E-documents in import LCs and collections, security and the start
How import documents travel as electronic records under the pilot: which documents can go digital, how ETRs stay unique and safe, how they are endorsed and handed over, what happens when the other country does not recognise them, and how banks keep it all secure, report it and start small.
In Lesson 25, The digital documents pilot for imports: aims, scope and principles, Shabnam explained why Bangladesh Bank has started a pilot for digital trade documents, which import deals it covers, the principles every participant follows, how a bank asks to join with a trade corridor, and why contracts, LCs and collection instructions must clearly allow e-documents. Rakib loved the big picture. Then Monday came.
Lamia, who imports pharmaceutical raw materials in Dhaka, walks into Sadia's branch holding up her phone like a cricket trophy. "My supplier says the bill of lading for my next shipment will be electronic. No courier, no paper. So who actually holds it? How do I get my drums out of the port? And what if someone changes a number in the file?"
Rakib looks at Sadia. Sadia looks at the clock. "Perfect timing. Iyan is visiting us this afternoon." Iyan once ran operations for a shipping line and a freight forwarder. He has handled more bills of lading than most of us have had cups of tea.
Iyan listens and smiles. "On paper, a negotiable bill of lading is the key to the cargo. Whoever holds it can claim the goods. An electronic one is still a key. We just have to make sure there is only one key, and that everyone can see whose pocket it is in." This lesson covers the rest of Part I: e-documents under collections and LCs (I-6), endorsement and control (I-7), import deals under LCs and sales contracts (I-8), security (I-9), service providers (I-10), reporting (I-11) and how the pilot is rolled out (I-12).
Electronic documents under documentary collections and LCs
In plain words
Which import documents can go electronic, and how are the special ones kept safe? I-6 has four parts.
(a) What may go electronic. ADs may process trade documents in electronic form, including but not limited to:
commercial invoices;
transport documents, including electronic bills of lading where applicable; and
bills of exchange (drafts).
"Including but not limited to" means these are examples, not a closed list.
(b) Extra care for ETRs. Where documents are ETRs, the AD must make sure that mechanisms are in place to preserve three things:
Singularity: there is one unique, authoritative version of the document. No twins.
Control: it is possible to identify, and transfer, exclusive control to a single holder.
Integrity: the document is protected against unauthorised alteration, including by cryptographic methods or equivalent safeguards.
Why so strict? Iyan explains: "If two 'original' electronic bills of lading were floating around, two people could turn up for the same container. Only one of them would go home happy."
(c) Digital fingerprints.Unique identifiers, such as digital fingerprints or hashes, must be used where feasible to protect the document's integrity. A hash is a short code worked out from a document's contents; change even one figure and the code changes.
(d) A paper safety net. Where full electronic handling of title documents is not feasible, hybrid arrangements with physical fallback may be used. The circular doesn't spell out how a hybrid arrangement should be set up.
At the desk
Lamia's electronic bill of lading reaches Sadia's branch as an ETR. Before accepting it, Rakib checks with Sadia that the platform keeps one authoritative version, shows clearly who holds control, and protects the file with a hash so that any change would show. For another of Lamia's suppliers, full electronic handling of the title documents is not feasible, so the branch uses a hybrid arrangement with a paper bill of lading as the fallback.
Key words
Electronic Transferable Record (ETR)
An electronic version of a document that can be transferred, such as a bill of lading or a bill of exchange, carrying the same rights as the paper one.
Singularity
For an ETR, the existence of one unique, authoritative version of the document.
Hash
A unique code worked out from a document's contents, like a digital fingerprint; if the document changes, the code changes.
Hybrid arrangement
Handling documents partly electronically, with physical (paper) documents as a fallback where full electronic handling of title documents is not feasible.
Read the rule as written (Para I-6)
(a) ADs may process trade documents in electronic form, including but not limited to:
(i) Commercial invoices
(ii) Transport documents (including electronic bills of lading where applicable)
(iii) Bills of exchange / drafts
(b) Where documents constitute ETRs, ADs shall ensure that mechanisms are in place to preserve:
Singularity: Existence of a unique authoritative version of the document;
Control: Ability to identify and transfer exclusive control to a single holder;
Integrity: Protection against unauthorized alteration, including use of cryptographic methods or equivalent safeguards.
(c) Unique identifiers (e.g., digital fingerprints or hashes) shall be used where feasible to ensure document integrity.
(d) Where full electronic handling of title documents is not feasible, hybrid arrangements with physical fallback may be applied.
Source: Bangladesh Bank, FEPD-1 Circular No. 30, 13 August 2026, Part I, paragraph 6 (page 29). The original circular is the authority.
I-7 explains how e-documents change hands, and how that is proved. It has three parts.
(a) Ways to endorse. Electronic endorsement may be done through:
digital signatures;
secure platform-based transfer mechanisms; and
authenticated interbank messaging systems, where required for sending settlement instructions, endorsements or operational messages, particularly where platform-based electronic channels are not available or not mutually agreed.
These tools may be used individually or in combination, for issuing, sending, endorsing, authenticating and otherwise processing e-documents under the approved pilot framework. So a bank might sign a document digitally and also confirm it by bank message: belt and braces.
(b) The record is the proof.Platform-generated audit trails and system logs count as evidence of:
endorsement;
transfer of control; and
receipt and acceptance.
If anyone argues later, the system's own record of who did what, and when, does the talking.
(c) One holder at a time. Any transfer of an ETR must ensure that only one party exercises control at any point in time. Iyan compares it to the keys of a container yard: "The moment you hand the key over, it is no longer in your pocket. Two people never hold it at once."
"Sign it, log it, and keep one hand on the key at a time," Iyan sums up. "That's I-7 in one breath," he adds with a grin.
At the desk
Lamia's LC is with a supplier whose bank is not on the same platform as Sadia's branch, and the two banks have not agreed on one. So the endorsement is signed digitally, and the settlement instructions travel through an authenticated interbank messaging system. Weeks later the supplier's bank asks when the documents were received; Rakib pulls up the system logs, which show receipt and acceptance with dates and times.
Key words
Digital signature
An electronic signature, made with secure technology, that shows who signed a document.
Audit trail
A step-by-step record, kept by a system, of who did what and when.
Transfer of control
Passing the control of an ETR from one holder to the next, so that only one party has control at any time.
Read the rule as written (Para I-7)
(a) Electronic endorsement of documents may be executed through:
(i) digital signatures;
(ii) secure platform-based transfer mechanisms; and
(iii) authenticated interbank messaging systems, where required for communication of settlement instructions, endorsements, or operational messages, particularly where platform based electronic channels are not available or mutually agreed.
These mechanisms may be used individually or in combination for the issuance, transmission, endorsement, authentication, and related processing of electronic trade documents under the approved pilot framework.
(b) Platform-generated audit trails and system logs shall constitute evidence of:
(i) Endorsement
(ii) Transfer of control
(iii)Receipt and acceptance
(c) Transfer of ETRs shall ensure that only one party exercises control at any point in time.
Source: Bangladesh Bank, FEPD-1 Circular No. 30, 13 August 2026, Part I, paragraph 7 (page 29). The original circular is the authority.
Import transactions under LC arrangements and sales contracts
In plain words
I-8 brings the pilot to the import desk. It has three parts.
(a) Electronic presentation, if the banks accept it. Import transactions under LCs, and documentary collections under sales contracts, may be processed with electronic presentation of trade documents. There is a condition: the relevant banks involved must accept it. The circular gives examples: issuing, advising, nominated or settlement banks, as applicable. Think of a relay race. If one runner in the chain can't carry the electronic baton, the race can't be run that way.
(b) When the other country doesn't recognise e-documents. Sometimes ETRs or electronic trade documents are not legally recognised or enforceable in the counterpart jurisdiction, that is, the country on the other side of the deal. Then ADs may:
accept electronic copies of documents for preliminary verification purposes, an early check; and
require the physical documents of title or other original documents, where necessary for compliance, legal enforceability or risk management.
Iyan puts it simply: "The file lets you start checking early. The paper is what counts in that country if something goes wrong."
(c) Releasing the goods. Goods under import transactions may be released based on mutually agreed electronic confirmation and verification mechanisms set up within the approved pilot framework. This is subject to the applicable regulatory requirements and the contractual terms between the parties. The circular doesn't describe these mechanisms in detail or list the regulatory requirements. It leaves the mechanism to what the parties agree within the pilot, and the other rules still apply.
At the desk
Lamia's new supplier is in a country where ETRs are not legally recognised or enforceable. Sadia's branch accepts the electronic copies of the invoice and bill of lading for a preliminary check, so Rakib can start looking for problems early. But because the document of title must be enforceable there, Sadia also asks for the original paper bill of lading.
Key words
Issuing bank
The buyer's bank that opens the LC and promises to pay against the right documents.
Nominated bank
The bank named in the LC where the seller may present documents and be paid.
Counterpart jurisdiction
The country, and its legal system, on the other side of a deal, such as the supplier's or the foreign bank's country.
Document of title
A document, such as a negotiable bill of lading, that gives its holder the right to claim the goods.
Read the rule as written (Para I-8)
(a) Import transactions under LCs and documentary collection under sales contracts may be processed with electronic presentation of trade documents, subject to acceptance by the relevant banks involved, including issuing, advising, nominated banks, or settlement banks, as applicable.
(b) Where ETRs or electronic trade documents are not legally recognized or enforceable in the counterpart jurisdiction, ADs may:
(i) accept electronic copies of documents for preliminary verification purposes; and
(ii) require submission of physical documents of title or other original documents, where necessary for compliance, legal enforceability, or risk management.
(c) Release of goods under import transactions may be effected based on mutually agreed electronic confirmation and verification mechanisms established within the approved pilot framework, subject to compliance with applicable regulatory requirements and contractual terms between the parties.
Source: Bangladesh Bank, FEPD-1 Circular No. 30, 13 August 2026, Part I, paragraph 8 (page 30). The original circular is the authority.
I-9 is the security chapter of the pilot. Its four parts are about what the AD (the bank) must do, not the importer.
(a) A safe road for the documents. ADs must make sure documents travel through secure transmission channels with all four of these:
Encryption: the data is scrambled so outsiders can't read it.
Authentication: the system checks who is sending and who is receiving.
Time-stamping: a reliable record of when each document was sent or received.
Tamper-proof audit logs: a record of every step that nobody can quietly change.
Think of a bonded warehouse: a strong lock, an ID check at the gate, a register with times, and CCTV that can't be erased. All four, not just one.
(b) Recognised standards. Systems must comply with internationally recognised information security standards. The circular doesn't name a particular standard.
(c) Where sensitive data sits. Sensitive document data shall not be mandatorily stored in shared or public infrastructures. Read simply, storing it on shared or public systems must not be made compulsory. The circular doesn't define "sensitive".
(d) A front door for customers. ADs must set up and maintain digital interfaces, platforms or secure channels so customers can submit, access, track and manage trade documents and related data electronically. These must ensure data security, user authentication, auditability and compatibility with interoperable digital trade document systems.
At the desk
Lamia asks how she will actually send and follow her documents. Rakib shows her the bank's customer portal: she logs in with a password and a one-time code, uploads her documents, and sees each step and its time as the file moves. "Like tracking a container at sea," Iyan says, "only this cargo is made of data." Lamia is delighted.
Key words
Encryption
Scrambling data into a secret code so that only someone with the right key can read it.
Time-stamping
Recording, in a reliable way, the exact date and time a document was sent, received or changed.
Tamper-proof audit log
A record of every action on a document that nobody can secretly change or delete afterwards.
Information security standards
Recognised sets of good practice for keeping computer systems and data safe.
(b) Systems shall comply with internationally recognized information security standards.
(c) Sensitive document data shall not be mandatorily stored in shared or public infrastructures.
(d) ADs shall establish and maintain appropriate digital interfaces, platforms, or secure channels to enable their customers to electronically submit, access, track, and manage trade documents and related data flows under this framework. Such interfaces shall ensure data security, user authentication, auditability, and compatibility with interoperable digital trade document systems.
Source: Bangladesh Bank, FEPD-1 Circular No. 30, 13 August 2026, Part I, paragraph 9 (page 30). The original circular is the authority.
A bank doesn't have to build every piece of technology itself. I-10 says ADs may use digital trade platforms, service providers or open-source solutions, as long as they meet three tests:
They support interoperability, meaning they can work with other systems.
They enable independent verification of documents, so another party can check that a document is genuine without simply trusting the platform.
They meet acceptable governance and security standards.
Then come two softer points:
Preference should go to solutions that avoid vendor lock-in and support cross-platform compatibility. Vendor lock-in is like a phone charger that fits only one brand: change phones, and the charger is useless. The word is "preference", not a ban.
Costs of these services may be treated as normal banking charges. The circular doesn't set an amount or a ceiling.
Notice what I-10 doesn't do. It doesn't name any approved platform or provider. It gives the tests, and the AD applies them.
At the desk
Sadia's head office is choosing between two platforms. Both support interoperability, let the supplier's bank verify documents on its own, and meet governance and security standards. But one keeps everything in its own special format, so moving away later would be hard and costly; the other works smoothly across platforms. Following I-10's preference for avoiding vendor lock-in, the bank picks the second one.
Key words
Interoperability
The ability of different systems to work together and exchange documents and data.
Vendor lock-in
Being stuck with one supplier's system because moving to another would be too hard or too costly.
Open-source solution
Software whose code is published openly, so anyone can check, use and improve it.
Read the rule as written (Para I-10)
(a) ADs may utilize digital trade platforms, service providers, or open-source solutions that:
(i) Support interoperability
(ii) Enable independent verification of documents
(iii)Meet acceptable governance and security standards
(b) Preference should be given to solutions that avoid vendor lock-in and support cross platform compatibility.
(c) Costs associated with such services may be treated as normal banking charges.
Source: Bangladesh Bank, FEPD-1 Circular No. 30, 13 August 2026, Part I, paragraph 10 (page 30). The original circular is the authority.
I-11 is one sentence, and it is about reporting. ADs must:
keep following their usual reporting requirements (the pilot doesn't switch them off); and
follow any additional instructions that come based on the pilot's outcomes.
So an import done through the pilot is still reported the usual way. And because this is a pilot, more instructions may follow as Bangladesh Bank learns what works, a bit like a new recipe that gets adjusted after the first tasting. I-11 doesn't say what those extra instructions will be or when they will come.
At the desk
Lamia's first pilot import is paid. Rakib asks Sadia whether the branch can skip its usual reports, since the platform has every record anyway. "Same reports as always," says Sadia. "And if additional instructions come based on the pilot's outcomes, we follow those too," she adds.
Key words
Reporting requirements
The returns and information a bank must regularly send to Bangladesh Bank.
Pilot basis
Trying a new way of working first on a small scale, before using it widely.
Read the rule as written (Para I-11)
ADs shall observe usual reporting requirements, including additional instructions based on pilot outcomes.
Source: Bangladesh Bank, FEPD-1 Circular No. 30, 13 August 2026, Part I, paragraph 11 (page 30). The original circular is the authority.
I-12, the last paragraph of Part I, tells us how the pilot starts and how it can grow.
Phased: the pilot is implemented on a phased basis, step by step, not all at once.
Only on approved trade corridors: it runs under approved trade corridors. A deal outside an approved corridor is not a pilot deal. I-12 doesn't list the corridors.
Growth is earned: expansion depends on satisfactory performance and regulatory assessment. Iyan compares it to a new shipping service: "You run one route well before you add more ports."
The old rules still stand: existing foreign exchange regulations remain applicable unless otherwise modified. Going digital changes how the documents travel. It doesn't cancel the import rules you met in earlier lessons, unless they have been modified.
At the desk
Lamia also buys from a supplier in another country and asks whether that shipment can go through the pilot too. Rakib checks with Sadia: the route is not an approved trade corridor, so the pilot doesn't cover it. "And on any route," Sadia adds, "the existing foreign exchange regulations still apply unless they have been modified," and Rakib notes it in the file.
Key words
Phased basis
Rolling something out step by step, in stages, rather than all at once.
Approved trade corridor
A trade corridor approved for the pilot: an approved route between two countries or regions through which banks pilot the digital processing of trade documents.
Read the rule as written (Para I-12)
(a) The pilot framework shall be implemented on a phased basis under approved trade corridors.
(b) Expansion shall be subject to satisfactory performance and regulatory assessment.
So far: under the pilot, ADs may process invoices, transport documents and drafts electronically, keeping ETRs singular, controlled and intact, using hashes where feasible and a paper fallback where needed; endorsement may use digital signatures, platforms or authenticated interbank messages, logs are the evidence, and only one party controls an ETR at a time. Import LCs and collections may use electronic presentation if the banks involved accept it, with paper originals where the other country doesn't recognise e-documents, and goods may be released through agreed electronic checks within the pilot. Banks must keep channels and data secure, give customers a safe digital front door, choose interoperable providers, keep reporting as usual, and grow the pilot in phases on approved trade corridors, with existing foreign exchange regulations still in force.
Next: Part I of the import room is complete. Part J, on retention of export proceeds for settlement of import payments, starts in Lesson 27, Keeping export earnings 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
I-6(a) lists commercial invoices, transport documents (including electronic bills of lading where applicable) and bills of exchange/drafts, including but not limited to these. (I-6)
I-6(b): where documents are ETRs, ADs ensure mechanisms preserve singularity, control and integrity. (I-6)
I-6(c): unique identifiers (e.g. digital fingerprints or hashes) shall be used where feasible to ensure document integrity. (I-6)
False. I-6(a) says "including but not limited to", so the list gives examples only. (I-6)
I-6(b): for ETRs, mechanisms must preserve singularity, the existence of a unique authoritative version. (I-6)
I-6(d): where full electronic handling of title documents is not feasible, hybrid arrangements with physical fallback may be applied. (I-6)
I-7(a) lists digital signatures, secure platform-based transfer mechanisms and authenticated interbank messaging systems. (I-7)
I-7(b): audit trails and system logs constitute evidence of endorsement, transfer of control, and receipt and acceptance. (I-7)
False. I-7(c): transfer of ETRs shall ensure that only one party exercises control at any point in time. (I-7)
I-7(a)(iii): authenticated interbank messaging may be used, particularly where platform-based channels are not available or mutually agreed. (I-7)
Set 2 of 3
I-7(b): platform-generated audit trails and system logs constitute evidence of receipt and acceptance. (I-7)
I-8(a): electronic presentation is subject to acceptance by the relevant banks involved, including issuing, advising, nominated or settlement banks, as applicable. (I-8)
I-8(b) applies where ETRs or electronic trade documents are not legally recognised or enforceable in the counterpart jurisdiction. (I-8)
I-8(c): release may be based on mutually agreed electronic confirmation and verification mechanisms within the approved pilot framework, subject to regulatory requirements and contractual terms. (I-8)
True. I-8(b)(i) lets ADs accept electronic copies of documents for preliminary verification purposes. (I-8)
I-8(b): ADs may accept electronic copies for preliminary verification and require physical documents of title or other originals where necessary. (I-8)
I-8(a): electronic presentation is subject to acceptance by the relevant banks involved, including advising banks, as applicable. (I-8)
I-9(a) lists encryption, authentication, time-stamping and tamper-proof audit logs. (I-9)
I-9(d): such interfaces shall ensure data security, user authentication, auditability and compatibility with interoperable systems. (I-9)
True. I-9(c) says exactly this. (I-9)
Set 3 of 3
I-9(a) needs time-stamping and tamper-proof audit logs as well as encryption and authentication. (I-9)
I-9(d) requires ADs to give customers digital interfaces to submit, access, track and manage trade documents and data. (I-9)
I-10(a) lists interoperability, independent verification of documents and acceptable governance and security standards. (I-10)
True. I-10(c) says such costs may be treated as normal banking charges. (I-10)
I-10(b): preference should be given to solutions that avoid vendor lock-in and support cross-platform compatibility. (I-10)
I-11 keeps the usual reporting requirements and adds any instructions based on pilot outcomes. (I-11)
I-11: ADs shall observe usual reporting requirements, including additional instructions based on pilot outcomes. (I-11)
I-12(a): the pilot framework is implemented on a phased basis under approved trade corridors. (I-12)
I-12(b): expansion is subject to satisfactory performance and regulatory assessment. (I-12)