Module 2: Predicate offences and terrorist and proliferation financing - Certificate in Anti-Money Laundering Fundamentals

What you will learn

Explain what a predicate offence is
Name typical predicate offences listed in Bangladesh law
Distinguish money laundering from terrorist financing and proliferation financing

Predicate offences

A predicate offence is the underlying crime that produces the illegal proceeds. Section 2(cc) of the MLPA lists 28 predicate offences in Bangladesh. They include:

corruption and bribery;
fraud and forgery;
drug offences and smuggling;
customs, excise and tax offences;
human trafficking, including taking money on false promises of jobs overseas (wording added in 2015);
dowry offences and environmental offences;
insider trading and market manipulation;
terrorism and its financing, and organised crime.

Proceeds from any of these, once disguised, are money laundering.

Terrorist financing (TF)

Terrorist financing is providing or collecting funds to support terrorism. It differs from money laundering in an important way:

The money is often from legal sources: salaries, donations, small businesses.
The amounts are often small.
The goal is to use the money for an act or group, not to hide where it came from.

So the red flags for TF are usually about destination, purpose and links to listed persons, rather than the size of a transaction. The Anti-Terrorism Act, 2009 is the main law (see Module 3).

Proliferation financing (PF)

Proliferation financing is funding the development or spread of weapons of mass destruction. The main control is targeted financial sanctions issued by the United Nations Security Council: freezing and refusing services to listed persons and entities. Bangladesh Financial Intelligence Unit (BFIU) instructions now speak of "ML, TF and PF" together.

Why NGOs and charities matter

Non-profit organisations can be misused to collect or move money for terrorism or other crime, for example by raising funds in their name or by passing money through unregistered partners. This is one reason Bangladesh treats NGOs, including MFIs licensed by the Microcredit Regulatory Authority, as reporting organisations.

Bangladesh lens

BFIU issues sector-specific instructions on ML, TF and PF to every type of reporting organisation. For example, BFIU Circular No. 33 (30 September 2026) covers NGOs and non-profits, including MFIs. It requires, among other things, that no service be given to persons on United Nations Security Council or Government of Bangladesh lists, and that a transaction be suspended and BFIU told by the next working day if a match is found. (Details in Modules 4 and 7.)

Illustrative case, MFI (fictional): a field officer notices that a savings group's small weekly deposits are being collected by an outsider who is not a member and whose phone number appears on several groups' records. The amounts are small and the cash is lawful, but the link to an unknown person is the warning sign.

Illustrative case (fictional): a small donation collected in a village is sent through a mobile wallet to a person the NGO cannot identify. The amount is small and the source is lawful, but the destination is unknown. For TF, that is the red flag.

Key takeaways

A predicate offence is the crime that creates the illegal money; the MLPA lists 28.
TF money is often small and legal in origin.
PF is controlled mainly through UN targeted financial sanctions.
NGOs, including licensed MFIs, are reporting organisations in Bangladesh.

Practice quiz

Five questions, instant feedback. Not graded for the certificate.

Based on the Money Laundering Prevention Act 2012 (as amended 2015), the Anti-Terrorism Act 2009 and BFIU circulars, as understood on 16 October 2026. Laws and circulars change: always check the latest text on bfiu.org.bd. This course is general education, not legal advice. Cases marked "illustrative" are fictional.