Mollie Sitkowski is Trade Compliance Counsel at Faegre Drinker, where she handles import and export control and compliance work on behalf of the firm’s clients. She has assisted numerous clients in developing and implementing import and export compliance programs, and offers continued training to the business areas that touch on import and export compliance. She discusses how import and export compliance intersects with human trafficking.
 

 
Customs has the authority to issue a WRO (withhold-release-order) if they have information that reasonably indicates that goods were made, either in part or in full, with forced labor. The goods are detained until you can prove otherwise. The vast majority of forced labor detentions are done under WROs, Mollie says. You have to provide two things required by the regulations within 90 days or you can choose to export. However, customs has escalated so much that it is difficult to acquire all the necessary data within 90 days, unless you already have a good compliance program and good auditing in place.
 
“To require you to have mapped out your entire trade flow and be able to provide that kind of detail all the way through the chain; I think that’s something that hopefully will really be an impediment to trafficking over the long run,” Gwen shares.
 
Resources
Mollie Sitkowski on LinkedIn | Twitter