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New Compliance Obligation - North Korean Forced Labor

December 8, 2017

compliance obligationMany importers which purchase goods from Chinese vendors are unaware that some of those products (especially those made in factories in northern China) are made/assembled by laborers from North Korea "working" in China.  However, that labor pool can consist of prisoners, indentured workers who perform labor pursuant to "contracts" that pay them next to nothing, or laborers otherwise forced to work against their will.  Thanks to legislation passed by Congress in August (Countering America's Adversaries Through Sanctions Act, or "CAATSA"), importers will have to ramp up their "due diligence" of potential and actual vendors to prevent items manufactured with prohibited forms of labor from entering the U.S. - even though the applicable law in this area (19 U.S.C. § 1307) has been on the books since passage of the Tariff Act of 1930. 

CBP recently updated its "Reasonable Care" Informed Compliance Publications with a new section on "Forced Labor" - and is now sending out Requests for Information (Customs Form 28) to obtain confirmation from importers that reliable procedures are in place to address this law, and that periodic audits of vendors in this area are taking place.

To read on the updates in the Informed Compliance Publication, please see the link below: 


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