AD Forum · 41st meeting · 3 August 2026

Foreign Exchange Policy Department-2 Bangladesh Bank, Head Office, Dhaka Record notes of the 41st meeting of the Bangladesh Bank–Authorized Dealers’ Forum The 41st meeting was held on 3 August 2026 at 11:30 a.m. in the Jahangir Alam Conference Hall, fifth floor of Bangladesh Bank’s main building. The meeting was chaired by the Forum’s convener, Mr Md. Enamul Karim Khan, Executive Director, Bangladesh Bank. The members and representatives present are listed in Appendix A. The chair welcomed those present and opened the proceedings with introductions. The record notes of the 40th meeting were presented, and the meeting was informed of progress in complying with and implementing its decisions. Circulars and circular letters on foreign-exchange transactions issued between the 40th and 41st meetings, and other matters raised, were explained or clarified. After discussion in accordance with the agenda, the following decisions were recorded. 01. Unreconciled Nostro accounts Presenter: Foreign Exchange Policy Department-2, Bangladesh Bank, Head Office. Implementation: All banks. FEPD-2 stated that, because AD banks do not properly respond in the Local Book to entries in the Foreign Book, or vice versa, significant differences remain between the two books of Nostro accounts. Consequently, banks’ assets are understated or overstated in Net Open Position calculations, and the Net Open Position report does not show the true FX holdings of the foreign-exchange market. FEPD-2 also stated that some AD banks respond to debit entries in the Foreign Book of a Nostro account by issuing Interbranch Debit Advice and crediting the corresponding entries in the Local Book before creating a liability in the customer’s name or collecting the money from the customer. The meeting discussed that creating a forced loan on time could, in some cases, classify a customer’s loan and make the customer ineligible for further lending or investment; classified loans also require provisioning. FEPD-2 stated that some banks leave the IBDAs unresponded to give customers irregular facilities and avoid making provisions. In this context, the chair instructed the concerned AD banks that, before creating the liability in the customer’s name or collecting the money from the customer, they must not issue Interbranch Debit Advice and credit the entries in the Local Book to respond to debit entries in the Foreign Book of a Nostro account. [Sentence continues on original page 2.]

Continuation of item 01: The entries must not be responded to or reconciled in that manner. 02. Collection of revenue on internet-based transactions: Writ Petition 5227/2018 Presenter: Foreign Exchange Operations Department-2, Bangladesh Bank, Head Office. Implementation: All banks. FEOD-2 informed the meeting of the High Court judgment dated 8 November 2020 in Writ Petition 5227/2018. The judgment directs collection of VAT, turnover tax and supplementary duty from transactions including advertising on Google, Facebook, YouTube and other internet-based social media, sale of domains and licence fees, together with VAT imposed under section 15 of the Value Added Tax and Supplementary Duty Act, 2012, income tax and all other applicable revenue. It also directs the National Board of Revenue to instruct the concerned respondents to collect that revenue and outstanding revenue and to submit statements of collection to the Court by affidavit every six months. FEOD-2 stated that the concerned AD banks need instructions to comply properly with the judgment and ensure proper collection of duties and taxes on amounts paid through international cards. The meeting also discussed requiring the banks to submit a revenue-collection statement to FEOD-2 every six months, by 15 January and 15 July. The statement would contain the institution’s name, transaction type, transaction purpose and amount, type and amount of revenue deducted, collection of arrears, challan number and related particulars. The chair instructed all concerned AD banks to comply properly with orders 1, 2 and 3 of the judgment and to submit the revenue-collection statements to FEOD-2 within the prescribed six-monthly deadlines. The chair again instructed the banks to ensure proper collection of duties and taxes on international-card payments in accordance with FE Circular Letter No. 30/2019. 03. Creating a loan in the customer’s name before payment of the LC value Presenter: Bank Supervision Department-7, Bangladesh Bank, Head Office. Implementation: All banks. Bank Supervision Department-7 stated that some banks do not properly comply, at the time of paying the LC value, with the instructions in paragraph 82(3) of FE Circular No. 33 dated 14 August 2025. [Continues on original page 3.]

Continuation of item 03: The chair instructed all concerned AD banks to comply properly with FE Circular No. 33 dated 14 August 2025. 04. Online reporting of export claims Presenter: Standard Chartered Bank. Implementation: Foreign Exchange Policy Department-1, Bangladesh Bank, Head Office. Standard Chartered Bank stated that FEOD Circular No. 01 dated 3 March 2024 established online reporting for “other types of export claims”. The meeting noted that paragraph 77 of FE Circular No. 37 dated 30 September 2025 still contains provisions for that type of reporting. FEPD-1 informed the meeting that this matter would be reviewed when preparing the remittance-related compilation in September 2026. 05. Time limits concerning incomplete cash-incentive applications Presenter: Standard Chartered Bank. Implementation: All banks. Standard Chartered Bank stated that, during initial scrutiny of cash-assistance applications, the AD bank branch informs the exporter of discrepancies in the application within three days. Existing circulars do not, however, set a specific period within which the exporter must submit the necessary corrections. To ensure transparency, accountability and prompt customer service, the bank proposed clear time limits for every step of processing an application, covering the applicant, the bank, the audit firm and all other concerned parties. FEPD-1 informed the meeting that an exporter is expected to submit corrections requested by the bank promptly, according to the exporter’s own requirements. It did not find justification for prescribing a fixed period for the exporter to submit those corrections. FEPD-1 stated that the existing circular instructions would remain in force at this stage. 06. Treatment of export advances after the one-year period expires Presenter: Standard Chartered Bank. Implementation: All banks. Standard Chartered Bank asked what ADs should do if exports are not completed or advances are not refunded after the one-year period. Existing instructions require shipment against an advance within one year and repayment of the advance if the export does not take place. The bank asked whether prior Bangladesh Bank approval is required after that period and whether overdue advances require a specific report or special treatment. FEPD-1 participated in the discussion. [Its response continues on original page 4.]

Continuation of item 06 FEPD-1 stated that reporting through an ARV (Advance Receipt Voucher) is appropriate after ensuring that the advance export proceeds have actually been repatriated. For exports on FCA terms, where export proceeds are received at the stage of delivery of the goods at the named place, it would be appropriate to credit those proceeds to the relevant pool account instead of reporting through ARV. If export within one year is not possible for justified reasons, Bangladesh Bank must be informed and its no-objection obtained. 07. Sending cross-border Vostro remittances through interbank RTGS to beneficiaries with accounts at other banks Presenter: Standard Chartered Bank. Implementation: Payment Systems Department-2, Bangladesh Bank, Head Office. Standard Chartered Bank proposed that, to deliver remittances received as intermediary bank to beneficiaries more efficiently and promptly, taka remittances under Vostro arrangements could, like foreign-currency remittances, be sent without delay through RTGS to the beneficiaries’ banks. A separate Transaction Type in the ISO 20022 MX message tag was proposed for incoming Vostro remittances processed through local RTGS, so that these transactions could be identified as cross-border transactions. For transactions under that Transaction Type, the beneficiary bank would assume responsibility for all regulatory reporting and applicable requirements, including incentives and VAT collection. The meeting also received a proposal to exempt this Transaction Type from the BDT 100,000 (one lakh) threshold. It was further proposed that each scheduled bank designate and operate a Central Contact Point and a nominated Focal Point Officer, reachable at a specified email address and telephone number. The meeting noted that this would organise communications, improve operational efficiency and service quality, and help meet applicable regulations and supervisory expectations. PSD-2 informed the meeting that, for Vostro remittances, money of any amount can be transferred on a 24/7 basis through IBFT on the NPSB platform. [Continues on original page 5.]

Continuation of item 07 PSD-2 explained that PSD Circular No. 09 dated 30 June 2021 prescribed the following NPSB IBFT limits: an individual’s single transaction, BDT 300,000 (three lakh); an individual’s daily transactions, BDT 1,000,000 (ten lakh); an institutional single transaction, BDT 500,000 (five lakh); and institutional daily transactions, BDT 2,500,000 (twenty-five lakh). PSD Circular Letter No. 04 dated 3 July 2022 instructed that those limits would not apply to banks’ payment of remittances and the associated incentives. It also instructed use of two separate Merchant Category Codes, MCC 6014 and MCC 6015, to identify remittance-related transactions separately. PSD-2 stated that using these MCCs could address the matter raised. The chair instructed PSD-2 to examine the proposal in detail and take the necessary steps. 08. Setting an overall export limit for the facility under FEPD-1 Circular No. 06/2026 Presenter: Bank Asia PLC. Implementation: All banks. Bank Asia stated that FEPD-1 Circular No. 06 dated 16 March 2026 sets a maximum of USD 100,000 (one hundred thousand) for each export invoice, but does not prescribe an overall limit by exporter. To reduce export-related risk, protect exporters’ interests and ensure proper supervision of foreign-trade activities, it proposed considering an acceptable maximum export limit per exporter within a specified period. FEPD-1 informed the meeting that it did not find justification for an exporter-based export limit. It stated that, if title documents are issued subject to due diligence in export transactions, the type of risk described need not arise in conducting those activities.

09. Proposal for a multimodal freight-forwarding remittance policy Presenter: Bank Asia PLC. Implementation: All banks. Bank Asia stated that payments by Bangladeshi freight forwarders to overseas hub agents for the second leg of multimodal shipments face difficulties because there is no clear policy. These are legitimate service payments rather than capital transfers, but there is no separate Bangladesh Bank circular. As a result, AD banks follow differing processes, with delays and extra documentation that increase business costs and time. Bank Asia proposed a specific guideline allowing approval on the basis of minimum documentation and monthly reporting. The meeting was informed that a draft multimodal-shipment policy had previously been uploaded to Bangladesh Bank’s website, but was not issued because stakeholders did not respond. FEPD-2 stated that Bangladesh Bank considers banks’ applications on a case-by-case basis. 10. Simplifying back-to-back LC transmission and advising Presenter: Bank Asia PLC. Implementation: Foreign Exchange Operations Department-1, Bangladesh Bank, Head Office. Bank Asia stated that banks transmit back-to-back LCs through SWIFT and automatically authenticate the issuing bank. FEOD Circular Letter No. 01 dated 13 February 2022 nevertheless requires the relevant information to be verified in BBOIMS before advising an LC. The issuing banks have no API integration with OIMS. Therefore, even when banks report within the prescribed time and the information is updated in OIMS, it is not reflected in real time. This delays verification and LC advising. Bank Asia proposed a policy decision to simplify back-to-back LC advising without making OIMS information a mandatory precondition for advising. FEOD-1 informed the meeting that development of a Local LC Interface was in progress and that completion of that work would resolve the identified back-to-back LC problems.

11. A separate LC/Contract code for imports on Open Account terms Presenter: Southeast Bank PLC. Implementation: Foreign Exchange Operations Department-1, Bangladesh Bank, Head Office. Southeast Bank explained that, under Open Account trade, goods are generally sent to the importer first and payment is made later at the contractual due date, such as under 30-, 60- or 90-day credit terms. After shipment, the invoice, bill of lading and other required documents are sent directly to the importer, and payment is made to the exporter through banking channels at the agreed time. It stated that LC/Contract Harmonized Codes 15 and 16 are currently designated respectively for Foreign Contract (DP)/Advance Payment (TT) and Foreign Contract (DA). A separate LC/Contract code for Open Account imports would help identify these transactions correctly and ensure transparent calculation and reporting. Southeast Bank proposed introducing that separate code under the LC/Contract Harmonized Code system. The chair instructed FEOD-1 to examine the proposal in detail and analyse it. 12. Amendment of a new LC/TT in OIMS after exceeding the annual import limit against an IRC Presenter: Southeast Bank PLC. Implementation: Foreign Exchange Operations Department-1, Bangladesh Bank, Head Office. Southeast Bank stated that OIMS currently permits reporting of the Importer’s Limit (Import Slab) prescribed by the Chief Controller of Imports and Exports against the relevant IRC up to FY 2023–2024. Because the system does not permit reporting of the prescribed Importer’s Limit for FY 2025–2026 and subsequent financial years, renewed import limits cannot be monitored effectively. The bank proposed enabling reporting of the prescribed Importer’s Limit in OIMS for FY 2025–2026 and each subsequent financial year. It also raised the situation where an importer—other than under ad hoc, industrial or unlimited IRC categories—has exceeded the annual import limit prescribed against the IRC. [Proposal continues on original page 8.]

Continuation of item 12 It was proposed that, when a new LC/TT is reported after the relevant annual IRC limit has been exceeded, OIMS automatically notify the concerned AD branch immediately and prevent reporting a new amendment against that LC/TT after the import limit is exceeded. The chair instructed FEOD-1 to examine and analyse the proposal in detail. 13. A beneficiary-bank MIS report in OIMS showing issuing-bank payments against local back-to-back LCs Presenter: Southeast Bank PLC. Implementation: Foreign Exchange Operations Department-1, Bangladesh Bank, Head Office. Southeast Bank stated that OIMS provides consolidated payment information—the Local LC Payment Report—through the issuing bank’s User ID. It does not provide a consolidated display of receipts against local back-to-back LCs through the beneficiary bank’s User ID. Individual LC information can be found by manually searching each LC ID, but there is no consolidated MIS report. Consequently, where another bank issues the local back-to-back LC and the reporting bank is the beneficiary bank, the beneficiary bank cannot obtain a consolidated report of payments made by the issuing bank under its own User ID. Southeast Bank proposed adding an OIMS MIS report under the beneficiary bank’s User ID showing completed payments made by issuing banks against local back-to-back LCs. The chair instructed FEOD-1 to examine and analyse the proposal in detail. 14. Cash-incentive eligibility where export proceeds are repatriated through an NBFI Presenter: BRAC Bank PLC. Implementation: All banks. Referring to FE Circular Letter No. 31/2021 on cash assistance, BRAC Bank asked whether cash assistance is available where export proceeds are sent by TT through an NBFI using a Nostro bank and the TT copy contains an export reference. FEPD-1’s Export Section responded. [Continues on original page 9.]

Continuation of item 14 FEPD-1 stated that there is no provision for granting cash assistance against export proceeds repatriated outside banking channels. The meeting was informed that the instructions of the relevant circular must therefore be followed properly. 15. Thresholds for high import content and high domestic value addition in merchandise exporters’ ERQ limits Presenter: BRAC Bank PLC. Implementation: All banks. BRAC Bank proposed a clear percentage-based threshold for determining “High” and “Low” Import Content when crediting foreign currency against export proceeds to ERQ accounts. It also proposed a standardised accounting framework or method for measuring “High Domestic Value Addition”. FEPD-1 informed the meeting that local value addition may be below the prescribed ERQ limit when foreign currency is credited. However, to grant facilities according to that limit, it is necessary to ensure the prescribed limit and local value addition above that level. 16. Further guidance on FE Circular No. 47 dated 19 November 2025 Presenter: BRAC Bank PLC. Implementation: All banks. BRAC Bank stated that card-issuing banks do not control which payment gateway an airline uses for e-commerce purchases or sales of international tickets. Banks therefore cannot determine whether transactions at airline outlets are completed through a Bangladeshi gateway or channel as required by the circular. It also stated that there is no issue of adjusting the USD 300 limit for other-quota transactions against transactions conducted in Bangladeshi taka at those outlets. Existing bank systems also do not permit ticket purchases made in Bangladeshi taka to be replenished or refilled against the travel quota. BRAC Bank requested further guidance on what banks should do to comply with and implement the circular. FEPD-1 informed the meeting that separate authorisation, outside the travel quota, has been granted for buying international tickets for journeys from Bangladesh to overseas destinations. However, where proceeds of tickets sold by airlines operating in Bangladesh are deposited through a local bank’s acquiring service, the meeting was informed that the travel-quota facility may be replenished against those funds. 17. Increasing the sample-export limit and receiving payment against sample exports Presenter: BRAC Bank PLC. Implementation: All banks. BRAC Bank referred to the existing Export Policy’s annual limit for sample exports, excluding commercial value. [Continues on original page 10.]

Continuation of item 17 The stated existing annual limit is USD 10,000. BRAC Bank proposed increasing it to USD 100,000 and considering inclusion of provisions for receiving payment from overseas buyers against sample exports, subject to price verification. The meeting was informed that setting the limit for sending free samples is within the Government’s jurisdiction. FEPD-1 stated that, if payment for samples sent for justified reasons is repatriated to Bangladesh, the concerned bank must encash it and report it in the appropriate code, 274. The proposed increase to USD 100,000 is recorded here as a proposal, not an adopted limit. 18. Electronic EXP register Presenter: Citibank N.A. Implementation: All banks. Citibank stated that paragraph 7 of Chapter 8 of GFET 2018 permits electronic maintenance of an EXP Register with the necessary data backup. It quoted the provision that an AD bank may maintain an electronic EXP register with data backup in accordance with its own IT-security policy. It noted that paragraph 11 of FE Circular No. 31 contains no clear instruction or indication on maintaining the EXP Register electronically and proposed considering this matter. FEPD-1 informed the meeting that the issue had been included in the 2026 export compilation, FEPD-1 Circular No. 26/2026. 19. Searching for Bills of Entry in BBOIMS Presenter: Citibank N.A. Implementation: Foreign Exchange Operations Department-1, Bangladesh Bank, Head Office. Citibank stated that the current system requires separate entry of each customer’s IRC number and importer name to check for outstanding Bills of Entry, which is time-consuming. It proposed examining the possibility of a “Preferred List Search” tab in BBOIMS to save importer names and IRC numbers. Banks could then select the relevant customers at the beginning of the day and readily obtain consolidated, updated information on their outstanding Bills of Entry. The bank requested the necessary guidance for adding the proposed Preferred List Search tab. [Continues on original page 11.]

Continuation of item 19 Citibank presented the proposal to the meeting. The chair instructed FEOD-1 to examine and analyse it in detail. 20. Remittances against discrepant documents or documents received directly by importers Presenter: Citibank N.A. Implementation: Foreign Exchange Policy Department-1, Bangladesh Bank, Head Office. With reference to paragraph 25 of FE Circular No. 33/2025, Citibank requested specific guidance on whether banks may remit or pay against discrepant documents or other documents received directly by the importer, on the basis of the importer’s customs bill of entry and the relevant certified copies after customs clearance. FEPD-1 stated that this issue would be clarified in the 2026 import compilation. Miscellaneous M01. Banks’ verification of documents for imports under LCs or contracts Presenter: Foreign Exchange Policy Department-1. Implementation: All banks. FEPD-1 stated that FE Circular Letter No. 29/2022, updated in FE Circular No. 33 dated 14 August 2025, page 02, paragraph 06, requires the concerned bank to report in OIMS 24 hours before opening an LC of USD 30 million or above. Although banks report those LCs, in many cases they do so without properly obtaining and verifying the required supporting documents before opening the LC. Examples discussed were: not obtaining board or competent-authority approval where required for loans from overseas lenders; not obtaining approval from the relevant Bangladesh Bank department even when an LC exceeds the bank’s capacity; not obtaining the sponsoring authority’s updated registration for imports of industrial raw materials; not verifying sponsor permission and price for industrial capital-machinery imports; and not properly checking credit reports. The meeting also noted that some goods have an additional premium included in the FOB price, but banks sometimes open LCs without properly understanding it. Various organisations also import coal commercially for power plants. [Continues on original page 12.]

Continuation of miscellaneous item M01 Commercial coal imports are made under contracts between the concerned parties. These contracts contain important particulars including coal quality, price and premium. Nevertheless, the meeting noted that, in many cases, LCs are opened without properly checking and calculating the index used to determine the coal price. The chair instructed AD banks to obtain the relevant supporting documents and properly verify them before reporting any LC or contract in OIMS. M02. Compliance with Bangladesh Bank instructions for imports under LCs or contracts Presenter: Foreign Exchange Policy Department-2. Implementation: All banks. FEPD-2 stated that BRPD Circular No. 05/2026 requires running loans to be renewed within the existing term, but a loan must not be renewed without adjusting the portion exceeding its limit. Nor may the excess portion of a running loan be separated from the main loan account to create a new loan or transferred to another loan account. It was noted that, although there is no provision for separating interest or profit from loan outstanding when calculating a customer’s credit limit, some banks open new LCs without adjusting the customer’s excess borrowing. The meeting described this as a clear breach of the stated circular. It was also noted that, under BRPD Circular No. 07 dated 3 April 2024, where one defaulting company in a group has not been identified or listed as a wilful defaulter, credit facilities may be given to the group’s other or all companies subject to obtaining Bangladesh Bank’s prior approval. FEPD-2 proposed providing the necessary advice and guidance to banks to ensure compliance with Bangladesh Bank’s instructions on LC/contract-based imports. The chair instructed AD banks to comply properly with the relevant instructions.

M03. Remittance of Protection and Indemnity/Defence insurance premiums by domestic container-carrying vessels Presenter: Foreign Exchange Operations Department-2. Implementation: All banks. FEOD-2 stated that, with applications for prior approval to remit foreign currency for domestic container-carrying vessels’ Mutual Protection & Indemnity and Freight, Defence and Demurrage cover, AD banks need to submit the premium calculation, information on instalment determination, and a copy of the contract between the customer and the insurance institution. The chair instructed AD banks to ensure that the above information and necessary documents accompany applications for prior approval of foreign-currency remittances. M04. Use of IMP forms and C-forms under suppliers’ or buyers’ credit Presenter: AD banks; the discussion records a request by Dhaka Bank PLC. Implementation: Foreign Exchange Policy Department-1, Bangladesh Bank, Head Office. Dhaka Bank stated that GFET Volume 2 refers to use of IMP forms and C-forms under suppliers’ or buyers’ credit. In such imports, however, payment is made at maturity, whereas the forms in the guidelines do not correspond to the acceptance date. It requested clarification. FEPD-1 informed the meeting that it would discuss the matter with the relevant department and take the necessary action. M05. Foreign-buyer credit reports for export orders received through buying houses Presenter: Commercial Bank of Ceylon. Implementation: All banks. Commercial Bank of Ceylon asked whether a foreign buyer’s credit report must be obtained against export orders received through buying houses. FEPD-1’s Export Section stated that the instructions in paragraph 13 of FE Circular No. 26/2026 must be followed for all exports.

M06. Advising and financing of Islamic back-to-back LCs Presenter: Social Islami Bank PLC. Implementation: All banks. Social Islami Bank informed the meeting that it was going to merge with Sammilito Islami Bank. It stated that necessary banking services were being provided to its exporter customers, but a number of banks were not accepting Social Islami Bank’s LCs and were not financing accepted bills. It stated that, following Bangladesh Bank’s appointment of an administrator, efforts were continuing to make payments on time. It requested the necessary assistance for the country’s overall development. In response, the chair drew the attention of everyone present and requested the necessary cooperation. The chair concluded the meeting with sincere thanks to all those present. Signed in the original: Md. Enamul Karim Khan Convener, Bangladesh Bank–AD Forum and Executive Director, Bangladesh Bank