Time To Cotton On: Managing Supply Chain Risks

Introduction

Potential criminal activity in international supply chains can create reputational, civil, and criminal risks. This can be particularly difficult to manage when there are many links in a chain from the source of raw materials to the final product.

One regular question is whether revenue and profit generated from tainted supply chains can be regarded as the proceeds of crime; if so, anti-money laundering legislation may be engaged. This has been considered in a recent High Court case, arising in the context of a special interest group challenging a law enforcement decision not to launch an investigation into alleged supply chain criminality¹.

Background

The World Uyghur Congress ('Congress') is a non-governmental organisation that seeks to promote the collective interests of the Uyghur people. Congress alleges that it has provided compelling evidence to UK law enforcement agencies that UK companies importing cotton from the Xinjiang Uyghur