In recent years, a multinational focus on preventing forced labor within supply chains has shaped due diligence requirements for companies worldwide. Recent changes to global policies and potential shifts in enforcement...more
5/5/2025
/ Corporate Counsel ,
Customs and Border Protection ,
Due Diligence ,
Enforcement ,
EU ,
Forced Labor ,
Human Rights ,
Imports ,
International Trade ,
New Legislation ,
Supply Chain ,
Uyghur Forced Labor Prevention Act (UFLPA)
Key Takeaways: The Uyghur Forced Labor Prevention Act (UFLPA) went into effect on June 21, 2022, and requires the U.S. Customs and Border Protection (CBP) to presume that all goods manufactured wholly or in part in the XUAR,...more
Will 2022 Be the Year of Supply Chain Ethics?
Effective June 21, 2022, in an effort to address forced labor concerns, U.S. law will broadly prohibit imports of products from China’s Xinjiang Uyghur Autonomous Region...more
1/19/2022
/ China ,
Compliance ,
Customs and Border Protection ,
Due Diligence ,
Enforcement ,
Environmental Social & Governance (ESG) ,
Ethics ,
Forced Labor ,
Human Rights ,
Imports ,
Sanctions ,
Supply Chain ,
Tariff Act of 1930 ,
Uyghur Forced Labor Prevention Act (UFLPA) ,
Withhold Release Orders (WROs)
On January 13, 2021, U.S. Customs and Border Protection (CBP) issued a withhold-release order (WRO) on all cotton and tomato products from China’s Xinjiang Uyghur Autonomous Region (XUAR) based on information that reasonably...more
On December 2, 2020, U.S. Customs and Border Protection (CBP) issued an import detention or Withhold Release Order (WRO) against cotton produced by Xinjiang Production and Construction Corps (XPCC) based on information that...more
On September 14, 2020, U.S. Customs and Border Protection (CBP) issued five Withhold Release Orders (WROs) for a range of goods produced in the Xinjiang region of China. Under 19 U.S.C. § 1307, CBP can initiate enforcement...more
On April 19, 2020, the Treasury Department in conjunction with Customs and Border Protection (CBP) released a temporary interim final rule (“Rule”) to provide importers that meet the qualifying criteria with the option of a...more
On April 7, 2020, the Federal Emergency Management Agency (FEMA) released for public inspection a temporary rule that prohibits the export of five types of personal protective equipment (PPE) without explicit approval by...more
The Court found the disqualification of an offeror from a pharmaceutical procurement was in error based on a U.S. Customs and Boarder Protection (CBP) interpretation of the Trade Agreements Act of 1979 (TAA)....more
2/14/2020
/ Country of Origin ,
Customs and Border Protection ,
Department of Veterans Affairs ,
Federal Acquisition Regulations (FAR) ,
Imports ,
India ,
Pharmaceutical Industry ,
Prescription Drugs ,
Public Procurement Policies ,
Trade Agreements Act ,
WTO
Criminal investigations will target businesses profiting from the importation into the United States of goods made using forced labor.
The new criminal enforcement initiative seeks to leverage data about corporate supply...more
8/6/2019
/ Compliance ,
Corporate Counsel ,
Criminal Prosecution ,
Customer Due Diligence (CDD) ,
Customs and Border Protection ,
Department of Homeland Security (DHS) ,
Department of Justice (DOJ) ,
Forced Labor ,
Imports ,
NGOs ,
Strategic Enforcement Plan ,
Supply Chain ,
Tariff Act of 1930 ,
Trafficking Victims Protection Act of 2000
On November 22, 2017, Apple, Inc. (“Apple”) released a statement confirming reports that its major supplier in China, Foxconn Technology Group (“Foxconn”) has used illegal student labor to assemble the latest version of the...more
12/5/2017
/ Apple ,
China ,
Customs and Border Protection ,
Economic Sanctions ,
Forced Labor ,
Imports ,
iPhone ,
Manufacturers ,
North Korea ,
Supply Chain ,
Tariff Act of 1930 ,
Trade Facilitation and Trade Enforcement Act
In a development that may have important implications for companies selling products to the U.S. government, on December 7, 2016, the Court of International Trade (“CIT”) issued a decision holding that the assembly in the...more