U.S. law prohibits the importation of goods mined, produced, or manufactured, wholly or in part, in any foreign country by forced labor, including convict, indentured, and forced child labor. Enforcement of this prohibition is on the rise, including Withhold Release Orders (WRO) and shipment detentions.

It is therefore no longer enough for importers to know the conditions of manufacture only back to their tier one suppliers; instead, they need to have complete supply chain transparency all the way back to the point of extraction, growth, or original input creation. Importers should be taking affirmative steps to ensure compliance and manage risk.

Looking for resources, proposed legislation and worldwide actions to prevent forced labor? Visit our Forced Labor & Supply Chain Visibility Resource Page.

Why Use ST&R’s Forced Labor Services

Comprehensive guidance. ST&R can assess companies’ current compliance, test measures they have put in place, and help them develop remedial protocols. ST&R also assists in developing and implementing effective due diligence strategies, including 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. In addition, we work with corporate legal, procurement, and CSR departments to ensure all relevant personnel understand the ramifications of forced labor laws and regulations.

Representation. If your goods get caught in a WRO, ST&R examines your contracts, purchase orders, and other communications to minimize the impact and get your operations back on track. ST&R also advocates for company interests before agencies like U.S. Customs and Border Protection, the Office of Foreign Assets Control, and the Bureau of Industry and Security and monitors their related regulations and policies.

Cost effectiveness. ST&R utilizes companies’ existing corporate social responsibility and customs compliance resources, which ensures our approach is efficient, less costly, and rapidly implemented.

Key Contacts

Elise Shibles

Textiles & Apparel Practice Leader; Forced Labor Practice Leader


J. Nicole Bivens Collinson

President, International Trade & Government Relations


Amanda Levitt



David F. Olave

Associate & Trade Policy Advisor



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