With news of serious forced labour allegations emerging in the UK, calls for forced labour reforms will require companies to take proactive action to monitor and mitigate risk.
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Latest from International Trade Law
Department of Commerce Unveils New Tool to Inform Supply Chain Risk Mitigation
At the inaugural Supply Chain Summit on September 10, 2024, the US Department of Commerce introduced an innovative diagnostic risk assessment tool, marking a significant investment in the U.S. government’s ongoing efforts to fortify the nation’s supply chain ecosystem.
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BIS Amends Voluntary Self-Disclosure Process and Penalty Guidelines and Adds First-Ever Chief of Corporate Enforcement
On September 12, 2024, the U.S. Department of Commerce Bureau of Industry and Security (BIS) issued a final rule to amend the Export Administration Regulations (EAR) revising provisions related to the voluntary self-disclosure (VSD) process for persons who believe that they may have violated the EAR, or any order, license or authorization issued thereunder. The
USTR Announces Final Decisions on Section 301 Tariffs
The Office of the United States Trade Representative (“USTR”) today published a Federal Register notice announcing its final modifications to its Four-Year Statutory Review of U.S. Section 301 tariffs on a range of Chinese-origin goods. While the USTR declined to modify its proposed increase of additional duties on electric vehicles (to 100 percent in 2024),
OFAC Extends Recordkeeping Requirements from 5 to 10 Years Through Interim Final Rule
On September 11, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that it is seeking comments on a new interim final rule amending OFAC’s Reporting, Procedures and Penalties Regulations to extend recordkeeping requirements from five to ten years. While OFAC is seeking comments within 30 days, the interim final rule
The EU Batteries Regulation: Taking Stock of the New EU Battery Requirements
More than a year ago, the EU Batteries Regulation (Regulation (EU) 2023/1542) entered into force. In approximately one year’s time, the EU Batteries Regulation is set to repeal the 2006 Batteries Directive (Directive 2006/66/EC), with some exceptions. During the 2024 summer, a number of the new requirements under the EU Batteries Regulation have begun to
OFAC, State Department, and BIS Expand Russian/Belarusian Sanctions
On August 23rd, 2024, the U.S. Treasury’s Office of Foreign Assets Control (OFAC), the U.S. Department of State (State), and the Commerce Department’s Bureau of Industry and Security (BIS) acted against Russia’s international supply chains.
OFAC and State collectively sanctioned nearly 400 individuals and entities. Of note, this included a substantial focus on targeting non-Russian
DDTC Publishes ITAR Amendments to Implement the AUKUS Exemption
On August 20, 2024, the Department of State’s Directorate of Defense Trade Controls (DDTC) published an interim final rule to streamline defense trade between and among Australia, the United Kingdom (UK), and the United States in furtherance of the trilateral security partnership (the “AUKUS” partnership). The interim final rule implements the proposed rule DDTC published
DDTC Publishes Amendments to the ITAR Definition of Activities That Are Not Exports, Reexports, Retransfers, or Temporary Imports
On August 15, 2024, the DDTC published a final rule to expand the ITAR’s definition of “activities that are not exports, reexports, retransfers, or temporary imports.” The final rule implements the amendments the DDTC originally proposed on December 16, 2022 with six changes. The rule is effective on September 16, 2024 and codifies longstanding DDTC
DHS Adds Five Companies to UFLPA Entity List
On August 8, 2024, the U.S. Department of Homeland Security (DHS) added five companies to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List.
The companies are:
- Kashgar Construction Engineering (Group) Co., Ltd.;
- Xinjiang Habahe Ashele Copper Co., Ltd. (also known as Ashele Copper);
- Xinjiang Tengxiang Magnesium Products Co., Ltd.;
- Century Sunshine Group Holdings,