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DHS Adds Five Companies to UFLPA Entity List

By Jeffrey L. Snyder, Pierfilippo M. Natta & Edward Goetz on August 8, 2024
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On August 8, 2024, the U.S. Department of Homeland Security (DHS) added five companies to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List.

The companies are:

  • Kashgar Construction Engineering (Group) Co., Ltd.;
  • Xinjiang Habahe Ashele Copper Co., Ltd. (also known as Ashele Copper);
  • Xinjiang Tengxiang Magnesium Products Co., Ltd.;
  • Century Sunshine Group Holdings, Ltd.; and
  • Rare Earth Magnesium Technology Group Holdings, Ltd.

The listings take effect on August 9.

Over the last few months. pressure from Congress has led to DHS and CBP working together to expand the scope of the UFLPA by increasing the number of entities designated on the entity list and has identified new high priority sectors subject to stricter enforcement.

The UFLPA requires the Forced Labor Enforcement Task Force (FLETF) to develop and update the UFLPA Entity List. U.S. Customs and Border Protection (CBP) enforces a rebuttable presumption that the importation of goods produced by entities identified in the UFLPA Entity List (as well as all goods produced wholly or in part in Xinjiang Uyghur Autonomous Region) is in violation of 19 U.S.C. § 1307 and prohibited from entry to the United States.

Photo of Jeffrey L. Snyder Jeffrey L. Snyder

Since 1986, Jeff’s practice has concentrated on the U.S. regulation of international trade. Clients seek him out for troubleshooting and problem solving in cross-border transactions. Jeff advises on import, export, and sanctions laws. He develops approaches for multinationals to manage the impact of…

Since 1986, Jeff’s practice has concentrated on the U.S. regulation of international trade. Clients seek him out for troubleshooting and problem solving in cross-border transactions. Jeff advises on import, export, and sanctions laws. He develops approaches for multinationals to manage the impact of U.S. extraterritorial regulations. Jeff assists companies in day-to-day compliance with these laws, and with interventions — such as audits and investigations, and civil enforcement proceedings.

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Photo of Pierfilippo M. Natta Pierfilippo M. Natta

Pierfilippo M. Natta (Pier), is the Director of Supply Chain and Forced Labor in Crowell’s International Trade Law practice. He focuses on complex international trade matters, ranging from implementing sanctions and export controls programs to forced labor investigations and general trade disputes. Pier…

Pierfilippo M. Natta (Pier), is the Director of Supply Chain and Forced Labor in Crowell’s International Trade Law practice. He focuses on complex international trade matters, ranging from implementing sanctions and export controls programs to forced labor investigations and general trade disputes. Pier works on developing Business and Human Rights legal guidance with global reach including US, EU and Asia. His investigatory work has primarily focused on South-East Asia.

Pier applies his international trade knowledge to help clients identify manage and remediate risks. He has helped U.S. and global companies develop programs specific to UN, US, and EU sanctions. More recently, Pier and the Crowell team are working to develop Crowell’s Business and Human Rights sub-practice which includes Crowell’s anti-forced labor investigatory work.

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Photo of Edward Goetz Edward Goetz

Edward Goetz is the Director for International Trade Services in Crowell & Moring’s Washington, D.C. office. Edward leads the firm’s international trade analysts providing practice support to the International Trade Group in the areas of customs regulations, trade remedies, trade policy, export control…

Edward Goetz is the Director for International Trade Services in Crowell & Moring’s Washington, D.C. office. Edward leads the firm’s international trade analysts providing practice support to the International Trade Group in the areas of customs regulations, trade remedies, trade policy, export control, economic sanctions, anti-money laundering (AML), anti-corruption/anti-bribery, and antiboycott. He has extensive government experience providing information and interpretive guidance on the International Traffic in Arms Regulations (ITAR) concerning the export of defense articles, defense services, and related technical data. He also assists attorneys with matters involving the Export Administration Regulations (EAR), economic sanctions, AML, anti-corruption/anti-bribery, and trade remedies.

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  • Posted in:
    Government Contracts
  • Blog:
    International Trade Law
  • Organization:
    Crowell & Moring LLP
  • Article: View Original Source

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