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Lesson 26 of 42 · Part I · Level 2 · Explained

Online payment gateways and cards for service income

Small service exports can come home through an online payment gateway, as long as nothing stays parked abroad and each payment is within USD 10,000. App and game developers can also get a two-currency Freelancer Card. How the money flows, who pays the fees and what the bank must check.

In Lesson 25, Acquiring banks: card payments and e-commerce sales, we saw how a bank can act as an acquiring bank, so that IT firms and online sellers can take card payments from customers abroad. That works well for a firm with a website and a merchant agreement. But what about a young freelancer who gets USD 300 for a logo through an online payment gateway?

That is exactly Enzo's question. The freelance designer from Mirpur arrives at Eliana's export desk holding his phone. "My client says he paid me through a gateway. The app shows the money, then it vanishes, then it shows up in my bank days later. Where does it go in between? And who keeps taking these little fees?"

Right behind him is Nabila, whose software firm does small off-shore IT jobs for clients abroad. She has a different worry: "Some of my developers build mobile games at home. They keep asking me about a 'Freelancer Card'. Is that a real thing?"

Eliana has invited Mithu to her branch's learning session that afternoon. Mithu is a chartered accountant and a former CFO of a large export group, and she has followed money through more ledgers than most people have read novels. "Money never really vanishes," Mithu says. "It just sits in an account you can't see. Let's find that account." This lesson covers payments through online payment gateways (I-3) and the Freelancer Card (I-4).

Para I-3

Repatriation of export proceeds through OPGSPs

In plain words

I-3 lets ADs help bring home payments for small value service exports in non-physical form, such as data entry/data processing, off-shore IT service and business process outsourcing ("etc.", so the list is open), through OPGSPs (online payment gateway service providers).

(a) The accounts. The AD makes standing arrangements with internationally recognised OPGSPs, and keeps a separate nostro collection account for each OPGSP. The exporter opens a notional account with an OPGSP, but only with an OPGSP that has an arrangement with an AD in Bangladesh. No funds may stay in the notional account: every receipt is automatically swept and pooled into the AD's nostro collection account. A notional account is never a resident's bank account for keeping foreign exchange income; OPGSPs must strictly observe this.

(b) The limit. Only for non-physical service exports of up to USD 10,000 per transaction.

(c) Only three debits are allowed from the nostro collection account:

  1. sending the export proceeds to Bangladesh to pay the service exporters;
  2. the OPGSP's fee/commission, at the predetermined rates/frequency/arrangement;
  3. a charge back to the foreign client where the exporter failed to deliver the service as specified.

(d) Bringing it home. Once the AD confirms the proceeds have been swept from the exporter's notional account into the nostro collection account, it repatriates the balance and credits the exporter's account with a bank in Bangladesh.

(e) Crediting. The AD checks the relevant documents to be satisfied the deal is bona fide. It may credit the ERQ account up to the permissible limit "at their options". The circular doesn't say clearly whose option this is; read with the next words ("at exporter's option"), it most likely means the exporter chooses. The remainder, or the full amount if the exporter chooses, must go to a local currency account after conversion. The AD deducts and pays any applicable taxes.

(f) Reporting. Online reporting and monthly schedules/statements to Bangladesh Bank, with the right purpose codes, plus any documents Bangladesh Bank asks for later.

(g) Each nostro collection account is reconciled and audited quarterly.

(h) Payment complaints of exporters in Bangladesh are the OPGSP's responsibility.

(i) ADs report each OPGSP arrangement to the Foreign Exchange Policy Department-1, Bangladesh Bank, Head Office.

(j) ADs apply due diligence and follow foreign exchange, AML/CFT and other laws.

I-3 doesn't define "internationally recognised", or state the ERQ share or a tax rate.

At the desk

A client in Canada pays Enzo USD 450 for a logo through an online payment gateway. The money is automatically swept from Enzo's notional account into the nostro collection account Eliana's bank keeps for that gateway, and the gateway's fee comes out there at its agreed rate. Once Eliana confirms the sweep, her bank brings the balance home, credits the ERQ share Enzo wants to his ERQ account and the rest in Taka, after deducting any applicable tax. Mithu points at the statement: "That fee line is your cost of selling abroad. Track it every month, like rent."

Key words
OPGSP
Online Payment Gateway Service Provider, for example a platform that pays freelancers.
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.
Nostro collection account
A separate nostro account that an AD keeps for each OPGSP. Under I-3, receipts in exporters' notional accounts are swept and pooled into it before they come home.
Charge back
Under I-3, money paid back to the foreign client (the service recipient) when the service exporter failed to deliver the service as specified.
Read the rule as written (Para I-3)

ADs are permitted to facilitate the repatriation of remittances against small value service exports in non-physical form such as data entry/data process, off-shore IT service, business process outsourcing, etc. through OPGSPs, subject to compliance with the following instructions:

(a) ADs shall enter into standing arrangements with internationally recognized OPGSPs and maintain separate nostro collection account for each OPGSP to repatriate the above-mentioned service export related payments. Service exporters availing of this facility shall open notional accounts with only those OPGSPs having arrangements with ADs in Bangladesh. It shall be ensured that no funds are retained in such accounts and all receipts shall be automatically swept and pooled into the nostro collection account maintained by the ADs. In no way, income in foreign exchange by residents can be retained in notional accounts like resident bank accounts. OPGSPs shall observe it with strict compliance.

(b) This facility shall only be available for service export in non-physical form of value not exceeding USD 10,000 per transaction.

(c) The following debits will only be permitted to the nostro collection account opened and maintained under this arrangement:

(1) Repatriation of funds representing service export (as mentioned in the opening paragraph) proceeds to Bangladesh for payment to service exporters;

(2) Payment of fee/commission to OPGSP as per the predetermined rates/frequency/ arrangement; and

(3) Charge back to the service recipient/importer where the service exporter has failed in discharging the obligations as per specifications.

(d) ADs shall repatriate the balances held in the nostro collection account and arrange to credit the respective exporter's account with a bank in Bangladesh on being confirmed that the export proceeds have been swept and pooled into the nostro collection account from the exporter's notional account.

(e) ADs shall satisfy themselves as to the bonafide of the transactions on examination of relevant documents and credit the amount in ERQ account of exporters up to the permissible limit at their options. The remainder (or up to full, at exporter's option) shall mandatorily be credited in local currency accounts after conversion. ADs shall also ensure deduction of applicable taxes, if any and payment thereof.

(f) Besides online reporting and monthly reporting in schedules/statements of the transactions to Bangladesh Bank with appropriate purpose codes, ADs shall submit all the relevant information/documents relating to any transaction under this arrangement to Bangladesh Bank, as and when advised to do so.

(g) Each nostro collection account shall be subject to reconciliation and audit on a quarterly basis as per regulatory requirements.

(h) Resolution of all payment related complaints of exporters/service providers in Bangladesh shall remain the responsibility of OPGSPs concerned.

(i) ADs entering into arrangements with any OPGSPs shall report to the Foreign Exchange Policy Department-1, Bangladesh Bank, Head Office with necessary details. The arrangements are subject to strict compliance by OPGSPs with the instructions contained in this circular.

(j) As usual, ADs shall exercise due diligence in respect of the transactions with OPGSPs and comply with the foreign exchange regulations, AML/CFT regulations and any other relevant laws/regulations in force.

Source: Bangladesh Bank, FEPD-1 Circular No. 26, 30 July 2026, Part I, paragraph 3 (page 34). The original circular is the authority.

Para I-4

Repatriation of ICT related service income through international card

In plain words

I-4 is a special help for one group: individual developers/freelancers of mobile apps and games. ADs may credit payments these people receive from abroad into international card numbers/accounts, for their services.

Who qualifies? The developer must have an acknowledgement, training, boot-camp, hackathon or course participation certificate on mobile application development, arranged by a government authority, BASIS or its member organisation, or any other recognised training/academic institute.

The card. ADs issue these developers an international card called the 'Freelancer Card'. It has two currency units (a foreign currency unit and a local currency unit) and is prepaid from abroad: it is filled by payments coming in from abroad. The rules:

(a) Splitting a payment. When money arrives, the developer may choose to keep up to the eligible ERQ portion in the foreign currency unit. The rest must go to the local currency unit, converted at the prevailing exchange rate.

(b) Using the dollars. The ERQ balance in the foreign currency unit may be used, through the usual banking channel, for international current account transactions: bona fide business expenses, including legitimate personal expenses. The card may also be used for permissible online transactions from Bangladesh. Any outward remittance from the foreign currency balance is subject to paying any taxes due first.

(c) Big receipts. An inward receipt of more than USD 20,000 or equivalent needs a declaration on Form-C (ICT), the form you met in Lesson 23.

(d) Reporting. ADs report these transactions to Bangladesh Bank in the relevant statement/schedule and the online reporting system, using the code for ICT/computer services.

I-4 doesn't state the ERQ percentage; it only says "eligible ERQ portion". 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

Enzo has finished a mobile application development boot camp run by a BASIS member organisation, and now builds small mobile games too. His bank issues him a Freelancer Card, and a games studio abroad pays USD 600 into it. Enzo keeps the eligible ERQ portion in the card's dollar unit to pay for a design software subscription abroad, and the rest is converted into the Taka unit at the prevailing rate. Mithu nods: "Two pockets on one card. Dollars for dollar bills, Taka for Dhaka bills. Your cash flow just got tidier."

Key words
Freelancer Card
An international card that ADs issue under I-4 to individual developers/freelancers of mobile apps and games. It has two currency units and is prepaid from abroad.
ERQ
Exporters' Retention Quota: the share of export earnings an exporter may keep in foreign currency, in an ERQ account.
Form-C
The declaration form (Appendix-11) that the beneficiary of an inward remittance fills in online; for ICT-related services, a separate Form-C (ICT) (Appendix-12) is used.
Read the rule as written (Para I-4)

ADs may provide facilities to credit inward remittances received in international card numbers/accounts against the services provided by individual developers/freelancers of mobile apps and games having acknowledgements/training/boot-camps/hackathons/course participation certificates on mobile application development arranged by government authority/BASIS, or its member organization and any other recognized training/academic institutes. In this context, ADs shall issue to individual developers/freelancers international cards (termed as 'Freelancer Card') having dual currency units with features of being prepaid from abroad and observe the following instructions:

(a) On receipts of the payment, up to eligible ERQ portion may be credited at the options of beneficiaries in foreign currency unit of the card, the remainder mandatorily in local currency unit after conversion at prevailing exchange rate.

(b) The balance held in foreign currency unit of the card as ERQ is usable for payment, through usual banking channel, on international current account transactions for bonafide business expenses including legitimate expenses for personal purposes. The cards may be used for permissible online transactions from Bangladesh. Outward remittances from foreign currency balance are subject to fulfillment of taxes payment obligations, if any.

(c) Inward receipt exceeding USD 20,000 (Twenty thousand) or equivalent is subject to declaration on Form-C (ICT).

(d) ADs shall report the transactions to Bangladesh Bank in relevant statement/schedule and online reporting system mentioning appropriate code relevant to ICT/computer services.

Source: Bangladesh Bank, FEPD-1 Circular No. 26, 30 July 2026, Part I, paragraph 4 (page 35). The original circular is the authority.

Putting it together

So far: Under I-3, small non-physical service exports of up to USD 10,000 per transaction can come home through internationally recognised online payment gateways. Nothing may stay in the exporter's notional account: it is swept into the AD's separate nostro collection account, which allows only three debits, is audited quarterly, and is reported to Bangladesh Bank. Under I-4, mobile app and game developers with recognised training certificates can get a two-currency Freelancer Card, keep the eligible ERQ portion in dollars, take the rest in Taka, and declare receipts above USD 20,000 on Form-C (ICT).

Next: Lesson 27, Payment service providers, mobile wallets and the ERQ choice.

Check yourself

30 questions, in 3 sets of up to 10. Nobody sees your answers but you.

Set 1 of 3

1. Which kind of exports may ADs help repatriate through OPGSPs under I-3?
2. What is the most a single transaction may be worth under the OPGSP facility in I-3?
3. Under I-3(a), what account must an AD keep for its OPGSP arrangements?
4. With which OPGSPs may service exporters open notional accounts under I-3?
5. Which of these is NOT a permitted debit to the nostro collection account under I-3(c)?
6. How often must each nostro collection account be reconciled and audited under I-3(g)?
7. Under I-3(j), what must ADs do in their transactions with OPGSPs?
8. To whom must an AD report an arrangement it enters into with an OPGSP?
9. Under I-3(d), when does the AD credit the exporter's account in Bangladesh?
10. Under I-3(e), where must the amount not credited to the ERQ account go?

Set 2 of 3

11. True or false: under I-3, a service exporter may leave earnings in a notional account with an OPGSP for a few months, like a savings account.
12. True or false: under I-3, ADs must ensure deduction of applicable taxes, if any, and payment of them.
13. True or false: under I-3(e), a service exporter may choose to have the full amount credited in local currency instead of keeping part in ERQ.
14. A client in Canada pays Enzo USD 450 through an online payment gateway, and Eliana confirms it has been swept into her bank's nostro collection account. What happens next?
15. Nabila's firm expects one payment of USD 14,000 for an off-shore IT job and wants it to come through its online payment gateway under I-3. What does Eliana say?
16. Enzo wants to open a notional account with a gateway abroad that has no arrangement with any AD in Bangladesh, because its fees are lower. What should Eliana tell him?
17. A foreign client paid Nabila's firm through a gateway, but the firm failed to deliver the data processing work as specified. The client wants a refund. Which I-3 debit fits?
18. Enzo complains that a gateway payment shown as 'sent' has not reached him after a week. Under I-3, whose responsibility is resolving this payment complaint?
19. Eliana's bank has just signed a standing arrangement with a new internationally recognised OPGSP. Which extra step does I-3 require of the bank?
20. Months after reporting a gateway transaction with its purpose code, Eliana's bank gets a request from Bangladesh Bank for the papers on that payment. What does I-3(f) say?

Set 3 of 3

21. Under I-4, who may receive the 'Freelancer Card'?
22. Which features does the Freelancer Card have under I-4?
23. Above what amount does an inward receipt on the Freelancer Card need a declaration on Form-C (ICT)?
24. Under I-4(a), how is the part of a receipt above the eligible ERQ portion credited?
25. Under I-4(b), what may the ERQ balance in the card's foreign currency unit be used for?
26. True or false: under I-4, the Freelancer Card may be used for permissible online transactions from Bangladesh.
27. True or false: under I-4, an inward receipt of USD 15,000 on a Freelancer Card must be declared on Form-C (ICT).
28. Enzo, now holding a Freelancer Card after a BASIS member organisation's app development boot camp, receives USD 600 from a games studio abroad. He wants to keep some in dollars. What applies?
29. A graphic designer with no certificate of any kind on mobile application development asks Eliana for a Freelancer Card. What does I-4 say?
30. Eliana's bank credits several Freelancer Card receipts this month. How must the bank report them?
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