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Lesson 11 of 39 · Part B · Level 2 · Explained

When can the bank pay?

The bank may pay for most imports on its own, but not always. Courier parcels, bills the buyer refused, discrepant documents and goods cleared under penalty each have their own rule.

In Lesson 10, Firm orders and the right payment route, Rakib learned that an import starts with a firm order and travels on an approved payment route. Now the bills are arriving, and he has a new question.

It is Sunday morning at the AD branch. Rakib's tray holds four files: a courier parcel of medicine raw materials for Lamia, a bill the first buyer refused to pay, a set of documents with a late shipment date, and a penalty order. "Can I just pay all of these?" he asks.

Sadia, his team lead, puts down her tea. "Most days, yes. The bank pays on behalf of Bangladesh Bank, so we don't ask permission every time. But each of these four files has a small 'if'. Let's open them one by one."

This lesson is about those 'ifs': when the bank may pay on its own, and when it must first ask Bangladesh Bank.

Para B-8

Applications for remittances against imports

In plain words

The good news first. An AD may approve a payment for an import on behalf of Bangladesh Bank. The bank doesn't need to ask Bangladesh Bank each time. But two conditions must be met:

  • The conditions set out in Part A and elsewhere in this circular must be complied with.
  • The import documents must come through the AD. This is true whether the import is under an LC or not.

Imports by post or courier have one extra rule. It depends on whose name is on the parcel:

  • Parcel addressed directly to the AD: the AD may pay without prior approval of Bangladesh Bank.
  • Parcel addressed to an individual "care of" the AD, or to the individual directly: the bank must apply to Bangladesh Bank for prior approval before paying.

Why does the address matter? Think of a birthday gift. If it arrives at your office in your boss's name, your boss knows it came. If it goes straight to your home, nobody at the office sees it. The circular doesn't give a reason, but here is one way to see it: when the parcel comes to the bank, the bank is in the loop, just like any other import. When it goes to a person, the bank is not, so the case goes to Bangladesh Bank first.

At the desk

Lamia needs a small parcel of medicine raw materials sent by courier. Before she places the order, she asks Rakib how to address it. Rakib checks with Sadia and tells her: "Have the supplier address it directly to our bank. Then we can pay on our own. If it comes to you, even 'care of' our bank, we'll first have to get Bangladesh Bank's approval." Lamia changes the address on her order the same day.

Key words
Prior approval
Permission from Bangladesh Bank that a bank must get before it acts, case by case.
Courier
A private company that carries parcels and documents door to door, often faster than the post.
Read the rule as written (Para B-8)

ADs may approve on behalf of Bangladesh Bank remittance against imports into Bangladesh provided the conditions set out in Part-A and elsewhere in this circular are complied with and provided also that the documents covering the import, whether under LC or otherwise, are received through ADs concerned. In case of import by post/courier, ADs may make remittance without prior approval of Bangladesh Bank only if the parcel is addressed directly to ADs. Where the parcel is addressed to an individual care of ADs/ to the individual direct, prior approval of Bangladesh Bank should be applied for.

Source: Bangladesh Bank, FEPD-1 Circular No. 30, 13 August 2026, Part B, paragraph 8 (page 13). The original circular is the authority.

Para B-9

Remittance of proceeds of dishonored bill

In plain words

This paragraph has two rules.

1. The name must match. If the importer's name on the bill of exchange is different from the information in Bangladesh Bank's online reporting system, the AD should not pay the bill. The circular gives no exception here. A different name is a red flag: who is really buying, and who is really paying?

2. A new buyer for refused goods. Sometimes the first buyer (the drawee) dishonours the bill: he refuses to pay or accept it. This can happen under a documentary collection (DP or DA) and even under an LC. The foreign seller, or the seller's local agent, then finds another buyer in Bangladesh for the same goods.

Can the bank pay for the new buyer? Yes, but only:

  • with prior permission of Bangladesh Bank, and
  • after the goods have been released by Customs, shown by a Bill of Entry.

So before the bank pays, both must be in place: the goods released by Customs, with the Bill of Entry as proof, and Bangladesh Bank's prior permission. The circular doesn't list any other papers for this case, so stick to what it says and wait for Bangladesh Bank's answer.

At the desk

A shipment of onions sits at Benapole after the first buyer refuses to pay the bill. The seller's local agent offers the onions to Fahim, who agrees to buy them. Rakib wants to pay quickly, before the onions spoil. Sadia agrees speed matters, but the steps stay the same: the onions must be released by Customs, with the Bill of Entry as proof, and the bank must have Bangladesh Bank's permission before any money goes out.

Key words
Dishonour
When the drawee refuses to pay or accept a bill of exchange.
Drawee
The person asked to pay or accept a bill of exchange; in a collection, the buyer.
DA
Documents against Acceptance: the buyer accepts a bill to pay later and gets the documents now.
Bill of Entry
The importer's declaration of the imported goods to Customs. Once Customs certifies it, it proves the goods were cleared.
Read the rule as written (Para B-9)

An AD should not remit the proceeds of bills in cases where the name of the importer on the bill of exchange differs from the information available in Bangladesh Bank online reporting system. Where goods are imported under documentary collection (DP or DA) basis or even under LC and the original drawee dishonors the bill and the foreign shipper or his local agent finds another buyer for the goods, ADs may make the remittance with prior permission of Bangladesh Bank provided that the goods have released from the customs authority evidenced by bill of entry.

Source: Bangladesh Bank, FEPD-1 Circular No. 30, 13 August 2026, Part B, paragraph 9 (page 13). The original circular is the authority.

Para B-10

Remittance against discrepant documents/documents received directly by the importers

In plain words

(1) Discrepant documents. Sometimes the documents don't match the LC or each other, for example a late shipment date or a small spelling mistake. That is a discrepancy. The importer may waive it, which means agreeing to accept the documents anyway.

The AD may treat such a bill as eligible for payment if:

  • the importer's waiver rests on reasonable grounds that the AD accepts; and
  • the waiver does not lead to the material changes described in paragraph 16(3) of this Part. (We reach paragraph 16 in Lesson 14.)

The same rule applies when the documents reach the importer directly, instead of coming through the bank.

In simple words: a small slip can be waived. A waiver that changes the deal itself in a big way cannot.

(2) Releasing goods against copies. Sometimes the importer gets copy documents directly from the seller, and the goods arrive before the originals do. The importer then asks the bank for a shipping guarantee, an airway release or a delivery order to take the goods.

Before issuing any of these, the AD must do due diligence. The aim: when the originals arrive later, there should be no reason to raise discrepancies on them.

At the desk

Fahim's documents for machinery parts show a shipment date two days after the LC's latest shipment date. Fahim waives the discrepancy: the parts are the right ones, at the right price, and he needs them now. Rakib checks that the goods, quantity and price are unchanged, so the waiver doesn't change anything material, and Sadia accepts his reasons. The bill is treated as eligible for payment.

Key words
Discrepancy
A difference between the documents and the LC terms, or between the documents themselves. It can delay or stop payment.
Waiver
The buyer's agreement to accept documents despite their discrepancies, so the issuing bank can pay.
Due diligence
Careful checking before acting, to make sure a deal is genuine and safe.
Delivery Order
Instruction from the shipping company to release goods to a named party.
Read the rule as written (Para B-10)

(1) ADs may consider discrepant import bills, waived by importers under reasonable grounds acceptable to ADs, as eligible for payments provided that such waivers will not result in material changes as outlined in paragraph 16(3) of this part. This provision is also applicable for document received directly by respective importers.

(2) ADs shall conduct due diligence before issuance of shipping guarantees/airway releases/delivery orders, for the release of respective goods, against 'copy documents' received directly by importers so that there creates no question to raise discrepancies on original documents.

Source: Bangladesh Bank, FEPD-1 Circular No. 30, 13 August 2026, Part B, paragraph 10 (page 13). The original circular is the authority.

Para B-11

Remittance against goods imported under penalty

In plain words

Sometimes a penalty is imposed on an import, and a penalty order records it. For these goods imported under penalty, the rule is short and firm: the AD may not pay on its own.

Instead, every application to pay for such an import goes to Bangladesh Bank for prior approval. The application must carry:

  1. an attested copy of the Customs Bill of Entry for consumption in Bangladesh;
  2. the penalty order; and
  3. full particulars of the relevant circumstances, meaning the whole story of what happened.

Think of it like a school report card with a red mark. The headteacher wants to see the card, the note explaining the mark, and the full story before signing it. The circular doesn't say why the penalty was imposed or how Bangladesh Bank decides; it only says what the bank must send.

At the desk

Fahim's consignment is cleared for consumption, but under a penalty order. Fahim asks the bank to pay his supplier as usual. Rakib explains that the bank can't pay this one on its own. He collects the attested Bill of Entry for consumption, the penalty order and Fahim's written account of what happened, and Sadia sends the full set to Bangladesh Bank for prior approval.

Key words
Penalty order
The official order that imposes a penalty on an import and records it.
Cleared for consumption
Released by Customs for use or sale inside Bangladesh, after any duties and taxes due are paid.
Read the rule as written (Para B-11)

An AD may not make remittance in payment of goods imported under penalty. All applications for remittances of foreign exchange covering such imports should be submitted to Bangladesh Bank for prior approval and should be accompanied by the attested copy of the Customs Bill of Entry for consumption in Bangladesh, the relative penalty order together with full particulars of relevant circumstances.

Source: Bangladesh Bank, FEPD-1 Circular No. 30, 13 August 2026, Part B, paragraph 11 (page 14). The original circular is the authority.

Putting it together

So far: the bank may pay for imports on behalf of Bangladesh Bank, as long as the rules are followed and the documents come through the bank. A courier parcel addressed directly to the bank can be paid without prior approval; one addressed to a person needs it. A name that doesn't match Bangladesh Bank's online records stops payment, and paying for refused goods sold to a new buyer needs Customs release plus Bangladesh Bank's permission. Reasonable waivers of discrepancies are fine if nothing material changes, and goods imported under penalty always go to Bangladesh Bank first.

Next: Lesson 12, Paying in advance. What happens when the supplier wants the money before the goods are even shipped?

Check yourself

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

Set 1 of 3

1. On whose behalf does an AD approve payments for imports under B-8?
2. Under B-8, for the AD to approve the payment on its own, how must the documents covering the import be received?
3. An import comes by courier. In which case may the AD pay without Bangladesh Bank's prior approval?
4. Which conditions must be met before an AD pays for an import on its own under B-8?
5. True or false: if a courier parcel is addressed to the importer 'care of' the AD, the AD may pay without Bangladesh Bank's prior approval.
6. Lamia's supplier sends a courier parcel of raw materials addressed to her factory. She asks the bank to pay. What should Rakib do?
7. Rakib tells Lamia, 'Sorry, banks can never pay for imports that come by courier.' Sadia steps in. What is the correct rule?
8. An importer under an open account deal wants the supplier to send all import documents straight to him, not through the bank, and still wants the bank to pay on its own. What does B-8 say?
9. Under B-9, the importer's name on the bill of exchange is checked against what?
10. Under which payment methods can the 'new buyer for refused goods' rule apply?

Set 2 of 3

11. After the first buyer dishonours a bill, who may find another buyer for the goods under B-9?
12. What proof must show that the goods have been released by Customs before payment for a new buyer under B-9?
13. True or false: when a new buyer takes over goods the first buyer refused, the AD may pay for the new buyer without asking Bangladesh Bank, as long as Customs has released the goods.
14. The first buyer refuses to pay for a shipment of onions. The seller's agent sells them to Fahim. The onions are still at the land port, not yet released by Customs. Can the bank pay now?
15. Rakib sees that an import bill names 'Fahim Traders', but the online reporting system shows a different importer name for the same import. Sadia's advice?
16. When may an AD treat a discrepant import bill as eligible for payment?
17. Which paragraph does B-10 point to for the 'material changes' a waiver must not cause?
18. Before issuing a shipping guarantee, airway release or delivery order against copy documents received directly by the importer, what must the AD do?
19. Who waives a discrepancy in an import bill under B-10?
20. True or false: the waiver rule for discrepant bills also applies to documents received directly by the importer.

Set 3 of 3

21. True or false: under B-10, an AD may accept any reason the importer gives for waiving a discrepancy, even one the AD finds unreasonable.
22. Fahim's documents show a shipment date two days late, but the goods, quantity and price are exactly as agreed. He waives the discrepancy and Sadia finds his reasons sound. What may the bank do?
23. Machinery parts arrive at the port before the original documents. Fahim has only copies sent by the supplier and asks for a delivery order today. What should Rakib do first?
24. Can an AD pay on its own for goods imported under penalty?
25. Which paper must go with an application to pay for goods imported under penalty?
26. True or false: an application to pay for goods imported under penalty must include the penalty order and full particulars of the circumstances.
27. What does 'full particulars of relevant circumstances' mean in a penalty case?
28. Fahim's goods are cleared, but under a penalty order. He asks the bank to pay his supplier as usual. What should Rakib do?
29. Rakib is preparing a penalty case for Bangladesh Bank. He has the attested Bill of Entry for consumption and Fahim's written account. What is still missing?
30. Sadia gives Rakib a quick test: 'Which of these four needs Bangladesh Bank's approval first?' Which one is it?
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