On July 1, 2020, the US Department of State, jointly with the US Department of Treasury, the US Department of Commerce, and the US Department of Homeland Security, issued an advisory (the “Advisory”) to caution US businesses about the risks of supply chain links to entities that allegedly engage in human rights abuses including the forced labor of Uyghurs, ethnic Kyrgyz, ethnic Kazakhs and other Muslim minority groups, in the Xinjiang Uyghur Autonomous Region (“Xinjiang”) in China and beyond. The Advisory builds on the Uyghur Human Rights Policy Act of 2020, recently signed into law, authorizing the President to impose sanctions on persons, including Chinese government officials, determined to be responsible for certain human rights violations and abuses committed against Muslim minority groups in China or elsewhere. (Our blog posts on the background of this law and its passage are available here and here). The Advisory was issued following a series of actions by the US Government as outlined therein, including the June 5th addition of thirty-three entities to the Bureau of Industry and Security’s (BIS) Entity List (our blog post available here).
- What activities present heightened risks?
- What are the red flags to watch out for?
- What actions should companies take?
The authors thank Taylor Parker for contributing to this blog post.