On July 31, 2026, the Department of Homeland Security (DHS) announced the addition of 43 companies based in China to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List, bringing the total number of entities on the UFLPA Entity List to 187 entities. Effective August 3, 2026, U.S. Customs and Border Protection (CBP) will apply a rebuttable presumption
Forced Labor/Human Rights
USTR Implements Tariffs in Section 301 Forced Labor Investigations
On July 23, 2026, the Office of the U.S. Trade Representative (USTR) announced in a Notice of Action its final action in the Section 301 investigation of 60 economies for “their failure to impose and effectively enforce a prohibition on the importation of goods produced with forced labor.” Under Section 301 of the Tariff Act…
USTR Launches Section 301 Investigations into Forced Labor Practices
On March 12, 2026, the U.S. Trade Representative (USTR) announced that it was launching Section 301 investigations into 60 trade partners to determine whether they have been engaged in forced labor practices. The investigations, to be conducted pursuant to Section 301of the Trade Act of 1974, include China, the European Union, India, and Mexico. A…
USTR Announces Section 301 Tariffs on Nicaragua
On December 10, 2025, the Office of the United States Trade Representative (USTR) issued a Federal Register notice announcing actions under Section 301 of the Trade Act of 1974 to address Nicaragua’s acts, policies, and practices related to abuses of labor rights, abuses of human rights and fundamental freedoms, and the dismantling of the rule…
CBP Issues WRO on Garments and Apparel Manufactured in Mauritius
On November 18, 2025, U.S. Customs and Border Protection (CBP) announced the issuance of a Withhold Release Order (WRO) against garments, apparel, and textiles manufactured in Mauritius by Firemount Group Ltd. The WRO follows an investigation into the company where CBP discovered several indicators of forced labor use, including abuse of vulnerability, debt bondage, deception…
USTR Issues Section 301 Determination on Nicaragua’s Abuses of Labor Rights and Human Rights Practices
On October 20, 2025, the United States Trade Representative (USTR) determined under Section 301 of the Trade Act of 1974 that Nicaragua’s acts, policies, and practices related to abuses of labor rights, abuses of human rights and fundamental freedoms, and dismantling of the rule of law are unreasonable and burden or restrict U.S. commerce. The…
CBP Issues WRO on Bicycles Manufactured in Taiwan
On September 24, 2025, U.S. Customs and Border Protection (CBP) issued a Withhold Release Order (WRO) against bicycles, bicycle parts, and bicycle accessories produced by Giant Manufacturing Co. Ltd. in Taiwan. The WRO follows an investigation into the company where CBP discovered several International Labour Organization (ILO) forced labor indicators, including abusive working and living…
UFLPA Annual Strategy Update: U.S. Department of Homeland Security Designates New High-Priority Sectors and Adds 78 Entities to Forced Labor List
- the Entity List
Top Five Takeaways from DOJ’s Newest Guidance for Investigation & Prosecution of White Collar Crimes
On May 12, the U.S. Department of Justice (DOJ) issued updated policy memoranda relating to the investigation and prosecution of white collar crimes, including its White-Collar Enforcement Plan, Revised Corporate Enforcement and Voluntary Self-Disclosure Policy, Memorandum on Selection of Monitors in Criminal Division Matters, and the Criminal Division’s Corporate Whistleblower Awards Pilot Program Revisited. These…
CBP Issues WRO on Taepyung Salt Farm
On April 2, 2025, the U.S. Customs and Border Protection (CBP) issued a press release announcing that it had issued a Withhold Release Order (WRO) for imports of sea salt products from Taepyung Salt Farm, a South Korean company, “based on information that reasonably indicates the use of forced labor.” The WRO is effective immediately…
