With all due respect, you are being poorly advised about the benefits of whitening black money compared to the extensive loss of national reputation which could: 

* decrease foreign direct investment (FDI), 

* encourage capital flight, and; 

* accelerate a growing patriotism gap due to the corrosive effects of favoring the rich and powerful over the law-abiding, tax-paying citizens of this country where I have resided for the past 9.5 years.  

Let me present a few questions for your consideration that will demonstrate the multiple negative effects of this FY2024-25 black money whitening policy.

Is the government condoning the original fraud and embezzlement of funds that impacted the rights of business partners, foreign investors, shareholders, and senior managers due payouts under a profit-sharing scheme? 

“Who does money laundering?....The bribe takers and corrupts  are amongst us (the 5% educated people). We must change our character…”

Is the government substituting itself for international judicial processes? Why does the government have a superior right to these ill-gotten gains compared to others who have been defrauded?

The original embezzlement, defalcation, and tax fraud, arguably, were enabled via knowingly false certified financial statements and knowingly false audit reports issued by Bangladeshi chartered accountants or financial advisors. They too will now be exposed as part of a collusive relationship to defraud the government, foreign investors, business partners, shareholders, and others.

Will the government grant amnesty to all parties including the chartered accountants and financial advisors who not only committed a crime, but who also violated their dutifully sworn Code of Ethics? Is this the underlying reason for the policy in the first place?

If the amnesty extends to the chartered accountants and financial advisors, a reputational whitening, when a foreign direct investor, conducts a due diligence review to retain the services of Bangladeshi chartered accountants and financial advisors will the investors receive an honest answer to the following question: “Have you or your current or previous accounting firm or similar enterprise  been granted amnesty under a government-sponsored black money whitening policy?”

To corroborate responses to the above question, is a foreign direct investor conducting due diligence to retain the services of Bangladeshi chartered accountants and financial advisors guaranteed to receive an honest answer from the government to the following question submitted under the Right to Information Act: “Have any of the following, listed chartered accountants or accounting firms currently under consideration to provide technical and fiduciary services to our company ever been granted amnesty under a government-sponsored black money whitening policy?”  If the government declines to respond, is this not evidence of additional corruption? Isn’t the government itself conducting a corrupt act?

World-wide, the favorite place to launder money is in real estate so, it is not surprising that the only voice raised in support of this benighted black money whitening policy come from the real estate sector. Accordingly, recognizing the experience and expertise of companies in this industry, will the government have the skills to track the whitened money so that it does not foster additional corruption?  If the looters are celebrated for their “patriotic” acts what are the moral constraints that will guide other legitimate developers, especially those who play by the rules?  Is this a can of worms?

Will the government require a full financial and lifestyle audit as a condition of approving a whitening request (hoping, nevertheless, that you will choose a wiser path and reject this hare-brained scheme)? What about a case where an embezzler requests the government to whiten 2.5 crore which is, in reality, only a fraction of the 20 crore that was stolen from investors, stockholders, Board members, etc.  Approval of that request would be foolish, playing the government for a dummy. Will the government require a complete liquidation of looted funds as a condition for whitening and funds?

Granting complete confidentiality to the transgressors as part of the black money whitening exercise is a prima facie indicator that what is being done is illegal, immoral and unethical. If the looters were seeking forgiveness – not seeking a mild slap on the wrist – they would agree to be named. Morally reprehensible black money whitening cannot be enabled by some obscure accounting transaction! There must be a lesson taught and a lesson learned by the individual, the enterprise, the society, and the government. The spotlight of integrity needs to be shone on them.

In light of the above, Madame Prime Minister, I hope you will withdraw your approval and ask appropriate officials to cancel this policy. My recommendations are based on direct experience in over forty countries. If that is not enough, may I quote from an individual whom you know quite well:

“Today I will say that the number one task of the people of Bangladesh will be to eliminate the corrupt people from the soil of Bengal and I need your help”.

John Dalton is not affiliated with any organization, the ideas and recommendations are his own, personal observations and recommendations. He is a former State government official, advisor to the President of Liberia, the Prime Minister of Zimbabwe, the Anti-Corruption Commission in Zambia, and Department of Budget and Management in the Philippines, among other assignments.. He has carried out numerous consultancies for funding agencies on public financial management, general management, anti-corruption, and integrity.