Yesterday, as part of its annual Virtual Trade Week series, US Customs and Border Protection (“CBP”) issued a list of Frequently Asked Questions on forced labor (“the FAQs”). The FAQs consist of responses to ten questions focused on current issues and latest developments in forced labor enforcement. As mentioned in the FAQs, in FY2020 (October 1, 2019 – September 30, 2020), CBP set a record by issuing 13 Withhold Release Orders (“WROs”), detaining over $55…
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 March 5, 2021, US Customs and Border Protection (“CBP”) issued a new factsheet regarding how Withhold Release Orders (“WROs”) might be modified or revoked by CBP (“WRO Modification and Revocation Guidance”), which builds upon previous guidance by CBP on similar issues, including the factsheet issued on August 6, 2020. As a reminder, a WRO can be issued when CBP reasonably (but not conclusively) believes that certain goods are mined, produced, or manufactured, wholly or…