BDschema world-payments-v1trajectory: not recorded
Last updated · 14 modules · 65 sourced
findings · 118 sources in the cumulative register
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Confidence mix(sums to 14 rendered modules; click to filter)
Jurisdiction brief
Lead Signal
Bangladesh's payment-licensing architecture is entering its most consequential reshaping in over a decade. The Payment and Settlement Systems Act, 2024, passed 4 July 2024, now provides the statutory basis for licensing, replacing reliance on the 2014 payment-systems regulations, with Bangladesh Bank's Payment Systems Department remaining sole licensing authority across bank-led mobile financial services, non-bank payment-service-provider and payment-system-operator tracks, and the Digital Bank track. Layered onto that transition, a draft set of Regulations for E-Money Issuers, still in public consultation, would open e-money issuance to non-bank entities for the first time through new authorised-EMI and dedicated-EMI categories, requiring existing operators to re-apply within six months of the rules taking effect. Neither reform is yet in force. The reform push runs alongside the unraveling of Nagad, the country's second-largest mobile financial services operator, placed under a Bangladesh Bank-appointed administrator and management board in August-September 2024 after allegations of misappropriating social safety net allowances and stipends quantified at between Tk 1,711 crore and Tk 2,356 crore across differing estimates. Bangladesh Bank has since initiated legal action against Nagad's former chairman, its former managing director and chief executive, and twenty-two others, shortly before an Anti-Corruption Commission raid found preliminary evidence of large-scale corruption and money laundering. The juxtaposition is instructive: regulators are simultaneously trying to widen non-bank participation in payments while Nagad's governance collapse illustrates the supervisory risk such participation can carry.
Other Developments
Operational resilience regulation escalated sharply this cycle: Bangladesh Bank's Cybersecurity Framework, Version 1.0 (2026), mandates compliance by 31 December 2026 for all scheduled banks, NBFIs, mobile financial services providers, payment service providers and payment system operators, the first sector-wide cyber directive the central bank has issued, alongside a companion Guidelines on Partner Network requiring prompt incident reporting and tiered resilience standards for network providers on the same deadline. Card-scheme oversight is also being reshaped: a draft Payment System Operator Regulation, 2025 would require international card networks including Visa, Mastercard, American Express and UnionPay to register locally and obtain a Bangladesh Bank licence within six months of taking effect. Interoperability reform remains commercially contested: the National Payment Switch Bangladesh upgrade connected banks, mobile financial services providers and payment service providers on a single platform from 1 November 2025, but bKash refused to integrate at launch citing security concerns despite holding roughly 60% mobile financial services market share. On cross-border payments, Swift selected Bangladesh as an initial launch market for its new retail cross-border payments framework, naming City Bank a Gateway Intermediary Bank. On digital money, Bangladesh Bank maintains a formal ban on cryptocurrency and virtual-currency use, with no licensing framework for stablecoin issuance. On correspondent banking, Bangladeshi banks depend on a concentrated set of global correspondent banks for US-dollar clearing, a structural vulnerability with a documented history of de-risking. On consumer protection, Bangladesh Bank's Customer Interest Protection Centre provides a formal complaint-escalation path, but no UK/PSR-style mandatory reimbursement regime for authorised-push-payment fraud is in force.
Cross-Monitor Connections
Several findings this cycle sit at the boundary between payments-market structure and illicit-finance analysis and have been flagged onward to FIM rather than analysed here. Bangladesh's Financial Intelligence Unit froze accounts holding Tk 15,000 crore across 366 individuals and entities in late 2024, a scale of action that, together with the Nagad corruption and laundering findings, warrants dedicated illicit-finance review beyond the Sentinel-fed provenance carried in this monitor's AML/CFT module. Separately, growing underground USDT usage for remittances persisting despite Bangladesh's formal cryptocurrency ban sits outside Bangladesh Bank's KYC monitoring perimeter and is flagged as a sanctions-evasion-adjacent signal. The 2016 Bangladesh Bank heist, which exploited weaknesses in the interfaces linking the central bank's systems to Swift, is likewise flagged for its financial-crime dimension.
Outlook
The next two quarters carry several hinge points for Bangladesh's payments architecture. Whether the draft E-Money Issuer regulation and the draft Payment System Operator Regulation are finalised will determine whether non-bank issuers and international card schemes are brought inside the licensing perimeter on the timelines currently floated; no enactment date has yet been published for either. The 31 December 2026 compliance deadline for the Cybersecurity Framework will test operational readiness across a sector still absorbing the Nagad governance shock. Continued resistance from bKash to full National Payment Switch Bangladesh interoperability suggests rail unification will remain commercially contested even as the regulatory mandate hardens.
trust tier: ai_unverified
Regulatory Status
Bangladesh's payments regulatory environment is in a period of escalating regulatory activity following the Nagad scandal and the 2026 cybersecurity framework, with the Nagad governance crisis, the statutory transition to the Payment and Settlement Systems Act 2024, and the first sector-wide cybersecurity framework together marking intensified regulatory tightening across licensing, resilience, and AML enforcement. Licensing sits mid-transition: the 2024 Act now governs bank-led MFS, non-bank PSP/PSO and Digital Bank tracks, while a draft E-Money Issuer regime and a draft Payment System Operator Regulation targeting international card schemes both remain in consultation. Conduct oversight runs through a bank-custody safeguarding model and a newly statute-backed Bangla QR mandate, alongside thin enforcement of service-charge transparency rules. Bangladesh maintains a formal prohibitory stance on cryptocurrency and stablecoins, with the e-Taka CBDC initiative stalled. Operational resilience regulation escalated via the Cybersecurity Framework and Partner Network Guidelines, both due 31 December 2026. Card-scheme and interoperability compliance is being reshaped by the draft PSO Regulation and by contested NPSB rollout. Correspondent-banking concentration and historical de-risking remain structural vulnerabilities. Consumer protection lacks a mandatory APP-fraud reimbursement regime despite high measured MFS fraud incidence. AML/CFT enforcement intensity, sourced via Sentinel.gi, has risen materially following large-scale account freezes tied to the Nagad case.
Outlook
The next several quarters will test whether Bangladesh's parallel reform tracks - non-bank market-access liberalisation, operational-resilience hardening, and AML/CFT enforcement escalation - converge into a coherent, differentiated regulatory architecture or continue to advance at uneven speeds; the Nagad case remains the single clearest bellwether for how much governance risk the system can absorb while that liberalisation proceeds.
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Bangladesh's payment licensing regime is undergoing a foundational shift: the Payment and Settlement Systems Act, 2024 (passed 4 July 2024) now provides the statutory basis for licensing, replacing reliance on the older Bangladesh Payment and Settlement Systems Regulations, 2014 (BPSSR-2014). Bangladesh Bank's Payment Systems Department (PSD) remains sole licensing authority, operating a two-phase NOC-then-licence process across three main tracks: bank-led MFS (Bangladesh Mobile Financial Services (MFS) Regulations, 2022), non-bank PSP/PSO licences, and (from August 2025) a revised Digital Bank regime. A draft Regulations for E-Money Issuers would open e-money issuance to non-bank entities for the first time, breaking the historic bank-led monopoly, but remains in consultation and is not yet in force.
Movement — NEWBaseline established: PSSA 2024 statutory transition + draft non-bank EMI regime.First BD baseline cycle for W1a.
Key judgment — High · impact HIGHBangladesh's payments-licensing architecture is mid-transition from a bank-led MFS monopoly toward a broader statutory framework (PSSA 2024) that will, once the draft E-Money Issuer and PSO Regulations are finalised, materially open non-bank e-money issuance and bring international card schemes under local incorporation - but neither reform is yet in force.claims: wpm-2026-W1a-001, wpm-2026-W1a-003, wpm-2026-W4-002
Open gap — wpm-int-3Final enactment/in-force date for the draft Regulations for E-Money Issuers is not yet published; the six-month re-licensing window will only begin once the regulation takes effect.no under-indexing note recorded
Open gap — wpm-int-6Post-hoc challenge review flags a potential factual/date discrepancy regarding the claimed August 2025 issuance of 'Digital Bank Guidelines Version 2': verified press reporting describes a capital-requirement circular under s.13 Bank Company Act 1991 rather than confirmed issuance of a titled Version 2 document on that date, though Bangladesh Bank's official guideline list does show a Version 2 document exists. Requires primary-source verification before publication.no under-indexing note recorded
Standing sub-brief264 words · last cycle wpm-2026-07-04
Licensing, Authorisation & Market Access
Bangladesh's payment licensing regime rests statutorily on the Payment and Settlement Systems Act, 2024, passed 4 July 2024, which replaces reliance on the 2014 payment-systems regulations; Bangladesh Bank's Payment Systems Department remains sole licensing authority across bank-led mobile financial services, non-bank payment-service-provider/payment-system-operator, and Digital Bank tracks. Bangladesh Bank raised the minimum paid-up capital requirement for Digital Bank licensees from BDT 125 crore to BDT 300 crore via a circular dated approximately 22-25 August 2025, reported by some sources as 'Digital Bank Guidelines Version 2'; the precise dating of that titled document requires primary-source verification. A draft set of Regulations for E-Money Issuers, still in public consultation, would open e-money issuance to non-bank entities for the first time, introducing 'authorised EMI' and 'dedicated EMI (DEMI)' categories and requiring existing MFS/PSP operators to re-apply within six months of the rules taking effect, breaking the historic bank-led e-money monopoly. Separately, the Bangladesh Mobile Financial Services (MFS) Regulations, 2022 require new bank-led MFS subsidiary applicants to hold minimum paid-up capital of BDT 45 crore, with a bank equity partner holding at least 51%, via a two-phase NOC-then-licence process.
Outlook
Whether the draft E-Money Issuer regulation is finalised on the terms currently floated will determine how quickly non-bank entities can enter e-money issuance; no enactment date has yet been published, and the precise instrument and date behind the reported Digital Bank capital increase still require primary-source confirmation. The statutory transition to the 2024 Act and the parallel Digital Bank licensing track point toward a more differentiated, tiered market-access regime over the next several quarters.
No periodic updates recorded against this sub-brief.
Customer fund safeguarding for MFS/PSP operates through a bank-custody model (Trust Fund/mobile-account float held with scheduled banks) rather than a segregated-trust EMI model. Conduct oversight runs through Bangladesh Bank's Customer Interest Protection Centre (CIPC) under the Technology Risk and Digital Banking Supervision Department, with mandatory escalation stages. Enforcement of conduct standards (e.g., against misleading fee advertising) has been criticised as weak by civil-society oversight, and mandatory adoption of interoperable Bangla QR is now backed by statutory penalties.
Movement — NEWBaseline established: bank-custody safeguarding + statutory Bangla QR mandate.First BD baseline cycle for W1b.
Standing sub-brief196 words · last cycle wpm-2026-07-04
Conduct, Safeguarding & Promotions
Customer fund safeguarding for MFS operates through a bank-custody model in which the scheduled bank's book balance must at all times equal the virtual balance of all registered mobile accounts, with banks liable for improper agent conduct - a bank-held custodial float model rather than a segregated-trust EMI arrangement. Bangladesh Bank has made mandatory the adoption of the interoperable Bangla QR platform by banks, MFS providers, PSPs and PSOs, warning of statutory penalties under s.37(5) of the Payment and Settlement Systems Act 2024, including fines up to Tk 30 lakh and imprisonment up to three years - the first instance of statutory rather than merely supervisory penalty backing for a conduct-adjacent interoperability mandate. Civil-society oversight assessment has separately found that Bangladesh Bank and the Bangladesh Competition Commission failed to substantively enforce against MFS providers over strategically misleading service-charge advertising, issuing only warnings rather than punitive measures.
Outlook
Statutory backing for the Bangla QR mandate signals a broader shift toward hard-penalty conduct enforcement; whether that rigor extends to service-charge transparency and agent-level conduct, where oversight has so far been limited to warnings, is the key test for this module over the coming cycles.
No periodic updates recorded against this sub-brief.
Bangladesh maintains a formally restrictive stance on cryptocurrency and stablecoins: Bangladesh Bank has repeatedly stated crypto is not authorised legal tender and that FX/AML law prohibits virtual currency use, while pursuing its own e-Taka CBDC feasibility work since 2022 (pilot in 2024, stalled since). There is no licensing or legal framework for stablecoin issuance, and underground stablecoin (USDT) usage for remittances is large and growing despite the ban, creating a widening gap between the formal position and de facto market behaviour.
Movement — NEWBaseline established: formal crypto ban vs growing underground adoption; stalled CBDC.First BD baseline cycle for W2.
Key judgment — Assessed · impact ELEVATEDA structural gap persists between Bangladesh's formally prohibitive crypto/stablecoin stance and substantial, growing underground USDT usage for remittances, creating latent AML/CFT exposure outside Bangladesh Bank's KYC monitoring perimeter.claims: wpm-2026-W2-001, wpm-2026-W2-003
Open gap — wpm-int-1No dedicated stablecoin/EMT licensing regime exists in Bangladesh (not applicable under current regime); WPM will continue monitoring for any shift toward a formal framework.no under-indexing note recorded
Standing sub-brief174 words · last cycle wpm-2026-07-04
Stablecoins & Digital Money
Bangladesh Bank maintains a formal ban on cryptocurrency and virtual-currency use under the Foreign Exchange Regulation Act 1947 and Money Laundering Prevention Act 2012, with no licensing or legal framework for stablecoin issuance. The e-Taka CBDC initiative has stalled after a 2022 announcement and feasibility study; although a 2024 pilot was reported by some sources, a Bangladesh Bank official confirmed in 2025 that the initiative 'did not move forward significantly, though we may work on it in the future.' Underground USDT and stablecoin usage persists despite the ban - Bangladesh ranked 13th worldwide in grassroots crypto adoption per Chainalysis 2025 - and Bangladesh Bank does not monitor or enforce KYC on crypto activity, unlike international platforms applying their own KYC.
Outlook
The structural gap between formal prohibition and substantial informal usage is unlikely to close without either enforcement capacity Bangladesh Bank does not currently deploy or a licensing pathway it has not yet proposed; the stalled e-Taka programme suggests no near-term formal digital-currency alternative is likely to narrow that gap.
No periodic updates recorded against this sub-brief.
Bangladesh Bank has substantially escalated operational-resilience regulation in 2025-2026, moving from the long-standing ICT Security Guideline (v4.0, 2023) to a first-ever sector-wide, technology-neutral Cybersecurity Framework, Version 1.0 (2026), mandatory for banks, NBFIs, MFS providers and PSPs/PSOs by 31 December 2026, alongside a new Guidelines on Partner Network, Version 1.0 (2026) governing interconnectivity and incident reporting. This follows active cyber-threat alerts against critical financial infrastructure in mid-2025.
Movement — NEWBaseline established: first sector-wide Cybersecurity Framework v1.0 (2026), deadline 31 Dec 2026.First BD baseline cycle for W3.
Key judgment — Assessed · impact HIGHBangladesh Bank's 2026 Cybersecurity Framework and Partner Network Guidelines mark the first-ever sector-wide operational-resilience mandate for payments, with a hard 31 December 2026 compliance deadline requiring material investment by MFS/PSP/PSO operators; direct T1 sourcing for the deadline is still pending verification.claims: wpm-2026-W3-001, wpm-2026-W3-002
Open gap — wpm-int-7The claimed 31 December 2026 compliance deadlines for the Cybersecurity Framework v1.0 and Partner Network Guidelines v1.0 (2026) are sourced only from T2/T3 trade press this cycle, not a directly cited T1 Bangladesh Bank circular/gazette notification; confidence held at Assessed pending primary-source confirmation.no under-indexing note recorded
Horizon · 2026-12-31 (±quarter)Guidelines on Partner Network Version 1.0 (2026) mandatory compliance deadlinein_force_pending · TT2
Standing sub-brief178 words · last cycle wpm-2026-07-04
Operational Resilience & Critical Infrastructure
Bangladesh Bank's Cybersecurity Framework, Version 1.0 (2026), mandates compliance by 31 December 2026 for all scheduled banks, NBFIs, MFS providers, PSPs and PSOs - the first sector-wide cyber directive issued by Bangladesh Bank. The companion Guidelines on Partner Network, Version 1.0 (2026) requires prompt cyber-incident and disruption reporting, use of approved network providers with redundancy, and tiered resilience standards distinguishing Category-A from Category-B providers, with compliance due on the same 31 December 2026 deadline. Both directives follow a mid-2025 Bangladesh Bank ICT Department cybersecurity alert warning that critical financial infrastructure faced heightened attack risk, which directed institutions to adopt fourteen precautionary measures including multi-factor authentication, endpoint detection and response, and incident-response plans.
Outlook
With both directives sharing the same 31 December 2026 deadline, and the earlier 2025 alert already flagging critical infrastructure risk, operational-resilience compliance is likely to become the dominant supervisory conversation for MFS, PSP and PSO operators through the remainder of 2026; the deadline itself still rests on trade-press reporting pending direct confirmation from a Bangladesh Bank circular or gazette notification.
No periodic updates recorded against this sub-brief.
Bangladesh Bank directly regulates interchange and merchant discount pricing for domestic card/NPSB transactions (fixed 1.6% MDR / 1.1% IRF via PSD Circular 10/2021) and mandates use of the domestically-owned National Payment Switch Bangladesh (NPSB) and Bangla QR. A significant reform is underway to bring international card schemes (Visa, Mastercard, Amex, UnionPay) under local corporate registration and licensing via a draft PSO Regulation, 2025, aimed at capturing scheme fee income within the domestic tax net.
Movement — NEWBaseline established: fixed MDR/IRF pricing + draft PSO Regulation 2025.First BD baseline cycle for W4.
Open gap — wpm-int-4Final enactment/in-force date for the draft PSO Regulation 2025 (foreign card-scheme local incorporation) is not yet published.no under-indexing note recorded
Standing sub-brief185 words · last cycle wpm-2026-07-04
Scheme & Network Compliance
Bangladesh Bank PSD Circular 10/2021 fixes a minimum 1.6% Merchant Discount Rate on National Payment Switch Bangladesh POS card transactions, of which 1.1% is passed to the card-issuing bank as interchange, with no pass-through to customers permitted - regulator-fixed pricing rather than market-negotiated interchange. A draft Payment System Operator (PSO) Regulation, 2025 would require international card networks including Visa, Mastercard, American Express and UnionPay to register as companies under the Companies Act 1994 and apply for a Bangladesh Bank licence within six months of the regulation coming into force, capturing scheme-fee income within the domestic tax net. The National Payment Switch Bangladesh mandates national interoperability across banks with mandatory two-factor authentication for online, e-commerce and card-not-present transactions; 54 banks were connected for ATM and 50 for POS as of March 2026.
Outlook
The draft PSO Regulation's local-incorporation requirement for international schemes would be the most consequential scheme-compliance shift since NPSB's 2012 launch, but no enactment timeline has yet been published; in the interim, fixed domestic MDR/interchange pricing and NPSB's expanding bank connectivity continue to set the baseline economics of card acceptance.
No periodic updates recorded against this sub-brief.
Bangladesh's dominant payment corridors are inbound worker remittances from the Gulf (UAE, Saudi Arabia) and other diaspora markets, channelled through banks and MFS platforms under strict rules that permit only inward MFS remittance handling (no outward transactions via MFS). Bangladesh is a launch market for Swift's new retail cross-border payments framework aimed at speeding up G20-aligned remittance delivery, while corridor costs from key Gulf markets remain above global targets.
Movement — NEWBaseline established: Gulf-dominated inbound remittance corridors + Swift framework launch market.First BD baseline cycle for W5.
Standing sub-brief140 words · last cycle wpm-2026-07-04
Payment Corridor Dynamics
Bangladesh Bank MFS remittance rules restrict MFS platforms to inward remittance handling only, via Nostro credits of scheduled banks paying out in Taka, with outward cross-border transactions remaining reserved for Authorized Dealership-licensed bank branches. Swift's retail cross-border payments framework selected Bangladesh as one of its initial launch markets, naming City Bank a Gateway Intermediary Bank, reflecting Bangladesh's status as a top-10 global remittance-receiving country. The UAE-Bangladesh remittance corridor is tracked by the World Bank's Remittance Prices Worldwide database as one of Bangladesh's largest inbound remittance channels, given the scale of Bangladeshi migrant labour in the UAE.
Outlook
Swift's launch-market selection and City Bank's Gateway Intermediary role point toward incremental modernisation of Gulf-facing inbound corridors, but the structural inward-only constraint on MFS platforms means outward transaction capacity remains concentrated in bank Authorized Dealership branches for the foreseeable future.
No periodic updates recorded against this sub-brief.
Bangladesh's payments industry is dominated by a bank-led MFS duopoly-plus (bKash and Nagad, with Rocket a distant third), overlaid by a growing ecosystem of PSP/PSO fintechs and an emerging digital-banking cohort following the 2025 licensing window. Governance failures at Nagad (administrator appointment, alleged large-scale e-money misappropriation) have materially reshaped market dynamics and regulatory trust, while bKash retains commercial dominance and profitability.
Movement — NEWBaseline established: MFS duopoly-plus structure + Nagad governance crisis.First BD baseline cycle for W6.
Open gap — wpm-int-8The quantum of alleged Nagad misappropriation is inconsistently reported across sources (TIB: BDT 1,711 crore in safety-net allowances; ACC: Tk 2,356 crore in broader corruption/laundering findings); unclear whether these are cumulative, overlapping, or separately scoped allegations and requires reconciliation.no under-indexing note recorded
Standing sub-brief149 words · last cycle wpm-2026-07-04
Industry Structure & Commercial Dynamics
bKash and Nagad dominate Bangladesh's MFS market in an approximately 80/20-pattern duopoly-plus, with Rocket a distant third; only 13 of licensed MFS providers remain active. Nagad was placed under a Bangladesh Bank-appointed administrator in August 2024 and a management board in September 2024 following allegations of misappropriating social safety net allowances and stipends, quantified at BDT 1,711 crore per Transparency International Bangladesh and Tk 2,356 crore per a separate Anti-Corruption Commission-sourced estimate. bKash refused to integrate with the new National Payment Switch Bangladesh interoperability platform at its 1 November 2025 launch, citing security concerns, despite holding approximately 60% MFS market share.
Outlook
Nagad's governance rehabilitation and bKash's continued NPSB resistance mean the duopoly-plus structure faces two divergent pressures at once: regulatory-forced consolidation of trust in one operator and commercially-driven fragmentation from the other, with market-structure implications likely to sharpen over the next several quarters.
No periodic updates recorded against this sub-brief.
The Nagad corruption scandal is the dominant payments-sector litigation event: Bangladesh Bank initiated legal action against Nagad's former chairman and ex-CEO along with 22 others, the Anti-Corruption Commission raided Nagad's headquarters citing evidence of large-scale irregularities, and a Supreme Court writ petition attempting to block a forensic audit was ultimately unsuccessful. Separately, Bangladesh's broader commercial-litigation and bank-resolution architecture has been reformed via the Bank Resolution Ordinance 2025 and Commercial Court Ordinance 2026.
Movement — NEWBaseline established: Nagad litigation + Bank Resolution/Commercial Court Ordinances.First BD baseline cycle for W7.
Key judgment — High · impact CRITICALThe Nagad governance crisis (administrator appointment, ACC raid, ongoing prosecutions) is the most material legal/commercial risk event in the BD payments sector this cycle; resolution of its interoperability licensing gap in December 2025 only partially restores its standing.claims: wpm-2026-W7-001, wpm-2026-W6-002, wpm-2026-W13-002
Standing sub-brief150 words · last cycle wpm-2026-07-04
Legal & Litigation
Bangladesh Bank initiated legal action against Nagad's former chairman Syed Mohammad Kamal, ex-MD/CEO Tanvir Ahmed Mishuk, and 22 others, shortly before an Anti-Corruption Commission raid found preliminary evidence of Tk 2,356 crore in corruption and laundering. The Supreme Court of Bangladesh rejected a writ petition attempting to block a forensic audit of Nagad's financial operations, following an earlier stay order that had allowed an accused former director to become CEO. Separately, the Bank Resolution Ordinance, 2025 establishes Bangladesh Bank as exclusive statutory resolution authority for failing banks, superseding general insolvency law and introducing open bank resolution (M&A/P&A) and bridge-bank powers.
Outlook
With the Supreme Court clearing the path for continued forensic oversight and the Bank Resolution Ordinance now in place, the coming quarters are likely to bring further disclosures on the scale of Nagad's alleged misappropriation and a first practical test of the new resolution regime's powers.
No periodic updates recorded against this sub-brief.
Merchant acquiring runs through a mix of bank acquirers, MFS platforms, and licensed PSO/PSP payment aggregators (e.g., SSLCommerz, aamarpay, ekpay) operating under Bangladesh Bank-fixed pricing (1.6% MDR / 1.1% IRF for NPSB card transactions), with QR acceptance now mandated at scale (approximately 700,000 merchants) via the interoperable Bangla QR scheme and penalties for merchants misusing QR for cash-out rather than payment.
Movement — NEWBaseline established: acquiring pricing regime + mass QR merchant rollout.First BD baseline cycle for W8.
Standing sub-brief104 words · last cycle wpm-2026-07-04
Merchant Acquiring & Risk
NPSB card transactions are subject to regulator-fixed 1.6% Merchant Discount Rate / 1.1% interchange reimbursement fee pricing with no customer pass-through permitted, structuring merchant-acquiring economics nationally. The Bangla QR merchant acceptance network has scaled to approximately 700,000 merchants under Bangladesh Bank's mandated interoperable QR scheme, with PSOs including SSLCommerz, aamarpay, ekpay, surjomukhi and walletmix acting as QR merchant acquirers among 18 licensed PSP/PSO companies.
Outlook
The scale of QR acceptance build-out suggests merchant-acquiring competition will increasingly concentrate on service quality among licensed PSO acquirers rather than on price, given fixed national MDR settings that leave little room for rate-based differentiation.
No periodic updates recorded against this sub-brief.
Product innovation is centred on domestic rail-building: the TakaPay national card scheme (launched June 2024) aims to reduce reliance on foreign card networks, and the November 2025 NPSB interoperability upgrade allows direct transfers across banks, MFS wallets and PSPs at fixed regulator-set fees — though rollout has been contested by the two largest MFS operators. Digital banking (2025 licensing window) and a nascent regulatory sandbox for fintech represent the next wave of innovation infrastructure.
Movement — NEWBaseline established: TakaPay + NPSB interoperability + Digital Bank window.First BD baseline cycle for W9.
Key judgment — High · impact HIGHInteroperability reform (NPSB, Nov 2025) is being contested at the commercial level by the two largest MFS operators (bKash's refusal to integrate, Nagad's initial exclusion), indicating continued fragmentation risk despite regulatory intent to unify rails.claims: wpm-2026-W9-002, wpm-2026-W6-003
Standing sub-brief150 words · last cycle wpm-2026-07-04
Product Innovation & Market Development
The TakaPay national card scheme launched on 12 June 2024, with nine banks initially issuing chip-based cards supporting ATM, POS and QR payments routed through the National Payment Switch Bangladesh, aiming to reduce reliance on foreign card-network fees. The NPSB interoperability upgrade connected banks, MFS providers and PSPs on a single platform from 1 November 2025 with fixed maximum fees per transfer type, superseding the failed 2022 'Binimoy' interoperable platform. A Bangladesh digital banking licensing window opened from 1 September to 30 September 2025 for new Digital Bank licence applications under revised guidelines raising minimum paid-up capital to Tk 300 crore.
Outlook
TakaPay's foreign-fee-avoidance rationale and the NPSB/QR interoperability build-out point toward a coherent domestic-rail strategy, but the Digital Bank window's revised capital threshold suggests entry into the newest product tier will be reserved for well-capitalised players, echoing the capital-driven consolidation already visible in MFS.
No periodic updates recorded against this sub-brief.
Consumer protection runs through Bangladesh Bank's Customer Interest Protection Centre (CIPC) and the Guidelines for Customer Services and Complaint Management, requiring escalation from provider complaint cells to CIPC with defined resolution timelines. There is no UK/PSR-style mandatory APP-fraud reimbursement regime in force; instead, consumer-fraud exposure is addressed via ad hoc awareness campaigns against a backdrop of high measured MFS fraud incidence (an estimated 9.3% of MFS users victimised) and emerging malware/social-engineering threats such as SikkahBot.
Movement — NEWBaseline established: CIPC mechanism, no APP-fraud reimbursement regime, high fraud incidence.First BD baseline cycle for W10.
Open gap — wpm-int-2No UK/PSR-style mandatory APP-fraud reimbursement scheme was found in sourcing this cycle; high MFS fraud incidence is documented but a formal reimbursement-liability framework is unconfirmed.no under-indexing note recorded
Standing sub-brief101 words · last cycle wpm-2026-07-04
Consumer Protection & APP Fraud
Bangladesh Bank's Customer Interest Protection Centre provides a formal consumer-complaint escalation path from provider complaint cells to Bangladesh Bank Head Office; no UK/PSR-style mandatory authorised-push-payment fraud reimbursement regime is in force. MFS users suffer an estimated 9.3% fraud victimisation rate averaging Tk 9,000 loss per victim, driven by PIN-compromise scams, fake apps, and the SikkahBot malware campaign intercepting one-time passwords.
Outlook
Absent a mandatory reimbursement scheme, fraud losses continue to fall primarily on individual MFS users, and the emergence of OTP-intercepting malware such as SikkahBot suggests technical fraud vectors are outpacing the current complaint-based consumer-protection architecture.
No periodic updates recorded against this sub-brief.
Sentinel.gi position: Bangladesh's AML/CFT regime is anchored on the Money Laundering Prevention Act, 2012 (amended 2015) and Anti-Terrorism Act, 2009, enforced by the Bangladesh Financial Intelligence Unit (BFIU, established 2002 within Bangladesh Bank). Enforcement intensity has risen materially in the payments context following the Nagad e-money scandal and broader banking-sector corruption cases, with large-scale account freezes recorded in late 2024, even as structural weaknesses (cash dominance, hundi informal transfer systems, trade-based laundering) persist per Sentinel-monitored payments-context indicators.
Movement — NEWBaseline established (Sentinel-fed): BFIU mandate + late-2024 enforcement escalation.First BD baseline cycle for W11.
Standing sub-brief156 words · last cycle wpm-2026-07-04
AML/CFT & Financial Crime
This module's intelligence is sourced from the Sentinel.gi feed and is carried here as payments-context provenance rather than original illicit-finance analysis. The Bangladesh Financial Intelligence Unit (BFIU) serves as the central agency analysing suspicious- and cash-transaction reports and disseminating AML/CFT intelligence, operating within Bangladesh Bank under the Money Laundering Prevention Act 2012 and Anti-Terrorism Act 2009. BFIU froze accounts of 366 individuals and entities holding Tk 15,000 crore in late 2024, including prominent business groups and politically exposed persons - findings flagged onward to FIM for dedicated illicit-finance review. bKash deployed AML360 in 2023, an automated real-time suspicious-transaction monitoring system cited as a best-practice case relative to smaller providers lacking comparable technology.
Outlook
Enforcement intensity in AML/CFT is likely to remain elevated as the Nagad case works through Bangladesh's courts; original analysis of the illicit-finance dimensions of the BFIU freezes and Nagad findings sits with Sentinel.gi and FIM rather than this monitor.
No periodic updates recorded against this sub-brief.
T?FIM (sentinel.gi) per-JID baseline profile — Bangladesh — Bangladesh operates under the Money Laundering Prevention Act 2012 and Anti-Terrorism Act, supervised by the Bangladesh Financial Intelligence Unit (BFIU) under Bangladesh Bank. Bangladesh exited the FATF ICRG monitoring process in 2014 but remains in APG enhanced follow-up on technical-compliance deficiencies, including partial compliance on virtual-asset provider (R.15) obligations. Post-2024 interim government has intensified corruption enforcement against the former ruling elite.
T2FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-003) — Enforcement: Bangladesh Bank — Islami Bank Bangladesh Ltd. board of directors
Bangladesh's correspondent banking network is concentrated among a small number of global banks (notably Standard Chartered and Mashreq for full-service correspondent relationships, plus Wells Fargo, JPMorgan Chase, Citibank and Habib American Bank for USD clearing), creating meaningful concentration risk. De-risking has materially affected Bangladeshi banks historically, most notably HSBC's 2016 cutoff of all USD clearing services, and remains a live structural vulnerability given global de-risking trends affecting emerging-market/South Asian banks disproportionately.
Movement — NEWBaseline established: correspondent-bank concentration + de-risking/settlement-security precedents.First BD baseline cycle for W12.
Standing sub-brief141 words · last cycle wpm-2026-07-04
Correspondent Banking, Settlement & Access
Bangladeshi banks depend on a concentrated set of correspondent banks - including Standard Chartered, Mashreq, Wells Fargo, JPMorgan Chase, Citibank and Habib American Bank - for US-dollar clearing, creating structural concentration risk. HSBC cut off all US-dollar clearing services to Bangladeshi banks in 2016 despite no recorded default history, a landmark de-risking event still cited as the most severe instance affecting Bangladesh. Bangladesh Bank's Nostro/Vostro account at the New York Fed was targeted in the Bangladesh Bank heist, which exploited weaknesses in the interfaces linking Bangladesh Bank's systems to Swift to attempt fraudulent transfers.
Outlook
Correspondent-bank concentration remains a structural vulnerability that neither the historical HSBC withdrawal nor the Bangladesh Bank heist has prompted diversification away from; settlement-security investment following the heist is likely to remain the more tractable near-term lever than reducing correspondent concentration itself.
No periodic updates recorded against this sub-brief.
Trailing-12-month commercial activity in Bangladesh payments is dominated by a wave of new PSP/PSO licence grants, the Digital Bank licensing window, and the resolution of major interoperability licensing disputes (Nagad), alongside an active but still-early seed-funding environment shifting from consumer MFS apps toward payments/compliance infrastructure plays.
Movement — NEWBaseline established: PSP licence grants, Nagad interoperability resolution, Swift/City Bank partnership, seed-funding shift.First BD baseline cycle for W13.
Open gap — wpm-int-5Precise disclosed deal values for 2025-2026 Dhaka fintech seed-stage rounds are not available in current reporting.no under-indexing note recorded
Standing sub-brief172 words · last cycle wpm-2026-07-04
Commercial Intelligence
Bangladesh Bank granted new PSP licences under s.5(4) of the Payment and Settlement Systems Act, 2024 to Samadhan Services Limited (Grameen Telecom), Progoti Systems, iPay Systems, D Money Bangladesh and Recursion Fintech in June 2025. Nagad was issued a formal licence by Bangladesh Bank for its interoperable payment system in December 2025, resolving a prior licensing gap and clearing its path to NPSB interoperability participation. Swift and City Bank partnered on Swift's retail cross-border payments framework, announced September 2025, with City Bank named a Gateway Intermediary Bank for the Bangladesh corridor. Dhaka's fintech seed-stage ecosystem shifted toward MSME credit workflows, credit evaluation engines, and interoperability-ready payments tooling in early 2026, away from consumer-facing MFS apps; specific deal amounts were not publicly disclosed in available reporting.
Outlook
This trailing-12-month wave of licence grants and partnership announcements signals continuing commercial activity even as some events (the PSP licence grants, Nagad's licence resolution) sit outside the four standard commercial-event categories and are logged here as plain dated entries rather than structured deal records.
No periodic updates recorded against this sub-brief.
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