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In early March of this year, a bipartisan group of members of the House Armed Services Committee formed the Defense Critical Supply Chain Task Force (the “Task Force”). Co-chaired by House Democrat Elissa Slotkin (Michigan) and Republican Mike Gallagher (Wisconsin), the Task Force was formed to address what has been perceived as U.S. overreliance on vulnerable defense supplies manufactured in other countries, such as China.

On 12 July the European Commission and the European External Actions Service (EEAS) published guidance on “due diligence for EU businesses to address the risk of forced labour in their operations and supply chains”. The non-binding guidance seeks to provide European companies with practical advice on the implementation of effective human rights due diligence practices to address forced labour risks in their supply chains.

In the recent flurry of US Government activity related to Xinjiang, one thing is clear: trade compliance risks continue to increase for companies with supply chains that involve Xinjiang. These latest actions add to the expanding list of companies that face import bans, export bans, and sometimes both, in addition to broader measures under consideration in Congress. This blog post summarizes the past month’s developments.

The Ministry of Trade (MOT) has issued Minister of Trade Regulation No. 59 of 2020 (“Regulation 59”) which is an amendment to Minister of Trade Regulation No. 118/M-DAG/PER/12/2015 on Import Provisions for Complementary Goods, Goods for the Purpose of Market Testing, and After-Sales Service (“Regulation 118”).

Through Resolution No. 706/2021, published on July 27 2021 and in effect as from that day, the Secretary of Energy created the “Liquefied Natural Gas Operators Registry” within the scope of the Undersecretariat of Hydrocarbons, dependent on the Secretary and the Ministry of Economy. The Resolution also regulated the requirements for granting LNG export permits for up to 20 years.

On Monday, 26 July, the Ukrainian president enacted a decision of the National Security and Defense Council, which imposed economic sanctions against six individuals and ten entities, including three non-profit organizations related to the self-proclaimed Donetsk People’s Republic.