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Elise Shibles

Telephone: 415.490.1403
E-mail: eshibles@strtrade.com

Marilyn-Joy Cerny

Telephone: 202-549-0161
E-mail: mjcerny@strtrade.com

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CBP Enforcement of Import Ban on Forced Labor Goods

Goods made with forced labor (including prison or forced child labor) are banned from importation into the United States. Recently Congress passed two new laws paving the way for U.S. Customs and Border Protection to increase its enforcement of this ban. The first law eliminated a critical obstacle to CBP’s detention of goods suspected of being made with forced labor. The second created a rebuttable presumption that any North Korean laborers, employed in any country and anywhere in the supply chain, are presumed to be forced laborers.

CBP has already taken action to enforce these new standards. To avoid lengthy detentions of merchandise, importers should update their practices, procedures, and documents to address forced labor and the nationality of workers with respect to not only immediate vendors but also suppliers of materials further back in the supply chain. In addition, these issues may overlap with Office of Foreign Assets Control sanctions that generally prohibit U.S. persons from dealing with or providing payments to entities supplying North Korean workers to third-country projects, making it increasingly important to know your suppliers and their workforce partners.

Join us for a discussion of forced labor and related issues as they pertain to U.S. importers and exporters.

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