Author

Eunkyung Kim Shin

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Yesterday U.S. Customs and Border Protection (CBP) issued its first finding of forced labor in 24 years (Finding) against importation into the United States of certain goods from a Chinese company.  The Finding was made pursuant to 19 U.S.C. 1307, which prohibits the importation of merchandise mined, manufactured, or produced, wholly or in part, by forced labor, including convict labor, forced child labor, and indentured labor.  Building upon the withhold release order issued in May…

Historically, corporate sanctions compliance programs have tended to focus primarily on ensuring that products and services are not sold or diverted to prohibited customers or sanctioned territories. There has often been less focus on the entirety of the supply chain, particularly the significant sanctions compliance risks that can arise upstream in the context of suppliers and vendors. Over the past few years, there has been a shift, with many companies now paying closer attention to…