Supply Chain Compliance

On August 20, the Bureau of Industry and Security (“BIS”) published a final rule (“final rule”) amending the Export Administration Regulations (“EAR”) to expand restrictions on transactions involving Huawei entities that are included on BIS’s Entity List (“designated Huawei entities”).  The newly expanded rule applies to a broader range of items produced outside of the

Over the last month, the United States has taken a variety of steps to increase pressure on China in response to the imposition of China’s National Security Law in Hong Kong and alleged human rights abuses in Xinjiang.  These measures include new sanctions programs targeting Hong Kong, export and trade control restrictions, and sanctions targeting actors in the Xinjiang region.  The U.S. government also issued a lengthy Advisory warning U.S. and global companies of supply chain risks related to forced labor and other human rights issues in Xinjiang.

In this post, we highlight some key risks that companies should consider when doing business in the region against the backdrop of rising U.S.-China tensions.


Continue Reading China and Hong Kong Developments: Sanctions, Export Controls, and Supply Chain Risks

On Friday, October 25th, the Office of the U.S. Trade Representative (USTR) announced that the United States will be suspending certain benefits for imports from Thailand under the United States’ Generalized System of Preferences (GSP) program for failure to “adequately provide internationally-recognized worker rights.”  As a result, 573 U.S. Harmonized Tariff Schedule line

The World Health Organization has announced a new initiative, REPLACE, that seeks the cooperation of governments to ban artificial trans fats by 2023.  Trans fats can either be naturally occurring in foods such as milk products, or artificially produced.  Partially hydrogenated oils account for most artificial trans fats.  These fats are commonly found in baked

The AP recently reported that North Koreans are working in China as forced labor and their products are being imported into the U.S.  The AP followed the production of seafood from Chinese facilities to U.S. retailers, but stated that there other affected product categories, including apparel and wood flooring.

While it has been known that North Korea sends workers abroad, this report is the first time the supply chain has been documented to show North Korean forced labor products entering the U.S., which is a federal crime.  It has been reported that North Korea sends tens of thousands abroad, bringing in revenue estimated at $200-$500 million per year as Kim Jong Un keeps a large percentage of the salaries.  According to the AP, the North Korean workers in China remain under constant surveillance and live in forced labor conditions.
Continue Reading Importers Beware: U.S. Customs Targets Imports Made in China by North Korean Workers