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Lesson 22 of 39 · Part G · Level 2 · Explained

Paying back-to-back LCs and the input stock

How back-to-back usance bills are paid at maturity from export money set aside in a separate account, why they are paid even when the export fails, the post facto approval and reports that follow, and the bank's watch on bonded stock.

In Lesson 21, Inland back-to-back and Taka LCs, Evelyn learned to pay makers like Arman in dollars and traders in Taka. Her yarn came from Arman's mill, her fabric came from abroad, and her T-shirts for Hamburg are now coming off the lines.

Then the calendar taps her on the shoulder. Her first back-to-back bill for imported fabric falls due next month. "I will pay it when Hamburg pays me," she tells Habib. "That's how back-to-back works, isn't it? One LC pays the other."

"Mostly," says Habib. "But what if Hamburg pays late, or pays less, or the order is cancelled?" Evelyn goes quiet. Arman, who has dropped in to collect his own papers, goes even quieter. His cotton came in on a back-to-back LC too.

Habib has invited Mithu, a chartered accountant and former CFO of a large export group, to talk to his exporters about cash flow. Mithu has seen many factories that were rich on paper and empty in the bank. "A back-to-back LC is two promises tied together," Mithu says. "The bank must keep its promise even if the other one breaks. So let's see where the money sits, and what happens when things go wrong."

This lesson covers the last two paragraphs of Part G: paying back-to-back LCs (G-5) and the bank's watch on the stock of inputs (G-6).

Para G-5

Payment against back to back LCs

In plain words

G-5 answers three questions: where the money comes from, what the bank checks before paying, and what happens when the export goes wrong.

1. Where the money comes from

The usance bill under a back-to-back LC is paid at maturity, out of the proceeds of the related export, repatriated in foreign exchange. The foreign exchange needed is set aside from the export proceeds, including payments received in advance, in a separate foreign currency account in the AD's subsidiary ledger. Think of it as a labelled tiffin box: this money is for the fabric bill, not for lunch.

2. What the bank checks before paying

Before remitting against the back-to-back import bill, the AD should see that the authenticated copy of the bill of entry for bond has been submitted. It is the proof that the imports actually arrived.

3. When the export goes wrong

The usance bill must still be settled at maturity even where:

  • the export has not taken place;
  • the export proceeds have not been realised; or
  • the realised proceeds, net of the value addition requirement, are not enough to cover the back-to-back payment.

The foreign supplier is not left waiting. Then the paperwork follows:

  1. The AD seeks post facto approval from Bangladesh Bank (FEOD, Head Office or other offices of Bangladesh Bank) within fifteen days of the following month of making the payment. Read simply, if the bank pays in March, it applies within the first fifteen days of April.
  2. The application must fully explain the export failure or the non-realisation or short realisation, with supporting documents.
  3. Where the export failed, the AD also reports it to the NBR and the concerned Commissioner of Customs, so they can closely watch the stock of those goods in the bonded warehouse.
  4. A copy of the letter to the NBR goes to Bangladesh Bank with the post facto application.
  5. Every post facto application in these cases (export failure, short or non-realisation) carries the authenticated copy of the bill of entry showing the back-to-back imports were actually received.
At the desk

Evelyn's Hamburg buyer cancels part of the order after the fabric has arrived. Her back-to-back bill matures on 20 March, and Habib's bank pays the supplier on time. By 15 April, Habib sends Bangladesh Bank a post facto application explaining the export failure, with the supporting documents, the authenticated bill of entry and a copy of the bank's letter reporting the failure to the NBR. "Pay first, explain fully, and keep the paper trail tidy," Mithu tells Evelyn.

Key words
Maturity date
The day an accepted bill of exchange must be paid.
Subsidiary ledger
A detailed side record in a bank's books for one type of account. Under G-5, the separate foreign currency account for back-to-back payments is kept here.
Bill of entry for bond
The Bill of Entry for goods entering a bonded warehouse. Under G-5, its authenticated copy is the proof that the back-to-back imports actually arrived.
Post-facto
Done afterwards, after the event.
Read the rule as written (Para G-5)

Payment in settlement of usance bill against the back to back LCs shall be made at maturity, out of proceeds of the relative export repatriated in foreign exchange; the required foreign exchange will be set aside, out of the export proceeds including payments realized in advance, in a separate foreign currency account in the subsidiary ledger of ADs. Before making remittance against the back to back import bill, ADs should see that the authenticated copy of bill of entry for bond in evidence of actual arrival of the relative imports has been submitted. Usance bills against back to back LCs should be settled at maturity even where for some reason export has not taken place, or where the export proceeds have not been realized or where the realized export proceeds net of value addition requirement is not adequate to cover the back to back import payment. In such cases post facto approval of Bangladesh Bank (FEOD, Head office or other offices of Bangladesh Bank) will have to be sought for within fifteen days of the following month of effecting the payment, explaining fully the circumstances of export failure or non-realization/short realization of export proceeds, with relevant supporting documents. Cases of failure of export against the relative master LCs should also be reported to the NBR and the concerned Commissioner of Customs so that they may monitor closely the level of stock of the relative goods in the bonded warehouse. A copy of the letter to NBR reporting the export failure should be submitted to Bangladesh Bank along with the application for post facto approval of remittance towards back-to-back import payment. Also, all applications for post facto approval of such remittance in the event of export failure and short realization/non-realization of export proceeds should be accompanied by the authenticated copy of the relative bill of entry evidencing actual receipt of the back to back imports.

Source: Bangladesh Bank, FEPD-1 Circular No. 30, 13 August 2026, Part G, paragraph 5 (page 25). The original circular is the authority.

Para G-6

Stock of inputs procured under back to back LC

In plain words

G-6 is one sentence, and it makes the bank a watchful neighbour.

  • ADs must keep an effective watch on the stock of inputs bought under the back-to-back arrangement, and on the finished products made from them.
  • If any sign of illegal disposal of stock from the bond comes to the AD's knowledge, the AD must report it immediately to the concerned Commissioner of Customs and the NBR.

Why does a bank care? Because the inputs came in under the bond to be made into exports, and the bank's back-to-back LC paid for them. If fabric slips out of the bond into the local market, the export never happens and the whole chain is broken.

The circular doesn't list the methods for keeping an "effective watch". Mithu's accountant's habit helps: inputs that came in should match goods shipped out plus what is still in stock. When the numbers don't agree, it is time to ask questions.

At the desk

Arman's bank compares the cotton he imported under his back-to-back LC with the yarn he has supplied and the stock left in his bond. The numbers agree, and Mithu calls it "the most boring report in the world, which is exactly what you want". At another customer's factory, though, a bank officer hears that bonded fabric is being sold in the local market. Habib's advice is clear: report it at once to the concerned Commissioner of Customs and the NBR.

Key words
Illegal disposal
Selling or removing bonded goods in a way the rules don't allow, for example into the local market.
Stock reconciliation
Comparing what came in, what went out and what is left, to check that the numbers agree.
Read the rule as written (Para G-6)

ADs should maintain effective watch on the stock of inputs procured under the back to back arrangement and of finished products made therewith; any indication of illegal disposal of stocks from the bond coming to the knowledge of ADs should immediately be reported to the concerned Commissioner of Customs and NBR.

Source: Bangladesh Bank, FEPD-1 Circular No. 30, 13 August 2026, Part G, paragraph 6 (page 25). The original circular is the authority.

Putting it together

So far: back-to-back usance bills are paid at maturity from the related export proceeds, set aside in a separate foreign currency account, and only after the authenticated bill of entry for bond shows the imports arrived. If the export fails or the money falls short, the bill is still paid on time; the AD then seeks Bangladesh Bank's post facto approval within fifteen days of the following month, reports export failures to the NBR and the Commissioner of Customs, and sends the supporting papers. Throughout, the AD watches the bonded stock and reports any sign of illegal disposal at once.

Next: Part G of the import room is complete. Part H, on alternative trade finance mechanisms for imports, starts in Lesson 23, Beyond the LC: other ways to pay for imports.

Check yourself

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

Set 1 of 3

1. When must the usance bill under a back-to-back LC be paid?
2. Out of what money is a back-to-back usance bill normally paid under G-5?
3. Where is the foreign exchange needed for back-to-back payments set aside?
4. True or false: the foreign exchange set aside for back-to-back payments may come from export payments realised in advance, as well as later proceeds.
5. Before remitting against a back-to-back import bill, which document should the AD see has been submitted?
6. Habib is about to remit payment for Evelyn's back-to-back fabric bill. The file has everything except the authenticated bill of entry for bond. What should he do?
7. The Hamburg buyer cancels Evelyn's order after her imported fabric has arrived, and her back-to-back bill falls due. What does G-5 require?
8. True or false: if the export fails, the AD may delay paying the back-to-back usance bill until the exporter finds a new buyer.
9. Which situation does G-5 list among those where the back-to-back bill must still be paid at maturity?
10. From which part of Bangladesh Bank may post facto approval be sought under G-5?

Set 2 of 3

11. Within what time must post facto approval be sought after making such a payment?
12. Habib's bank pays a back-to-back bill on 20 March after Evelyn's export failed. By when should it seek post facto approval, reading G-5 simply?
13. A junior officer drafts a post facto application with a single line: 'Export failed, please approve.' What is missing under G-5?
14. Besides Bangladesh Bank, to whom must cases of export failure against master LCs be reported?
15. Why are export failures reported to the NBR and the Commissioner of Customs?
16. In an export-failure case, what must go to Bangladesh Bank along with the post facto application?
17. True or false: every post facto application for such remittances, after export failure or short or non-realisation, must include the authenticated copy of the bill of entry showing actual receipt of the back-to-back imports.
18. Evelyn's buyer pays only part of the export bill. After setting aside the value addition share, the money is not enough for her back-to-back bill. What should Habib's bank do?
19. Evelyn's export proceeds arrive in full and on time, and her back-to-back usance bill is paid at maturity from the set-aside account. Does Habib's bank need post facto approval from Bangladesh Bank for this payment?
20. What does 'post-facto' mean?

Set 3 of 3

21. Evelyn receives a large export payment from Hamburg and wants to spend all of it on a new knitting machine. Two back-to-back bills will mature next month. What does Mithu explain?
22. In G-5, what does 'short realisation' of export proceeds mean?
23. After a failed export, Habib's bank paid the back-to-back bill and applied for post facto approval, but reported nothing to anyone else. What has it missed?
24. What must ADs keep an effective watch on under G-6?
25. To whom must an AD report signs of illegal disposal of stock from the bond?
26. True or false: under G-6, an AD that learns of signs of illegal disposal from the bond may wait for the year-end audit before reporting.
27. A bank officer hears that a customer's bonded fabric, imported under back-to-back LCs, is being sold in the local market. What does G-6 require?
28. True or false: G-6 asks ADs to watch only the imported inputs, not the finished goods made from them.
29. Arman's bank compares the cotton he imported under his back-to-back LC with the yarn he supplied and the stock left in his bond. Which G-6 duty does this serve?
30. In G-6, what does 'illegal disposal of stocks from the bond' mean?
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