On January 29th, 2026 U.S. Customs and Border Protection announced a Withhold Release Order on all shipments of coffee harvested by Finca Monte Grande, a Mexican coffee farm in Chiapas, Mexico. Effectively immediately CBP will detain all shipments of coffee harvested by Finca Monte Grande at any U.S. Port of Entry for probable forced labor violations.

As a result of CBP investigation into the Finca Monte Grande plantation, evidence demonstrates that workers are subject to 6 of the 11 indicators of forced labor including:

  • Abusive Working and Living Conditions
  • Abuse of Vulnerability
  • Debt Bondage
  • Excessive Overtime
  • Retention of Identify Documents
  • Withholding of Wages

Under 19 U.S.C. § 1307, any good that is produced wholly or in part with forced labor is prohibited from entering the United States and if violations are found, goods are subject to detention and seizure at the time of importation. A 2024 US Department of Labor report found that multiple industries in Mexico engage in child labor and forced labor violations with the agricultural sector being the largest risk. These affected commodities include coffee, melons, sugarcane and other agricultural products.

This is the first issued WRO in 2026 and emphasizes the importance of supply chain tracing by importers to ensure compliance with US regulations, avoiding unnecessary disruptions and costly delays. For more information on implementing due diligence and supply chain management, please feel free to reach out to Crowell & Moring for assistance.

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Photo of Simeon Yerokun Simeon Yerokun

imeon Yerokun is a counsel in Crowell & Moring’s International Trade group and based in the firm’s Washington, D.C. office. He advises clients on all areas of import regulatory compliance, trade remedies, and international trade litigation.

Simeon has extensive experience counseling companies in

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imeon Yerokun is a counsel in Crowell & Moring’s International Trade group and based in the firm’s Washington, D.C. office. He advises clients on all areas of import regulatory compliance, trade remedies, and international trade litigation.

Simeon has extensive experience counseling companies in the areas of business and human rights law, including compliance with global anti-forced labor and human rights requirements. He regularly represents companies before U.S. government agencies on forced labor-related matters, including securing the release of goods detained and seized by U.S. Customs and Border Protection. He also offers deep experience assisting companies in mapping their supply chains, including linking imported products back to their raw materials using enterprise software and other inventory management audit tools. Simeon is highly accomplished in forced labor supply chain mapping and risk assessments, as well as verifying due diligence efforts with on-the-ground visits to client facilities, incorporating third-party intelligence and audit resources.

Simeon’s experience also covers a broad spectrum of trade and customs issues, including those related to import regulatory compliance matters such as valuation, classification, duty drawback, marking and labeling, entry procedures, and penalties; free trade agreements; antidumping and countervailing duty issues; trade litigation; intellectual property issues such as trademark and copyright infringement; the enforcement of exclusion orders issued by the International Trade Commission (ITC); steel and aluminum tariffs under the Section 232 National Security Investigation; and the additional tariffs on products from China under Section 301 of the Trade Act of 1974.

Additionally, Simeon handles antidumping (AD) and countervailing duty (CVD) investigations before the U.S. Department of Commerce’s International Trade Administration (ITA) and the U.S. International Trade Commission (ITC) under the Tariff Act of 1930, and litigation involving the U.S. Court of International Trade (CIT).

Prior to joining Crowell, Simeon was a trade and finance attorney in the Office of Chief Counsel—U.S. Customs and Border Protection (CBP), and before that, he served as counsel to Commissioner Irving A. Williamson at the U.S. International Trade Commission.

Simeon is a proud graduate of Howard University School of Law, where he served as technical editor of the school’s Human Rights and Globalization Law Review.

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Photo of Brett Everett Brett Everett

Brett Everett is a senior international trade specialist II in Crowell & Moring’s Los Angeles office. He has over ten years of experience as a Licensed Customs Broker with a primary focus on trade with Asia. He has experience with client inquiries into

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Brett Everett is a senior international trade specialist II in Crowell & Moring’s Los Angeles office. He has over ten years of experience as a Licensed Customs Broker with a primary focus on trade with Asia. He has experience with client inquiries into the classification of merchandise under the Harmonized Tariff Schedule of the United States, antidumping/countervailing orders and circumvention, Section 232, and Section 301 matters. Brett has developed compliance and audit programs and has experience with Post Entry Correction filings, protests, and other filings with U.S. Customs and Border Protection (CBP).

He supports clients with import regulatory matters pending primarily before CBP in all areas of import regulatory compliance, customs valuation, country of origin and marking, trade preference programs and free trade agreements, and CBP inquiries (i.e., CF-28s and CF-29s).

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