On November 18, 2022, Customs Trade Partnership Against Terrorism (CTPAT) director Manual Garza announced that Customs and Border Protection (CBP) added three new forced labor benefits for its trade compliance partners “to the greatest extent possible and practical effective immediately.” These benefits include:

  • Front of the Line Admissibility Review: CTPAT trade compliance members who have their shipments detained due to forced labor concerns will have their admissibility packages prioritized for review by the appropriate Center of Excellence and Expertise. To avail itself of the benefit, the importer must assert that it is a CTPAT member and request prioritized review at the time that supporting documentation is submitted to CBP.
  • Redelivery Hold: CTPAT members whose shipments have been held due to ties to forced labor, where redelivery is normally requested, may hold their shipments at their facility until an admissibility determination is made or until such time as a physical inspection is required. 
  • Detained Withhold Release Order Shipments Move to Bonded Facility: CTPAT members whose shipments have been detained by CBP due to a withhold release order will be allowed to move their goods to a bonded facility to be held until such time that an admissibility determination by CBP is made.

CBP’s announcement follows its addition of six new forced labor requirements to its CTPAT trade compliance program in August 2022. These requirements include risk-based mapping, code of conduct, evidence of implementation, due diligence and training, remediation planning and sharing of best practices. These requirements are detailed in the CTPAT Trade Compliance Handbook.

Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

**Not licensed to practice law.

Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.

Photo of Samir D. Varma Samir D. Varma

Samir advises multinational corporations on export controls, economic sanctions and customs, and counsels individuals and corporations on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. He represents clients in enforcement actions before U.S. regulatory agencies and conducts corporate internal investigations.

Photo of William L. Matthews** William L. Matthews**

Bill has 40 years of experience in international trade. He assists the group’s lawyers in advising clients on matters regarding customs law, regulations and procedures; antidumping and countervailing duty proceedings; import and export policies; and WTO issues.

**Not licensed to practice law.