Supply Chain Management Reminder as US Blocks Imports Due to Forced Labor

The US issued a jarring reminder of how it views products it suspects are made with forced labor.  Effective yesterday, the US Customs and Border Patrol ("CBP") blocked one of the largest palm oil companies from importing its products into the US, issuing a "Withhold Release Order."  The CBP has increased the use of such orders, and took that step here based on concerns of forced labor, violence and other misconduct, including potentially child labor.  This quite obviously has had a serious and immediate impact both on the market participants affected by the Order and by bringing attention to the alleged mistreatment.  Please use this as a reminder to step back and assess your own key governance procedures underpinning supply chain management structures--are you collecting, understanding and acting upon important information?