Other service exports, deadlines and money kept abroad
Advice, research and other business services sold from Bangladesh follow the same money path as software and freelance work. Service earnings must come home like goods earnings, and keeping them abroad outside the accounts the circular allows, even in crypto, breaks the law.
In Lesson 23, Software and freelance exports by internet, Eliana helped two customers. Nabila's software firm in Dhaka sent code to foreign clients by internet, and Enzo, a young freelance designer in Mirpur, got paid for logos by inward remittance.
This week, both are back at Eliana's desk with new questions. Nabila's firm has started giving advice to a foreign client: how to plan its IT systems. "No software leaves Dhaka, only ideas," she says. "Does that still count as an export?"
Enzo's question is cheekier. "A friend says I should leave my dollars in an online wallet abroad, or turn them into crypto. Easier than queueing at the bank, no?"
Eliana knows the payment rules from Lesson 23. But the second question touches the law itself. So she invites Shabnam, a Supreme Court advocate in banking and commercial law, to her branch's Friday learning session. Shabnam laughs at Enzo's question. "Easier, yes. Legal, no. Let's walk through it, paragraph by paragraph," she says.
Software and outsourced data work are not the only services Bangladesh sells abroad. H-3 names other service exports, for example:
business services;
professional, research and advisory services;
and others ("etc."), so the list is open.
Two points describe these exports: the service is rendered from Bangladesh, and the foreign exchange payment is received through ADs.
Where can the money go? Remittances from abroad paid against these services, and against all other non-agency service exports in non-physical form, may also be credited to:
local currency accounts, and
ERQ accounts,
in the names of the exporters concerned.
The condition: the bank must observe "the same instructions as stated above". Those are the H-2 conditions you met in Lesson 23. In short: check the documents (such as e-mails) and the remittance message; make sure the exporter can really provide the service; take the online Form-C (with the USD 20,000 limit for crediting without Form-C, and the 30-day rule for getting the printout signed); deduct applicable taxes; do due diligence and follow AML/CFT rules; and keep records and report to Bangladesh Bank.
One small gap: the circular doesn't define "non-agency" in this paragraph. So stick to its words: the service is non-agency and delivered in non-physical form. Note: Part L of the same circular (L-6, Lesson 33) says Form-C and Form-C (ICT) stand discontinued, and that until banks' secure digital interfaces are ready, the purpose and supporting information are collected through banks' existing digital channels. The original circular is always the final word.
At the desk
Nabila's firm receives USD 8,000 from a foreign client for an IT advisory report sent by e-mail. Eliana checks the client's e-mails and the remittance message, and confirms the firm really does this kind of advisory work. Then she credits part of the money to the firm's ERQ account and the rest to its Taka account, following the same H-2 steps she used for Enzo's logo fees in Lesson 23.
Key words
Business services
Services that one business provides to help another business run, such as administrative, marketing or office support work.
Non-physical form
Delivered through the internet or other electronic media, not on a disk, drive or other physical object.
ERQ
Exporters' Retention Quota: the share of export earnings an exporter may keep in foreign currency, in an ERQ account.
Read the rule as written (Para H-3)
There are other service exports such as business services, professional/research and advisory services, etc. rendered from Bangladesh against which payments in foreign exchange are received through ADs. Remittances from abroad as payments against these and all other non-agency service exports in non-physical form may also be credited to local currency accounts and ERQ accounts in the names of the concerned exporters, subject to observance of the same instructions as stated above.
Source: Bangladesh Bank, FEPD-1 Circular No. 26, 30 July 2026, Part H, paragraph 3 (page 33). The original circular is the authority.
H-4 is short, but it closes a door some people hope is open: "Services are invisible, so maybe the money can stay away longer?" No.
Part-A paragraph 8(1) of this circular has the instructions for repatriating export proceeds against goods. H-4 says those same instructions are equally applicable to export proceeds against services.
Which services? Services as defined at Section 2(bbb) of the FER Act, 1947.
What this means in practice:
A service exporter has the same duty to bring the money home as a goods exporter.
Whatever Part-A 8(1) says for goods, including its time limit, applies to service earnings too.
H-4 itself does not repeat the time limit, and it does not quote the legal definition of services. The time limit sits in Part-A 8(1), and the definition sits in Section 2(bbb) of the FER Act, 1947. So when a service exporter asks "How long do I have?", the honest answer is: "The same as a T-shirt exporter, under Part-A 8(1)." Simple, and fair to both.
At the desk
Nabila asks Eliana whether her firm can let a foreign client pay "whenever it is convenient", since no goods were shipped. Eliana explains that H-4 applies the Part-A 8(1) repatriation instructions for goods equally to services. The firm must bring the money home on the same terms as a goods exporter, so the contract should not leave payment open-ended.
Key words
Repatriation
Bringing export money back into Bangladesh through a bank.
FER Act 1947
Foreign Exchange Regulation Act. The main law behind Bangladesh Bank's foreign exchange rules.
Section 2(bbb)
The clause of the FER Act, 1947 that defines services. H-4 uses that definition.
Read the rule as written (Para H-4)
The instructions to repatriate export proceeds against goods as noted at 8(1), Part-A of this circular are equally applicable to repatriation of export proceeds against services as defined at Section 2(bbb) of the FER Act, 1947.
Source: Bangladesh Bank, FEPD-1 Circular No. 26, 30 July 2026, Part H, paragraph 4 (page 33). The original circular is the authority.
H-5 answers two questions: which accounts may a service exporter use to collect money, and what is not allowed?
The allowed route. Part-I of this circular sets out how services delivered in non-physical form, in ICT and other businesses, work in practice. Under paragraphs 3 and 5 of Part-I, service exporters can maintain notional/merchant accounts to repatriate their income through their ADs in Bangladesh. H-5 does not describe these accounts; the details are in Part-I. Note their purpose: they are a channel for bringing money home.
Everything else is not allowed. Apart from these authorised accounts, retention of export proceeds abroad in any form is a breach. The circular gives examples, and says it is not limited to them:
equity or portfolio investment;
buying physical assets or virtual assets;
keeping accounts in any currency, including cryptocurrencies.
The legal result. Keeping proceeds abroad like this:
constitutes a contravention of Section 5(1)(e)(i) of the FER Act, 1947; and
is subject to cognizance under Section 23(1) of the same Act, as per SRO No. 59-LAW/2021 dated March 08, 2021.
In plain words: it breaks the law, and the matter can be formally taken up for action under Section 23(1). H-5 does not say what that action would be. The lesson for every service exporter is simple: earn abroad, bring it home.
At the desk
Enzo tells Eliana he has USD 3,000 from three logo jobs sitting in an online wallet abroad, and asks if he can turn it into cryptocurrency "for later". Eliana explains that, apart from the notional/merchant accounts allowed under Part-I, keeping export proceeds abroad in any form, crypto included, breaches Section 5(1)(e)(i) of the FER Act, 1947. Shabnam adds, "And H-5 says such a breach is subject to cognizance under Section 23(1) of the same Act, as per SRO No. 59-LAW/2021. The only safe road is home." Enzo decides to bring the money home through the bank that afternoon.
Key words
Notional/merchant account
An account that Part-I (paragraphs 3 and 5) lets a service exporter keep, to bring income home through an AD in Bangladesh.
Retention abroad
Keeping export money outside Bangladesh, in any form, instead of bringing it home.
Cryptocurrency
A form of digital money that exists only in electronic form.
Cognizance
When a court or authority formally takes notice of a matter, so that action can begin under a law.
Read the rule as written (Para H-5)
Part-I of this circular outlines operational modalities on services delivered in non-physical form relating to ICT and other businesses. Service exporters can maintain notional/ merchant accounts to repatriate their income through concerned ADs in Bangladesh as per paragraphs 3 and 5, Part-I of this circular. Excepting these authorized accounts, retention of export proceeds abroad in any form without limiting to equity/portfolio investment, purchase of physical assets/virtual assets, maintenance of accounts regardless of currencies including cryptocurrencies constitutes contravention of Section 5(1)(e)(i) of the FER Act, 1947 and is subject to cognizance under Section 23(1) of the said Act as per SRO No. 59-LAW/2021 dated March 08, 2021.
Source: Bangladesh Bank, FEPD-1 Circular No. 26, 30 July 2026, Part H, paragraph 5 (page 33). The original circular is the authority.
So far: Advice, research, professional and other business services sold from Bangladesh follow the same money path as software and freelance work: the earnings may go to Taka and ERQ accounts under the same H-2 instructions. Under H-4, service earnings must come home under the same Part-A 8(1) instructions as goods. Under H-5, only the notional/merchant accounts allowed by Part-I may be used, and keeping export proceeds abroad in any other form, crypto included, breaks Section 5(1)(e)(i) of the FER Act, 1947.
Next: Part H of the export room is complete. Part I, on export proceed realisation services, starts in Lesson 25, Acquiring banks: card payments and e-commerce sales.
Check yourself
30 questions, in 3 sets of up to 10. Nobody sees your answers but you.
Set 1 of 3
H-3 names business services and professional/research and advisory services as other service exports. (H-3)
H-3 speaks of services rendered from Bangladesh against which payments in foreign exchange are received through ADs. (H-3)
H-3 lets these remittances be credited to local currency accounts and ERQ accounts in the names of the exporters. (H-3)
H-3 extends the rule to all other non-agency service exports in non-physical form. (H-3)
H-3 says the crediting is subject to the same instructions as stated above, that is, the H-2 conditions. (H-3)
False. H-3 uses the words "non-agency service exports" but does not define them in this paragraph. (H-3)
True. H-3 names professional, research and advisory services rendered from Bangladesh and paid through ADs as service exports. (H-3)
H-3 applies the same instructions as stated above (the H-2 checks) to remittances for advisory and other service exports. (H-3)
H-3 applies the H-2 instructions, which let remittances up to USD 20,000 be credited without Form-C once the bank is satisfied the deal is genuine. (H-3)
H-3 applies the H-2 instructions, which require the Form-C printout to be signed within 30 days unless it came through a secured designated app. (H-3)
Set 2 of 3
H-4 points to the instructions noted at 8(1), Part-A of the circular. (H-4)
H-4 applies to export proceeds against services as defined at Section 2(bbb) of the FER Act, 1947. (H-4)
H-4 says the goods instructions are equally applicable to repatriation of proceeds against services. (H-4)
False. H-4 does not repeat the time limit; it applies the Part-A 8(1) instructions for goods to services. (H-4)
True. H-4 makes the Part-A 8(1) repatriation instructions for goods equally applicable to services. (H-4)
H-4 applies the Part-A 8(1) repatriation instructions for goods equally to service export proceeds. (H-4)
H-4 applies the goods repatriation instructions in Part-A 8(1) to services; the 30 days in H-2 is for signing the Form-C printout. (H-4)
H-5 says Part-I outlines operational modalities on services delivered in non-physical form relating to ICT and other businesses. (H-5)
H-5 allows notional/merchant accounts as per paragraphs 3 and 5, Part-I, to repatriate income through ADs in Bangladesh. (H-5)
H-5 says service exporters can maintain these accounts to repatriate their income through concerned ADs in Bangladesh. (H-5)
Set 3 of 3
H-5 lists equity/portfolio investment, physical or virtual assets and accounts in any currency, including crypto, as forms of retention abroad. (H-5)
H-5 says such retention constitutes contravention of Section 5(1)(e)(i) of the FER Act, 1947. (H-5)
H-5 says retention abroad is subject to cognizance under Section 23(1) of the FER Act, as per SRO No. 59-LAW/2021. (H-5)
H-5 cites SRO No. 59-LAW/2021 dated March 08, 2021. (H-5)
True. H-5 includes maintenance of accounts regardless of currencies, including cryptocurrencies. (H-5)
H-5 says retention of export proceeds abroad in any form, including crypto accounts, contravenes Section 5(1)(e)(i) of the FER Act, 1947. (H-5)
H-5 lists equity/portfolio investment as a form of retaining export proceeds abroad, which contravenes Section 5(1)(e)(i). (H-5)
H-5 lists purchase of physical assets among forms of retention of export proceeds abroad, which contravenes the FER Act. (H-5)
H-5 lets service exporters maintain notional/merchant accounts under Part-I paras 3 and 5 to repatriate income through ADs. (H-5)
H-5 says retention abroad in any form, without limiting to the listed examples, is a contravention. (H-5)
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