A credible programme starts with an honest risk assessment of how the business deals with officials, state-owned customers and intermediaries. It then needs clear leadership commitment, a short written policy, rules on gifts, hospitality, donations and sponsorships, third-party due diligence, contract clauses, payment controls, training, a confidential reporting channel and periodic review. Documents alone are not enough. Authorities and lenders look for evidence that the controls are used and enforced. We build anti-corruption compliance programmes that reflect the company's size, sector and risk, rather than importing a long global manual that nobody in Dhaka reads or follows in practice.

No. Bangladesh law does not recognise an exception for small payments made to speed up routine government action, and the UK Bribery Act also prohibits them. The United States Foreign Corrupt Practices Act has a narrow exception, but many groups prohibit facilitation payments as a matter of policy. In practice, requests for speed money arise at ports, utility offices, licensing desks and land offices. We help companies plan realistic timelines, use official fast-track services where they exist, document refusals, and support staff who face pressure, including where a request comes with a threat to health or safety.

The depth should match the risk. A distributor that resells consumer goods to private retailers needs less scrutiny than an agent who will interact with government buyers or regulators for a success fee. Relevant factors include the counterparty's role, government touchpoints, compensation structure, ownership, reputation and the business case for using it. For higher-risk relationships we carry out enhanced checks, including company and litigation searches, media review, references and interviews. Our anti-corruption compliance advice concludes with a clear recommendation, conditions for proceeding and contract terms that reflect the identified risk, together with a schedule for periodic refresh.

The Commission's core mandate concerns corruption involving public servants, but private companies and their officers can be investigated and prosecuted where they are alleged to have offered or paid bribes, participated in misappropriation of public funds, or laundered proceeds. The Commission can issue notices, request documents and summon individuals. Companies that supply government, hold public contracts or deal with state-owned banks are most exposed. We advise on responding to notices, protecting legal rights, preparing witnesses and, where appropriate, challenging procedural irregularities through the courts, while maintaining professional working relationships with investigators. Early handling often narrows an enquiry.

Buyers can inherit the consequences of a target's past conduct, including tainted contracts, licence challenges, investigations, debarment and reputational damage, and foreign buyers may face scrutiny under their own laws. Anti-corruption compliance due diligence should therefore start early, focus on the target's real risk areas, and feed into valuation, transaction documents and integration planning. We review records, interview management, assess intermediaries and government business, and recommend warranties, specific indemnities, escrow, conditions precedent and post-closing remediation steps where concerns are found. Sometimes the right advice is to restructure the deal or delay closing until specific concerns are resolved.

Modest, transparent and infrequent courtesies, such as refreshments at a business meeting or low-value branded items, are generally lower risk. Cash, gift cards, travel for family members, expensive festival gifts, and hospitality offered while a tender, licence or inspection is pending carry high risk. Bangladesh's government servant conduct rules also restrict what officials may accept. We draft gifts and hospitality rules with clear thresholds, pre-approval steps and registers, and train staff to handle cultural expectations around Eid, Puja and other festivals without creating an appearance of improper influence. Registers should be reviewed regularly by compliance staff.

Take the report seriously, protect the whistleblower from retaliation, and preserve relevant documents and data before anyone is alerted. The board or a committee should decide who will oversee the review, and lawyers should usually lead it so that legal privilege can be protected as far as possible. We scope the investigation, collect and review evidence, interview staff, and report findings with options. Decisions about disciplinary action, reporting to authorities, lenders or a foreign parent, and remediation of control weaknesses then follow, with our anti-corruption compliance advice on each step. Communication with staff, auditors and insurers is planned carefully throughout.

Yes. Development finance institutions and multilateral development banks require borrowers and contractors to meet integrity standards, often including specific prohibited practices, audit and inspection rights, and cooperation with their investigation units. Breaches can lead to debarment that affects work across many countries, and cross-debarment arrangements can extend the effect between banks. Companies working on funded projects in Bangladesh, including contractors and consultants, should align their anti-corruption compliance programme with the lender's policies. We review project agreements, advise on subcontractor flow-down, and support clients facing integrity enquiries or audits from lenders and their investigation units.