We assist clients to understand UFLPA compliance, to diligence their supply chains and to facilitate uninterrupted trade with the U.S., to minimize supply chain interruptions. The UFLPA prohibits the importation into the United States of products mined, manufactured, or produced in the Xinjiang Uyghur Autonomous Region of the People’s Republic of China or by entities on the UFLPA Entity List. Importation of such products in violation of the UFLPA may result in civil or criminal penalties under 19 U.S.C. § 1592 (penalties for fraud, gross negligence or negligence, 19 U.S.C. § 1595a (importations contrary to law and 18 U.S.C. § 545 (smuggling goods into the United States). The CBP may issue a Withhold Release Order (WRO) when the agency has reasonable evidence of the use of forced labor in the manufacturing or production of a good or goods entering into the United States supply chain. A WRO allows CBP to detain the products in question at all US ports of entry until and unless importers can prove the absence of forced labor in their product supply chain. CBP issues a finding when the agency determines that forced labor was used in the manufacturing or production of goods entering US supply chain. A Finding allow the CBP to seize all goods in question at all US ports of entry. If a prohibited shipment is not detained upon entry into the U.S., potential liability in the form of civil penalties may apply to products after entry if they are later deemed to have violated the UFLPA at the time of entry.