January 19, 2022

Jenner & Block Partner Rachel K. Alpert and Associate Grace C. Signorelli-Cassady discuss the Uyghur Forced Labor Prevention Act in a recent Law360 article. In the piece, they explain the presumption prohibiting entry of all items from Xinjiang and what companies can expect from the US strategy to prevent items produced using forced labor in China from being imported.

They also detail steps companies can take to prepare for the enactment of the Uyghur Forced Labor Prevention Act:

  • Check suppliers for Xinjiang forced-labor warning signs.
  • Comply with U.S. sanctions, export controls, and CBP and Labor Department guidance.
  • Document the origin and method of production at each step in the supply chain.
  • Institute explicit policies against forced labor and track implementation.
  • Conduct comprehensive external audits — but know their limits.

Ms. Alpert is co-chair of the firm’s National Security, Sanctions, and Export Controls Practice. She is an international lawyer who brings a wealth of experience in economic sanctions, export controls, and human rights issues from her seven years in the United States Department of State’s Office of the Legal Adviser. She counsels domestic and international clients on a range of issues, including trade sanctions compliance, supply chain and human rights accountability, and CFIUS matters.

Ms. Signorelli-Cassady is a litigation associate and a member of both the firm’s Investigations, Compliance and Defense practice and its Government Controversies and Public Policy Litigation practice.