On 5th April, Ropes & Gray reported that on March 30th, the Department of Homeland Security published FAQ relating to section 321(b) of the Countering Americas Adversaries Through Sanctions Act, which was adopted in August 2017 and restricts entry into the US of goods made with North Korean labour, wherever located, and imposes sanctions on foreign persons that employ North Korean labour.  It also deals with rebutting the presumption that North Korean Labor is forced labour and due diligence to mitigate the risk of North Korean Labor in the supply chain.  It notes that if North Korean nationals or citizens are not involved in the mining, production or manufacturing of imported merchandise, that merchandise is not prohibited under Section 321(b), but if North Korean nationals or citizens are present at the docks or otherwise involved in the movement and shipping of merchandise, that may violate other provisions of the CAATSA or other US laws and regulations.  The FAQ encourage companies that find North Korean workers in their supply chains to report their findings to US Customs and Border Protection.

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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