On Tuesday, October 23, 2018, the Ninth Circuit Court of Appeals issued an important opinion reviving a decade-old Alien Tort Claims Act (ATS) suit based on alleged aiding and abetting slave labor in cocoa farms on the Ivory...more
11/9/2018
/ Aiding and Abetting ,
Alien Tort Statute ,
Appeals ,
Buyers ,
Child Labor ,
Claim Amendments ,
Corporate Liability ,
Domestic Corporations ,
Farm Workers ,
Farms ,
Financing ,
Forced Labor ,
Foreign Corporations ,
Human Rights ,
Remand ,
Reversal ,
Sellers ,
Slavery ,
Supply Chain
In the wake of the 2016 dismissal of human rights cases filed against food companies in California, a new class action case was filed on February 26, 2018 in Massachusetts federal court (Tomasella v. Hershey Co.) alleging...more
3/7/2018
/ Child Labor ,
Consumer Protection Laws ,
Cooperative Compliance Regime ,
Corporate Social Responsibility ,
Food Manufacturers ,
Forced Labor ,
Hersheys ,
Human Rights ,
Human Trafficking ,
Risk Mitigation ,
State and Local Government ,
Supply Chain ,
Transparency
[Warning: The juxtaposition of the jolly old man and forced labor is not to make light of human rights violations but to highlight the hidden evils in supply chains and the potential reputational damage to wholesome...more
12/21/2017
/ Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Forced Labor ,
Human Rights ,
Human Trafficking ,
Manufacturers ,
Modern Slavery Act ,
Pending Legislation ,
Retailers ,
Supply Chain ,
Tariff Act of 1930 ,
Trade Facilitation and Trade Enforcement Act ,
Transparency in Supply Chains Act ,
UK
Amnesty International recently released a report alleging that supply chains for production of palm oil—a common ingredient in many consumer products—are tainted by forced and child labor. In the nearly 150-page report titled...more
12/2/2016
/ Amnesty International ,
Child Labor ,
Disclosure Requirements ,
Due Diligence ,
Forced Labor ,
Human Rights ,
Internal Controls ,
Manufacturers ,
Modern Slavery Act ,
Retail Market ,
Retailers ,
Risk Management ,
Risk Mitigation ,
Supply Chain ,
Transparency in Supply Chains Act
The holiday retail season is an ideal time to check that forced labor and bribery—two top and interconnected supply-chain threats—do not undermine the success of your critical sales period.
Not long ago, many in the...more
11/28/2016
/ Anti-Bribery ,
Bribery ,
Cooperative Compliance Regime ,
Corruption ,
Disclosure Requirements ,
Due Diligence ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Forced Labor ,
Foreign Corrupt Practices Act (FCPA) ,
Holidays ,
Human Rights ,
Human Trafficking ,
Manufacturers ,
Modern Slavery Act ,
Pending Legislation ,
Proposed Legislation ,
Securities and Exchange Commission (SEC) ,
Subcontractors ,
Supply Chain ,
Tariff Act of 1930 ,
Transparency in Supply Chains Act ,
UK
The federal government took another step in the fight against human trafficking and forced labor. President Obama signed into law on February 24, 2016, the Trade Facilitation and Trade Enforcement Act of 2015 (TFTEA), which...more
3/4/2016
/ Child Labor ,
Corporate Counsel ,
Forced Labor ,
Human Rights ,
Human Trafficking ,
Imports ,
Manufacturers ,
New Legislation ,
Reporting Requirements ,
Slavery ,
Supply Chain ,
Tariff Act of 1930 ,
Trade Facilitation Agreement ,
Young Lawyers
It is that time of year again when we dust off the compliance crystal ball and take a look at what might be in store for 2014.
1. Executive Order 13627 Changes Government Contracting -
Want a government contract...more
1/15/2014
/ Anti-Corruption ,
Chief Compliance Officers ,
Compliance ,
Conflict Mineral Rules ,
Corporate Counsel ,
Enforcement ,
Enforcement Actions ,
Executive Orders ,
Forced Labor ,
Foreign Corrupt Practices Act (FCPA) ,
Human Trafficking ,
Office of Foreign Assets Control (OFAC) ,
Securities and Exchange Commission (SEC) ,
Supply Chain ,
Whistleblowers