Module 3: The legal framework in Bangladesh - Certificate in Anti-Money Laundering Fundamentals

What you will learn

Name the main AML/CFT laws and the authority responsible
Identify who is a reporting organisation
State the key powers and penalties in the MLPA

The main laws

Money Laundering Prevention Act, 2012 (Act No. 5 of 2012), amended by the Money Laundering Prevention (Amendment) Act, 2015 (Act No. 25 of 2015).
Anti-Terrorism Act, 2009, amended in 2012 and 2013, which covers terrorist financing.
Money Laundering Prevention Rules, 2019 and the Anti-Terrorism Rules, 2013.
Sector circulars issued by BFIU (see below).

BFIU

The Bangladesh Financial Intelligence Unit (BFIU) is the national central agency. It sits inside Bangladesh Bank and was set up under MLPA section 24. The 2015 amendment moved the section 23 powers from "Bangladesh Bank" to BFIU. BFIU:

receives suspicious transaction/activity reports (STR/SAR) and cash transaction reports (CTR) through the goAML system;
may ask any reporting organisation for information;
may suspend or freeze an account for 30 days, extendable by 30 days at a time for up to 6 more months;
may fine reporting organisations that fail their duties;
issues circulars and guidelines for each sector.

Reporting organisations (ROs)

Section 2(w) of the MLPA lists the ROs. They include banks and financial institutions, insurers, money changers and remitters, stock dealers, brokers and merchant bankers, NGOs, non-profit organisations and cooperative societies, real estate developers, dealers in precious metals and stones, trust and company service providers, and lawyers, notaries and accountants. An "NGO" includes institutions licensed under the Microcredit Regulatory Authority Act, 2006, so every licensed MFI is a reporting organisation.

Duties and penalties (selected)

Provision	Rule
s.4(2) money laundering by a person	4 to 12 years' imprisonment plus a fine of at least twice the property's value or Tk 10 lakh, whichever is greater
s.4(4) money laundering by an entity	Fine of at least twice the value or Tk 20 lakh, whichever is greater; registration may be cancelled
s.6 tipping off	Up to 2 years, or a fine up to Tk 50,000, or both
s.23(4) false information by an RO	Fine of Tk 20,000 to Tk 5 lakh
s.25(2) breach of s.25 duties by an RO	Fine of Tk 50,000 to Tk 25 lakh; licence or branch may also be cancelled

Section 25(1) is the heart of the RO's duty: keep correct customer identity information, keep transaction records for at least 5 years after an account is closed, give them to BFIU on demand, and report suspicious transactions immediately and on its own initiative.

Investigation and trial

Since the 2015 amendment, the agency that investigates the predicate offence also investigates the money laundering (earlier only the Anti-Corruption Commission did). Cases that the police can investigate go to the CID. Trials are before a Special Judge. Money laundering offences are cognizable, non-compoundable and non-bailable.

Sector circulars

BFIU issues instructions for each type of reporting organisation. Find the one for your sector:

Sector	BFIU instruction
Scheduled banks	Circular No. 26 (16 June 2020)
Financial institutions (NBFIs)	Circular No. 28 (30 May 2023)
NGOs/NPOs, including MRA-licensed MFIs	Circular No. 33 (30 September 2026), which replaces Circular No. 14 of 2015
Insurance	Circular No. 27 (2022)
Capital market intermediaries	Circular No. 31 (15 September 2026)
Mobile financial services (MFS)	Circular No. 20 (2017)
Payment service providers and operators	Circular No. 32 (24 September 2026)
Money changers	Circular No. 30 (18 August 2026)
Cooperatives	Circular No. 17 (2015)
Real estate, jewellers, trust and company service providers, lawyers	Circular No. 13 (2015); DNFBP guidelines, Circular No. 08 (2013)

BFIU also issues topic guidance, such as the trade-based money laundering guidelines (Circular No. 24, 2019) and e-KYC guidelines (Circular No. 25, 2020). This course explains the shared principles; read your own sector's circular for the detailed rules.

Bangladesh lens

The section 25 duties are the same for a bank officer, an insurance agent, a broker's dealer, a mobile-wallet agent and an MFI field officer: know the client, keep the records, report suspicion. Each sector then has its own BFIU circular for the detail. For NGO-MFIs the current rulebook is Circular No. 33, not the older Circular No. 14.

Key takeaways

MLPA 2012 (amended 2015) and ATA 2009 are the two core laws.
BFIU is the central agency, inside Bangladesh Bank, and holds the section 23 powers.
NGOs, including licensed MFIs, are reporting organisations.
Section 25 requires identity records, 5-year transaction records and prompt STRs.

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.