Bangladesh AML Obligations for Accountants: BFIU and the Money Laundering Prevention Act 2012

Bangladesh treats accountants as part of its anti-money laundering (AML) regime. The Bangladesh Financial Intelligence Unit (BFIU), which sits within Bangladesh Bank, lists accountants among the reporting organisations under the Money Laundering Prevention Act 2012 (MLPA 2012). This guide sets out what the BFIU's own published material says about those duties, and is open about the parts we could not confirm from primary sources. It is general information, not legal advice.

Who is covered, and who supervises

The BFIU's page on reporting organisations includes accountants in the list, and records that they were brought in by the 2012 Act. The BFIU's guidelines for designated non-financial businesses and professions (DNFBPs), which Bangladesh Bank published in 2013 (the BFIU's circular list shows them as BFIU Circular No. 8, dated 29 October 2013), say that accountants fall within the definition of reporting organisation in section 2 of the MLPA 2012. The guidelines name the BFIU as the lead supervisory authority and say they are issued under section 23 of the Act.

The guidelines cover accountants when they carry out particular activities for clients. Those listed include buying and selling real estate, managing client money, and creating, operating or managing legal persons. If your firm does only audit or tax compliance work, check the exact wording of the guidelines against what you do rather than assuming either way. The BFIU's circular list also shows a later circular, No. 13 of 9 July 2015, addressed to several professions including accountants. We did not read its text, so we cannot say what it adds.

What the DNFBP guidelines expect

As far as we could read them, the guidelines set out the familiar building blocks of an AML programme:

• a designated compliance officer;
• independent testing of the programme (an independent audit function);
• staff screening and training; and
• a list of red flags for each type of activity.

If you already run client due diligence under another regime, our guide to KYC and customer due diligence in accountancy practices explains the general approach. Treat it as background rather than as a statement of the Bangladeshi rules. The excerpt of the guidelines we could read was cut off before the detailed customer due diligence and record-keeping sections.

Reporting suspicious transactions

The BFIU's guidance on suspicious transaction reporting, dated January 2019, says that section 25(1)(d) of the MLPA 2012 requires a reporting organisation to report a suspicious transaction to the BFIU "immediately on its own accord". The guidance describes a web-based reporting system called goAML. It says that, inside an organisation, the branch-level anti-money laundering compliance officer evaluates a suspicion and the central compliance unit then reports to the BFIU without delay.

That guidance is written mainly with banks and similar institutions in mind, so an accounting practice would apply the same logic in a smaller structure. For the underlying concepts, see our guide to suspicious activity reports and tipping off, which is UK-focused but explains the practical sequence of spotting, escalating and reporting.

The same BFIU guidance says that where a person is on a listed or proscribed list, the transaction should be stopped and reported by the next working day. Check the current text before relying on that timing, as it comes from guidance rather than from the Act.

Penalties the BFIU's guidance cites

The BFIU's suspicious transaction guidance states that failure to report carries a fine under section 25(2) of the Act of between Tk 50,000 and Tk 25 lakh (Tk 2.5 million), and that a licence or registration can also be cancelled. It states that tipping off carries up to two years' imprisonment, a fine of up to Tk 50,000, or both, and that section 28 protects reports made in good faith. Section 6 deals with confidentiality of the information held by the authorities.

A separate BFIU guideline for capital market intermediaries lists further penalties under section 23, including daily fines for late provision of information requested by Bangladesh Bank and fines for giving false information. That document is written for a different sector, so we cite it only to show the shape of the enforcement powers, not as a statement of what applies to an accounting firm.

Record keeping

The capital market guideline says that records must be kept for at least five years after an account is closed, citing section 25(1)(b) of the MLPA 2012. We could not confirm the retention rule that applies to accountants from the DNFBP guidelines, so confirm it before setting your own policy. Our suggestion, for firms that also have UK or Irish clients, is to keep the longer of the two periods where the rules overlap.

Is the law changing?

A December 2025 news summary, reporting on a meeting of Bangladesh's National Coordination Committee on money laundering and terrorist financing, said the government had decided to revise the 2012 Act. The stated aims were faster recovery of laundered assets, quicker charge sheets and quicker mutual legal assistance. The same summary referred to Bangladesh's fourth mutual evaluation by the Asia/Pacific Group on Money Laundering, scheduled for 2027-28. We found no enacted replacement, but we could not read the Act's current text, so check the official sources. For wider context on how mutual evaluations and the Financial Action Task Force (FATF) lists work, see our explainer on the FATF Recommendations and grey list.

What we could not confirm

• The full current text of the MLPA 2012 and any later amendments, because the government law database would not let us retrieve it.
• Whether the Institute of Chartered Accountants of Bangladesh issues its own AML guidance for members. Its website could not be read.
• The content of BFIU Circular No. 13 of 2015 and any later instructions to accountants.
• Threshold, cash-reporting and registration requirements for accountants.

Suggested next steps

These are our suggestions, not requirements. Read the BFIU's DNFBP guidelines and its circular list in full. Confirm in writing with the BFIU or a Bangladeshi lawyer which of your services fall within the Act. Appoint a compliance officer and write down how staff escalate suspicions. Train staff against the red flags in the guidelines. If your team wants structured learning on AML, see our CPD courses.

Frequently asked questions

Are accountants in Bangladesh covered by AML law?

According to the BFIU's list of reporting organisations and its DNFBP guidelines, yes, for the activities the guidelines describe.

Who do accountants report suspicious transactions to?

The BFIU, according to its January 2019 guidance, which describes use of the goAML system.

Is the Money Laundering Prevention Act 2012 being replaced?

A December 2025 news summary said the government decided to revise it. We found no enacted replacement, so check the official sources for the latest position.