Alexis Chandler

Subscribe to all posts by Alexis Chandler

Supply Chains Are The Next Subject of Cyberattacks

The cyberthreat landscape is evolving as threat actors develop new tactics to keep up with increasingly sophisticated corporate IT environments. In particular, threat actors are increasingly exploiting supply chain vulnerabilities to reach downstream targets. The effects of supply chain cyberattacks are far-reaching, and can affect downstream organizations. The effects can also last long after the … Continue Reading

Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act Goes Into Effect Soon

On May 11, 2023, Canada passed the Fighting Against Forced Labour and Child Labour in Supply Chains Act(Bill S-211), which will take effect on January 1, 2024 (the “Act”). The purpose of this Act is to implement Canada’s international commitment to fighting forced and child labor through reporting obligations on (a) government institutions[1] producing, purchasing, … Continue Reading

Countdown to Compliance With European Union’s Deforestation Regulation

Companies are preparing to comply with the European Union’s new deforestation regulation (EUDR). On June 29, 2023, the European Parliament and Council formally adopted the EUDR.  The EUDR goes into effect on December 30, 2024 for large companies (operators and traders)[1] and June 30, 2025 for micro and small exporters.[2]… Continue Reading

Michigan Supreme Court Upholds UCC Statute of Frauds Rule Requiring Quantity Terms To Be In Writing

The Michigan Supreme Court issued an Opinion on July 11, 2023 in MSSC, Inc. v. Airboss Flexible Products Co., reversing a Court of Appeals opinion holding that blanket purchase orders were enforceable under the UCC Statute of Frauds. In short, the Michigan Supreme Court upheld the longstanding Statute of Frauds rule that contracts must contain … Continue Reading

CBP Targets Battery Tech for UFLPA Enforcement

Customs and Border Protection (CBP) recently indicated potential increased scrutiny of battery technology under the Uyghur Forced Labor Prevention Act (“UFLPA,” or the “Act”). Although the Act covers essentially all trade touching China’s Xinjiang region, it specifically lists cotton, polysilicon, and tomatoes as high-priority sectors for enforcement. Recent CBP actions indicate battery technologies are also … Continue Reading

DHS Adds Two Entities, Eight Subsidiaries to UFLPA Entity List

On June 12, 2023, the Department of Homeland Security (DHS), on behalf of the Forced Labor Enforcement Task Force (FLETF), published a Notice adding two entities and eight subsidiaries to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List, for allegedly working with the government of the People’s Republic of China’s Xinjiang Province to recruit, … Continue Reading

UFLPA Enforcement Remains Work in Progress

U.S. Customs and Border Protection’s (“CBP”) implementation of the Uyghur Forced Labor Prevention Act (“UFLPA”) remains a work in progress, as importers work to mitigate shipment detentions and respond to UFLPA reviews and enforcement actions. Emerging best practices may guide stakeholders as they navigate these uncertainties.… Continue Reading

Postal Code For Chinese Manufacturers To Be Required By U.S. CBP Beginning This Weekend

As part of a continued effort to enforce the Uyghur Forced Labor Prevention Act (UFLPA) and to provide early warning to importers and their representatives that goods may have been produced in the Xinjian Uyghur Autonomous Region (XUAR), U.S. Customs and Border Protection (CBP) will require businesses to provide a valid postal code for Chinese manufacturers … Continue Reading

Aluminum Is Now A Hot Topic In Supply Chain And Trade

Last Friday, February 24, 2023, the Biden Administration issued a Proclamation on Adjusting Imports of Aluminum into the United States.  You can read the full proclamation here. The Proclamation states that, beginning on March 10, 2023, a 200% ad valorem tariff will be imposed on all aluminum articles and derivative aluminum articles produced in Russia.  … Continue Reading

DHS Released a Notice on the Addition of Entities to the UFLPA Entity List

On August 4, 2022, the U.S. Department of Homeland Security (DHS), as the Chair of the Forced Labor Enforcement Task Force (FLETF), formally published the Uyghur Forced Labor Prevention Act (UFLPA) Entity List. The Entity list is a consolidated register of the four lists required to be developed and maintained pursuant to Section 2(d)(2)(B) of … Continue Reading

FLETF Released Strategy Guidance. Join SPB Webinar To Learn More!

Christmas came early this year.  Ok, not really, but the Department of Homeland Security, which chairs the Forced Labor Enforcement Task Force (FLETF) released its strategy guidance on the Uyghur Forced Labor Prevention Act on June 17, 2022—four days ahead of schedule.  Click here to view FLETF’s strategy guidance. SPB will be hosting a webinar … Continue Reading

CBP Issues Operational Importer Guidance Relating to UFLPA

Late Monday, June 13, 2022, Customs and Border Protection (CBP) issued its long-anticipated Operational Importer Guidance to guide importers before the Uyghur Forced Labor Prevention Act (UFLPA) enters into effect on June 21. As a reminder, beginning on that date, CBP will apply a rebuttable presumption that goods coming from the Xinjiang region violate a … Continue Reading

CBP Releases Known Importer Letters and Enforcement Guidance relating to the Uyghur Forced Labor Prevention Act

Earlier this year, U.S. Customs and Border Protection (CBP) released a statement on its website that it would be issuing letters to importers identified as having previously imported merchandise from locations or entities potentially subject to the Uyghur Forced Labor Prevention Act (UFLPA).  Well, CBP stuck to its word and just recently released two sample … Continue Reading

“Is Your Organization Complying With the US Uyghur Forced Labor Prevention Act?” 

The Uyghur Forced Labor Prevention Act goes into effect on June 21, 2022.  The Act creates a rebuttable presumption that “any goods, wares, articles, and merchandise mined, produced, or manufactured wholly or in part in the Xinjiang Uyghur Autonomous Region of the People’s Republic of China” (or by an entity included on a list required … Continue Reading

Supply Chain Investigations and Legal Privilege

Regulators worldwide are increasing their demands that manufacturers and retailers know and understand all aspects of their supply chains as they relate to Environmental, Social, and Governance (“ESG”) goals. Keeping the findings, communications, information, and reports generated in connection with supply chain ESG investigations is imperative to ensure full and candid fact-finding and to manage … Continue Reading
LexBlog