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John Foote

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On July 1, 2020, the US Department of State, jointly with the US Department of Treasury, the US Department of Commerce, and the US Department of Homeland Security, issued an advisory (the “Advisory”) to caution US businesses about the risks of supply chain links to entities that allegedly engage in human rights abuses including the forced labor of Uyghurs, ethnic Kyrgyz, ethnic Kazakhs and other Muslim minority groups, in the Xinjiang Uyghur Autonomous Region (“Xinjiang”)…

What has changed? On March 11, 2020, the Congressional-Executive Commission on China (“CECC”) announced new proposed legislation, the Uyghur Forced Labor Prevention Act, co-sponsored by the chairs of the CECC, Rep. Jim McGovern (D – MA) and Sen. Marco Rubio (R – FL), targeting supply chains linked to forced labor in the Xinjiang Uyghur Autonomous Region in China. The Uyghur Forced Labor Prevention Act would establish a rebuttable presumption that all labor occurring in Xinjiang,…

The US Departments of State, Treasury, and Homeland Security warned companies in a new advisory that deceptive practices by North Korea to evade US, UN, and other sanctions could put them at risk of prohibited or sanctionable dealings with the North Korean regime.  The advisory published on July 24, 2018 follows February 2018 guidance from the US Treasury Department’s Office of Foreign Assets Control regarding certain deceptive shipping practices of North Korea to avoid US sanctions (see our prior blog post here).  The new advisory encourages companies to undertake enhanced due diligence within their supply chains to avoid prohibited or sanctionable: (i) sourcing of goods, services, or technology from North Korea and (ii) use of the labor of North Korean citizens or nationals, which is presumed to be forced labor, regardless of where such labor occurs.