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.

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.

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.

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.

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.

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.

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.

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.