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David Stepp is an experienced trade lawyer who provides multinational companies with strategic advice on global customs and international trade compliance matters. David is a partner in the Los Angeles office of Crowell & Moring.

His practice focuses on advising companies on their e-commerce strategies globally, conducting global customs and international trade audits, and assisting clients on improving, benchmarking, and coordinating compliance programs across borders.

David has over 30 years of experience handling international trade regulatory matters, including those related to tariff classification, valuation, country of origin marking, free trade agreements, and Customs-Trade Partnership Against Terrorism (CTPAT).

On June 17, 2022, the Department of Homeland Security (DHS) – which serves as the chair of the Forced Labor Enforcement Task Force (FLETF) – released the Strategy to Prevent the Importation of Goods Mined, Produced, or Manufactured with Forced Labor in the People’s Republic of China (UFLPA Strategy) Report. The UFLPA Strategy Report was

On June 13, 2022, US Customs and Border Protection (CBP) issued CBP Publication No. 1793-0522, its UFLPA Operational Guidance for Importers (Operational Guidance). The Operational Guidance was issued by CBP to assist the trade community with its preparation for the UFLPA rebuttable presumption, which is set to go into effect next week on June

With just over two weeks until the Uyghur Forced Labor Prevention Act (UFLPA) goes into effect on June 21, 2022, U.S. Customs and Border Protection (CBP) has issued very minimal guidance to the importing community on how it will enforce the legislation. In webinars and meetings conducted by CBP last week, CBP stated that it

Customs and Border Protection (CBP) has announced that it will be issuing known importer letters to importers the agency has identified as having previously imported merchandise that may be subject to the Uyghur Forced Labor Prevention Act (UFLPA). CBP aims to issue these letters in advance of June 21, 2022 – which is when the

On February 23, 2022, the European Commission adopted a new proposal for a directive on corporate sustainability due diligence. The proposed directive specifically focuses on corporate responsibility in global supply chains with regards to human rights – such as child and forced labor – and the environment. This proposed directive comes nearly a year after

On February 3, 2021, U.S. Senators Josh Hawley (R-MO) and Kirsten Gillibrand (D-NY) introduced the Slave-Free Business Certification Act of 2022. The bipartisan bill would require companies that have an annual, worldwide receipts that exceeds $500 million and that are involved in the mining, production, or manufacture of goods for sale to conduct an audit

Comment Period for UFLPA Opens on January 24

As an update to our Uyghur Forced Labor Prevention Act (“UFLPA”) post, the public comment period will open on Monday, January 24, 2022.  A Federal Register Notice will be published on Monday and the 45-day comment period will end on March 10, 2022.  The UFLPA was

On December 8, 2021, the U.S. House of Representatives passed a bill called the Uyghur Forced Labor Prevention Act (with a 428-1 vote) that bans the importation of goods produced using forced labor by Uyghers and other minority Muslim populations in the Xinjiang Autonomous Region of China. A similar measure has already passed in the

On October 20 and October 21, 2021, U.S. Customs and Border Protection (CBP) issued a Withhold Release Order (WRO) against disposable gloves from Malaysian company Supermax Corporation BHD and its three wholly owned subsidiaries as well as a separate WRO against tomatoes produced by Mexican farms Agropecuarios Tom S.A. de C.V., Horticola S.A de C.V.,