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Lesson 14 of 39 · Part B · Level 2 · Explained

Closing the file

How the bank matches the Bill of Entry with the IMP form and closes the case, what happens when the goods don't match or never arrive, how refunds fix the gap, electronic Bills of Entry, and lost goods.

In Lesson 13, The IMP form and the Bill of Entry clock, Rakib learned that a four-month clock starts when import money leaves the country. This morning, Lamia walks in with her Bill of Entry, two weeks early. Rakib is delighted. "Now I can finally close the file!"

"Close it how?" asks Sadia. Rakib opens his mouth, then shuts it again.

At the bank's training session that afternoon, the guest speaker is Dr Omar: an economist and university professor, and a retired government officer who once served as Chairman of the Bangladesh Investment Board. Rakib asks him why banks fuss so much over one piece of paper. Dr Omar smiles. "Every dollar that leaves for an import should come back as goods. The Bill of Entry is how the country checks that the goods really came. If the two don't match, someone needs to ask why."

This lesson shows how a file is matched, closed and kept, and what happens when the story doesn't end neatly.

Para B-16

Disposal of IMP Forms

In plain words

An import file lives in stages.

1. Pay and report. The AD writes its approval on the reverse of the IMP form and reports to OIMS immediately after payment. The payment also goes in the usual monthly returns to Bangladesh Bank, without the IMP form attached.

2. Hold. The AD keeps the IMP form until the customs-certified Bill of Entry arrives. Meanwhile, if Bangladesh Bank asks, it sends the IMP form and the full set of import documents.

3. Match and close. The AD checks the Bill of Entry (or customs-certified invoice) against the IMP form and invoice: did the goods paid for really arrive? After verifying, it reports to OIMS. No material discrepancy means the case is closed, and the records are kept electronically for 5 years. If Bangladesh Bank's inspection team or another government agency is investigating, nothing is disposed of without its clearance.

4. When things go wrong.

  • Material discrepancy cases go monthly to FEOD in the Appendix-5 proforma, by the 10th day of the following month.
  • An importer whose Bill of Entry is not submitted, or not in the Customs electronic system, in time (or within Bangladesh Bank's extension) is barred from new LCs without Bangladesh Bank's prior permission. This also covers advance-payment imports and sales-contract imports without LCs.
  • The AD must not amend an LC whose IMP reporting is unmatched beyond 4 months from payment.

5. Refund. For goods not shipped or short shipped, the importer may get the unmatched amount (with bank charges) back in foreign currency from the same supplier, through the banking channel. The AD reports it to the 'Online Inward Remittance Monitoring System', then emails FEOD ([email protected]) to record it against the IMP number. If usual bank charges are deducted from the refund, the AD reports the refunded amount to the 'Online Inward Remittance Monitoring System'.

6. Advance-payment refunds may come from any legitimate source if: the remitter has a bona fide business relationship with the supplier; the remitter is in a FATF compliant country; and the AD checks authenticity and follows KYC and AML/CFT rules. The AD applies through the OIMS Online Ticketing Module ('Refund of Import Payments'), quoting the LC ID, IMP number and Inward ID number.

7. Waiver. If goods were lost or damaged by accident, auctioned by Customs or confiscated by the government, the AD may ask Bangladesh Bank to waive reporting the case as 'non-submission', with evidence as per paragraph 18 (B-18, below).

At the desk

Fahim paid for 50 tonnes of onions, but his Bill of Entry shows only 40 tonnes came through Benapole. Rakib flags the gap, and Sadia puts it in that month's Appendix-5 report to FEOD, due by the 10th of the next month. Five months after the payment, the gap is still open, and Fahim asks to amend that same LC. "Not while the IMP reporting under this LC stays unmatched beyond 4 months from payment," Sadia says. "Ask your supplier to refund the shortfall, plus the bank charges, through the bank. Once it arrives, we report it and ask FEOD to record it against your IMP number."

Key words
Material discrepancy
A real, important difference between the goods paid for and the goods actually received, as shown by the Bill of Entry or customs-certified invoice.
Short shipment
Shipping less than the quantity planned or declared.
Refund
Money sent back to the importer through the banking channel, for example when goods were not shipped or were short shipped.
FATF
Financial Action Task Force: the international body that sets standards against money laundering and terrorist financing.
Read the rule as written (Para B-16)

(1) To effect remittance against import, ADs shall endorse this approval on the reverse of the IMP Form in the space provided for the purpose. Immediately after import payment, ADs shall make report to the OIMS of Bangladesh Bank. Besides, import payment shall be reported in usual monthly returns to Bangladesh Bank without attachment of IMP Form. ADs shall continue to hold IMP Form until the customs certified bill of entry is received. During this stage of non-receipt of customs certified bill of entry, ADs shall, on demand, submit the IMP Form and full set of import documents to Bangladesh Bank.

(2) When the authenticated copy of the bill of entry/customs certified invoice evidencing entry of goods into Bangladesh, is submitted by the importer, the particulars therein should be matched and checked with those in the IMP form and invoice filed earlier to see if the merchandise for which remittance was made has been duly received in Bangladesh. ADs shall report the same to the OIMS after necessary verification. If no material discrepancy is detected, the case should be considered closed. Afterwards, ADs shall retain the IMP Form and relevant bill of entry with full set of import documents electronically with them for record and eventual inspection for a period of 5(five) years. However, in respect of cases which are under investigation by Bangladesh Bank inspection team/other Government agencies, the IMP form and full set of import documents including bill of entry shall be disposed of only after obtaining clearance from the inspection team/Government agency concerned.

(3) Cases with material discrepancy between the particulars of merchandise for which remittance was made and the merchandise actually received as evidenced by the authenticated copy of bill of entry/customs certified invoice, should be reported on monthly basis to FEOD, Head office or other offices of Bangladesh Bank, in proforma as given at Appendix-5 by 10th day of the following month. Importer who has failed to submit authenticated bill of entry or whose bill of entry is not available in Customs electronic system against any earlier remittance for import within the stipulated time (or within the extended period allowed by Bangladesh Bank) will be barred from opening new LC without prior permission of Bangladesh Bank. It will equally be applicable for import against admissible advance payment and/or imports under sales contract without LCs. ADs shall also refrain themselves from amending LCs under which IMP reporting remains unmatched beyond 4 months from the date of payment.

(4) To resolve the cases of unmatched overdue bill of entries (partial or full) due to non-receipt/short receipt of goods as per LC/Contract/IMP, importers may arrange to receive the unmatched amount in foreign currency (including associated bank charges) from the same foreign supplier through banking channel. Once the refund is received from foreign supplier abroad against non-shipment/short shipment of goods, etc., ADs shall report the same to the 'Online Inward Remittance Monitoring System'. Afterwards, ADs shall report to Bangladesh Bank (FEOD, Head Office, Dhaka to mail ID: [email protected]) for recording the refund information against the concerned IMP number reported to the OIMS.

(5) In case of usual bank charges deducted while on refund transactions, ADs shall report the refunded amount to the ‘Online Inward Remittance Monitoring System’.

(6) Refund against payments made in advance:

(a) Refund from legitimate sources irrespective of supplier may be acceptable provided that: (i) There is bonafide business relationship between the remitter(s) and the supplier(s) with whom the earlier contract/LC was established; (ii) Remitter(s) will have to be from FATF compliant countries; (iii) ADs shall satisfy themselves regarding the authenticity (with reference to LC/Contract/Invoice) of the transactions and adhere to KYC and AML/CFT guidelines.

(b) ADs shall submit all such applications through Online Ticketing Module of the OIMS under the Ticket Category titled ‘Refund of Import Payments’ for adjustment with respective IMP forms. It is mandatory to mention the relevant LC ID, IMP number and Inward ID number while issuing such tickets.

(7) In cases of failure of submission of bill of entry due to loss or damage of goods by accident, or for goods auctioned by customs authority or confiscated by Government, ADs may, apply to Bangladesh Bank soliciting waiver of reporting of such cases as ‘non-submission’ in their periodic return to Bangladesh Bank with documentary evidences as per paragraph 18 of this (as the case may be).

Source: Bangladesh Bank, FEPD-1 Circular No. 30, 13 August 2026, Part B, paragraph 16 (page 15). The original circular is the authority.

Para B-17

Acceptance of electronic bill of entry

In plain words

Today many Bills of Entry live inside the Customs computer system. B-17 lets the AD use them. The AD may accept a Bill of Entry it can see through the customs automated system to close (dispose) the IMP form, once the matching is done. Four conditions come with this:

(a) Goods released, duties paid. The AD must be satisfied that the imported goods were released and that the applicable duties and taxes on that import were paid.

(b) Print and keep. The AD takes a print-out of the Bill of Entry from the system. A competent official authenticates it, and it is kept in the import file for the prescribed period, for record and inspection.

(c) Only where the system exists. This option works only for imports through custom houses that have an automated system for issuing Bills of Entry.

(d) Not a free pass. If the Bill of Entry is not available in the system, within or beyond the statutory period, the AD must still obtain it from the importer. The same applies where Bangladesh Bank or other government agencies need it for other regulatory purposes.

So the electronic copy saves the importer a trip, but when the screen is blank, the paper chase is back on.

At the desk

Rakib searches the customs automated system and finds Lamia's Bill of Entry. The record shows the goods released and the duties and taxes paid. He prints it, Sadia authenticates it as the competent official, and it goes into the import file. A week later, Tahmid's Bill of Entry is nowhere in the system, so Rakib phones Tahmid and asks him to bring it in.

Key words
Customs automated system
Customs' computer system through which Bills of Entry are issued and which banks can access.
Authentication
A competent official signing or sealing a copy to confirm it is genuine.
Read the rule as written (Para B-17)

ADs may accept bill of entry accessible to them through the customs automated system to dispose IMP Form on completion of matching formalities. In this context, ADs shall observe the following instructions:

(a) ADs shall be satisfied with the release of imported goods and the settlement of payment on account of applicable duties and taxes against the relative import for which bill of entry has been generated;

(b) ADs shall take a print-out from the system of concerned bill of entry and preserve it in the relative import files, up to the prescribed period, after authentication by their competent officials for record and eventual inspection.

(c) The option as noted above shall be applicable only for import through custom houses having automated system for issuance of bill of entry.

(d) The above authorization shall not waive ADs to obtain bill of entry from importers due to non-availability of the same in the customs automated system within/beyond the statutory period, and other regulatory purposes required by Bangladesh Bank or by other relevant Government agencies.

Source: Bangladesh Bank, FEPD-1 Circular No. 30, 13 August 2026, Part B, paragraph 17 (page 17). The original circular is the authority.

Para B-18

Loss of goods

In plain words

Sometimes goods never make it. A container falls overboard, or a warehouse fire ruins part of a cargo. Then there is no Bill of Entry for the lost goods, so the file needs a different kind of proof.

  • Complete loss. A copy of the IMP form is forwarded to Bangladesh Bank, giving full particulars of the loss and how the insurance claim has been collected.
  • Partial loss. The authenticated copy of the customs Bill of Entry for the goods actually cleared is submitted, again with full particulars of the loss and how the insurance claim has been collected.

In both cases, Bangladesh Bank wants the same two things: what was lost, and how the insurance claim was collected. This is the paragraph that B-16(7) points to for the evidence behind a waiver request.

At the desk

Tahmid's machine is completely lost when it falls into the sea during loading abroad, and his insurer pays the claim. Rakib asks, "No goods, no Bill of Entry, so what do we send?" Sadia explains: a copy of the IMP form goes to Bangladesh Bank, with full details of the loss and of how the insurance claim was collected.

Key words
Cargo insurance
Insurance that pays if goods are lost or damaged while being transported.
Partial loss
When only part of the goods is lost; the rest is cleared through Customs.
Read the rule as written (Para B-18)

In the event goods are completely lost, copy of the IMP Form should be forwarded to Bangladesh Bank giving full particulars of the loss and the manner in which the insurance claim has been collected. In the event of partial loss, the authenticated copy of the customs bill of entry for the goods actually cleared should be submitted giving full particulars of the loss and the manner in which the insurance claim has been collected.

Source: Bangladesh Bank, FEPD-1 Circular No. 30, 13 August 2026, Part B, paragraph 18 (page 17). The original circular is the authority.

Putting it together

So far: after paying, the AD reports to OIMS, holds the IMP form until the Bill of Entry comes, then matches the two. A clean match closes the case, and the records are kept electronically for 5 years. Material discrepancies go to FEOD monthly in Appendix-5, importers with overdue Bills of Entry are barred from new LCs without Bangladesh Bank's permission, and refunds or waivers can settle the gap. Electronic Bills of Entry can be used where Customs has an automated system, and lost goods are reported to Bangladesh Bank with full particulars of the loss and how the insurance claim was collected.

Part B of the Import room is now complete! You have followed an import from start to finish: Opening an import LC: who and how (Lesson 8), Land ports and LC timing (9), Firm orders and the right payment route (10), When can the bank pay? (11), Paying in advance (12), The IMP form and the Bill of Entry clock (13) and Closing the file (14).

Check yourself

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

Set 1 of 3

1. When must an AD report an import payment to OIMS?
2. In which of these cases may an AD ask Bangladesh Bank to waive reporting a case as 'non-submission'?
3. How long does an AD hold the IMP form after payment?
4. Which references must be mentioned when issuing a 'Refund of Import Payments' ticket in OIMS?
5. For how long must the AD keep the IMP form, Bill of Entry and full set of documents after a case is closed?
6. By when must the monthly report of material discrepancy cases reach Bangladesh Bank?
7. What happens to an importer who has not submitted the authenticated Bill of Entry within the stipulated (or extended) time?
8. For a refund against an advance payment that comes from someone other than the supplier, where must the remitter be from?
9. True or false: The bar on opening new LCs also applies to imports against advance payment and imports under sales contracts without LCs.
10. True or false: Records of a case under investigation by Bangladesh Bank's inspection team may be disposed of after 5 years, even without the team's clearance.

Set 2 of 3

11. Lamia's Bill of Entry arrives. Rakib matches it with the IMP form and invoice and finds no material discrepancy. What happens next?
12. Fahim paid for 50 tonnes of onions, but his Bill of Entry shows only 40 tonnes received. How does the AD report this material discrepancy?
13. Fahim now wants to settle his onion shortfall. Which route does the circular allow?
14. Tahmid's IMP reporting under an LC is still unmatched 5 months after payment. He asks Sadia to amend the LC. What should Sadia do?
15. A refund against Lamia's advance payment comes from a company abroad other than her supplier. What must the AD be satisfied about before accepting it?
16. What may an AD use to dispose of an IMP form under B-17?
17. Before relying on an electronic Bill of Entry, the AD must be satisfied about...
18. What must the AD do with an electronic Bill of Entry it relies on?
19. Where does the electronic Bill of Entry option apply?
20. True or false: Because ADs may use electronic Bills of Entry, they never need to get a Bill of Entry from the importer.

Set 3 of 3

21. True or false: An AD may use an electronic Bill of Entry to dispose of an IMP form once the matching formalities are completed.
22. Rakib finds Lamia's Bill of Entry in the customs automated system, which shows the goods released and duties paid. What should he do with it?
23. An import for Fahim came through a custom house that has no automated system for issuing Bills of Entry. Can Sadia use the electronic option?
24. Tahmid's Bill of Entry cannot be found in the customs automated system, even after the statutory period. What follows?
25. If imported goods are completely lost, what is forwarded to Bangladesh Bank?
26. In a partial loss, which Bill of Entry is submitted?
27. Which detail must be given for both complete and partial losses?
28. True or false: In a partial loss, the importer only needs to submit the Bill of Entry for the cleared goods, with no details of the loss.
29. Tahmid's machine falls into the sea during loading abroad and is completely lost. His insurer pays the claim. What goes to Bangladesh Bank?
30. Some of Lamia's raw material drums are destroyed in a fire on the way; she clears the rest. What should be submitted?
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