Analysis Blog

Central bank’s unified import circular: a milestone in trade facilitationMehdi Rahman

Written by Mehdi Rahman

Researcher and Columnist


On 14 August 2025, Bangladesh Bank took a decisive step toward transforming the country’s import regime by issuing FE Circular No. 33, a master circular that consolidates decades of scattered policies into a single, unified framework. The directive, designed to remain effective for one year, sweeps away the patchwork of rules embedded in the Guidelines for Foreign Exchange Transactions-2018 and its subsequent amendments, replacing them with a streamlined, authoritative set of instructions. This move mirrors a similar consolidation recently undertaken for export regulations and reflects the central bank’s strategic ambition to simplify compliance, reduce procedural complexity, and align domestic trade governance with global best practices.

For years, Bangladesh’s importers and authorized dealer (AD) banks have struggled with a tangled web of circulars, guidelines, and notifications dating as far back as the early 1990s. Many of these overlapped, others contradicted each other, and some became obsolete without formal withdrawal. The resulting inconsistencies created uncertainty in interpretation, delaying transactions and generating disputes over compliance obligations. By introducing a single operational reference, Bangladesh Bank has delivered both clarity and predictability. Every AD bank now follows identical procedures for issuing letters of credit (LCs), processing remittances for import, reporting transactions, and carrying out due diligence. More importantly, the framework directly references international standards such as UCP, URC, Incoterms, and HS codes, embedding globally recognized principles into everyday operations.

The scope of the circular is wide-ranging. It governs LCs and remittance regulations, imports via direct sales and purchase contracts, supplier’s and buyer’s credit arrangements, software imports including electronic delivery mode, and inland foreign-currency LCs. It extends to special economic zones such as export processing zones and hi-tech parks, and covers sensitive goods like precious metals and jewellery. By integrating these areas into a single codified text, the circular provides both operational coherence and a future-proof basis for regulatory oversight.

A significant structural change lies in mandatory reporting through the Online Import Monitoring System (OIMS). Under the new rules, AD banks will upload underlying documents – proforma invoices, indents, and contracts – before processing any import, whether LC-backed or on sales contracts. For high-value imports of 3 million US dollar or more, excluding government transactions, reporting needs to occur at least twenty-four hours before LC issuance. This digital pipeline enables near-real-time monitoring by regulators and allows for better tracking of large-scale capital flows.

Price verification and full product specification have also become integral obligations. AD banks will ensure that invoice values match prevailing international market prices and that imported goods are described with precision, including brand names, production dates, packaging details, and accurate HS coding. These requirements aim to block over-invoicing, under-invoicing, and misclassification—common conduits for tax evasion and illicit capital flight.

The circular resolves a long-standing ambiguity over the liability of banks in direct sales or purchase contracts. It states unequivocally that for such imports, banks are not financially liable; they merely facilitate remittances using funds provided by importers. This clarity frees banks from unintended credit exposure while allowing importers greater flexibility in structuring supply arrangements outside conventional LC frameworks.
Another pragmatic provision concerns documentary discrepancies. Where differences between agreed terms and presented documents are minor and the importer provides a reasonable waiver, AD banks may proceed with processing. However, the discretion remains with the bank, which retains the right to decline transactions that could expose it to legal or compliance risks.

In recognition of the capital and financing cycles of industry, the circular extends payment terms under buyer’s or supplier’s credit arrangements. Industrial raw materials may now be financed for up to 180 days, coastal vessel imports for 360 days, active pharmaceutical ingredients and lab reagents for 360 days, heavy furnace oil for 360 days, and capital machinery for up to three years. These timelines are designed to ease cash-flow constraints, encourage large-scale industrial procurement, and support strategic infrastructure projects without forcing buyers into premature repayment schedules.

For export-oriented industries, the circular introduces a measure that could substantially improve liquidity management. Export earnings can be retained in foreign-currency pools for up to thirty days to settle import bills directly, bypassing the need for conversion into local currency and subsequent re-purchase of foreign exchange. Enterprises in EPZs and hi-tech parks can also use these pools for intra-group import settlements, adding operational flexibility and reducing transaction costs.

Digitalization threads through much of the new framework. AD banks are allowed to accept electronic customs bills generated by automated systems, complementing traditional paper documentation and cutting processing delays. They are also required to keep detailed records of import transactions, including IMP forms and quality certificates, for five years, ensuring readiness for inspections. Monthly reporting of overdue import bills becomes mandatory, as does reconciliation of unmatched or non-received goods under LCs or contracts through outward remittances. All such actions must be documented in OIMS using specific categories like ‘Refund of Import Payments’, ensuring traceability from initiation to closure.

Special import categories remain under strict oversight. Gold, silver, and jewellery imports require prior approval under the Gold Policy-2018 and must be channeled through licensed dealers. Passengers bringing foreign currency worth more than USD 10,000 shall declare them on the FMJ form, while overseas tourists gain the ability to pay for goods and services in Bangladesh using digital wallets via roaming arrangements – an innovation aimed at integrating modern payment systems into cross-border commerce.

The practical effects of this consolidation are already visible in industry reactions. Stakeholders anticipate reduced complexity, faster transaction processing, and fewer procedural disputes. Banks and traders alike benefit from the predictability of uniform protocols, which shorten onboarding times for new clients and reduce compliance costs. Extended credit terms are expected to fuel investment in capital-intensive sectors, while mandatory digital reporting enhances oversight, strengthens anti-money-laundering defenses, and supports compliance with global financial standards.

By formally embedding references to international trade norms, the circular also paves the way for smoother participation in cross-border transactions and stronger trade partnerships. Explicit accommodation for software imports, e-delivery mechanisms, and digital wallets signals Bangladesh Bank’s willingness to adapt to emerging global commerce trends, where services and digital goods play an ever-larger role.

Many in the commercial and financial community now hope that this model will be applied to other regulatory areas, including outward remittances, foreign borrowing, foreign direct investment, cross-border investment, and foreign currency account operations. They argue that similar master circulars could bring the same clarity, efficiency, and international alignment to other facets of Bangladesh’s external economic relations.

FE Circular No. 33 is, at its core, a reflection of institutional maturity. By dismantling a legacy of fragmented rules and replacing it with a coherent, modern, and technologically integrated framework, Bangladesh Bank has taken a step that combines administrative rationalization with strategic vision. The new system’s success will depend on faithful execution – AD banks must adopt the new processes, importers must adjust to the heightened documentation and price-verification standards, and the regulator must remain responsive to implementation challenges.

Yet the architecture is sound. Common guidelines will simplify workflows, reduce disputes, and enhance the predictability of import operations. Extended financing windows will enable industries to invest more ambitiously in production capacity. Digital documentation and robust due diligence will strengthen oversight and reinforce the country’s sovereignty over its foreign-exchange flows. In embracing e-customs and modern payment tools, the circular aligns Bangladesh’s trade infrastructure with the demands of 21st-century commerce.

In effect, Bangladesh has not only modernized its import regulation framework but also positioned itself for a future where clarity, transparency, and global integration are the hallmarks of economic policy. The issuance of this master circular marks the beginning of a more streamlined, accountable, and opportunity-rich chapter in the nation’s trade history.


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