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Forced Labor

ST&R assists companies in complying with recent changes to the forced labor laws by implementing due diligence, risk management/assessment, and remediation strategies. We utilize existing company corporate social responsibility and customs resources, which ensures our approach is efficient, less costly, and rapidly implemented.

Due diligence strategies include updating or creating audit procedures and questions, corporate policy documents such as compliance manuals and vendor manuals, vendor agreements and related documents, and training materials. We also inform the corporate legal, procurement, and CSR departments to ensure all relevant personnel understand the ramifications of the new laws.

Our risk assessment and monitoring strategies include reviewing and monitoring company ACE data relative to locations and entities that have been the focus of CBP, Department of State, Department of Labor, non-governmental organizations, and the media.  

We also work with companies to develop an action plan if North Korean labor is found in their supply chain and/or goods are detained at the border.

Contact us about our forced labor services.

What is Forced Labor?

The importation of goods mined, produced, or manufactured, wholly or in part, in any foreign country by forced labor, including convict labor, forced child labor, and indentured labor is prohibited. Such goods are subject to exclusion and/or seizure and may lead to criminal investigation of the importer. The Trade Facilitation and Trade Enforcement Act of 2015 closed a legal loophole that had allowed imports of certain forced labor-produced goods if they were not produced domestically in such quantities as to meet consumptive demands. CBP has recommended that companies use the Department of Labor’s Comply Chain principles for creating a social compliance system as a best business practice.

Learn More About Forced Labor

Marilyn-Joy  Cerny
T: 212.549.0161
  • ST&R
Paula M. Connelly
T: 781.897.1771
  • ST&R
Elise  Shibles
T: 415.490.1403
  • ST&R

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