Forced Labor/Human Rights

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On December 16, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced it was placing another eight Chinese technology firms on its Non-SDN Chinese Military-Industrial Complex Companies List (CMIC List). This action was taken pursuant to Executive Order 13959 (as amended by Executive Order 14032), which prohibits U.S. persons from conducting…

On December 9, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) announced that it was amending the Export Administration Regulations (EAR) to apply more restrictive treatment to exports and reexports to, and transfers within, Cambodia of items subject to the EAR.  BIS stated that it is taking this action “to address recent…

On December 10, 2021, the United States joined Australia, Denmark and Norway in announcing the Export Controls and Human Rights Initiative in recognition that “advanced technologies are a vital part of global economic growth and communication, helping people become more interconnected, share knowledge, and advance freedom, democracy, and opportunity” while also acknowledging that authoritarian governments…

On December 10, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 15 individuals and 10 entities in several countries for their connection to human rights abuse and repression. In addition, OFAC imposed investment restrictions on one Chinese company in connection with the surveillance technology sector

In China, OFAC has placed…

On December 2, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the expansion of sanctions against Belarus in response to the Lukashenka regime’s continued “disregard for international norms.” The actions taken by OFAC pursuant to Executive Orders 14038 and 13405 include 35 new designations to the Specially Designated Nationals and…

On September 17, 2021, President Biden issued an Executive Order (EO), “Imposing Sanctions on Certain Persons with Respect to the Humanitarian and Human Rights Crisis in Ethiopia,” targeting persons responsible for the conflict in Ethiopia, obstructing humanitarian access and preventing a ceasefire. The White House issued a statement in connection with the new sanctions indicating…

On August 9, 2021, the White House issued a new Executive Order (EO), “Blocking Property of Additional Persons Contributing to the Situation in Belarus,” which expands existing U.S. sanctions against Belarus to target various sectors. The Treasury Department’s Office of Foreign Assets Control (OFAC) also issued a host of new designations to the Specially Designated…

U.S. Customs and Border Protection (CBP) has issued five Frequently Asked Questions (FAQs) relating to its June 23, 2021 Withhold Release Order (WRO) requiring U.S. ports to detain shipments of silica-based products and materials as well as goods derived from those products manufactured by Hoshine Silicon Industry Co., Ltd. and its subsidiaries (“Hoshine”). Hoshine operates…

Key Notes:

  • On July 13, the U.S. government released an updated version of the Xinjiang Supply Chain Business Advisory advising U.S. companies of the widespread, PRC-government sponsored forced labor and intrusive surveillance practices targeting ethnic and religious minorities in Xinjiang.
  • The Advisory urges U.S. companies with supply chains, ventures or investments connected to Xinjiang to

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On July 16, 2021, the U.S. Departments of State, Commerce, Homeland Security and the Treasury issued a Hong Kong Business Advisory highlighting growing risks for U.S. companies operating in the Hong Kong Special Administrative Region (SAR) due to ongoing actions taken by the Government of the People’s Republic of China (China). The advisory states that…