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CBP Guidance Offers Anti-Forced Labor Compliance Insights


In this article, authors Dana Watts* and Mary Mikhaeel discuss the latest Customs Trade Partnership Against Terrorism (C-TPAT) Trade Compliance Handbook released by U.S. Customs and Border Protection (CBP) earlier this year. The handbook contains new anti-forced labor-related requirements for C-TPAT partners and can serve as a helpful tool to benchmark and build out their compliance programs. "While the C-TPAT requirements are not a mandatory due diligence regime for those who are not C-TPAT Trade Compliance partners, they demonstrate how U.S. enforcement agencies are looking to adopt and enforce these human rights due diligence concepts in the context of trade restrictions. Therefore, all U.S. importers that successfully integrate the new C-TPAT requirements will find themselves well-positioned in interactions with CBP in the event of a forced labor-related detention, and in meeting evolving human rights due diligence standards developing on an international level," the authors wrote. Richard Mojica and Nate Lankford also contributed to this article.

*Former Miller & Chevalier attorney