October 31, 2017 - The Trade Facilitation and Trade Enforcement Act of 2015 drew major attention to the issue of forced labor in global supply chains. The Act removed the "consumptive demand" clause, which was an enforcement barrier for U.S. Customs and Border Protection (CBP), and required US importers to take a closer look at their supply chains to ensure proper systems were in place for due diligence. Since then, President Trump signed into law new sanctions against North Korea over the summer and on Sep 21, 2017, the Countering America's Adversaries Through Sanctions Act (CAATSA) went into effect, requiring additional forced labor prevention action by US importers to ensure their supply chains do not include a North Korean person or national, even if that person is not physically in North Korea, in the production of goods.
CBP has begun issuing inquiries to importers via the CF 28 process enforcing the new regulations and has the authority to detain shipments for admissibility into the US.
For additional information about this topic, or if you have questions about how to implement these requirements, please contact the BDP Corporate Compliance Team at bdpcompliance@bdpint.com
Sources: CBP and CAATSA
