Facilitators & Agents | Bangladesh LNG Supply Framework

⚠️ Anti-Corruption Warning

Commission arrangements in government procurement carry significant legal risk under both Bangladesh and international law (e.g., FCPA for U.S. entities).

🚦 Risk Assessment Matrix

Activity	Risk Level	Notes
Technical consulting (pre-bid)	Lower Risk	Advisory services with disclosed fees
Market intelligence services	Lower Risk	Research and analysis
Commercial agent fees (private)	Medium Risk	Depends on disclosure
Success fees on govt contracts	High Risk	May violate procurement law
Commissions to govt officials	Prohibited	Criminal under ACC Act

⚖️ Legal Framework

▶Anti-Corruption Commission Act, 2004

Criminalizes bribery, abuse of position, and fraudulent procurement.

📄 ACC Act 2004

▶Public Procurement Act, 2006

Requires transparency and fair competition in government procurement.

📄 Procurement Act 2006

▶U.S. Foreign Corrupt Practices Act (FCPA)

U.S. law prohibiting bribery of foreign officials. Applies to U.S. companies engaging with Bangladesh government.

✅ Legitimate Activities

Market research — Understanding procurement landscape
Technical consulting — Preparing compliant bids
Legal advisory — Contract review, compliance
Logistics coordination — Shipping support
Translation — Document preparation

All activities should have disclosed, fixed fees — not success-based commissions.