Those of us in the business of global trade compliance are well aware of the increased attention in recent years to the issue of forced labor. This is not a new problem, but incidents in recent years with well-known brands, coupled with new legislation designed to curb behavior of this type, has increased the importance of supplier due diligence for those operating in global markets.

On January 31, 2019, the U.S. Office of Foreign Assets Control (OFAC) issued its first fine to e.l.f. Cosmetics for violating the Countering America’s Adversaries Through Sanctions Act (CAATSA), as it applies to North Korean labor under the North Korean Sanctions Regulations (NKSR).  The initial statutory maximum civil monetary penalty amount for the apparent violations was US$40,833,633. This enforcement action indicates that government agencies are watching closely for violations of this nature.

In an increasingly uncertain global logistics arena, is your company ready for a new era of complexity and risk?

This Tuesday, November 13, our VP of Global Markets Kevin Shoemaker will be joining American Shipper’s Managing Editor Ben Meyer and MercuryGate International’s Carla Zubko to discuss “Managing Transportation Through Today’s Trade Uncertainty.”

U.S. CBP recently began the process of sharing the proposed new minimum security criteria (MSC) for the Customs Trade Partnership Against Terrorism (CTPAT) program. The new MSC have been in the works for two years, and this is the first revision since they were created 16 years ago.

The current “Minimum Security Criteria Workbook for Importers” is available to all existing members through the CTPAT Portal. Workbooks for additional entity types are also available via the CTPAT Portal; however, this blogpost will focus on Importer criteria.

Members have until the end of October 2018 to review and submit their feedback. CBP plans to evaluate the feedback to determine if further modifications are needed before finalizing the new MSC. It is expected that in early 2019, the new MSC will be rolled out in a phased approach as CBP takes the time to educate the trade and prioritize feasibility.