← Regulations / Bangladesh / Operating Models / CEX

Centralized exchange in Bangladesh

Order-book exchange that takes custody of user assets and matches trades between users.

Not permitted AI-Generated · Unreviewed

CEX is not permitted in Bangladesh.

Verdict Details

Permitted
no
Local entity required
No
Licensing burden
None
Last updated
2026-07-13

AML Obligations

  • No AML obligations arise for a lawful operator because the activity itself is prohibited — there is no legal pathway to operate a centralized exchange.
  • Any AML obligations that could theoretically apply would arise under the Money Laundering Prevention Act, 2012 (MLPA), enforced by Bangladesh Bank/BFIU and law enforcement, but only in the context of criminal prosecution.
  • The FATF Travel Rule has not been adopted in Bangladesh; no travel-rule obligations exist because VASPs are not recognized.

Key Restrictions

  • Centralized crypto exchanges are explicitly prohibited under Bangladesh Bank circulars (FE Circular No. 15 of 2017, Circular No. 34 of 2021).
  • No licensing or registration regime exists for virtual assets — there is no legal application process for a VASP license.
  • Bangladesh Bank has instructed all financial institutions to block crypto-related transactions, cutting off banking access.
  • Law enforcement (CID, RAB) actively investigates and prosecutes persons operating crypto exchanges (arrests, asset seizures, imprisonment under MLPA Section 4).
  • Cross-border foreign exchange transactions involving crypto violate the Foreign Exchange Regulation Act, 1947.

Key Risks

  • Criminal prosecution risk: imprisonment of 4–12 years under MLPA Section 4 for money laundering linked to crypto activities.
  • Asset forfeiture: authorities can seize property connected to crypto activities.
  • Ongoing enforcement: Bangladesh authorities actively pursue crypto-related MLM scams, digital hundi, and illegal exchange operators — operator arrests and asset seizures are documented through 2025.
  • Bangladesh is on the FATF grey list, with ongoing scrutiny; any crypto activity is treated as an AML/CFT violation.
  • No travel-rule framework exists, but this is moot because the underlying activity is illegal.

Evidence

This verdict synthesizes the following facts. Each fact links to its primary source(s).

licensing 88% confidence

In Bangladesh, cross‑border foreign exchange transactions are governed by the Foreign Exchange Regulation Act, 1947 (as amended), which remains in force and is administered by Bangladesh Bank. Bangladesh Bank has stated via circulars that cryptocurrencies/virtual currencies are not legal tender in Bangladesh and has warned against their use, but there is no explicit, publicly available provision in the Act itself or authoritative judicial ruling that categorically deems every cryptocurrency transaction—especially solely by virtue of being a “currency”—to be a violation of the Foreign Exchange Regulation Act, 1947. Rather, potential violations would arise where such transactions fall within regulated foreign exchange or cross‑border payment activities without required Bangladesh Bank permission.

licensing 73% confidence

Money Laundering Prevention Act, 2012 (MLPA): The BB has highlighted the significant risks of money laundering and terrorist financing associated with the anonymity and unregulated nature of cryptocurrencies. While not specifically mentioning "virtual assets," engaging in transactions that facilitate money laundering through any means would fall under this act.

licensing 90% confidence

FE Circular No. 15 of 2017 (December 24, 2017): This was one of the earliest and most direct prohibitions. The BB warned against dealing in virtual currencies like Bitcoin, stating they are not legal tender, are not approved by the BB, and carrying out transactions with them could lead to violations of FERA and MLPA.

licensing 90% confidence

Circular No. 34 (of 2021) on Foreign Exchange Transactions (October 14, 2021): This circular reiterated the ban, explicitly stating that "virtual assets" (including cryptocurrencies like Bitcoin, Ethereum, Ripple, Litecoin) are not legal tender and are not permitted for transaction or exchange within Bangladesh. It also warned about associated risks and legal consequences.

licensing 90% confidence

Cryptocurrency Exchanges: Operating an exchange for buying, selling, or trading cryptocurrencies is prohibited.

licensing 95% confidence

Neither a registration nor a licensing regime exists for virtual assets in Bangladesh.

licensing 100% confidence

The current approach is one of outright prohibition and warning against engaging in any activities related to cryptocurrencies.

licensing 95% confidence

There is no application process for virtual asset licenses in Bangladesh because such licenses are not issued.

licensing 78% confidence

Under Bangladesh’s Money Laundering Prevention Act (MLPA), Section 4, individuals convicted of money laundering are subject to a statutory imprisonment range of 4 to 12 years, with the precise term within that range determined by the court based on the nature, severity, and value of the offense.

licensing 76% confidence

Asset forfeiture is a legal process in which authorities confiscate property connected to alleged criminal activity, including assets used in, derived from, or otherwise linked to crime, sometimes through in rem proceedings that do not require a criminal conviction and can extend beyond only the assets directly involved in specific illegal transactions.

licensing 90% confidence

Warnings to Financial Institutions: Bangladesh Bank has repeatedly issued warnings to all banks and financial institutions against dealing in, facilitating, or promoting cryptocurrencies. These warnings serve as an instruction to financial institutions to block transactions related to crypto.

aml 0% confidence

Violation Type: Engaging in cryptocurrency transactions, which is considered illegal under existing foreign exchange regulations (Foreign Exchange Regulation Act, 1947) and anti-money laundering laws (Money Laundering Prevention Act, 2012). BB states crypto carries high risks of money laundering, terror financing, and capital flight.

travel-rule 95% confidence

No, the FATF Travel Rule has not been adopted in Bangladesh. This is because the underlying activity of dealing in virtual assets itself is considered illegal and unauthorized by the central bank and the government.

travel-rule 82% confidence

N/A. There are no legally operating VASPs, and thus no thresholds for Travel Rule implementation.

travel-rule 100% confidence

FATF Mutual Evaluation Report (MER) for Bangladesh:

travel-rule 95% confidence

Key Finding (from the MER): The report highlights that Bangladesh has not taken steps to regulate or license VASPs because virtual assets are not permitted in the country. It states that the regulatory framework for virtual assets is non-existent as financial institutions are prohibited from providing services to VAs, and VAs themselves are prohibited.

enforcement 98% confidence

Entity Targeted: General public, financial institutions, and implicitly, anyone involved in cryptocurrency. Violation Type: Engaging in cryptocurrency transactions, which is considered illegal under existing foreign exchange regulations (Foreign Exchange Regulation Act, 1947) and anti-money laundering laws (Money Laundering Prevention Act, 2012). BB states crypto carries high risks of money laundering, terror financing, and capital flight. Penalty Amount: N/A (for a warning), but the underlying laws carry severe penalties (fines, imprisonment, asset forfeiture) for non-compliance. Outcome: Public awareness campaigns, continued illegal status of crypto, discouragement of financial institutions from dealing with crypto. This forms the basis for criminal prosecutions.

enforcement 95% confidence

Entity Targeted: Individuals running illegal multi-level marketing (MLM) schemes using crypto, conducting "digital hundi" (informal remittance) via crypto, or engaging in crypto-related scams. Violation Type: Fraud, money laundering, operating illegal financial schemes, breach of Digital Security Act. Penalty Amount: Varies upon conviction (fines and imprisonment). Asset seizures occur during arrest. Specific penalty amounts are not publicly available at the time of arrest or often even immediately after conviction. Outcome: Arrests, ongoing investigations, disruption of illegal schemes, seizure of assets. Violation Type: Money laundering, violation of Foreign Exchange Regulation Act, illegal hundi operations. Penalty Amount: Varies upon conviction. Outcome: Arrests, disruption of illegal remittance networks.

Verdict Attribution

Source:
AI-Generated · Unreviewed
AI synthesized:
2026-07-13 (deepseek-chat)
Last updated:
2026-07-13
Confidence:
high

This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.

No — operating a centralized exchange in Bangladesh is prohibited outright under Bangladesh Bank circulars and the Foreign Exchange Regulation Act, 1947; there is no licensing pathway, and participants face criminal prosecution (4–12 years imprisonment under the MLPA), asset forfeiture, and active law enforcement action.

Questions this verdict aims to answer

  • What exchange / VASP license applies?
  • What custody segregation rules apply to user assets?
  • What market-conduct and listing rules apply?
  • What travel-rule obligations apply on withdrawals?