Forced Labor/Human Rights

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On March 1, 2022, the Office of the U.S. Trade Representative (USTR) released President Joe Biden’s 2022 Trade Agenda and 2021 Annual Report.  The trade agenda highlights President Biden’s continued focus on a “worker-centered trade policy” by “promoting a broader agenda of fair competition to ensure that workers are competing on the basis of…

Key Notes:

  • Several federal agencies recently released a business advisory emphasizing the heightened risk of doing business in Burma.
  • Four key areas of risk were identified: (1) state-owned enterprises (SOEs); (2) gems and precious metals; (3) real estate and construction projects; and (4) arms, military equipment, and related activities.
  • U.S. businesses with supply chains tied

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U.S. Customs and Border Protection (CBP) has issued a “Notice of Finding” in which it has determined that certain palm oil and derivative products made wholly or in part with palm oil produced by Sime Darby Plantation Berhad, its subsidiaries, and joint ventures with the use of convict, forced or indentured labor, are…

On January 24, 2022, the Department of Homeland Security, on behalf of the Forced Labor Enforcement Task Force (Task Force), issued a request for public comments on “how best to ensure that goods, wares, articles, and merchandise mined, produced, or manufactured wholly or in part with forced labor in the People’s Republic of China are…

On December 16, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced it was placing another eight Chinese technology firms on its Non-SDN Chinese Military-Industrial Complex Companies List (CMIC List). This action was taken pursuant to Executive Order 13959 (as amended by Executive Order 14032), which prohibits U.S. persons from conducting…

On December 9, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) announced that it was amending the Export Administration Regulations (EAR) to apply more restrictive treatment to exports and reexports to, and transfers within, Cambodia of items subject to the EAR.  BIS stated that it is taking this action “to address recent…

On December 10, 2021, the United States joined Australia, Denmark and Norway in announcing the Export Controls and Human Rights Initiative in recognition that “advanced technologies are a vital part of global economic growth and communication, helping people become more interconnected, share knowledge, and advance freedom, democracy, and opportunity” while also acknowledging that authoritarian governments…

On December 10, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 15 individuals and 10 entities in several countries for their connection to human rights abuse and repression. In addition, OFAC imposed investment restrictions on one Chinese company in connection with the surveillance technology sector

In China, OFAC has placed…

On December 2, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the expansion of sanctions against Belarus in response to the Lukashenka regime’s continued “disregard for international norms.” The actions taken by OFAC pursuant to Executive Orders 14038 and 13405 include 35 new designations to the Specially Designated Nationals and…