
The U.S. Customs and Border Protection (“CBP”) issued its first ever Withhold Release Order (“WRO”) and Finding Modifications Guide (“Guide” or “the Guide”). The Guide serves as a roadmap for importers facing a possible WRO or Finding due to allegations of forced labor in the supply chain of their goods imported into the U.S. Guidance from CBP to modify WROs represents a key barometer for compliance programs for importers to institute preemptively, since importers are strictly liable for their supply chains. Click here to read the full version of the alert.