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David Lakhdhir Publishes Analysis in New York Law Journal
January 7, 2022
Corporate partner David Lakhdhir wrote an analysis, “New U.S. Law Imposes De Facto Import Ban on Products From Xinjiang,” published in the New York Law Journal. David analyzes the new Uyghur Forced Labor Prevention Act, the expected U.S. enforcement response and steps that importers of products or raw materials from China may want to take before the act comes into force on June 21. The act bans the importation of all products made in the Xinjiang Uyghur Autonomous Region of China and in other regions where the labor of Uyghurs, Kazakhs, Kyrgyz, Tibetans or members of other persecuted groups is used, under the rebuttable presumption that those products are made with forced labor.
“Companies will want to conduct an urgent review of their supply chain management systems, to determine whether their systems related to China are sufficiently rigorous to meet the high standards that will be required under the Act,” David writes. “And companies that have public reporting obligations will need to determine whether the risks presented by the Act and its potential impact are material, and thus will need to be disclosed in their upcoming SEC or similar filings.”