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ARTICLE · 09 SEPTEMBER 2026

Forced Labor Import Bans And The Next Frontier Of Anti-Corruption Compliance

Steptoe LLP
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As forced labor import restrictions proliferate globally, companies face a new compliance challenge: the corruption risks embedded in navigating these expanding regulatory regimes. This analysis examines how the rapid adoption of forced labor trade enforcement mechanisms worldwide may create opportunities for customs-related bribery and explores practical steps for integrating human rights and anti-corruption compliance strategies.

GlobalGovernment, Public Sector
Jonathan Drimmer
Jonathan Drimmer
Yousuf Aftab
Yousuf Aftab
Lindsay B. Arrieta
Lindsay B. Arrieta
Ruxandra Cana
Ruxandra Cana

This article is a companion to our earlier discussions of the distinction between human rights due diligence and documentary compliance in the context of forced labor import restrictions, our survey of the proliferating forced labor import bans taking root worldwide, and our reflections on key human rights governance steps in light of the Sime Darby matter. It examines a compliance challenge that has received comparatively little attention: the corruption risks that may accompany the rapid expansion of forced labor import enforcement around the world.

As our prior companion pieces have noted, the global landscape for forced labor enforcement is changing at lightning speed. For years, the United States stood largely alone in operating a comprehensive import prohibition targeting goods produced wholly or in part with forced labor. The European Union's Forced Labour Regulation, adopted in 2024, signaled the spread of this model. Events during 2026 suggest that the trend is now

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