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In another sign of the increasing commitment of the United States to curtail the importation of goods made by forced labor, the U.S. Customs and Border Protection (CBP) has issued a Withhold Release Order (WRO) against a Chinese fishing fleet for suspected use of forced labor in its fishing operations.  The WRO instructs CBP personnel at all U.S. ports of entry to detain tuna, swordfish, and other seafood that has been harvested by a fleet of 32 vessels owned and operated by Dalian Ocean Fishing Co., Ltd.  This marks the first time CBP has banned imports from an entire fishing fleet, as opposed to individual vessels.  The WRO import ban also applies to other end-use products containing seafood from the company, such as canned tuna and pet food.  This order is the latest in a string of trade and import bans that have been placed on companies with suspected forced labor in their operations, and highlights the increasing risk to companies that import goods into the U.S. that are made from forced labor in supply chains.  More information related to this Order can be found here.

Author

Aleesha Fowler is an associate in the Washington, DC office. She represents domestic and international corporate clients on a range of litigation and compliance matters, including criminal and civil investigations brought by the US Department of Justice and the US Securities and Exchange Commission. She regularly advises clients on white collar criminal matters, and has significant experience in handling investigations that raise issues under the Foreign Corrupt Practices Act and the US False Claims Act. Aleesha's pro bono practice is focused on providing legal advice and representation to incarcerated clients seeking parole and other available remedies.

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