The Bangladesh Competition Commission may take up the issue with stakeholders to stop manipulating the exchange rate

1. How insiders are manipulating Dollar rates
https://www.dhakatribune.com/business/2022/11/29/how-insiders-are-manipulating-dollar-
rates
The Bangladesh Competition Commission may take up the issue with stakeholders to stop
manipulating the exchange rate
Stacks of Bangladeshitaka Mehedi Hasan/ DhakaTribune
MS Siddiqui
November 29, 2022 4:36 PM
Some local and overseas banks secretlycollaboratedto fix the rate of the South African Rand
against the US Dollar.
The South African CompetitionCommissioncame to know about this and initiatedan
investigation.
During May 2015, their investigationfound involvements of Citigroup, Nomura, Standard Bank,
Investec, JP Morgan, BNP Paribas, Credit Suisse Group, CommerzbankAG, Standard New
York Securities Inc., Macquarie Bank, Bank of America Merrill Lynch (BAML), ANZ Banking
Group Ltd, Standard Chartered Plc and Barclays Africa (Absa), part of the Barclays Plc.
The commissionallegedthat the banks colluded with each other on prices for bids, offers and
bid-offer spreads for spot trades in relationto currencytrading involving the Dollar and the
Rand.

2. Following this, the commissionfound that the banks directlyand indirectlymanipulatedtrade of
the Dollar/Rand currency pair in relationto bids, offers,bid-offer spreads, spot exchange rate
and the terms and/or marginof executing client orders at the fix.
The commissionfined 10% of those banks' South African revenues.
Moreover, in May the following year, the commissionannounced that price fixing (both buying
and sellingprices), market divisionand tender collusion between competitors became criminal
offences in terms of section 73A(1) to (4) of the CompetitionAct, 2009).
The South African CompetitionAct also prohibiteddirect or indirect price-fixingbetween
competitors.
It also prohibited informationexchange between competitors which gave rise to anti-competitive
conduct.
The Bangladesh context
There are about 10 millionBangladeshi expatriates working in Middle Easterncountries.
They are a major source of foreign currencyfor the nation.
There are some exchanges in those countries which collect foreignexchange from expatriates
and send them back to Bangladesh.
According to Bangladesh Foreign Exchange Dealers Association (Bafeda), these exchanges in
other countries are making more profit than usual due to the lack of a uniform exchange rate in
case of bringing remittance Dollars.
Bafeda has informationthat currently90% of remittances come into the country through
domestic and foreign exchanges, which set the rate for sellingremittance Dollars to the banks.
It decided to set a Dollar rate on behalf of the country's banks to collect Dollars from the
exchanges at a reasonable price, which they term "one country, one exchange rate."
If the rate is implemented,all the banks will buy Dollars from the exchanges at a fixed price.
As a result,competitionamong banks will decrease, and the Dollar market will stabilize.
A source present at the meeting said the bank officials at the meeting signed a letter of consent to
accept these decisions.
In view of this decision, Bafeda issued a letter to hold a meeting with the Bangladesh Bank and
the Association of Bankers, Bangladesh (ABB) on September 7 earlier this year with the central
bank governor.

3. The governor tasked the ABB and Bafeda with settingthe Dollar exchange rate.
On the other hand, Bangladesh Bank on September 8 claimedthat it would allow the market,in
relationto demand and supply, to fix the exchange rate of the US Dollar against the Taka.
As the demand for Dollars increased due to the ongoing crisis,amid contractionof the area of
Dollar collection,the banks' interest in collectingDollars increased.
Competitionamong them also increased.
Utilizingthe opportunity, the exchanges are settingthe Dollar price much higher than normal for
their convenience.
Consequently, the banks are also sellingthe Dollar at a high price.
In a recent meeting, Bafeda decided to reduce the existingfixed rate of the Dollar.
Bangladesh's remittance inflow- which is already showing a steady decline - could continue on
this downward trend in the coming months as banks decided to lower the Dollar rate in foreign
exchanges from November 1, economists fear.
There is no dearth of evidence of fixationof the price of currency by trade associations.
A source present at the meeting said the bank officials at the meeting signed a letter of consent to
accept these decisions.
The CompetitionCommissionAct 2012, under sections 3 and 4, has jurisdictionon most
economic activities except involving national securityissues and goods and services not open for
the private sector.
The banking sector is open to the private sector.
The fixationof currency exchange rate is prohibitedunder the BCC Act, and the commission
may take action against the associationfor fixing the rate of the Dollar.
The banks in South Africa had colluded in a secret meeting,but the Bafeda had decided in an
open meetingwith consent from the governor of Bangladesh Bank and issued a press release to
the stakeholders.
The acts of Bafeda and ABB are illegal and the decision encourages expatriates to use the hundi
channel to get a fair price of their hard earned foreign currency.
Bangladeshi authorities have allowed banks to make profit keeping the rate below the set price
determinedby market mechanism.

4. Unfortunately,the legal experts and economists of the country remainedsilent except a few
about the consequences of tamperingcurrency rates.
IMF and World Bank also repeatedlyrequested for introducingfloatingcurrency rates to bring
optimum amount of foreign currencythrough banking channels.
The Bangladesh CompetitionCommissionmay take up the issue with stakeholders to stop
manipulatingthe exchange rate and increase inflow of the foreign currency in this crisis period
of the nation.
It is known that BCC has shortage of manpower and other infrastructure to investigate case
market manipulation,but in this case the evidence is available with Bangladesh and others.
Bafeda has decided to set a Dollar rate on behalf of the country's banks to collect Dollars from
the exchanges at a fixed price, under the pretext of "One Country, One Exchange Rate."
All the banks will buy Dollars from the exchanges at this “fixed price.”
According to them this collusive agreement will reduce competitionamongbanks, and the Dollar
market will reportedlystabilize.
This actionis illegal and has a very bad impact on our currency market.
The author is a legal economist and also non-government adviser at the Bangladesh
CompetitionCommission.He can be reached at mssiddiqui2035@gmail.com