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ARTICLE · 31 MARCH 2023

Custom's Increasing Expectations In Forced Labor Compliance

Barnes, Richardson & Colburn
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Earlier this week, Customs alerted the trade to a February 25, 2023 publication highlighting a New Year's change for the Customs Trade Partnership Against Terrorism (CTPAT) Trade Compliance program.

United StatesInternational Law
Pietro N. Bianchi
Pietro N. Bianchi

Earlier this week, Customs alerted the trade to a February 25, 2023 publication highlighting a New Year's change for the Customs Trade Partnership Against Terrorism (CTPAT) Trade Compliance program. Since Customs is pinging this monthly, it is safe to assume Customs will be focusing on this development. As of January 1, 2023, CTPAT members must have (had) a documented social compliance program addressing how the company ensures imports were not the products of forced labor. Previously, this was only recommended.

The social compliance program example that CBP gives is the U.S. Department of Labor's comply chain system. This 8-step plan for social compliance: engage stakeholders and partners; assess risks and impacts; communicate and train across your supply chain; develop a code of conduct; monitor compliance; remediate violations; independent review; and report performance and engagement. The first four steps can be viewed as risk mitigation actions that attempt to

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