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Compliance

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On September 24, 2021, the Commerce Department’s Bureau of Industry (“BIS”) published a “Notice of Request for Public Comments on Risks in the Semiconductor Supply Chain” (“Notice”). The Notice seeks responses from various parties in the semiconductor supply chain about current shortages and related issues. Comments in response to the Notice are due by November 8, 2021. The Notice was issued in response to a 100-Day Supply Chain Review (“Review”) of semiconductors and advanced packaging…

On October 8, the US Department of Labor (“DOL”) published a notice requesting information and comments on the following three reports on child labor and forced labor practices in foreign countries that are published by the US Bureau of International Labor Affairs (“ILAB”).  The comments will be used in preparing the 2022 edition of the TDA Report and TVPRA List, as well as any updates to the E.O. List.  The three reports are the US…

On 15 September, during the 2021 State of the Union Address, EU Commission President Ursula von der Leyen announced the European Commission’s intention to introduce a ban on the import of products made with forced labour into the EU market. In her Address, the Commission President noted that there are “25 million people…who are threatened or coerced into forced labour” and that “doing business around the world…can never be done at the expense of people’s…

On September 28, 2021, the US Department of Defense (“DoD”) published a notice of request for public comments. DOD’s request relates to Executive Order 14017, (“America’s Supply Chains” or “Supply Chain EO”). See some of our key blog posts on the Supply Chain EO for more background. As part of requiring agency reviews of key industrial bases’ supply chains, the Supply Chain EO mandated that DoD conduct a one-year review of supply chains within the defense industrial base…

US federal government agencies charged with implementing President Biden’s February 24, 2021 Executive Order 14017 (“America’s Supply Chains” or “Supply Chain EO”) continue to assess supply chain risks and vulnerabilities by issuing public requests for comment. Among other things, the Supply Chain EO directs the heads of several federal agencies to conduct a one-year review to examine supply chains for potential vulnerabilities in a number of sectors. (This is in addition to the 100-day reviews…

Concern regarding IP theft and other forms of unfair trade practices have been of paramount importance in the past five years in the United States – and have indeed been the justification for imposing significant and long-lasting trade barriers. The Biden Administration affirmed its commitment to using a wide range of remedies to address such trade practices through a set of reports on the 100-day interagency reviews conducted pursuant to Executive Order 14017 “America’s Supply…

On January 19, 2021, the US Commerce Department (“Commerce”) published an interim final rule (“Interim Rule”) to implement Executive Order 13873, “Securing the Information and Communications Technology and Services (“ICTS”) Supply Chain.” The Interim Rule was issued following the public comment period’s closure on January 10, 2021 on the proposed rules issued on November 27, 2019 (“Proposed Rules”). For more information on the Proposed Rules and the Interim Rule, please see our blog posts here and here. When it requested comments on…

Introduction In early March of this year, a bipartisan group of members of the House Armed Services Committee formed the Defense Critical Supply Chain Task Force (the “Task Force”). Co-chaired by House Democrat Elissa Slotkin (Michigan) and Republican Mike Gallagher (Wisconsin), the Task Force was formed to address what has been perceived as U.S. overreliance on vulnerable defense supplies manufactured in other countries, such as China. We previously reported on this on our blog here. …

In the recent flurry of US Government activity related to Xinjiang, one thing is clear: trade compliance risks continue to increase for companies with supply chains that involve Xinjiang. These latest actions add to the expanding list of companies that face import bans, export bans, and sometimes both, in addition to broader measures under consideration in Congress. This blog post summarizes the past month’s developments. Companies with Xinjiang anywhere in their supply chains should be…

On June 8, 2021, the White House published a set of reports on the 100-day interagency reviews (“Reports”) conducted pursuant to Executive Order 14017 (“Supply Chain EO”), which assessed supply chain risks and vulnerabilities for several supply chains, including those relating to semiconductor manufacturing and advanced packaging, and made policy recommendations to address those risks. The Reports suggest that export controls on semiconductor-related equipment and technology can help protect the technological advantage of the United States in…