Transport documents to the bank's order, the USD 100,000 facility, endorsements, direct dispatch and freight forwarder documents.
A Bill of Lading is like the key to a locked warehouse: whoever holds it can claim the goods. If the buyer gets the key before paying, the exporter (and Bangladesh) may never see the money.
That's why the rules usually keep the key with the bank until payment is safe. This lesson explains the normal rule and the carefully fenced exceptions.
The normal rule, given to every carrier (shipping lines, airlines, railways) and their agents:
Fresh mangoes flown to London can't wait for a bank courier, so perishables are exempt from the air rule. A container of jackets to Hamburg can wait, so its Bill of Lading goes to the bank's order.
In exercise of the powers vested in Bangladesh Bank under Section 20(3) of the FER Act, 1947 all carriers whether common or private (Railway, Shipping, or Airline companies), and their agents are directed as under:
(a) Transport documents, title to export of goods, must be drawn to the order of an AD in respect of exports of goods from Bangladesh (excluding exports from Type A industrial enterprise located in specialized zones) via land or sea routes. These documents shall be handed over to the authorized representatives of the designated AD only.
(b) If the goods reach the beneficiary port before the transport documents reach the foreign importer, the AD may request shipping companies to issue Delivery Order to deliver the goods to the order of AD's correspondent in the buyer's country. The AD also needs to send instructions through authenticated channel to its overseas correspondent to hand over Delivery Order to the consignee, and stating the amount to be realized from the consignee before the Delivery Order is released.
(c) In respect of export of goods from Bangladesh (excepting exports from Type A industrial enterprise located in specialized zones) to foreign countries by air, the Airway Bills and any other documents of title to cargo should be drawn to the order of a bank in the country of import nominated by the AD designated for this purpose by the respective exporter and delivered to the authorized representative of AD. The above directions shall not apply to exports exempted from repatriation of export proceeds as listed in paragraph 7 of this part. Exports of fresh fish, vegetables, fruits, poultry and other goods of perishable nature are also exempted from this direction.
(d) Railway Receipts, Bill of Lading, Airway Bill and other documents of title to cargo may be drawn to the order of importer or other designated parties only if (i) the shipment is being made against full payment received in advance by the exporter through AD and (ii) it is a requirement of export LC/contract. In this context, designated AD shall issue a certificate in the prescribed form (as per Appendix-3) to be produced to the carrier company, enabling them to draw the shipping documents accordingly.
Source: Bangladesh Bank, FEPD-1 Circular No. 26, 30 July 2026, Part A, paragraph 14 (page 11). The original circular is the authority.
New to the master circular (first issued by FEPD-1 Circular No. 06, March 2026). For shipments up to USD 100,000, a bank may let the exporter have the transport documents issued in the importer's name and sent straight to the importer, with a bank certificate to the carrier (Appendix-4). The fences:
A trusted exporter with USD 3 million of exports over three years, and no overdue bills, ships USD 60,000 of ceramics to a long-time buyer who wants documents directly. Allowed, with written consent and close follow-up. A new exporter with one past-due bill? Not allowed.
ADs may allow exporters, for shipment value up to USD 1,00,000 or equivalent, to arrange for transport documents, to be issued in the name of foreign importers or other designated parties, and to have them dispatched same to importers or other designated parties, upon issuance of a certificate (as per Appendix-4) to carrier companies, subject to the following conditions:
(a) Repatriation safeguards:
(1) Exporters shall provide written consent for availing this facility, and ADs must be satisfied with the repatriation mechanism before granting permission.
(2) ADs shall ensure that the arrangements do not compromise, in any manner, realization of export proceeds and shall maintain effective monitoring to secure timely repatriation within the statutory period.
(3) The respective exporter shall have no overdue export proceeds.
(b) Eligibility and operational conditions:
(1) ADs shall obtain valid export orders requiring such arrangements of shipments and satisfy themselves about the bonafides of foreign importers/consignees in accordance with the provisions of paragraph 13(1) of this part.
(2) The facility shall be available only to exporters with a minimum realization of USD 1.00 million or equivalent in aggregate export proceeds during the last three financial years.
Source: Bangladesh Bank, FEPD-1 Circular No. 26, 30 July 2026, Part A, paragraph 15 (page 12). The original circular is the authority.
When the transport document is made out to the bank's order, the bank endorses it to its foreign correspondent, never in blank and never straight to the buyer without Bangladesh Bank's approval. (Type A zone enterprises may blank-endorse or endorse to the buyer if the LC/contract says so.)
If the full money arrives after shipment but before the documents are sent abroad, there's no need to send them for collection. The bank may endorse them to the importer and deliver as the LC/contract says.
A blank endorsement is like signing a cheque and leaving the name empty: anyone holding it can use it. That is why it is not allowed without permission.
(1) ADs to whose order the relative Railway Receipts, Bills of Lading, etc. are drawn shall endorse the same to the order of their foreign correspondents but in no case, they shall make any blank endorsement or endorse it to the order of the consignee unless they have obtained specific or general approval of Bangladesh Bank thereof. However, in the cases of export from Type A industrial enterprises located in specialized zones, Bill of Lading/Airway Bill/other documents of title to cargo drawn to the order of ADs may be blank endorsed or endorsed in favor of the consignees as per terms of the export LC/contract.
(2) In case of export proceeds received after shipment but before sending export documents abroad for collection, it does not warrant documents to be sent abroad for collection. ADs may endorse transport documents of title to cargo in favor of the importer or other designated party and deliver the same as per stipulations of export LC/contract only if full export proceeds are received through normal banking channel before sending export documents to counterpart bank abroad for collection.
Source: Bangladesh Bank, FEPD-1 Circular No. 26, 30 July 2026, Part A, paragraph 16 (page 12). The original circular is the authority.
A bank may let the exporter send export documents directly to the importer through secure channels, except the original transport document of title, if:
The buyer wants copies of invoice and packing list fast, to prepare customs clearance at their end. The exporter couriers them directly. But the original Bill of Lading, the "key", stays with the bank.
ADs may allow exporters to dispatch export documents (excluding original transport document of title to cargo) directly to importers or their agents abroad through secured media, subject to observance of following instructions:
(a) The underlying LC/contract provides for such direct dispatch of export documents.
(b) ADs shall be satisfied with the arrangement of realization of export proceeds within the statutory period as per paragraph 8 of this part.
(c) ADs shall endorse original transport documents retained with them on receipt of payment against relevant export.
(d) ADs shall, within 14 days from the date of shipment, obtain EXP Form from exporters to comply with regulatory instructions, including routine reporting to Bangladesh Bank.
(e) Exporters' accounts with ADs are fully compliant with KYC/AML/CFT guidelines in force.
Source: Bangladesh Bank, FEPD-1 Circular No. 26, 30 July 2026, Part A, paragraph 17 (page 13). The original circular is the authority.
Sometimes the shipping document comes from a freight forwarder rather than the shipping line or airline: an FCR, a House B/L (HBL) or a House AWB (HAWB). A bank may negotiate a bill on such documents only if:
An LC says "Forwarder's Cargo Receipt acceptable". Good start. Rina still checks the forwarder's Customs licence before negotiating. An unlicensed forwarder's paper is just paper.
In case of negotiation of export bills using FCRs, HBLs, or HAWBs issued by freight forwarders, the following additional conditions are to be fulfilled:
(a) The export LC/contract specifically provides for negotiation of export bill against FCR/HBL/HAWB (as the case may be) issued by a freight forwarder;
(b) The freight forwarder issuing the FCR/HBL/HAWB is operating in Bangladesh with license from the Customs Authority; and
(c) ADs will be responsible for satisfying themselves about the arrangement for timely repatriation of proceeds of export bill negotiated against FCR/HBL/HAWB.
Source: Bangladesh Bank, FEPD-1 Circular No. 26, 30 July 2026, Part A, paragraph 18 (page 13). The original circular is the authority.
The key to the goods usually stays with the bank. It usually goes to the buyer directly only with full advance (when the LC/contract requires it), under the USD 100,000 facility for proven exporters, after full payment, or with Bangladesh Bank's approval. Zone (Type A) exports and perishables by air have their own easier rules. Next: what may be deducted from the export value, and which Incoterms are allowed.
Four quick questions. Nobody sees your answers but you.
A-15: shipment value up to USD 100,000 or equivalent.
A-15(b)(2): a minimum of USD 1.00 million in aggregate over the last three financial years.
A-14(c): perishables are exempt, along with the A-7 exports.
A-18 lists exactly these three conditions.
Anonymous. It only adds one to a count, so we know who the lessons are helping. We never learn who you are.
Brain feeling full? Take a tea break.