Economic Sanctions and Export Controls in Bangladesh
Economic sanctions and export controls advice for Bangladeshi exporters, importers, banks, shipping and technology businesses, and for foreign groups trading with Bangladesh, covering screening, blocked or delayed payments, dual-use goods, contract protections, bank enquiries, voluntary disclosures and regulatory investigations at home and abroad.
- Rapid issue assessment
- Evidence and documentation
- Engagement and licensing
- Controls and follow-through
Economic sanctions and export control risk for Bangladesh trade
Bangladesh does not maintain a broad autonomous sanctions regime of its own, yet economic sanctions affect Bangladeshi businesses every day. Banks clearing dollar, euro and sterling payments through foreign correspondents screen every party, vessel and port against United States, United Nations, European Union and United Kingdom lists. A single match can freeze a letter of credit, delay an export shipment or end a banking relationship. We advise exporters, importers, banks, shipping and logistics companies and foreign investors on how these rules reach transactions with a Bangladesh connection, and how to manage the commercial consequences when something goes wrong.
The legal picture combines domestic and foreign rules. United Nations Security Council measures are given effect in Bangladesh through anti-terrorism and anti-money laundering legislation, with Bangladesh Bank and the Bangladesh Financial Intelligence Unit setting screening and reporting expectations for reporting organisations. Foreign economic sanctions, particularly those administered by the United States Treasury, the European Union and the United Kingdom, apply through the nationality of banks, currencies, goods and personnel. We help clients understand which regime actually applies to a particular deal and why, rather than assuming every foreign list binds every Bangladeshi party in the same way.
Export controls raise a related but separate set of questions. Goods, software and technology originating in the United States or Europe can remain controlled after they reach Bangladesh, so re-exports of machinery, telecoms equipment, chemicals, drones, encryption products and certain components may require foreign licences. Bangladesh's own import and export policy instruments restrict or condition trade in some products, and treaty commitments such as the Chemical Weapons Convention impose controls on scheduled chemicals. We review product classifications, end users and end uses so that a sale does not create liability for the seller, the buyer or their banks.
When a payment is stopped or a counterparty is designated, speed matters. We act for businesses whose funds are held by banks pending sanctions review, whose shipments are delayed at Chattogram or Mongla, or whose foreign buyers have suspended orders pending their own economic sanctions checks. We prepare clear written explanations and supporting evidence for banks, engage with correspondent bank compliance teams, review licensing options with foreign counsel, and advise on whether contracts can be suspended, terminated or performed lawfully. Where economic sanctions disputes reach court or arbitration, we work with our dispute resolution team.
This economic sanctions practice sits within our regulatory work in Bangladesh. Barrister Tahmidur Rahman and Barrister Remura Meheruba Mahbub advise on transactions, banking and foreign investment matters, and Adv Syed Wahid leads related litigation. We coordinate with counsel in the UK, US, UAE, China, India and Singapore when a matter requires foreign law advice or a licence application abroad. Our aim is practical and commercial: identify the economic sanctions and export control exposure early, document a defensible position, and keep legitimate trade moving without exposing directors or the business to penalties, banking restrictions or reputational harm.
Core workstreams
Four clear stages
- 01Rapid issue assessment
- 02Evidence and documentation
- 03Engagement and licensing
- 04Controls and follow-through
Talk to a partner
Consultations in Dhaka or by video. Scope, team and fees are agreed in writing first.
Book →How we help with sanctions and export controls
Sanctions screening and risk assessment
- Rapid issue assessment
- Evidence and documentation
- Engagement and licensing
- Controls and follow-through
Blocked and delayed payments
- Rapid issue assessment
- Evidence and documentation
- Engagement and licensing
- Controls and follow-through
Export control classification and licensing
- Rapid issue assessment
- Evidence and documentation
- Engagement and licensing
- Controls and follow-through
Transaction due diligence and contracts
- Rapid issue assessment
- Evidence and documentation
- Engagement and licensing
- Controls and follow-through
Shipping, ship recycling and logistics
- Rapid issue assessment
- Evidence and documentation
- Engagement and licensing
- Controls and follow-through
Investigations and voluntary disclosures
- Rapid issue assessment
- Evidence and documentation
- Engagement and licensing
- Controls and follow-through
Sanctions screening and risk assessment
We assess a business's exposure to economic sanctions by reviewing its customers, suppliers, ownership chains, vessels, ports, currencies and banks. We then help design proportionate, workable screening procedures, escalation rules and record keeping, and we advise on the ownership and control tests that can extend sanctions to entities that do not appear on any list by name, which is where many Bangladeshi businesses are caught out by economic sanctions they never expected to apply.
Blocked and delayed payments
When a bank holds funds, returns a payment or refuses to process a letter of credit, we review the reason, gather supporting documents and prepare a structured response for the bank and its correspondent. We advise frankly on whether release is realistic and when, whether a foreign licence is needed, and how to protect the client's position under the underlying contract and the applicable documentary credit rules while the review continues.
Export control classification and licensing
We help manufacturers, importers, distributors and technology companies identify whether their goods, software or technical data are controlled, working with foreign counsel on classification under the relevant regimes. We advise on end-user certificates, re-export conditions, deemed exports of technology to foreign staff, and whether a licence is required before a shipment from or through Bangladesh, a transfer of source code or the provision of technical services to foreign customers.
Transaction due diligence and contracts
We carry out economic sanctions due diligence on targets, joint venture partners, lenders, suppliers and buyers in mergers, financings and supply arrangements. We draft and negotiate sanctions representations, compliance undertakings, termination rights, force majeure wording and payment mechanics so that each party knows what happens if a designation or new restriction takes effect during the life of the contract, including how losses, costs and delays are shared between them.
Shipping, ship recycling and logistics
Bangladesh's ports, shipping lines and ship recycling yards face particular sanctions scrutiny, including vessel ownership history, flag changes, ship-to-ship transfers and cash buyer structures. We review charterparties, sale contracts for end-of-life vessels, cargo documentation and insurance arrangements, and advise yard owners, carriers and forwarders on the evidence that banks, insurers and buyers will expect to see before payment is released. Early review is far cheaper than a frozen sale price.
Investigations and voluntary disclosures
If a possible breach is discovered, we help the business investigate the facts, preserve documents, interview staff and decide, with foreign counsel, whether a disclosure to a foreign authority is advisable. In Bangladesh, we advise on reporting obligations to Bangladesh Bank and the Bangladesh Financial Intelligence Unit, and on managing related enquiries from banks, auditors, investors and international buyers, keeping every account of the facts consistent and properly privileged.
Partner-led, on every matter.
Trade, Competition & Regulation matters at TRW are led by partners, supported by associates, with one responsible lawyer from first advice to final outcome.
Meet the firm →01Do United States economic sanctions apply to a Bangladeshi company?
United States economic sanctions primarily apply to United States persons, but they reach non-US companies in several ways. Payments in US dollars usually pass through US banks, US-origin goods and software carry export restrictions, and secondary sanctions can target foreign companies that deal with designated parties in certain sectors. In practice, Bangladeshi banks apply these lists because their correspondents require it. We analyse which elements of a transaction create a US connection and advise whether the risk can be managed, restructured or must be avoided altogether, so the client can take an informed commercial decision before funds or goods move.
02Our bank has frozen an export payment. What can we do?
First, find out exactly what the bank needs. Many holds arise from name matches, vessel history, transhipment ports or incomplete documents rather than a genuine sanctions breach. We prepare a clear response with ownership information, shipping documents, end-user details and screening results, and engage with the bank's compliance team. If the hold arises from a true match, we advise on foreign licensing routes and on the client's rights against the buyer, the bank and insurers. Acting quickly and keeping communications accurate and consistent often makes the most difference to the outcome, and to the banking relationship.
03How do economic sanctions affect letters of credit in Bangladesh?
Most Bangladeshi trade finance runs through documentary credits, and many credits now include sanctions clauses allowing banks to refuse to deal with sanctioned parties, goods or routes. International banking guidance treats some broad clauses as problematic, but banks still rely on them. Economic sanctions issues can arise at issuance, confirmation, presentation or payment. We review the credit terms before shipment, advise beneficiaries and applicants when a bank refuses payment on sanctions grounds, and assess carefully whether the refusal is justified under the credit, the applicable rules and the underlying sale contract, and what remedies follow.
04Are dual-use goods controlled when exported from Bangladesh?
They can be. Bangladesh's own export policy restricts some products, and treaty obligations cover specific categories such as scheduled chemicals. More often, the control comes from the country where the goods, components or technology originated. A Bangladeshi distributor re-exporting US or European equipment to a third country may need a foreign licence even though Bangladesh imposes none. We review product specifications, country of origin, end users and final destinations, coordinate classification with foreign counsel where needed, and recommend the documentation that should accompany the shipment and be kept on file for later bank or buyer enquiries.
05What ownership checks should we run on a new counterparty?
Screening the counterparty's name is not enough. Several regimes extend restrictions to entities owned or controlled by designated persons, sometimes above a fixed ownership threshold and sometimes based on control. Checks should therefore cover shareholders, directors, beneficial owners, parent companies and key agents, together with the vessels, ports and banks involved. We design proportionate economic sanctions due diligence for different risk levels, from simple supplier onboarding to acquisitions and long-term supply agreements, and advise on what to do when information is incomplete, inconsistent or refused by the counterparty during onboarding. Records of each check should be kept for later review.
06Can we terminate a contract because new economic sanctions were imposed?
It depends on the contract wording and the governing law. Many contracts contain sanctions or illegality clauses, and force majeure clauses may or may not cover new economic sanctions. Under Bangladesh contract law, performance that becomes unlawful may be excused, but a party that terminates without a sound basis risks a damages claim. We review the clause, the restriction actually imposed and whether lawful performance remains possible through a licence or alternative route, then advise on suspension, variation or termination and on the notices that should be served to protect the client's position if a dispute follows.
07Do software and cloud services raise export control issues?
Yes. Encryption software, certain development tools and technical data can be controlled, and providing access to controlled technology to people of certain nationalities may count as an export under some foreign regimes. Bangladeshi software companies serving foreign clients, and foreign groups with development teams in Dhaka, should understand where their code and data come from and who can access them. We review software licensing terms, user access controls and customer service agreements, and work with foreign counsel on classification so that the business can continue to sell and support its products lawfully in every market it serves.
08What should a Bangladeshi business do after discovering a possible breach?
Stop the activity if it is continuing, preserve documents and avoid internal speculation by email or messaging. Then establish the facts through a privileged internal review, ideally led by lawyers, covering what happened, who was involved, which regimes apply and what money or goods moved. Decisions on disclosure to foreign authorities need careful advice, because benefits and risks differ between regimes. We also consider Bangladesh reporting duties, bank notifications, insurance and employment issues, and help the board document a measured response to the economic sanctions concern that protects the business, its officers and its banking relationships.
From first call to resolution.
- 01
Rapid issue assessment
We identify the parties, goods, payment route, vessels and jurisdictions involved, establish which economic sanctions and export control regimes actually apply, and advise on immediate steps to avoid further exposure while the facts are gathered and verified.
- 02
Evidence and documentation
We collect ownership records, contracts, shipping papers, product specifications and screening results, and prepare a single consistent written explanation that banks, insurers, buyers and regulators can review without needing repeated follow-up questions, which often delay release of funds.
- 03
Engagement and licensing
We engage with Bangladeshi banks and their correspondents, coordinate with foreign counsel on licences or any contact with a foreign authority, and advise on contract notices, suspension or variation while the economic sanctions position is clarified and documented.
- 04
Controls and follow-through
Once the immediate issue is resolved, we review lessons learned and strengthen screening, contract clauses, training and record keeping so that the business can show banks and buyers that it manages economic sanctions and export control risks properly and consistently.
“Demonstrates an extraordinary command over both domestic litigation and international arbitration.”
The Legal 500 Asia Pacific, Bangladesh: Dispute resolution, client feedback
Related reading.

Anti-Dumping and Trade Remedies in Bangladesh 2026: Petitions, Foreign Cases, GSP Origin and Sanctions

Letter of Credit Disputes in Bangladesh: Legal Remedies for Importers and Exporters (2026)

Export Law in Bangladesh: Legal Guide for Exporters in 2026

Anti Money Laundering Law in Bangladesh: MLPA 2012, BFIU Reporting and Compliance in 2026
All insights →
Does Bangladesh have its own economic sanctions law?
Which sanctions lists do Bangladeshi banks screen against?
Can economic sanctions affect Bangladeshi garment exporters?
What is the difference between sanctions and export controls?
Are directors personally exposed to economic sanctions penalties?
Can TRW apply for a US or UK sanctions licence?
How often should screening procedures be updated?
How do we instruct TRW on a sanctions matter?
Keep legitimate trade moving through sanctions risk
Speak with the partners about economic sanctions in Bangladesh or across borders.
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