Lesson 33 of 42 · Part L · Level 2 · Explained
Tracking payments, bank-to-bank transfers and digital help
How banks spot incoming dollars during the day, reconcile their nostro accounts at least every 60 minutes as a benchmark, track each payment with its UETR, pass money to other banks without delay, and let customers give information online now that Form-C stands discontinued.
In Lesson 32, Inward remittances: telling the customer and crediting on time, we saw that banks must tell customers promptly when a remittance message arrives, and credit the money on the same business day if it comes in during banking transaction hours (or the next business day if it comes later), with risky cases checked first but settled within 3 business days.
Lovely rules. But Enzo, the young freelance designer from Mirpur, has a practical worry. He is back at Eliana's export desk, phone in hand again. "My client in Toronto says the money left on Tuesday. Today is Wednesday. Where is it? Is it stuck on a plane?"
Right behind him is Nabila, who runs a software firm in Dhaka. Her problem is different. "My client's payment reached another bank first, not yours. Will it get lost between two banks?"
That afternoon, Eliana's branch has a guest for its compliance session: Ihsaan, an expert in compliance and anti-money-laundering. Ihsaan listens to both stories and smiles. "Money does not get lost if every bank can see it, track it and pass it on quickly. That is exactly what the rest of Part L is about." This lesson covers L-3 to L-7, the second half of Part L.
Use of intraday confirmations and reduction of end-of-day dependency
In plain words
Think of a nostro account as the bank's dollar wallet, kept with a bank abroad. When Enzo's client pays, the money first lands in that wallet. The big question is: how soon does Eliana's bank notice it?
The old habit was to wait for the end-of-day or next-day statement of the nostro account. That is like checking your mobile wallet only at bedtime. Money that arrived at 10 a.m. sits unnoticed until night, or until tomorrow. L-3 changes the habit.
(a) Use information from during the day. ADs should reduce their dependence on end-of-day or next-day nostro statements for crediting inward remittances. To the extent feasible, they should use:
- intraday credit confirmations (messages saying "money has arrived", sent during the day); and
- scheduled intraday statements (statements sent at set times during the day),
so that beneficiaries get their money faster.
(b) Reconcile often. ADs shall put in place mechanisms, systems and controls for timely reconciliation of nostro balances and confirmation of incoming credits. This may be done:
- on a near real-time basis; or
- at frequent periodic intervals, to suit the bank's operational capabilities.
But as a general benchmark, reconciliation intervals shall not exceed 60 minutes.
Notice the two tones. Part (a) says "should" and "to the extent feasible". Part (b) says "shall", with 60 minutes as the benchmark. The circular does not list exceptions to that benchmark.
Why does this matter? Lesson 32 asked for same-day credit. You cannot credit money you have not spotted yet.
At the desk
At 11:05 a.m., Eliana's bank gets an intraday credit confirmation from its nostro bank: USD 1,200 for Enzo. She does not wait for tomorrow's statement. The reconciliation team, which matches the nostro balance every 45 minutes, confirms the credit in its next round, and Enzo's money reaches his account the same business day. Ihsaan notes that a 45-minute cycle sits comfortably inside the 60-minute benchmark.
Key words
- Nostro account
- A bank's own account, in foreign currency, held with a bank in another country.
- Intraday credit confirmation
- A message, received during the working day, confirming that money has arrived in the bank's nostro account.
- Reconciliation
- Matching the bank's own records against the nostro account balance and incoming credits, to check that they agree.
Read the rule as written (Para L-3)
(a) ADs should reduce dependence on end-of-day or next-day nostro account statements for crediting inward remittances and, to the extent feasible, use intraday credit confirmations and scheduled intraday statements to enable faster credit to beneficiaries.
(b) ADs shall put in place appropriate mechanisms, systems, and controls to ensure timely reconciliation of nostro account balances and confirmation of incoming credits. Such reconciliation may be undertaken on a near real-time basis or at frequent periodic intervals, commensurate with the bank's operational capabilities; however, reconciliation intervals shall, as a general benchmark, not exceed 60 minutes.
Source: Bangladesh Bank, FEPD-1 Circular No. 26, 30 July 2026, Part L, paragraph 3 (page 46). The original circular is the authority.
Payment tracking, transparency, and UETR compliance
In plain words
When you send a parcel by courier, you get a tracking number. You type it in and see: "picked up", "in transit", "delivered". L-4 asks banks to give remittances the same kind of tracking.
(a) Track every step. ADs shall ensure appropriate tracking of inward remittance transactions from receipt to final credit. This includes the use of the UETR (Unique End-to-End Transaction Reference), where applicable. In plain words, a UETR is one unique reference code that travels with a payment from start to finish, like the parcel's tracking number.
ADs are also encouraged to keep a high level of compliance in updating tracker information in a timely manner. A tracker that says "in transit" for three days after the money was credited helps nobody.
(b) Keep the code all the way. The UETR shall be carried through domestic transactions, including inter-bank transfers, right up to the ultimate beneficiary. The goal is end-to-end traceability: anyone checking can follow the money from the sender abroad to the final account in Bangladesh, with no blind spots in between.
The circular says "where applicable" in part (a), but does not list the cases where a UETR would not apply. It also does not name a particular tracking system.
Ihsaan puts it simply: "A payment you can trace is a payment you can trust. And a payment you cannot trace is the first one a launderer would choose." That is why the UETR matters so much to compliance teams.
At the desk
Enzo asks Eliana where his Toronto payment is. Eliana takes the UETR from the remittance message and checks the tracker: the money reached the bank's nostro account that morning and is in processing. She updates the tracker as soon as the credit is done, and Enzo gets a message that the payment is complete. Enzo puts his phone away, finally calm.
Key words
- UETR
- Unique End-to-End Transaction Reference: one unique reference code that travels with a payment from the sender's side right up to the final account.
- Traceability
- Being able to show exactly what was sent, when, and to whom.
- Payment tracker
- A record that shows where a payment is at each stage, from receipt to final credit.
Read the rule as written (Para L-4)
(a) ADs shall ensure appropriate tracking of inward remittance transactions from receipt to final credit, including the use of the Unique End-to-End Transaction Reference (UETR), where applicable. ADs are encouraged to maintain a high level of compliance in updating tracker information in a timely manner.
(b) The UETR shall be carried through domestic transactions, including inter-bank transfers, up to the ultimate beneficiary to ensure end-to-end traceability.
Source: Bangladesh Bank, FEPD-1 Circular No. 26, 30 July 2026, Part L, paragraph 4 (page 46). The original circular is the authority.
Inter-bank transfers
In plain words
Sometimes the money reaches one bank in Bangladesh, but the customer keeps her account at another. That is Nabila's worry. L-5 tells both banks what to do.
(a) Pass it on without delay. Where inward remittances are received for beneficiaries who keep accounts with other ADs, the receiving AD shall transfer the funds without delay to the relevant AD through the FC Clearing BD-RTGS System. No parking the money overnight "to batch it later". The circular does not set a number of minutes or hours for "without delay".
(b) Close the loop. Once the money is credited:
- the ultimate beneficiary's AD (the bank where the customer's account is) sends a credit-successful confirmation to the intermediary AD (the bank in the middle, which passed the money on), through appropriate messaging channels, including the UETR for end-to-end reference;
- the intermediary AD then updates its payment tracker.
Think of a relay race. The first runner must hand over the baton quickly, and the last runner must shout "Got it!" so everyone knows the race is finished. The UETR is the name written on the baton.
This links straight back to L-4: the UETR must be carried through inter-bank transfers, so the trail never breaks when money moves from one bank to another. The circular does not name the messaging channels to be used.
At the desk
Nabila's client pays USD 9,000, and it reaches another AD first. That AD transfers it without delay through the FC Clearing BD-RTGS System to Eliana's bank, with the UETR. Eliana credits Nabila's account and sends a credit-successful confirmation, carrying the same UETR, back to the first AD, which updates its payment tracker. Ihsaan smiles: two banks, one trail, no gaps.
Key words
- FC Clearing BD-RTGS System
- The system named in L-5 through which an AD transfers foreign currency to another AD in Bangladesh. RTGS stands for real-time gross settlement: each payment is settled on its own, as it happens.
- Intermediary AD
- The bank in the middle: the AD that receives an inward remittance and passes it on to the AD where the beneficiary keeps the account.
- Credit-successful confirmation
- A message from the beneficiary's AD to the intermediary AD saying the money has been credited, carrying the UETR.
Read the rule as written (Para L-5)
(a) Where inward remittances are received in favor of beneficiaries maintaining accounts with other ADs, the receiving AD shall transfer the funds without delay to the relevant AD through the FC Clearing BD-RTGS System.
(b) Ultimate beneficiaries' ADs shall send credit-successful confirmations to intermediary ADs through appropriate messaging channels, including the UETR for end-to-end reference. Intermediary ADs shall update payment trackers accordingly.
Source: Bangladesh Bank, FEPD-1 Circular No. 26, 30 July 2026, Part L, paragraph 5 (page 46). The original circular is the authority.
Digital facilitation and customer interfaces
In plain words
L-6 moves the paperwork online, and it carries some big news for readers of earlier lessons.
(a) Secure digital interfaces. ADs shall set up secure digital interfaces (safe online portals or apps) for foreign exchange transactions. Through them, customers can:
- submit required information and documents;
- receive electronic acknowledgements; and
- monitor the status of their transactions.
Information customers give through these interfaces, such as the repatriated amount, remitter details, purpose of remittance and other relevant particulars, is deemed authentic based on the customer's declaration. That does not mean the bank stops caring. The AD must still capture, validate and retain it in an auditable and retrievable manner, in line with its internal controls.
Information on inward remittances that comes through secure banking channels, including authenticated remittance messages, is treated the same way.
The big news: accordingly, Form-C and Form-C (ICT) stand discontinued. In Lessons 23 to 26 and Lesson 30 we met Form-C and Form-C (ICT) as the declarations for many inward remittances. Part L now says they stand discontinued, because the same information is captured through these secure interfaces and channels.
(b) Until the new interfaces arrive. Until such interfaces are implemented, ADs shall collect the remittance purpose and supporting information and documents through their existing digital channels, consistent with risk-based controls and regulatory compliance.
The circular does not give a separate date for the discontinuation, and does not say more about how part (a) and part (b) fit together in time.
At the desk
Enzo receives USD 2,500 for an app design. Eliana's bank has not yet launched its new secure interface, so she asks Enzo to state the remittance purpose and upload the client's contract through the bank's existing internet banking channel. The system records his declaration, validates it against the remittance message and keeps it in an auditable file. Enzo asks, "No Form-C?" Eliana explains that Part L says Form-C and Form-C (ICT) stand discontinued.
Key words
- 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.
- Secure digital interface
- A safe online portal or app through which a customer sends information and documents to the bank, gets electronic acknowledgements and follows a transaction's status.
- Deemed authentic
- Accepted as genuine on the basis of the customer's own declaration, while the bank still captures, validates and keeps the information.
Read the rule as written (Para L-6)
(a) ADs shall establish secure digital interfaces to facilitate foreign exchange transactions, enabling submission of required information and documents, electronic acknowledgements, and monitoring of transaction status by customers. Information provided by customers via secure digital interfaces-including repatriated amount, remitter details, purpose of remittance, and other relevant particulars-shall be deemed authentic based on the customer's declaration and shall be captured, validated, and retained by ADs in an auditable and retrievable manner in accordance with internal controls. Information relating to inward remittances received through secure banking channels, including authenticated remittance messages, shall be treated likewise. Accordingly, Form-C and Form-C (ICT) shall stand discontinued.
(b) Until such interfaces are implemented, ADs shall collect remittance purpose and supporting information/documents through their existing digital channels, consistent with risk-based controls and regulatory compliance.
Source: Bangladesh Bank, FEPD-1 Circular No. 26, 30 July 2026, Part L, paragraph 6 (page 46). The original circular is the authority.
Compliance
In plain words
L-7 is the to-do list for the whole of Part L. ADs shall take all necessary preparatory and progressive measures to ensure timely and effective compliance. "Preparatory" means getting ready; "progressive" means improving step by step.
The circular puts particular emphasis on five things. Here they are, with where you met each one:
- STP arrangements / risk-based expedited processing: crediting promptly, by straight-through processing or by risk-based fast handling where STP is not operational (L-2, Lesson 32);
- intraday credit confirmation arrangements (L-3);
- appropriate nostro account reconciliation intervals (L-3, with 60 minutes as the general benchmark);
- use of UETR for end-to-end transaction traceability (L-4 and L-5);
- digital facilitation and customer interfaces (L-6).
L-7 does not set a deadline date, and it does not add new rules. It tells banks to build the systems, train the people and keep improving until all five are working well.
Ihsaan's advice for any bank planning this: "Compliance is not one big jump. It is a staircase. Just make sure you are always climbing." Every step in the list above is one stair.
At the desk
Eliana's head office forms a small project team for Part L. Their checklist has five lines: STP or risk-based expedited processing, intraday credit confirmations, nostro reconciliation within the 60-minute benchmark, UETR tracking through to the final account, and a secure customer interface. Ihsaan reviews the plan and suggests one owner and a target for each line, so that progress can be seen month by month.
Key words
- Progressive measures
- Steps taken one after another, improving bit by bit until a rule is fully met.
- Risk-based approach
- Putting the most care where the risks are highest.
Read the rule as written (Para L-7)
ADs shall take all necessary preparatory and progressive measures to ensure timely and effective compliance, with particular emphasis on the implementation of STP arrangements/risk based expedited processing, intraday credit confirmation arrangements, appropriate nostro account reconciliation intervals, use of UETR for end-to-end transaction traceability, and the provision of digital facilitation and customer interfaces.
Source: Bangladesh Bank, FEPD-1 Circular No. 26, 30 July 2026, Part L, paragraph 7 (page 47). The original circular is the authority.
Putting it together
So far: Banks should rely less on end-of-day nostro statements and use intraday confirmations instead, and they must reconcile their nostro accounts often, with 60 minutes as the general benchmark. Every inward remittance must be tracked from receipt to final credit, with the UETR carried through to the ultimate beneficiary, even across banks; a receiving AD passes money to another AD without delay through the FC Clearing BD-RTGS System, and the beneficiary's AD confirms the credit back. Customers give information through secure digital interfaces (or existing digital channels until those are ready), Form-C and Form-C (ICT) stand discontinued, and L-7 asks banks to prepare and keep improving on all of this.
Next: Part L of the export room is complete. Part M, on re-export, entrepot, merchanting trade and counter-trade, starts in Lesson 34, Re-export, entrepot and merchanting trade.