Out by Invoice, Back by Treaty: Why Bangladesh's Missing Billions Are Stuck Abroad

1. A treaty for one account, and a test for the whole drive

Getting money out of Bangladesh took transfers and invoices; getting it back takes treaties, foreign courts and years. On 2 November the Cabinet, chaired by Prime Minister Tarique Rahman, approved the final draft of a mutual legal assistance agreement in criminal matters with Hong Kong, The Business Standard reported. Once signed, it would let the two sides share evidence and help each other trace and recover illicit assets. Hong Kong sent a first draft on 14 May 2025; its Department of Justice agreed the final text on 17 October 2026.

A case is waiting for it. On 9 September a Dhaka court, at the request of the Anti-Corruption Commission (ACC), ordered the seizure of assets and the freezing of bank accounts in Hong Kong belonging to Nazrul Islam Mazumder, chairman of the Nassa Group and a former chairman of Exim Bank, and his son and daughter. The ACC alleges that about Tk35,000 crore (some $2.8bn) was taken from 26 banks and laundered to the UK, the Isle of Man and Hong Kong, and names the three as beneficial owners of China Supreme Limited, a Hong Kong company with an account at the Bank of East Asia. How much reached Hong Kong has not been disclosed, and we found no public response from the family.

The agreement would be only Bangladesh's third, after India in 2010 and South Africa in 2019, and the first with one of the 10 jurisdictions the government has named as priorities for recovery. Of those ten, only Malaysia, Hong Kong and the UAE had agreed to sign by April; the US, the UK and Switzerland proposed memoranda of understanding or case-by-case agreements instead, The Daily Star reported. On 1 October Bangladesh Bank told MPs that the treaties with Malaysia and Hong Kong had been concluded, Prothom Alo reported, and that 30 requests for legal assistance had gone to 16 jurisdictions.

Chart 1

A short list of treaties

Mutual legal assistance (MLA) agreements and talks with priority jurisdictions (★), 2 Nov 2026

Hover or tap a row for dates and sources

JurisdictionStatus with BangladeshWhat it means in practice

India, South Africa

Signed

India in 2010, South Africa in 2019: the only two so far, and neither a priority.

Signed: India in 2010, South Africa in 2019Bangladesh's only two mutual legal assistance agreements so farNeither is among the 10 priority jurisdictionsSource: The Business Standard (2 Nov 2026)

Hong Kong ★

Approved 2 Nov

Text agreed by Hong Kong on 17 Oct 2026, approved by the Cabinet; not yet signed.

Approved by Bangladesh's Cabinet on 2 Nov 2026; not yet signedHong Kong sent a first draft on 14 May 2025; its Department of Justice agreed the final text on 17 Oct 2026Once signed, Bangladesh's third MLA agreement and the first with a priority jurisdictionSource: The Business Standard (2 Nov 2026)

Malaysia, UAE ★

Agreed to sign

Both had agreed to sign by April 2026; Bangladesh Bank says Malaysia's text is concluded.

Both had agreed to sign by April 2026Bangladesh Bank told MPs on 1 October 2026 that the treaty with Malaysia had been concludedSources: The Daily Star (1 Apr 2026); Prothom Alo (2 Oct 2026)

United Kingdom ★

In talks

Proposed an MoU or case-by-case deals instead; the NCA froze London property in 2025.

In talks: proposed an MoU or case-by-case agreements instead of a treatyThe Daily Star (1 Apr 2026)The NCA froze London property linked to the Rahman family in May 2025 and properties of Saifuzzaman Chowdhury in June

Singapore ★

In talks

Returned $2.66m in 2012-13 in the Koko case, without a treaty.

In talks; no treaty with BangladeshReturned $2.66m between November 2012 and August 2013 in the Koko case, after a US civil forfeiture actionStAR Asset Recovery Watch (updated 7 Dec 2023)

Switzerland ★

No reply

Proposed an MoU or case-by-case deals; a BFIU treaty letter had no reply by July 2026.

No reply to a BFIU letter on a treaty by July 2026Said by the BFIU chief (Daily Observer, 16 Jul 2026)Switzerland also proposed an MoU or case-by-case agreements (The Daily Star, 1 Apr 2026)

Four others ★

In talks

US, Canada, Australia, Thailand: no deal yet; the US also proposed an MoU or case-by-case deals.

US, Canada, Australia, Thailand: in talks, no agreement yetAll four are among the 10 priority jurisdictionsThe US also proposed an MoU or case-by-case agreements (The Daily Star, 1 Apr 2026)

Cyprus

Request granted

No agreement, yet a court froze an S Alam house on a Bangladeshi request in May 2026.

No agreement; Bangladesh's request granted in May 202619 May 2026: a Nicosia court froze a house of Mohammed Saiful Alam and his wifeOn an application by Cyprus's anti-money-laundering unit acting on a Bangladeshi request (Dhaka Tribune, 29 May 2026)

★ One of the 10 jurisdictions the government names as likely destinations of laundered money. By August 2026, 30 MLA requests had gone to 16 jurisdictions.

2. The $234bn is a leak, not a list of assets

The headline number estimates money that left, not money that can be found. It comes from a white paper committee chaired by Debapriya Bhattacharya of the Centre for Policy Dialogue (CPD), which handed its report to the interim leader, Muhammad Yunus, on 1 December 2024. It put illicit outflows under Sheikh Hasina's Awami League governments at about $234bn from 2009 to 2023, an average of $16bn a year and more than twice net foreign aid and foreign direct investment combined. "The problem is deeper than what we have thought," Bhattacharya said.

The method matters for recovery, and it is shakier than the total suggests. The estimate builds on Global Financial Integrity's trade figures for 2009-18, extended by the authors to 2023, according to a review in the Dhaka Courier, which called reliance on a single coefficient an oversimplification. Yet GFI, a Washington think tank, does not estimate illicit outflows in these reports: it measures value gaps between what exporters and importers record for the same trade, which may have a plausible explanation or reflect misinvoicing, and which its data cannot pin on either side. "To suggest that the estimated value gap is all related to one country would be incorrect," Tom Cardamone, a member of GFI's board and its president and chief executive until the end of 2025, wrote to Le Détroit on 4 November.

GFI's latest report, published in March 2026, puts the gaps in Bangladesh's trade at about $68.3bn in 2013-22, or $6.8bn a year, though GFI notes that Bangladesh reported data for only five of those years and, as countries can report to UN Comtrade years late, that this report alone should be used, not added to the earlier one. The report also cites trade-based laundering in Bangladesh through over-invoiced machinery imports: the channel is real, its size unknown. How the white paper got to $234bn is unclear even to GFI: "not having read the white paper, I cannot determine how the figure was arrived at," Cardamone wrote.

Taken at face value, the white paper's estimate explains the urgency in Dhaka. By Le Détroit's calculation, its average year of outflow equals 44% of gross foreign-exchange reserves on 26 October, 45% of a record year of remittances and almost three times the IMF programme agreed in 2023 and enlarged in 2025. On paper it is also 2.3 times GFI's average yearly gap, but the two do not compare like for like: GFI's ten-year average rests on only five years of Bangladeshi data, and GFI says its gaps are not estimates of illicit outflows and cannot be pinned on Bangladesh alone.

3. Freezing at home worked fast, then stalled

Domestic freezing was fast because it needs only a Bangladeshi judge, but the totals have barely moved since May. The interim government built the machinery within months: an inter-agency task force chaired by the central bank governor, and 11 joint investigation teams led by the ACC with police, tax and customs investigators. The Bangladesh Financial Intelligence Unit (BFIU) has since added a Stolen Asset Recovery Division, with technical help from bodies including the US Department of Justice. The 11 priority cases read like a roll-call of the old order: former land minister Saifuzzaman Chowdhury, Sheikh Hasina and her family, HBM Iqbal and the S Alam, Beximco, Sikder, Nassa, Orion, Bashundhara, Nabil and Summit groups, the finance minister told parliament on 24 June.

By August courts had attached or frozen assets worth Tk76,984 crore: Tk57,326 crore in Bangladesh and Tk19,658 crore abroad, according to Bangladesh Bank's report to parliament's Standing Committee on Estimates on 1 October, as described by Prothom Alo. At the central bank's rate of Tk124.30 per dollar on 2 November, that is about $6.2bn, including $1.58bn abroad. By Le Détroit's calculation, the total is 9% above the Tk70,446 crore the prime minister gave for 25 March, and the part abroad has risen by almost half, to a quarter of the whole; but the finance minister had already put the total at Tk76,814 crore in May, so it has grown by just 0.2% since.

The legal pipeline narrows sharply. Of 142 recovery cases filed by August, 16 had reached a charge sheet and six a verdict, and no return of money from abroad has been reported in these cases. "It normally takes four to five years to repatriate money from abroad; it is not instant," Ahsan H Mansur, then the central bank's governor, said in December 2025. His successor, Md Mostaqur Rahman, told newspaper editors on 8 June that $25m of assets frozen in the UK would soon be repatriated, The Business Standard reported; no such return has been reported since.

Set against the estimate, the freeze is small. Everything frozen so far equals 2.6% of the $234bn, and the part abroad 0.68%, by Le Détroit's calculation. The sum the ACC alleges was taken in the Nassa case alone equals nearly half of everything frozen.

4. Abroad, a Dhaka order is only a request

The bottleneck sits in foreign courtrooms, where Bangladesh must in effect win its case twice. A Bangladeshi freezing order has no force in London or Hong Kong. A local court has frozen overseas assets, but the freeze has not been enforced in those jurisdictions, The Financial Express reported in August, describing the response to dozens of requests as "lukewarm". Bhattacharya foresaw this in 2024: "After obtaining a decree from the host country, it must then be presented in the destination country."

Hong Kong's own rules show the hurdles: under its Mutual Legal Assistance in Criminal Matters Ordinance, it can act on a promise of reciprocity without a treaty, its Department of Justice explains in a guide updated in May 2026. But it restrains only identified property, cannot pay funds across until a final confiscation order is obtained abroad, and registers such an order only if it is no longer subject to appeal and those affected had notice and a chance to defend themselves. Nor is sharing automatic: Hong Kong's standard treaty clause leaves confiscated proceeds with the requested side unless both agree otherwise, though Hong Kong also applies the UN Convention against Corruption, which Bangladesh joined in 2007, to share or return assets with its parties. The treaty can settle those terms; recovery still depends on Bangladeshi convictions.

Every month on the ladder gives owners time to move. In July the BFIU chief, Ikhtiar Uddin Mohammad Mamun, said a foreign state had frozen Tk307 crore (about $25m) belonging to a former chairman of Eastern Bank and asked the BFIU to act, but administrative delays let the money leave for another jurisdiction. A High Court petition says Britain's crime agency held the funds for four weeks so that Bangladesh could act, then released them, and that they went to Dubai; on 25 August the court asked why BFIU officials should not face action, and the petition adds that the former chairman has since declared the money and paid tax and penalties on it. "We know that time is of the essence," Mansur told Al Jazeera in March 2025.

Chart 5

The seven rungs between a freeze and a refund

Steps a claim must climb to bring assets home, and where known cases stood on 2 Nov 2026

Hover or tap a rung or a case for details

returnedfrozen by a foreign authorityBangladeshi step, pending abroadslipped away

7

ReturnProceeds sent homeRung 7, return: proceeds sent homeHong Kong cannot pay funds across until a final confiscation order is obtained abroadIts standard treaty clause leaves confiscated proceeds with the requested side unless both agree otherwiseHong Kong DoJ asset-recovery guide (May 2026)

Koko case, Singapore$2.66m returned 2012-13 after a US forfeiture order

Koko case: $2.66m returned by Singapore, Nov 2012 to Aug 2013From accounts linked to Arafat Rahman Koko, after a US civil forfeiture action; recovery began in 2008StAR Asset Recovery Watch (updated 7 Dec 2023)

6

Enforce abroadForeign court registers itRung 6: a foreign court registers the orderHong Kong registers one only if it is no longer subject to appeal and those affected had notice and a chance to defend themselvesNo case from the current drive has reached this rung

No case from the current drive has reached this rung

5

Confiscate at homeFinal order, beyond appealRung 5: a final order at home, beyond appealSix verdicts in recovery cases by August 2026, none reported enforced abroadForeign judges test notice and a fair hearing, which in-absentia verdicts will make harder, in Le Détroit's reading

Six verdictsin recovery cases by August 2026; none reported enforced abroad

Six verdicts in recovery cases, by August 2026Of 142 cases filed, 16 reached a charge sheetNone reported enforced abroadBangladesh Bank via Prothom Alo (2 Oct 2026)

4

Freeze abroadRestraint of named propertyRung 4: a foreign authority restrains named propertyHong Kong restrains only identified propertyShown: freezes in the UK and Cyprus, and one UK hold that lapsed

Saifuzzaman ChowdhuryUK: NCA freeze, June 2025; firms in administration

Saifuzzaman Chowdhury: NCA freezing orders, June 2025Properties including a house in St John's Wood bought for £11mSix companies that held his UK portfolio went into administration; Grant Thornton was appointed to sell properties to repay lendersHe says his wealth was legitimately earned

Rahman familyUK: NCA freezes, May 2025; £86m to £90m

Rahman family: NCA freezing orders, May 2025London property linked to Ahmed Shayan Rahman and Ahmed Shahryar Rahman, the son and a nephew of Salman F RahmanWorth £86m by TI-UK's count, almost £90m by The Guardian's; civil freezesA spokesperson for Ahmed Shayan Rahman said he denies any wrongdoing

S AlamCyprus: house frozen May 2026

S Alam: house in Cyprus frozen, 19 May 2026By a Nicosia court, on an application by Cyprus's anti-money-laundering unit acting on a Bangladeshi requestMohammed Saiful Alam denies wrongdoing and has taken Bangladesh to ICSIDDhaka Tribune (29 May 2026)

Ex-Eastern Bank chairmanUK hold on about $25m lapsed; money moved to Dubai, a petition says

Ex-Eastern Bank chairman: a UK hold on about $25m lapsedThe BFIU chief said in July 2026 that a foreign state had frozen Tk307 crore of his, but administrative delays let it leaveA High Court petition says Britain's crime agency held the funds for four weeks, then released them, and that they went to DubaiThe petition adds that he has since declared the money and paid tax and penalties; bdnews24 (25 Aug 2026)

3

AskBy treaty or reciprocityRung 3: a request, by treaty or reciprocity30 requests for legal assistance to 16 jurisdictions by August 2026Hong Kong can act on a promise of reciprocity without a treaty

30 requests, 16 jurisdictionssent by August 2026

30 requests for legal assistance to 16 jurisdictions, by August 2026Bangladesh Bank told MPs on 1 October (Prothom Alo, 2 Oct 2026)The Financial Express described the response to dozens of requests as lukewarm, in August 2026

2

Freeze at homeDhaka court attachesRung 2: a Dhaka court attachesTk57,326 crore frozen at home by August 2026 ($4.61bn at Tk124.30, Le Détroit's conversion)A Bangladeshi freezing order has no force in London or Hong Kong

Nassa family, Hong KongDhaka court order, 9 Sep 2026; no Hong Kong freeze reported

Nassa family: Dhaka court order, 9 Sep 2026Seizure of assets and freezing of bank accounts in Hong Kong of Nazrul Islam Mazumder and his son and daughter, at the ACC's requestNo Hong Kong freeze reported; the sum allegedly moved there has not been disclosedThe Business Standard (2 Nov 2026)

1

TraceBFIU, joint teamsRung 1: trace the money11 joint investigation teams led by the ACC with police, tax and customs investigatorsA task force chaired by the central bank governor; a Stolen Asset Recovery Division at the BFIU

11 priority cases11 joint investigation teams

11 priority cases, 11 joint investigation teamsSaifuzzaman Chowdhury, Sheikh Hasina and her family, HBM Iqbal and the S Alam, Beximco, Sikder, Nassa, Orion, Bashundhara, Nabil and Summit groupsFinance minister in parliament, 24 Jun 2026 (UNB)

A simplified sequence; the UK freezes are civil. The Rahman family values are Transparency International UK's (£86m) and The Guardian's (almost £90m). Those named deny wrongdoing or have not responded.

5. London froze first, but others may be paid first

Where foreign authorities have acted, the money still has other claimants, and the owners are fighting back. The UK moved earliest. In May 2025 the National Crime Agency (NCA) obtained freezing orders on London property linked to Ahmed Shayan Rahman and Ahmed Shahryar Rahman, the son and a nephew of Salman F Rahman, whose Beximco group is on Dhaka's priority list; the property is worth £86m by Transparency International UK's count and almost £90m by The Guardian's. A spokesperson for Ahmed Shayan Rahman said he "denies any involvement in any alleged wrongdoing in the strongest possible terms". In June the NCA froze properties of Saifuzzaman Chowdhury, including a house in St John's Wood bought for £11m; he says his wealth was legitimately earned and calls the investigation a politically motivated "witch-hunt".

A freeze is not a refund. Six companies that held Chowdhury's UK portfolio went into administration, and Grant Thornton was appointed to sell properties to repay lenders including Singapore's DBS and the British Arab Commercial Bank, Prothom Alo reported in August 2025, citing The Daily Telegraph. Grant Thornton has since applied to a UK court for worldwide freezing orders under bankruptcy rules, which Dhaka hopes will serve its own claim, and Mansur said in December that two Bangladeshi banks had filed claims in London.

S Alam shows the counter-attack. On 19 May 2026 a court in Nicosia froze a house owned by Mohammed Saiful Alam and his wife, on an application by Cyprus's anti-money-laundering unit acting on a Bangladeshi request, the Dhaka Tribune reported. Alam, a Singaporean, denies wrongdoing, says his investments came from "legitimate foreign sources" and has taken Bangladesh to the World Bank's investment tribunal, ICSID, claiming damages his side estimates in the hundreds of millions. His Singapore lawyers call the court orders behind a five-month sentence passed in absentia in Chattogram in May "invalid".

6. A new government, an old pattern

Recovery has long been entangled with politics in Bangladesh, and foreign judges will look at how cases were won. The Bangladesh Nationalist Party (BNP) won a two-thirds majority in February's election, from which Sheikh Hasina's Awami League was barred, and Tarique Rahman, son of the former prime minister Khaleda Zia, was sworn in on 17 February. "Those who looted or siphoned off the people's money will face punishment as per the existing laws of the country," he told parliament on 1 April, according to UNB.

The accused see a purge. Sheikh Hasina, sentenced in absentia in November 2025 to 21 years in three cases over plot allocations, and her family called the cases "malicious, politically motivated and without any proper foundation". The BFIU's chief says his staff do not consider political affiliation, and that anyone in the interim government involved in laundering would also be exposed.

History cuts both ways: the precedent usually cited in Dhaka is the $2.66m Singapore sent back between November 2012 and August 2013 from accounts linked to Arafat Rahman Koko, Khaleda Zia's younger son and so the prime minister's brother, after a US civil forfeiture action; Koko had been convicted in absentia in 2011. Recovery began in 2008, according to the World Bank and UNODC's StAR database: five years for less than $3m. The only return from abroad we found since 2024 lies outside the priority cases: in March 2026 the police's Criminal Investigation Department brought home about $3.6m in cryptocurrency laundered abroad through MTFE, a Ponzi scheme that collapsed in 2023. "Chasing the stolen assets globally would give a strong signal to the persons involved in money laundering," Mustafizur Rahman of the CPD told The Financial Express.

Chart 7

Two speeds: out fast, back slowly

Key dates in Bangladesh's asset-recovery drive, 2012 to 2026

Hover or tap a date for details

Nov 2012 to Aug 2013

Singapore returns $2.66m in the Koko case, the precedent cited in Dhaka

$2,661,070 returned by Singapore, Nov 2012 to Aug 2013From accounts linked to Arafat Rahman Koko, after a US civil forfeiture action; Koko had been convicted in absentia in 2011StAR Asset Recovery Watch (updated 7 Dec 2023)

Aug 2024

Sheikh Hasina’s government falls; an interim government takes over

Aug 2024: Sheikh Hasina's government fallsAn interim government, led by Muhammad Yunus, builds the recovery machinery within monthsA task force chaired by the central bank governor; 11 joint investigation teams led by the ACC

1 Dec 2024

The white paper puts illicit outflows at about $16bn a year in 2009-23

White paper: about $234bn in 2009-23, $16bn a yearCommittee chaired by Debapriya Bhattacharya (CPD), handed to Muhammad YunusA review says it builds on GFI's trade figures; GFI says its own figures are trade-record gaps, not illicit outflowsThe Business Standard (1 Dec 2024)

14 May 2025

Hong Kong sends Dhaka a draft legal-assistance agreement

14 May 2025: Hong Kong sends a first draftIts Department of Justice agreed the final text on 17 Oct 2026, 17 months later, by Le Détroit's countThe Business Standard (2 Nov 2026)

May to Jun 2025

The UK’s NCA freezes London property tied to the Rahman family, then to Chowdhury

NCA freezing orders on London property, May and June 2025May: property linked to the Rahman family, £86m to almost £90m; June: properties of Saifuzzaman ChowdhuryCivil freezes; Ahmed Shayan Rahman denies wrongdoing, and Chowdhury calls the investigation a politically motivated witch-huntTI-UK (May 2025); Al Jazeera (11 Jun 2025)

17 Feb 2026

Tarique Rahman (BNP) is sworn in as prime minister

17 Feb 2026: Tarique Rahman sworn in as prime ministerThe BNP won a two-thirds majority in an election from which the Awami League was barredHe is the son of the former prime minister Khaleda ZiaMalay Mail (17 Feb 2026)

19 May 2026

A Nicosia court freezes S Alam’s house in Cyprus

19 May 2026: S Alam's house in Cyprus frozenBy a Nicosia court, on an application by Cyprus's anti-money-laundering unit acting on a Bangladeshi requestAlam denies wrongdoing; Dhaka Tribune (29 May 2026)

9 Sep 2026

A Dhaka court orders the seizure of Nassa family assets in Hong Kong

9 Sep 2026: a Dhaka court orders the seizure of Hong Kong assetsAssets and bank accounts there of Nazrul Islam Mazumder and his son and daughter, at the ACC's request; no Hong Kong freeze reportedThe ACC names them as beneficial owners of China Supreme Limited, with an account at the Bank of East AsiaThe Business Standard (2 Nov 2026)

17 Oct to 2 Nov 2026

Hong Kong agrees the final text; Bangladesh’s Cabinet approves it

17 Oct 2026: Hong Kong agrees the final text; 2 Nov 2026: Bangladesh's Cabinet approves itThe Cabinet was chaired by Prime Minister Tarique Rahman; the agreement is not yet signedIt would be Bangladesh's third, after India (2010) and South Africa (2019)The Business Standard (2 Nov 2026)

7. Le Détroit's reading

The Hong Kong agreement will not bring back $234bn, nor most of the $6.2bn frozen. That estimate rests on trade-record gaps that GFI, which calculates them, does not pin on Bangladesh alone, and a gap in trade statistics names no account to freeze. The recoverable part is the identified property of a few families and groups, held where mortgage lenders, insolvency administrators and investment-treaty lawyers stand in the queue ahead of Dhaka. Our reading is that the Tk57,326 crore frozen at home is the only pool Bangladesh fully controls, and that plea bargains or an amnesty, options Mansur floated in 2025, could return more, faster, than foreign courts; the convictions Bangladesh needs abroad must also survive foreign judges' tests of notice and a fair hearing, which in-absentia verdicts and the former ruling party's exclusion from the vote will make harder.

So far the clearest beneficiaries are lawyers, administrators and secured lenders abroad; the losers are Bangladeshi depositors and taxpayers, whose banks were drained and whose reserves the estimated outflow dwarfs. Three signals will show whether the drive is more than a freezing campaign: whether the Hong Kong agreement is signed with a sharing clause that favours return and Hong Kong's authorities seek a restraint order over the China Supreme account; whether the BFIU delivers the first reported return in the priority cases by the end of 2026, the deadline its chief set for "good news"; and whether a foreign forum, starting with S Alam's ICSID claim or the UK insolvency case, accepts a Bangladeshi judgment.