predicate-offence exposure specifically where the crypto activity is gambling-linked.

This is architecturally significant rather than merely incidental: it demonstrates that even in a jurisdiction with no crypto licensing framework and an outright FX-law prohibition on crypto trading, targeted legislative activity in an adjacent domain (gambling) can create new and specific AML exposure pathways for crypto-settlement activity without any change to the underlying crypto-prohibition stance itself.

Outlook

The key development to watch is whether Bangladesh Bank or BFIU issues any supervisory guidance connecting the new gambling-crypto predicate-offence nexus to broader crypto-related suspicious-activity monitoring, or whether this remains confined to the gambling-enforcement context. The underlying FX-law prohibition on crypto trading itself shows no sign of near-term change; the 2026 National Blockchain Policy's explicit carve-out suggests continuity rather than liberalisation is the base-case trajectory for this domain.

D6 Compliance Technology & Active Defence

Not covered

Compliance Technology & Active Defence is not yet covered for this jurisdiction in this report.

D7 AML/CTF Regime

AML/CTF Regime

Bangladesh's AML/CTF predicate-offence architecture expanded materially this cycle through the enactment of the Gambling Prevention Act, 2026 (Act No. 98 of 2026), which repeals the Public Gambling Act, 1867 and criminalises online gambling, crypto-denominated wagering, and VPN-based circumvention, effective 1 July 2026. This is confirmed by Tier 1 primary statutory text. The architecturally significant component for this domain is the Act's designation of gambling-linked money laundering - conducted via fake SIMs, fraudulent Mobile Financial Services accounts, or cryptocurrency settlement - as a predicate offence under the Money Laundering Prevention Act, 2012, carrying penalties of up to ten years' imprisonment. At a probable confidence tier, this development closes a previously identified structural gap between Bangladesh's gambling-prohibition regime and its digital-payments AML architecture.

The standing institutional architecture underpinning this development is worth restating: BFIU functions under the provisions of the Money Laundering Prevention Act, 2012 and the Anti-Terrorism Act, 2009, per Bangladesh Bank's own confirmed institutional description, and it is this existing MLPA framework into which the new gambling-linked predicate-offence designation has been inserted rather than a wholly new AML statute being created. This is consistent with the architecture-over-incident framing appropriate to this domain: the material development is not a single enforcement action but a structural expansion of what counts as laundering-predicate conduct under an already-established AML statute.

On jurisdiction-wide FATF standing, 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 - a probable-confidence corroboration of the standing tracker position rather than a new development. This matters for the AML/CTF regime read as a whole: Bangladesh's predicate-offence expansion this cycle occurs against a backdrop of continued FATF good standing, suggesting the legislative activity is domestically driven (closing a gambling-specific enforcement gap) rather than externally compelled by FATF grey-listing pressure.

Outlook

The principal gap flagged this cycle is evidentiary rather than architectural: the gambling-linked predicate-offence characterisation rests on a single Tier 3/4 secondary source (ZIGRAM), and no independent second primary confirmation - such as a BFIU circular or gazette notification specifically implementing the designation - was located this cycle. A Ministry of Home Affairs-led implementation task force, working alongside Bangladesh Bank, the Bangladesh Telecommunication Regulatory Commission, BFIU, the Criminal Investigation Department, and the National Cyber Security Agency, is expected to operationalise enforcement in the 2026 Q4 window, with international-cooperation provisions noted as part of that build-out. General industry AML monitoring practice in this market has not yet incorporated gambling-linked predicate-offence typologies into transaction-monitoring rule sets, an implementation gap that risk direction is assessed as improving against as the task force stands up.

Regulatory horizon

In Force2026-Q4 · ±half_year

Gambling Prevention Act 2026 implementation task force

Gambling-linked financial flows now carry an explicit statutory AML predicate-offence characterisation, and an inter-agency task force with international-cooperation provisions is being stood up.

Source

1 dated · 3 pending date · baseline fim-2026-07-09

Role action cards

MLROAssessed

Gambling-linked laundering via fake SIMs, fraudulent MFS accounts, or crypto settlement is now an explicit MLPA 2012 predicate offence in Bangladesh.

MLROs with Bangladesh exposure, particularly through mobile-financial-services or crypto-adjacent payment rails, should be aware that a new statutory predicate-offence characterisation now exists for gambling-linked laundering typologies, closing a previously identified gap between gambling law and AML law. The finding rests on a single secondary source without independent primary confirmation this cycle.

3 evidence refs

ComplianceAssessed

MFS ghost-account/ghost-SIM abuse formalised as an AML enabler channel via new predicate-offence designation.

Compliance functions overseeing Bangladesh-linked MFS relationships should note that fake SIMs and fraudulent MFS accounts are now formally recognised, at a probable confidence tier, as the primary enabler channel for gambling-linked laundering, following on from BFIU's prior pattern of suspending tens of thousands of MFS accounts on related grounds.

2 evidence refs

LegalAssessed

Bangladesh Bank's crypto-trading prohibition under FERA 1947 is reaffirmed via the 2026 National Blockchain Policy carve-out, with a new gambling-linked crypto AML nexus.

Legal counsel assessing Bangladesh crypto exposure should note the confirmed, unchanged foreign-exchange-law prohibition on virtual-currency trading, now compounded by a new AML predicate-offence exposure specifically where crypto settlement is gambling-linked under the Gambling Prevention Act 2026.

2 evidence refs

BoardAssessed

Bangladesh enacted a comprehensive gambling-prohibition statute this cycle with a direct AML predicate-offence wiring, while remaining off the FATF grey list.

The Board should note that Bangladesh's regulatory environment tightened materially this cycle through new gambling-linked AML predicate-offence architecture, occurring against a backdrop of continued FATF good standing, indicating domestically-driven rather than externally-compelled reform.

3 evidence refs

CTOAssessed

Crypto-denominated gambling settlement is now criminalised and linked to an AML predicate offence in Bangladesh.

Technology functions assessing crypto-adjacent infrastructure exposure to Bangladesh should note the new statutory nexus wiring crypto-settlement activity into AML predicate-offence architecture specifically where gambling-linked, layered atop the pre-existing FERA-based crypto-trading prohibition.

2 evidence refs

RiskAssessed

A new enabler-channel typology (MFS ghost-accounts/fake SIMs) is formalised in Bangladesh's AML predicate-offence framework.

Risk functions should treat the MFS ghost-account enabler channel as an emerging typology with a structural rather than episodic character, though currently supported by only a single secondary source without independent primary confirmation.

2 evidence refs

OperationsPossible

Transaction-monitoring rule sets in this market have not yet incorporated gambling-linked predicate-offence typologies.

Operations teams running MFS or gambling-adjacent transaction monitoring for Bangladesh exposure should note the explicit gap identified between the new statutory predicate-offence characterisation and current monitoring rule-set coverage.

1 evidence refs

AuditPossible

No material change this cycle.

No material change for this persona this cycle

Decision lens

MLRO

Gambling-linked laundering via fake SIMs, fraudulent MFS accounts, or crypto settlement is now an explicit MLPA 2012 predicate offence in Bangladesh.

Compliance

MFS ghost-account/ghost-SIM abuse formalised as an AML enabler channel via new predicate-offence designation.

Legal

Bangladesh Bank's crypto-trading prohibition under FERA 1947 is reaffirmed via the 2026 National Blockchain Policy carve-out, with a new gambling-linked crypto AML nexus.

Board

Bangladesh enacted a comprehensive gambling-prohibition statute this cycle with a direct AML predicate-offence wiring, while remaining off the FATF grey list.

CTO

Crypto-denominated gambling settlement is now criminalised and linked to an AML predicate offence in Bangladesh.

Risk

A new enabler-channel typology (MFS ghost-accounts/fake SIMs) is formalised in Bangladesh's AML predicate-offence framework.

Operations

Transaction-monitoring rule sets in this market have not yet incorporated gambling-linked predicate-offence typologies.

Audit

No material change this cycle.

Shared evidence: 4 refs

Scenario sketches

AMLA transition and the reshaping of cross-border obliged-entity supervision

As the EU AML Package matures, the move from purely national AML supervision toward AMLA direct and indirect supervision of cross-border obliged entities, under the AMLA Regulation (Reg (EU) 2024/1620) alongside the directly-applicable AMLR (Reg (EU) 2024/1624) and per-state 6AMLD transposition, could illustratively reshape how supervisory attention is allocated across EU-linked correspondent and payment relationships. For a non-EEA jurisdiction such as Bangladesh, whose own AML architecture is expanding domestically through gambling-linked predicate-offence designation rather than through EU-driven supervisory convergence, this illustrates a structural divergence: EU-linked obliged entities may face a hybrid EU-level supervisory layer, while Bangladesh's own MLPA-based predicate-offence framework continues to expand along a domestically-driven track. This is illustrative orientation only, not a prediction of how either architecture will actually evolve.

Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact.

Standing trackers (T1–T6)

Tracker	Status	Note
T1 · Russian Sanctions-Evasion Architecture	no_change	No material change bearing on BD this cycle.
T2 · EU AML Package / AMLA	no_change	Not applicable to BD, a non-EEA autonomous jurisdiction.
T3 · FATF Grey List	no_change	Bangladesh is not on the FATF grey list; June 2026 plenary added Bosnia and Herzegovina and Iraq, removed Algeria and Namibia, leaving 22 listed jurisdictions -- BD not among them.
T4 · Beneficial-Ownership Register Status	no_change	No BD-specific beneficial-ownership development identified this cycle.
T5 · Crypto & Digital-Asset Integrity	material_change	Gambling Prevention Act 2026 newly criminalises crypto-denominated gambling settlement and treats associated laundering as an MLPA predicate offence, a new statutory nexus between crypto and AML enforcement in BD.
T6 · Sanctions Regime Divergence	no_change	No BD-specific autonomous-listing divergence identified this cycle.

Registers

Enforcement actions

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

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)

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

[CRITICAL] 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

Sources

Coverage gaps

Primary FATF/APG documentation specific to Bangladesh is dat…

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.

Estimates of public funds lost to corruption under the prior…

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.

Bangladesh has no licensed virtual asset service provider re…

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.

Post-2024 anti-corruption and asset-recovery enforcement in …

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

No structured claims published for this jurisdiction yet.