According to President Trump, “Tariff is the most beautiful word in the dictionary.” Throughout his presidential campaign, Trump promised to use tariffs as a central part of his foreign policy strategy. His America First Trade Policy memorandum also directs the administration to review various tariff- and tariff-adjacent levers the United States could use to further
Supply chain

Tariff mitigation through alternative sourcing: Navigating customs country of origin compliance risks
In a time of escalating tariff tensions, companies are investing heavily in analyzing the impact of tariff changes on their business and adapting to the shifting trade landscape. To mitigate tariff impacts and maintain competitiveness, many explore supply chain adjustments, such as alternative sourcing or relocating production. While “tariff engineering” is becoming an increasingly popular…
DHS expands UFLPA Entity List by over one-third
Effective January 15, the Department of Homeland Security (DHS) added 37 China-based companies to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List, marking the single largest expansion of the UFLPA Entity List since its creation in 2022. Included in the additions is a large supplier of critical minerals, as well as one of…

Emerging money laundering risks in the UK’s clothing and retail sectors
A UK Court of Appeal decision in June 2024 has heightened the UK’s focus on the potential for money laundering offences within global supply chains. There is now a greater risk that UK law enforcement may recover assets from companies that fail to perform adequate due diligence on their supply chain, even if adequate consideration…
EU 14th Sanctions Package against Russia
On 24 June 2024, the EU agreed the long-awaited 14th package of sanctions against Russia. These latest measures introduce several new thematic restrictions and imposed asset freeze measures on an additional 116 individuals and entities including Sovcomflot and the Volga Dnepr Group.
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EU Forced Labour Regulation nears final adoption
On 14 September 2022, as part of a suite of regulatory changes targeting cross-border supply chains, the European Commission presented its proposal for a Forced Labour Regulation.
In November 2023, the European Parliament adopted its position on the Commission’s proposal, followed by the Council of the EU adopting its General Approach in January 2024. After…
DHS adds 26 China-based cotton traders and warehouse facilities to UFLPA Entity List
Effective May 17, the Department of Homeland Security (DHS) is adding 26 China-based cotton traders and warehouse facilities to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List based on the U.S. government’s reasonable cause to believe the entities source or sell cotton from China’s Xinjiang Uyghur Autonomous Region (Xinjiang). These companies will now be…

The EU is ready to introduce mandatory supply chain due diligence obligations under CS3D
On 14 December 2023, the two EU co-legislators, the Council of the EU and the European Parliament, provisionally reached an agreement on the Corporate Sustainability Due Diligence Directive (CS3D). In essence, the Directive sets out an obligation for companies to comply with human rights and environmental due diligence and provides for an enforcement mechanism with…
EU FAQs – STS in EU Territorial Waters
On 2 August 2023 evening, the EU Commission released new FAQs (here and here; word search “2 August 2023”). Of greatest interest are the two new FAQs in the “Oil Import” section, relating to STS activity relating to Russian oil and petroleum products, in EU territorial waters. We set out extracts of these two below.
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