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In Compliance

Baker McKenzie Video Series: Biden Supply Chain Policy

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In an era where supply chain disruptions and risks are regular front-page news, the Biden Administration has been undertaking a range of initiatives intended to create resilient supply chains that reflect the Administration’s policies around national security, foreign policy, human rights, and the US economy. Considering the non-stop legal and compliance developments in this space, with more on the horizon, in-house counsel and compliance professionals for companies with supply chains that touch the United States…

In Compliance

Commerce Department Issues Notice of Request for Public Comments on Risks in the Semiconductor Supply Chain and Announces Virtual Forum on Risks in the ICT Supply Chain

by , and 3 Mins Read

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…

In Compliance

Department of Labor Requests Comments on Forced and Child Labor Reports

by and 4 Mins Read

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…

In Compliance

Proposed EU Forced Labour Import Ban

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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…

In Compliance

DoD Requests Public Comments to Assess Defense Industrial Base Supply Chains

by and 3 Mins Read

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…

In Compliance

Federal Agencies Issue Requests for Public Comments to Assess Strength of Supply Chains Following “America’s Supply Chains” Executive Order

by , and 3 Mins Read

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…

In Compliance

Biden Administration Supply Chain Reports Deeper Dive #4: Unfair Trade Practices and the Trade Strike Force

by , and 4 Mins Read

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…

In Compliance

Industry Groups Continue to Criticize Commerce Department’s Proposed Supply Chain Regulations and Licensing Procedure

by and 7 Mins Read

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…

In Compliance

Defense Critical Supply Chain Task Force Issues Final Report

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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 Compliance

Recent US Developments Demonstrate Increasing Xinjiang-Related Trade Compliance Risks

by , and 6 Mins Read

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…

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