Under a new presidential directive the U.S. will use trade, economic, and other authorities to address illegal, unreported, and unregulated fishing, which can involve forced labor and human trafficking.

The directive commits the U.S. to promoting worker-centered trade policies and working to ensure that fishery supply chains are free from forced labor, including through the following actions.

- U.S. Customs and Border Protection is directed to (1) investigate fishing vessels and operators suspected to be harvesting seafood with forced labor and issue withhold release orders, (2) share evidence with allies and partners to encourage parallel customs enforcement actions, and (3) investigate prospective civil penalty cases against importers connected to previously issued fishing vessel WROs.

- CBP is also directed to work with other agencies to (1) leverage existing and emerging technologies to detect IUU fishing and prevent or deter illegal seafood imports from entering the U.S. market and (2) consider the use of countervailing duties, Section 301 tariffs, import declarations, Pelly Amendment certifications, and due diligence requirements to counter forced labor in the seafood supply chain.

- By the end of 2022 the Department of Commerce will initiate a rulemaking to expand the Seafood Import Monitoring Program to include additional species and species groups.

- The Department of Labor will lead efforts to engage seafood importers, financial
institutions, business organizations, and labor stakeholders on forced labor in seafood supply chains, including by promoting supply chain transparency and responsible business practices, and is encouraged to apply lessons learned from U.S. government policies addressing the use of forced labor in the cotton sector and other relevant sectors.

- The Office of the U.S. Trade Representative will lead efforts to (1) engage with free trade agreement partners, preference program beneficiaries, and others to address forced labor and other abusive labor practices in fishing and (2) collaborate with Canada and Mexico to prohibit imports of goods, including seafood, produced in whole or in part by forced labor.

- The Interagency Working Group on Illegal, Unreported, and Unregulated Fishing will release by the end of July a five-year strategy that prioritizes efforts to combat IUU fishing, curtail the global trade of IUU fish and fish products, and promote global maritime security.

Sandler, Travis & Rosenberg offers a comprehensive suite of services to help companies address forced labor concerns, including supply chain reviews, due diligence strategies, and proactive remediation. ST&R also maintains a frequently updated web page offering a broad range of information on forced labor-related efforts in the U.S. and around the world. For more information, please contact ST&R at

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