Gregory Husisian Outlines Supply Chain Due Diligence Under UFLPA

Foley & Lardner LLP partner Gregory Husisian was highlighted in International Trade Today analyzing recent developments in enforcement under the Uyghur Forced Labor Prevention Act (UFLPA).

Husisian observed the challenges companies face in conducting supply chain due diligence, saying, “Many companies try to get by on just polling suppliers.”

“In practice, you cannot rely solely on what your direct supplier tells you (at least for higher-risk/higher-volume products), because supply chains are complicated and there are commercial reasons why suppliers are reluctant to share information fully,” he added.

Husisian further explained that information-access restrictions can complicate forced labor exposure investigations “on the ground in China.” “It also is possible that China will take more specific actions targeted at US companies operating in China, although to date there have been no such announcements,” he concluded.

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