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  3. Forced Labor & Global Supply Chains

Forced Labor Economic Sanctions

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A number of entities and individuals have been added to the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) Specially Designated Nationals And Blocked Persons (“SDN”) List and the US Department of Commerce, Bureau of Industry and Security’s (“BIS”) Entity List based on their actions in connection with forced labor in XUAR and in connection with North Korean forced labor.

Several entities and current or former government officials have recently been added to OFAC’s SDN List in connection with serious human rights abuses against ethnic minorities in the XUAR. These individuals were added due to their roles in the XPCC and XPSB, which connected them to serious human rights abuses in the XUAR. The action was taken pursuant to Executive Order (E.O.) 13818, “Blocking the Property of Persons Involved in Serious Human Rights Abuse or Corruption,” which builds upon and implements the Global Magnitsky Human Rights Accountability Act. OFAC’s action complemented actions taken by the European Union, the United Kingdom, and Canada, which imposed sanctions on those and other individuals.

Several entities have also been added to BIS’s Entity List based on their involvement in human rights violations and abuses in the implementation of China’s campaign of repression, mass arbitrary detention, forced labor, and high-technology surveillance against Uyghurs, Kazakhs, and other members of Muslim minority groups in the XUAR.

Companies should cross-reference these lists for export restrictions or licensing requirements in connection with any export transactions. Contact our office for an updated list of these restricted entities.

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