In another sign of the increasing commitment of the United States to curtail the importation of goods made by forced labor, the U.S. Customs and Border Protection (CBP) has issued a Withhold Release Order (WRO) against a Chinese fishing fleet for suspected use of forced labor in its fishing operations.  The WRO instructs CBP personnel at all U.S. ports of entry to detain tuna, swordfish, and other seafood that has been harvested by a fleet of 32 vessels owned and operated by Dalian Ocean Fishing Co., Ltd.  This marks the first time CBP has banned imports from an entire fishing fleet, as opposed to individual vessels.  The WRO import ban also applies to other end-use products containing seafood from the company, such as canned tuna and pet food.  This order is the latest in a string of trade and import bans that have been placed on companies with suspected forced labor in their operations, and highlights the increasing risk to companies that import goods into the U.S. that are made from forced labor in supply chains.  More information related to this Order can be found here.


Aleesha Fowler is an associate in Baker McKenzie’s North American Litigation Practice Group in New York, New York. She has experience in the areas of white collar criminal defense, internal investigations, regulatory compliance matters, and complex civil litigation. Aleesha focuses her practice on white collar criminal defense, internal investigations, regulatory and compliance matters, and complex civil litigation. She has significant experience representing financial institutions under investigation by the US Department of Justice, the US Securities and Exchange Commission, FINRA, and the OCC. She also has experience advising companies (both domestic and foreign) on their compliance with the US Foreign Corrupt Practices Act.