Uyghur Forced Labor Compliance

One of my biggest focus areas since 2019 has been on eradicating forced labor in our supply chain through the strategic implementation of proactive measures using a combination of enhanced screening tools and creating reactive plans in the event of shipment detainment.

Early on in the process, the first step was for Customs to review the current supply chain and our risk-levels. 

This gave us an idea of what to improve upon and how we can increase compliance levels with our vendors and service providers. in our future processes. 

Then, we presented our findings to our internal cross-functional group on human rights.

I oversaw the key portions of this project for the Customs team prior to being able to obtain funding to hire a PM to oversee the Forced Labor program. 

I utilized my knowledge from my tenure at Costco on FTAs and Sanctions to map out an admissibility packet to get started on a formalized plan with outside counsel. 

I also joined the multi-industry Forced Labor Working Group to stay up-to-date on the latest information presented and check-out service providers that would be best for the company.

Things kicked into high-gear when the Uyghur Forced Labor Act was signed into law, but there are still missing bits that will not be released, such as the entity list, on the implementation date in June. 

Ultimately, I was confident in the progress that we made in creating a compliant program. My first large budget request of almost $1M was approved by the owners to hire support for the newly-implemented procedures and programs, as well as work on an end-to-end tool.

The AAFA and NRF valued my input, such as coming up with the Traceability sub-committee, working on the White Paper to submit to DHS with outside counsel on the Customs Strategy and Enforcement sub-committee, and inviting me to speak as a panelist to this year's AAFA Trade Conference in DC/Baltimore.