29/11/2025
For years, of 2019 quietly reshaped the fate of in Bangladesh. Under this framework, banks were required to the names of employees dismissed for financial crimes, corruption, forgery, or loss of “moral aptitude” to the (Corporate Memory Management System) maintained by Bangladesh Bank. This database is mandatorily checked by banks at the time of . The practical has been clear—once listed in CMMS, re-entry into the banking sector becomes , regardless of time passed or any .
In substance, this system has long operated as a sector-wide exclusion mechanism. The expression “ ” is itself elastic and wide enough to capture almost every form of . As a result, a dismissal did not merely terminate an employment relationship with one bank—it imposed a across the entire industry.
But this long-settled position now begins to unravel with the #2025 amendment to the Bangladesh Labour Act. Section 2(78) of the amended Act now formally defines - as the creation of any list or database declaring a worker ineligible for future employment after dismissal. More critically, Section 195(1)(m) now expressly prohibits issuing any black-listing notice or including any worker in any such .
This is where the legal tension becomes impossible to ignore. The very logic on which -based recruitment screening operates—centralised recording for permanent sector-wide exclusion—now with a clear statutory prohibition. What for years functioned as a now sits on the fault line of legality.
This places the regulator in an unusually delicate position. On the one hand, was introduced as a prudential safeguard to protect the integrity of the . On the other hand, the Government of Bangladesh has now drawn a clear statutory line against black-listing and database-based exclusion. The result is a direct contradiction between practice and law.
So, with black-listing now by the 2025 Ordinance, the real question remains—how will Bangladesh Bank reposition CMMS?
Oh, on a side note, the Hon’ble has just clarified in a recent writ petition that also come within the of labour law, and therefore labour inspectors are legally permitted to and visit bank premises as well.
