On July 1, 2020, the U.S. Departments of State, Treasury, Commerce, and Homeland Security jointly issued an advisory, “Risks and Considerations for Businesses with Supply Chain Exposure to Entities Engaged in Forced Labor and Other Human Rights Abuses in Xinjiang” (the “Advisory”). The Advisory highlights the risks for businesses with potential exposure in their supply chain to the Xinjiang Uyghur Autonomous Region of China (XUAR) or to facilities outside the XUAR that use labor or goods from Xinjiang and notes that these businesses should be aware of the reputational, economic, and legal risks of involvement with entities that engage in human rights abuses, including but not limited to forced labor in the manufacture of goods intended for domestic and international distribution. The Advisory encourages businesses to apply industry human rights due diligence policies and procedures to address risks, including reputational, economic, legal, and other risks. The Advisory was published not long after the Uyghur Human Rights Policy Act (the “Act”) was signed into law on June 17, 2020. The Act, which directs U.S. resources to address human rights abuses in XUAR, and the Advisory suggest a possible shift in enforcement focus on activities involving the XUAR, including imports from and exports to the region.
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