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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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On November 23, 2022, Customs and Border Protection (CBP) issued a <a href="https://www.cbp.gov/newsroom/national-media-release/cbp-issues-withhold-release-order-central-romana-corporation" target="_blank" rel="noopener">Withhold Release Order (WRO)</a> that mandates CBP personnel at all U.S. ports of entry detain raw sugar and sugar-based products produced in the Dominican Republic by Central Romana Corporation Limited (Central Romana). This WRO followed an investigation that reasonably indicated Central Romana uses forced labor in its operations in the Dominican Republic. The WRO will likely have an impact on the sugar market as, according to an <a href="https://apps.fas.usda.gov/newgainapi/api/Report/DownloadReportByFileName?fileName=Sugar%20Annual_Santo%20Domingo_Dominican%20Republic_DR2022-0004.pdf" target="_blank" rel="noopener">April 2022 report</a> by the U.S. Department of Agriculture (USDA), Central Romana is the largest sugar producer in the Dominican Republic, accounting for approximately 59% of the Dominican sugar market in 2021-22 and resulted in 62.84% of the U.S. tariff rate quota for raw sugar in fiscal year 2021.
CBP issued the WRO upon identifying five of <a href="https://www.ilo.org/global/topics/forced-labour/publications/WCMS_203832/lang--en/index.htm" target="_blank" rel="noopener">the International Labor Organization&rsquo;s 11 indicators of forced labor</a> in Central Romana&rsquo;s operations: (i) abuse of vulnerability, (ii) isolation, (iii) withholding of wages, (iv) abusive working and living conditions, and (v) excessive overtime. Accordingly, the WRO is authorized under 19 U.S.C. &sect;1307, which prohibits the importation of merchandise produced, in whole or in part, by convict labor, forced labor, and/or indentured labor, including forced or indentured child labor.
CBP&rsquo;s WRO follows a myriad of activity aimed to raise awareness of forced labor in global supply chains, including a September 2022 update by the U.S. Department of Labor to its <a href="https://www.dol.gov/agencies/ilab/reports/child-labor/list-of-goods">List of Goods Produced by Child Labor or Forced Labor</a> to include sugarcane from the Dominican Republic. According to CBP Acting Commissioner Troy Miller, &ldquo;[t]he agency will continue to set a high global standard by aggressively investigating allegations of forced labor in U.S. supply chains and keeping tainted merchandise out of the United States.&rdquo;
With the WRO against Central Romana, CBP now oversees the enforcement of 55 WROs and nine Findings.

core/freeform

SmarTrade

Senior Legislative and Regulatory Policy Advisor

Scott E. Diamond

Partner

Francesca M.S. Guerrero

Samir D. Varma

Senior Manager of International Trade

William L. Matthews

Associate

Aaron C. Mandelbaum

International Trade

CBP Issues WRO on Sugar Produced by Central Romana in the Dominican Republic Following Forced Labor Investigation