CBP Using Entity List as Resource for Forced Labor Enforcement
In its recently issued Forced Labor Enforcement Strategy, DHS said CBP is making use of the Bureau of Industry and Security's export enforcement arm to identify Xinjiang entities that are involved in forced labor. CBP uses a “range of sources and research tools, both public and non-public,” to identify the entities, DHS said in its strategy document, including the interagency end-user review committee, which selects the parties that are added to the Commerce Department’s Entity List.
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.
BIS examines several factors before adding a company to the Entity List, including whether they are involved in human rights violations and the use of forced labor, the document said. Since 2019, the agency has added at least 15 entities “implicated in the practice of accepting or utilizing forced labor,” DHS said. BIS will “continue to review activities of the Chinese government and commercial entities to determine whether placement of additional entities on the BIS Entity List or removal of compliant entities is warranted.”
CBP and BIS have been thought to be working closely on forced labor and Entity List enforcement, mostly because some companies that become subject to a CBP withhold release order are later added to the Entity List, including China-based Hetian Haolin Hair Accessories (see 2106180017, 2005010040 and 2007200026).