FE Circular No. 31 dated July 31, 2025

Foreign exchange regulations - export trade transactions

Learning purpose: This portal is prepared for Authorized Dealer banks, export operations, compliance, audit and client advisory teams.

Item	Circular content
Issuer	Foreign Exchange Policy Department, Bangladesh Bank, Head Office, Dhaka.
Circular number and date	FE Circular No. 31, dated July 31, 2025.
Subject	Foreign exchange regulations - export trade transactions.
Purpose	To compile existing export transaction regulations in one place with required modifications.
Repeal effect	Existing instructions regarding export transactions in GFET-2018 Vol-1 and subsequent circulars stand repealed, except monthly reporting instructions in GFET-2018 Vol-2.
Authority	Issued under Section 20(3) of the Foreign Exchange Regulation Act, 1947.
Validity	Valid for one year from issuance; subsequent instructions within the period are to be read with this circular.

Important: This file is based on the attached FE Circular 31 export trade transaction content. No separate subsequent update layer has been applied.

EXP / OEMSProceeds repatriationOpen account exportService exportERQSpecialized zones

Full Circular Map

Part	Area	Key coverage
Part-A	General Guidelines	Legal base, registration and EXP declaration; Exempted exports; Realization period; etc.
Part-B	Export from Specialized Zones	Zone types; Declaration and proceeds; NFCD use for discounting; etc.
Part-C	Export Trade Safeguards	Cross-border banking and AML/CFT; Transaction safeguards; Guidance when concerns arise.
Part-D	Export under Open Account Credit Terms	Open account permitted with risk coverage; Financing cost and competitive pricing; Counterparty, documents and compliance.
Part-E	Export of Services including ITES	Software/data processing export; BPO and individual service export; Business services and retention abroad.
Part-F	Export Proceed Realization Services	Acquiring service and e-commerce; OPGSP route; Freelancer card, PSP/MFSP routes; etc.
Part-G	Export through E-Commerce	B2C advance and electronic declaration; COD/payment on shipment and small value.
Part-H	Re-export, Entre-pot and Merchanting Trade	Re-export and entre-pot; Merchanting trade; Counter-trade arrangement.
Part-I	Currency, FX, Gold, Jewellery and Securities	FX, local currency and securities; Jewellery export.
Part-J	Exporters' Retention Quota (ERQ) Account	Retention quota limits; Eligible currency and utilization; ERQ term deposit and remittance; etc.
Part-K	FC Accounts for Enterprises in Specialized Zones	Type A proceeds; Type B/C proceeds.

Part-A: General Guidelines

Para	Topic	Circular-based learning point	AD control question
1-6	Legal base, registration and EXP declaration	Export is regulated by Import & Export (Control) Act, Export Policy, FER Act and BB circulars. Exporters must be registered and all non-exempt exports require EXP declaration with undertaking to repatriate proceeds.	Is this requirement evidenced, reported and retained according to FE Circular 31?
7	Exempted exports	Trade samples, personal effects, ships stores, government/military shipments, eligible gift packets, BB-certified parcels without FX transaction, and e-commerce exports up to USD 500 are exempted from declaration/repatriation requirements subject to customs satisfaction.	Is this requirement evidenced, reported and retained according to FE Circular 31?
8	Realization period	General period for export proceeds repatriation is four months. Raw jute and jute goods may be up to 360 days against irrevocable confirmed LC or under open account, with extended due diligence on price and usance interest.	Is this requirement evidenced, reported and retained according to FE Circular 31?
9-10	Permitted receipt and ERQ retention	Export payments may be received through AD in freely convertible currency including CNY, NR Taka account, escrow under counter-trade, acquiring service, OPGSP or legitimate operators. Exporters may retain eligible proceeds in ERQ and single pool where permitted.	Is this requirement evidenced, reported and retained according to FE Circular 31?
11-12	EXP and electronic EXP	EXP number has 11 digits: 4-digit AD branch code, 5-digit export register serial and 2-digit year. Electronic EXP is acceptable through OEMS before customs; exporters submit shipment info immediately and AD completes reporting within 14 days if exporter does not report.	Is this requirement evidenced, reported and retained according to FE Circular 31?
13	AD due diligence before export	AD must ensure arrangements for realization, receipt of title documents, bonafide of buyers/consignees, and report doubts or common-interest/collusion concerns to Bangladesh Bank.	Is this requirement evidenced, reported and retained according to FE Circular 31?
14-15	Transport document control	Transport documents for exports generally must be drawn to order of AD/bank and delivered to AD. Blank endorsement or direct endorsement to consignee requires BB approval except permitted Type A zone cases and fully paid cases as per circular.	Is this requirement evidenced, reported and retained according to FE Circular 31?
16-18	Document dispatch and EXP disposal	Direct dispatch of export documents excluding original title document is allowed where LC/contract permits, proceeds realization is arranged, KYC/AML is compliant, and EXP/documents are submitted to AD within 14 days from shipment. AD retains EXP and full documents for 5 years.	Is this requirement evidenced, reported and retained according to FE Circular 31?
19-20	Deductible charges and Incoterms	Foreign commission/brokerage may be deducted/remitted up to 5% unless BB approval; books/journals/magazines may allow up to 33.5% discount. Allowed incoterms: EXW, FCA, FOB, FAS, CFR, CIF, CPT and CIP if stipulated in LC/contract.	Is this requirement evidenced, reported and retained according to FE Circular 31?
21-30	Advance receipts, overdue reporting, PRC and financing	Advance export receipt requires ARV and online reporting, confirmed LC/contract, no interest, at least 10% retained until export, export within one year, and refund rules. ADs upload overdue EXP by 10th monthly, issue PRC through OEMS, may arrange bill discounting within benchmark +4% all-in-cost, and insurance does not waive repatriation duty.	Is this requirement evidenced, reported and retained according to FE Circular 31?

Part-B: Export from Specialized Zones

Para	Topic	Circular-based learning point	AD control question
31	Zone types	Specialized zones include EPZ, PEPZ, EZ and HTP. Type A is 100% foreign owned including NRB-owned; Type B is foreign-Bangladeshi joint venture; Type C is 100% Bangladeshi resident owned. Certain zone service providers are treated as zone industrial enterprises for FX purposes.	Is this requirement evidenced, reported and retained according to FE Circular 31?
32-33	Declaration and proceeds	Exports from specialized zones require EXP declaration and repatriation. Export proceeds of zone enterprises are released to their foreign currency accounts under Part-K.	Is this requirement evidenced, reported and retained according to FE Circular 31?
34	NFCD use for discounting	NFCD balances may be used for discounting usance bills drawn by Type A/B zone enterprises for raw material supply under BTB arrangement and accepted by ADs outside zones, including sight BTB payments, up to 50% of total NFCD balance of the AD.	Is this requirement evidenced, reported and retained according to FE Circular 31?
35	Bangladeshi sale to zones	Sale of Bangladeshi goods/raw materials to zone enterprises against FX is treated as export from Bangladesh. Reporting refers to EXP numbers; DPA EZ to TA Taka transactions are exempt from EXP/IMP formalities under NBR order.	Is this requirement evidenced, reported and retained according to FE Circular 31?

Part-C: Export Trade Safeguards

Para	Topic	Circular-based learning point	AD control question
36	Cross-border banking and AML/CFT	ADs maintaining correspondent/nostro relationships must comply with AML/CFT, Core Risk Management, BFIU circulars, no shell bank relationship, and TBML prevention guidance.	Is this requirement evidenced, reported and retained according to FE Circular 31?
37	Transaction safeguards	LCs should be routed through authenticated channels from banks with proper relationships. ADs must verify authenticity, bonafide of issuing/applicant/transferring banks, first beneficiary in transferred LCs, overseas importers and importer banks under sales contracts.	Is this requirement evidenced, reported and retained according to FE Circular 31?
38	Guidance when concerns arise	If execution is problematic or doubtful, ADs should guide exporters to change importer bank, bring transaction under external payment guarantee, or arrange other suitable safeguards.	Is this requirement evidenced, reported and retained according to FE Circular 31?

Part-D: Export under Open Account Credit Terms

Para	Topic	Circular-based learning point	AD control question
39	Open account permitted with risk coverage	ADs may allow exports on open account credit terms within statutory period if backed by payment undertaking/risk coverage from international factoring companies, foreign banks/FIs, trade financiers or insurance entities.	Is this requirement evidenced, reported and retained according to FE Circular 31?
40-41	Financing cost and competitive pricing	Guarantee commission and early payment interest/charges must not exceed benchmark +4% all-in-cost annually, excluding normal bank charges. Export price declared in EXP must be competitive considering the credit period.	Is this requirement evidenced, reported and retained according to FE Circular 31?
42-48	Counterparty, documents and compliance	Designated institutions should be reputable/licensed with acceptable rating. Documents must be sent within 14 days from shipment; early payment is non-recourse; proceeds may be assigned; AD must verify export bonafide, KYC/AML and taxes.	Is this requirement evidenced, reported and retained according to FE Circular 31?

Part-E: Export of Services including ITES

Para	Topic	Circular-based learning point	AD control question
49	Software/data processing export	Physical export of software/data services follows EXP procedure. Non-physical export through internet/electronic media does not require EXP and follows service export and proceeds realization rules.	Is this requirement evidenced, reported and retained according to FE Circular 31?
50	BPO and individual service export	AD may credit BPO/service export receipts after ERQ retention and local currency conversion; Form-C required above USD 20,000, with Form-C ICT for ICT services. Electronic Form-C print/signature is required within 30 days unless secured app process applies.	Is this requirement evidenced, reported and retained according to FE Circular 31?
51-53	Business services and retention abroad	Professional/research/advisory and other non-agency service receipts may be credited to local and ERQ accounts. Four-month repatriation applies to service export. Unauthorized retention abroad, including virtual assets/crypto and overseas accounts outside permitted merchant/notional accounts, breaches FER Act provisions.	Is this requirement evidenced, reported and retained according to FE Circular 31?

Part-F: Export Proceed Realization Services

Para	Topic	Circular-based learning point	AD control question
54-55	Acquiring service and e-commerce	ADs may act as acquiring banks for internet/web generated payments by international card for registered IT/software exporters and e-commerce export proceeds under merchant agreements, due diligence, Form-C where applicable, ERQ/local credit and reporting.	Is this requirement evidenced, reported and retained according to FE Circular 31?
56	OPGSP route	Small-value non-physical service exports up to USD 10,000 per transaction may be repatriated through internationally recognized OPGSPs with AD standing arrangement, separate nostro collection account, auto-sweep from notional accounts, permitted debits only, quarterly reconciliation and reporting.	Is this requirement evidenced, reported and retained according to FE Circular 31?
57-59	Freelancer card, PSP/MFSP routes	Eligible app/game freelancers may receive through dual-currency Freelancer Card; receipts over USD 20,000 require Form-C ICT. ADs may support market place/platform, eligible payment operator, digital wallet, MFSP/PSP channels subject to declaration, undertaking, tax, KYC/AML and reporting.	Is this requirement evidenced, reported and retained according to FE Circular 31?
60	Retention and outward remittance	Service exporters may retain eligible FC in ERQ and use it for permissible business expenses. ADs must follow limits, taxes, reporting and subsequent adjustment requirements.	Is this requirement evidenced, reported and retained according to FE Circular 31?

Part-G: Export through E-Commerce

Para	Topic	Circular-based learning point	AD control question
61-62	B2C advance and electronic declaration	Business-to-consumer export through sales orders against advance receipt is allowed using e-commerce platform information and electronic declaration process.	Is this requirement evidenced, reported and retained according to FE Circular 31?
63-64	COD/payment on shipment and small value	B2C export through COD/payment-on-shipment has specific declaration and realization controls. Small value e-commerce export without EXP is allowed within prescribed threshold and process.	Is this requirement evidenced, reported and retained according to FE Circular 31?

Part-H: Re-export, Entre-pot and Merchanting Trade

Para	Topic	Circular-based learning point	AD control question
65	Re-export and entre-pot	Re-export/entre-pot transactions require compliance with import/export legs, documentation, price competitiveness and BB reporting instructions.	Is this requirement evidenced, reported and retained according to FE Circular 31?
66	Merchanting trade	Merchanting trade may involve procurement from one country and sale to another without goods entering Bangladesh. AD must not pay import leg from own sources; import payment is met from export-leg receipts or permitted short-term buyer's credit without AD payment undertaking. Reporting is on gross basis as merchanting services.	Is this requirement evidenced, reported and retained according to FE Circular 31?
67	Counter-trade arrangement	Bangladeshi parties may use escrow accounts in approved currency/Taka for settlement of import payments against export proceeds. No interest/profit on escrow balances; EXP/IMP formalities and counter-trade marking apply; ACU transactions are excluded.	Is this requirement evidenced, reported and retained according to FE Circular 31?

Part-I: Currency, FX, Gold, Jewellery and Securities

Para	Topic	Circular-based learning point	AD control question
68-71	FX, local currency and securities	Persons may take out foreign exchange issued by AD and endorsed on passport. Residents may take out up to USD 10,000 equivalent brought in without declaration. Currency notes/coins cannot be sent by post/courier. Local currency carrying limit is Tk 10,000. Export of securities requires BB permission.	Is this requirement evidenced, reported and retained according to FE Circular 31?
72-75	Jewellery export	Jewellery includes articles made wholly/mainly of gold, platinum, diamonds, stones or pearls. Registered exporters may export gold/silver jewellery under EXP; BTB input import allowed with value addition of 10% gold, 15% stone-studded gold and 25% silver. If inputs are prepaid abroad, repatriate only local value addition; consignment export requires prior BB permission.	Is this requirement evidenced, reported and retained according to FE Circular 31?

Part-J: Exporters' Retention Quota (ERQ) Account

Para	Topic	Circular-based learning point	AD control question
76	Retention quota limits	High domestic value-added merchandise: 30% of repatriated FOB value. High import content goods: 7.5%. ICT/software/data processing: 35% of net export earnings. Other service exporters: 30%. Agents/trade facilitators: 10% of eligible commission receipts.	Is this requirement evidenced, reported and retained according to FE Circular 31?
77	Eligible currency and utilization	ERQ may be held in USD, GBP, EUR, JPY or CNY. Uses include business travel, fairs/seminars, overseas offices, raw materials/machinery/spares, authorized foreign loan repayment, IT/software fees, approved overseas equity investment, import liability and authorized foreign loan settlement for exporter/sister concerns subject to controls.	Is this requirement evidenced, reported and retained according to FE Circular 31?
77(3)-(5)	ERQ term deposit and remittance	ERQ may be placed in renewable term deposit with minimum USD 2,000 equivalent. Advance import payment from ERQ up to USD 25,000 requires PI/contract, no obtainable repayment guarantee, IPO compliance, repatriation responsibility, BTB value adjustment and undertaking. Without ERQ balance, service remittance up to USD 5,000 may be allowed with subsequent adjustment.	Is this requirement evidenced, reported and retained according to FE Circular 31?
78	International card	International cards may be issued to exporters against ERQ and ARQ balances as per GFET chapter 19 and subsequent circulars.	Is this requirement evidenced, reported and retained according to FE Circular 31?

Part-K: FC Accounts for Enterprises in Specialized Zones

Para	Topic	Circular-based learning point	AD control question
79(1)-(2)	Type A proceeds	Type A zone enterprises may retain 100% repatriated export proceeds in FC accounts with ADs/OBUs. FC balances may meet foreign obligations, import payments and zone authority payments; encashment allowed for local expenses. Taka accounts cannot be converted back to FX and are for local expenses only. FC balances may be used for share purchase subject to chapter 9 compliance.	Is this requirement evidenced, reported and retained according to FE Circular 31?
79(3)-(5)	Type B/C proceeds	Type B/C non-garments enterprises may retain up to 80% of repatriated export proceeds; Type B/C garments enterprises up to 75%; remainder encashed to Taka. Foreign obligations including import and foreign loan repayment may be met from FC accounts. Equity/authorized loans may be credited and cards may be used for business travel.	Is this requirement evidenced, reported and retained according to FE Circular 31?

Appendices

Appendix	Purpose
Appendix-1	EXP Form
Appendix-2	Export Register
Appendix-3	Certificate of AD for carrier company
Appendix-4	Information relating to export orders with foreign agent commission
Appendix-5	Application for approving remittance of discount on RMG and leather goods
Appendix-6	Advance receipt voucher
Appendix-7	PRC Direct Export
Appendix-8	PRC Deemed Export
Appendix-9	Certificate of AD for carrier company under open account
Appendix-10	Form-C
Appendix-11	Form-C (ICT)
Appendix-12	Certificate by AD against IT related services
Appendix-13	Form TM
Appendix-14	Form of Undertaking

AD Bank Checklist

Control area	Actionable check
Exporter eligibility	Check exporter registration under Importers, Exporters and Indentors (Registration) Order, 2023.
EXP requirement	Confirm whether export is exempt; otherwise ensure EXP/e-EXP before customs formalities.
Realization tracker	Track general four-month realization period and special raw jute/jute goods period up to 360 days.
Buyer/counterparty risk	Verify bonafide and standing of buyer/consignee/importer bank, especially CAD/DA, contract-only and transferred LC cases.
Transport document control	Ensure title documents are drawn/endorsed as circular permits and original title documents remain under AD control unless allowed.
14-day document timeline	Obtain EXP, Bill of Export and shipping documents within 14 days from shipment; complete reporting where exporter fails.
OEMS reporting	Report export transactions regularly and upload overdue EXP data by 10th day monthly with reason/action/litigation status.
Deductible charges	Commission/brokerage within 5% unless BB approval; verify stipulated bank/trade charges and special discount rules.
Advance export receipt	Use ARV, online ARV reporting, confirmed LC/contract, no interest, 10% retention, one-year execution and refund controls.
PRC control	Issue direct/deemed export PRC through OEMS using Appendix-7/8 and maintain authorized signatory list with Bond/DEDO.
Export financing	For bill discounting/open account early payment, verify bonafide export, non-recourse arrangement where applicable and benchmark +4% all-in-cost ceiling.
Specialized zones	Identify Type A/B/C; apply EXP, zone proceeds release, NFCD and local sales to zones reporting rules.
Service export	Determine physical vs non-physical export; use Form-C/Form-C ICT threshold, ERQ/local credit, tax and reporting controls.
OPGSP/PSP/MFSP	Confirm arrangement, nostro/settlement account, notional/merchant account, value limits, auto sweep, quarterly reconciliation, KYC/AML and reporting.
E-commerce	Check B2C sales order, advance/COD/payment-on-shipment route, electronic declaration and small-value no-EXP eligibility.
Merchanting/counter-trade	Ensure import-leg not funded from AD own sources, escrow/counter-trade marking, gross reporting and ACU exclusion.
ERQ	Apply correct retention percentage, eligible currency, utilization, transfer, term deposit, advance import and service remittance controls.
Currency/jewellery	Check passport endorsement/carrying limit, no post/courier of currency notes, Tk 10,000 local currency limit, securities permit and jewellery value addition/consignment approval.

Control conclusion: ADs should maintain end-to-end evidence from exporter onboarding, EXP/OEMS, document receipt, title document handling, proceeds realization, ERQ, PRC, service-export route, specialized zone treatment and overdue monitoring.

Quiz: FE Circular 31 Export Trade Transactions

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