From Liquidation to Illumination: Bangladesh Bank–Initiated Resolution, Court Supervised Accountability, and Public Interest Veil Lifting in NBFI Wind Downs -- A scholarly commentary / policy analysis

Bangladesh Bank (BB)’s 2026 move to wind down five non‑bank financial institutions (NBFIs)—FAS Finance, Fareast Finance, Aviva Finance, People’s Leasing and Financial Services, and International Leasing and Financial Services—signals a pivotal shift in Bangladesh’s financial governance by making institutional failure administratively possible. Yet liquidation is not synonymous with reform. In governance environments shaped by capture risk, agency failure, and ceremonial compliance, closure can become an accountability bypass that socialises losses while preserving controlling networks. This commentary proposes a visibility lens distinguishing integrity‑by‑default (truth becomes visible through ordinary controls, reporting, and supervision) from truth‑enforcement (truth must be compelled through forensics, ownership tracing, sanctions, and recovery). It then advances an implementable model: Bangladesh Bank–initiated resolution combined with court‑supervised accountability and veil‑lifting, supported by the statutory architecture of the Bank Resolution Act, 2026 (Act No. 88 of 2026)—including explicit recognition of Ultimate Beneficial Owners (UBOs) (Bangladesh Gazette Extraordinary, 10 April 2026, pp. 16660–16661). A structured Public Interest Veil‑Lifting Protocol is presented to convert wind‑down into enforceable accountability, reduce depositor residue, and limit “recyclable impunity.” Keywords: Bangladesh Bank; NBFI resolution; liquidation; veil‑lifting; Ultimate Beneficial Owner (UBO); forensic audit; asset recovery; regulatory capture; Anti‑Corruption Commission; Bangladesh Financial Intelligence Unit; Artha Rin Adalat.