Requiring Audits Deeper Into Supply Chain Likely Policy Approach, Attorney Predicts
A bipartisan bill that would require businesses with more than $500 million in gross annual receipts to conduct annual audits to investigate whether there is forced labor among their suppliers or secondary suppliers has been introduced again. Ted Murphy, a trade lawyer at Sidley Austin, wrote that while the Slave-Free Business Certification Act of 2022 has bipartisan sponsorship, from Sen. Josh Hawley, R-Mo., and Sen. Kirsten Gillibrand, D-N.Y., "it is not clear whether this bill has much chance of becoming law (a previous version of the bill was introduced in 2020, but did not advance out of committee)."
Sign up for a free preview to unlock the rest of this article
Export Compliance Daily combines U.S. export control news, foreign border import regulation and policy developments into a single daily information service that reliably informs its trade professional readers about important current issues affecting their operations.
Still, he said, companies should take notice of the approach, "as we believe it may be adopted in the future," either through the Uyghur Forced Labor Prevention Act or another mechanism. "Companies need to recognize that the landscape has changed and respond accordingly. For example, in the past, there may not have been any commercial reason for you to map your supply chain beyond the vendor of the finished product; whereas, today, not having increased visibility into your supply chain, at least for certain products (or products from certain regions), is incredibly risky. The game has changed; companies that recognize and adapt to the new rules will have a competitive advantage over those that do not," he wrote Feb. 14.