TRW & Co’s London office (Holborn Gate, 330 High Holborn, London WC1V 7QH) advises international corporates and recruiters on cross‑border labour supply and outsourcing. This note outlines the regulatory landscape in Bangladesh at a high level and sets out practical compliance and risk‑management points relevant to organisations based in England and Wales that work with Bangladeshi recruitment agencies or send workers to or receive workers from Bangladesh.

Regulatory landscape: authorities and institutional context

Bangladesh operates a regulated regime for overseas employment and recruitment. The Bureau of Manpower, Employment and Training (BMET) and the Ministry of Expatriates’ Welfare and Overseas Employment are central to licensing and oversight. The Bangladesh Association of International Recruiting Agencies (BAIRA) is a trade body with a code of conduct for its members. These actors set licensing expectations, prohibited practices (for example, unlawful charging of workers in many circumstances), and registration requirements for recruitment agencies.

Key compliance considerations for international counterparties

• Licensing and standing: confirm whether a Bangladeshi recruitment partner is authorised under local law and whether they are a member of recognised trade bodies; ensure any contractual counterparties have the right to supply or place workers.
• Fees and worker protections: understand who bears recruitment costs and confirm compliance with local prohibitions on charging workers unlawful fees; document obligations on welfare, health insurance and repatriation.
• Anti‑slavery and human rights due diligence: include modern slavery risk assessments, grievance mechanisms and monitoring in supply‑chain contracts and pre‑departure processes.
• Data protection and immigration compliance: ensure cross‑border transfers of personal data comply with applicable regimes; verify visa sponsorship, work permits and immigration status for placed workers.
• Financial crime and AML checks: apply KYC, beneficial‑ownership screening and sanctions screening for recruitment partners and any intermediaries.
• Contractual clarity: allocate responsibilities for recruitment, onboarding, insurance, third‑party costs, termination and dispute resolution in written contracts that address applicable law and enforcement mechanisms.

Due diligence and practical checklist

Before entering a relationship with a recruitment agency or placing workers sourced from Bangladesh, consider the following practical checklist.

1. Verify agency registration and any public records of licence suspension or enforcement.
2. Obtain and review templates of worker contracts, job orders and recruitment invoices.
3. Confirm policies on fees, insurance, medical screening and repatriation assistance.
4. Require anti‑modern slavery and whistleblowing provisions; assess grievance channels for workers.
5. Perform KYC and sanctions screening on shareholders and senior controllers of the agency.
6. Agree dispute‑resolution forum and enforceability steps (see below).

Dispute resolution and cross‑border enforcement

Contracting parties should carefully select governing law and dispute resolution mechanisms. Arbitration clauses with seats in neutral jurisdictions are frequently used where enforcement across borders is required. For companies operating from England and Wales, consider English law and ICC or LCIA arbitration if your priority is predictability and enforceability under the New York Convention. Factor in criminal enforcement risks in Bangladesh for unlawful recruitment practices and the practicalities of executing judgments or arbitral awards across jurisdictions.

Jurisdiction and sources

• Bureau of Manpower, Employment and Training (BMET)
• Ministry of Expatriates’ Welfare and Overseas Employment
• Bangladesh Association of International Recruiting Agencies (BAIRA)
• Ministry of Labour and Employment, Government of Bangladesh

Engaging local counsel in Bangladesh remains important to confirm current licensing criteria, application processes and any recent regulatory changes. From an England & Wales perspective, ensure contracts, compliance systems and remediation processes are aligned with applicable domestic obligations (eg, anti‑slavery legislation, sanctions and data‑protection rules).

General information only; not legal advice and not a substitute for advice on a particular matter.