Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In the latest episode of FCPA Compliance Report, Tom Fox visits Virginia Newman from Miller & Chevalier, an expert on the Uyghur Forced Labor Prevention Act (UFLPA) and supply chain ESG work. Together, they discuss the UFLPA, its affirmative obligation on companies to comply with US import laws, and the burden of proof on businesses to prove their goods were not made using forced labor. Virginia shares valuable insight into the CBP’s enforcement efforts and how companies can exercise reasonable care to avoid having their goods detained. They also delve into trade compliance and third-party screening, predictive mapping, and the long-term changes companies must make to their compliance and sourcing programs. Thomas recommends Virginia as a source of knowledge on the subject because of her passion. Listen to this engaging and informative podcast to better understand the UFLPA and its impact on businesses.
Key Highlights:
- Virginia’s background and UFLPA
- US Law Prohibiting Import of Xinjiang-made Goods
- US Customs’ Role in Enforcing UFLPA
- CBP’s Forced Labor Technical Expo Solutions
- Types of Companies for Supply Chain Mapping
- Impact of a trade war on supply chain compliance
Notable Quotes:
“The US government had an import prohibition for any goods made in whole or in part with forced labor.
“The US import prohibition is one of the longstanding ones that has had the most effect on companies, but it wasn’t enforced too much until about 3 years ago.”
“If your goods are coming from Xinjiang, and you accept that they’re coming from Xinjiang, Then, really, the burden is on you to prove that they’re not made with any forced labor, which is an incredibly high burden and to our knowledge importers have not been trying meet it.”
“Customs put together this enforcement dashboard that contains all of these statistics on how they’ve been enforcing the UFLPA.”
Resources
Virginia Newman on LinkedIn
Tom Fox
