Interdicting imports of goods made with forced labor is one of the objectives of the Department of Homeland Security’s recently released strategy for combating human trafficking. DHS states that it plans to publish within 180 days a plan for implementing this strategy that includes specific deliverables, timelines, and metrics for key results.

DHS notes that it is already taking steps to prevent the importation of goods produced with forced labor. These include streamlining trade policies and procedures, inspecting imports, investigating suspicious trade activity, issuing notices to detain or seize particular goods at U.S. ports, and pursuing criminal prosecutions against individuals and companies. DHS is also working to strengthen international, interagency, and non-governmental coordination to interdict illicit goods in supply chains.

Going forward, the strategy indicates that DHS will also take the following steps.

- expand its capacity to assess civil penalties and pursue criminal prosecutions against U.S. importers for violations of forced labor authorities

- consider streamlining regulatory frameworks guiding the process for enforcement actions

- coordinate, consolidate, and publicize allegation and intake reporting channels and other information to ensure quality and actionable leads, gain information for ongoing cases, and verify forced labor allegations

- educate industry on the threat of goods produced with forced labor destined for U.S. importation

- improve trade alert reporting, due diligence policies, and compliance assistance tools

- raise awareness among foreign partners of U.S. trade laws, limitations, and innovations

- encourage international adoption and enforcement of reciprocal safeguards that combat forced labor

- obtain agreements to support investigation and verification of forced labor allegations

- work with international partners on a two-way system for issuing trade alerts when enforcement actions go into effect

For more information on the trade-related impacts of forced labor, please contact trade consultant Nicole Bivens Collinson at (202) 730-4956 or trade attorney Elise Shibles at (415) 490-1403.

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