KPMG report: Keeping forced labor out of U.S. supply chains as scrutiny rises

Heightened scrutiny from multiple federal agencies has led to a significant increase in enforcement actions.

Heightened scrutiny from multiple federal agencies

The focus on forced labor in U.S. supply chains has become more intense in the last few years and recently has garnered the attention of policymakers. Additionally, heightened scrutiny from multiple federal agencies, including U.S. Customs and Border Protection (CBP), has led to a significant increase in enforcement actions—most notably the issuance of “withhold release orders” (WROs) effectively preventing the imported goods from entering the United States if suspected of being produced by forced labor.

CBP has specifically targeted imports from countries with allegations of forced labor, including China and Malaysia, with the majority of WROs being imposed on Chinese entities. The apparel industry has been heavily targeted, but CBP has also increased enforcement action across a broader range of industries such as agricultural, seafood, and electronics.

With additional U.S. legislation on the horizon, importers may now want to assess how they are positioned to identify and prevent forced labor in their supply chains.

Read a KPMG report* [PDF 373 KB] that:

  • Discusses the evolution of U.S. forced labor legislation and enforcement
  • Explores several recent WROs
  • Identifies potential controls importers can implement to mitigate the financial risks and supply chain disruptions associated with the enforcement of regulations to combat forced labor

*Reprinted with permission from the publisher

For more information on this topic or to learn more about KPMG’s Trade & Customs Services, contact:

Doug Zuvich
Partner and Global Practice Leader
T: 312-665-1022
E: dzuvich@kpmg.com

John L. McLoughlin
Principal and East Coast Leader
T: 267-256-2614
E: jlmcloughlin@kpmg.com

Andy Siciliano
Partner and National Practice Leader
T: 631-425-6057
E: asiciliano@kpmg.com

Steve Brotherton
Principal and Global Export and Sanctions Leader
T: 415-963-7861
E: sbrotherton@kpmg.com

Luis (Lou) Abad
Principal, Washington National Tax
T: 212-954-3094
E: labad@kpmg.com

Irina Vaysfeld
Principal
T: 212-872-2973
E: ivaysfeld@kpmg.com

Amie Ahanchian
Principal
T: 202-533-3247
E: aahanchian@kpmg.com

Christopher Young
Principal
T: 312-665-3229
E: christopheryoung@kpmg.com

Gisele Belotto
Managing Director
T: 305-913-2779
E: gbelotto@kpmg.com

George Zaharatos
Principal
T: 404-222-3292
E: gzaharatos@kpmg.com

Andy Doornaert
Managing Director
T: 313-230-3080
E: adoornaert@kpmg.com

Jessica Libby
Managing Director
T: 612-305-5533
E: jlibby@kpmg.com

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