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.

The Australian Government integrated Norfolk Island with Australia’s tax, health, and social security systems and began delivering essential national functions such as immigration, customs, and biosecurity in Norfolk Island.