On May 17, 2024, the Department of Homeland Security (DHS) issued a Federal Register notice announcing that effective immediately, 26 Chinese entities have been added to the UFLPA Entity List. These entities include cotton traders and warehouse facilities within China, but the majority of which operate outside of the Xinjiang Uyghur Autonomous Region (XUAR). DHS determined that there was reasonable cause to believe that 21 of the entities source and sell cotton from the XUAR on the wholesale market, and that five entities also source cotton from the XUAR.

As a result of their listing on the UFLPA Entity List, goods produced by these 26 entities will be presumed to be made by forced labor and subject to detention under the Uyghur Forced Labor Prevention Act. DHS Secretary Alejandro N. Mayorkas stated, “Today’s announcement strengthens our enforcement of the UFLPA and helps responsible companies conduct due diligence so that, together, we can keep the products of forced labor out of our country. We will continue to execute on our textile enforcement strategy and hold the PRC accountable for their exploitation and abuse of the Uyghur people.”

For general background information on the Uyghur Forced Labor Prevention Act (UFLPA), see Thompson Hine’s International Trade Update of June 2022.

Print:
Email this postTweet this postLike this postShare this post on LinkedIn
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.