I'm Scott. I'm Bill. And we're the Trade Guys. You're listening to the Trade Guys, a podcast produced by CSIS where we talk about trade in terms that everyone can understand. I'm H. Andrew Schwartz and I'm here with Scott Miller and Bill Reitch, the CSIS Trade Guys. Welcome to this episode of the Trade Guys. Bill and I will meet with a special guest, John Foote. John is a partner at the Law firm of Kelly Dry Warren and is a specialist on
forced labor and specifically the Weeger forced labor prevention act. John's going to give us an update on all things UFLPA and give us his forecast for the future. All this and more on the Trade Guys. Well, it's a real honor to have back with us John Foote. It's a partner at Kelly Dry Warren, that law firm that I was affiliated with for six years. John is coming back to discuss our favorite acronym, UFLPA, which stands for the Weeger of Force Labor Prevention Act. And he's
going to bring us up today. Now what's happening? Yeah. Well, thanks so much for having me on. It's great to be back with both of you again here on the Trade Guys. You know, look, the Weeger Force Labor Prevention Act from my standpoint is having a pretty dramatic impact on the trade landscape. I think you'd be hard pressed to find another law that has had such a dramatic impact on trade in such a rapid period of time, particularly a law that isn't officially a trade law,
right? It wasn't enacted as part of trade legislation. It wasn't enacted. I'm codified as part of FIDLE 19 of the U.S. Code, which you got to have in my mind is sort of where you look for trade laws as the customs statute within the U.S. Code. This is a human rights law. It's specifically a presumption that invokes the application of the forced labor import ban section 307. It has been put to pretty dramatic effect, which is to say there has now been several billion dollars worth
of trade that has been targeted for enforcement by U.S. Customs, which is a pretty meaningful amount of trade by any standard, by any metric. I think if you listen to people within the ecosystem, there are a wide range of opinions about this law. You know, it's the best law ever. It's the most
important law ever. It's incredibly important from a human rights standpoint that the United States was able to sort of look at a major instance of state-sponsored forced labor and then take action against it by establishing this kind of a presumption and actually seeing commercial enforcement against enforcement against commerce. There's also a lot of what I view as legitimate complaints about the law, which is to say it has certainly impacted trade that ultimately
is not linked to forced labor at a pretty remarkable scale. It's an interesting phenomenon about the law itself is that customs is reporting out a certain amount of data on the law in the form of this UFLPA dashboard. And front and center on the UFLPA dashboard are statistics about the volume and the number of shipments within different categories that have been targeted for detention and then ultimately the resolution of those detentions. And there's essentially
three resolutions that are captured on the dashboard. You have merchandise that has been rejected entering into the United States. You have merchandise that has been released into the United States, following customs review, and you have the merchandise that is still pending review by CBP. So merchandise released into the United States. This is merchandise that was detained at the border out of some concern or theory on the part of customs that perhaps there's a supply chain link
to forced labor. And then this merchandise has ultimately been determined not to be subject to the UFLPA. And it has been released into commerce in the United States. And that number has fluctuated a little bit for a month to month, but it has hovered right around 50%. And what that means is of all merchandise that has been fully adjudicated by customs to date. What that means is that approximately half of all the merchandise that has been impacted by the UFLPA has been
definitively found by US customs not to be subject to the law. It has no supply chain connection to forced labor. It has no supply chain connection to forced labor. It has no supply chain connection to the Xinjiang Uyghur Autonomous Region. And yet it was subject to detention. It was subject to the full spate of requirements associated with detention activity, which means the production of a lot of traceability documentation very meticulously constructed and put together. This is a
huge impact on trade that is not ostensibly within the scope of the law. And of course we know about it because the way that customs is reporting the stats, which is interesting in its own right. But I can't think of any other law that operates this way in the world of trade. Maybe that's because
it isn't a trade law. It's a human rights law that's impacting trade. You can imagine sort of anti-dumping duties being applied on merchandise, but like half of the merchandise that are being charged anti-dumping duties aren't in scope of an anti-dumping proceeding or export controls on a particular variety of merchandise. But half of the merchandise that has actually been restrained from sale and for export isn't within the scope of the ostensible export control.
You sort of can't find another example that even makes any sense in the context of trade, but it certainly has been impactful. And it's difficult to say that it has been particularly effective at finding merchandise with a supply chain like the Forrest-Wheeger Labor. Why is this to the customs folks simply not know what they're doing or is it really complicated to figure this out and they err on the side of the tensions? I'm almost aggressively defensive
of US customs and border protection. That is sort of the first place you would look like who spelt is it? Are these bozos who are enforcing it? And the answer is no. US customs is doing in my view what I have been able to observe is I think their level best to enforce a law that was not crafted with any consideration of like how the thing would be enforced. And what I mean by that
is that the UFLPA it jumps in midstream, right? It applies the presumption to merchandise that was holier in part made in the Xinjiang region or bi-listed entity, but it just sort of assumes that customs is able to identify such merchandise. It can just tell what merchandise was made in the Weeger region or bi-listed entity and it's simply not true. It's not possible for customs to look at merchandise coming across the border and know our priori what the supply chain looks like.
It's difficult for companies sometimes to know what their supply chains look like and customs has less visibility than companies do, but nevertheless that was the statute that was enacted. So it jumps in midstream and as a result, customs is charged with enforcing the law that Congress
enacted. And given that this is the law Congress enacted, customs is doing the only rational thing it could do, which it is identifying merchandise for which it believes there is a credible basis to suspect that that merchandise has a supply chain linked to the Weeger region or to a listed entity. It's making essentially educated guesses. It is trying to pick out targets that seem reasonable, given the evidence that customs is able to accumulate. And it's still only about half
right. And they're still only about half right. Now whether they're doing a good job or not, we could evaluate them based on the output of the statistics, but we also don't know exactly how they go about picking targets. That is regarded as a matter of extreme confidentiality by U.S. Customs and Border Protection. It is a separate question from the entity list. The entity list is interesting, but not particularly relevant to the question of which targets customs is going
to pick out. Customs has put up a little bit of information, but by and large, very little is understood about what it picks, how it picks, other than what you can reverse engineer when you actually look at any individual detention. Now if I'm an importer or distributor and one of my shipments is considered a suspect and is detained by customs. And I managed to prove my innocence. And get it released. I get my stopback some months later. Okay. And how many months by the way,
but is there any remedy? It's not enough that I have to prove my own innocence. But then once I prove it, I had to incur a lot of costs to do so. What do I get from the government? I get my reputation back, I guess, but what else? Well, there's not much in the way of a remedy against CBP for its enforcement of the UFLPA. It's picking out targets. It's trying to do a good job, I think. And to my observation, the selections that CBP has made are not manifestly foolish selections. They're
not obviously wrong, obviously ridiculous targets for detention activity. They're picking out what they think has a credible basis for a serious apply chain linkage to the region in question. I think it might surprise some people just the extent to which this law is not being enforced against goods from China. For a long time, goods from Malaysia have led as have goods from Vietnam. And recently, Thailand took over the third highest in terms of value, the number of
detentions and the value of detentions. China is actually a pretty distant fourth, and it's hovering right around 11% of all detention activity by US customs. It's only targeting about 11% of it as goods that are country of origin, China. That might surprise some people to the extent they think that UFLPA is really a law that is targeting Chinese origin goods really overwhelmingly to 90% of it is being targeted at merchandise manufactured outside of China on a theory of
supply chain linkage, a theory of potential connection to the region. If you get your shipment
clear, that's regarded as a good outcome under the law. If you have the unfortunate experience of having detention activity, what I would say is that I have observed to a certain extent that the CBP algorithm in selecting targets for detention activity tends to favor and reward companies that do well in navigating the detention activity, which is to say if a company does a good job clearing shipments, that doesn't necessarily mean you won't get shipments detained in the future.
You might. They might even come after you for shipments. You're getting from a different source, but there is, I observe some evidence that customs is trying to reward in borders that are in good faith presenting the proof of the supply chain. Again, very meticulous, very high level of detail documentary review, and you can actually get to a potentially better outcome in the future state by engaging in good faith with CBP. I observe that feedback loop. I definitely have seen that in practice.
It's not exactly sort of getting compensated for a harm, but it's not nothing. I'll say that. Originally, I think most of the focus here was on cotton, textiles, apparel, tomatoes, and polysilicon. But I gather recently, they've started to branch out and broaden their enforcement scope since the statute doesn't limit it's the matter of I think resources. There's been a
recent set of back and forth with Congress about automobiles and auto parts. Can you talk a little bit about both Autos and about the broadening scope of the enforcement generally? Yeah, sure. So officially under the UFLPA, there is the designation of high priority sectors
for enforcement. Really, what that has meant in practice is it has meant certain categories of merchandise that are being produced and significant quantities in the Shinjong-Uyuer autonomous region that are then making their way into supply chains that are destined for the
United States. There's been plenty of research that has been put out by many different outfits within the academic and NGO community that have identified this type of production happening in Shinjong or this type of manufacturing happening in context that is connected to forced-wee your labor. What Congress did in enacting the UFLPA was it designated certain categories that are high priority sectors, which are the three that you mentioned, Bill. But customs, of course,
is not limited to enforcement against the high priority sectors. It simply must ensure that it dedicates a significant amount of resources to enforcement against those high priority sectors. And in fact, in practice, customs has detained many, many more varieties of merchandise in many additional categories and has explored detention activity in many different additional contexts.
In theory, the purpose of this sort of exploratory or what I sometimes call burgeoning sector detention is that customs is looking for merchandise for which it thinks there is a supply chain link to forced-wee your labor or the Shinjong region. That could potentially be added as high priority sectors. So every year, the forced labor enforcement task force or the Fletaft has to update the strategy for UFLPA enforcement, and they have to select new targets for high
priority sectors. Last year, Fletaft did not add any additional high priority targets, but we're coming up here on middle of the year, which means Fleta is getting ready to publish its updated strategy. I would be very surprised if they don't identify additional categories for high priority enforcement given all the many publications in the NGO and activist space, which are really
driving enforcement. Artiparts could be one of them. Illuminums, seafood, there's so many different categories of merchandise that have been connected in one way or another to forced-wee your labor. Outside of Shinjong or to the region itself, any number of those could be selected by Fletaft for inclusion. Let's go back to one step. Seafood from Shinjong. Yeah, so a lot of folks ask that question. The reporting has indicated that it's processors of seafood, particularly in eastern China,
that have participated in the social programs of concern. So with the weavers in the somewhere else, not in Shinjong? Exactly, exactly. And that's really the part of the whole challenge associated with UFLPA is that, yeah, you've got this region that is a complete surveillance state in far northwest China that is designed to exert maximum pressure and maximum control on the population there, which is overwhelmingly bigger and other ethnic minorities. But then you also have the
social programs of concern. That's the term that I use for it, which is the social programs that require weavers to leave Shinjong and get into a labor transfer program as part of the domestic migrant worker apparatus that exists within China. And so they'll be moved to manufacturing locations elsewhere in China. It's an offer you cannot refuse if you are weaver. You have no
credible option to opt out. You simply have to go. And so in theory, that's what the UFLPA entity list, the sort of best suited to capturing is it's supposed to capture Chinese companies that have participated in the social programs of concern that have taken transfers of weaver workers and are employing them under conditions of legitimately forced labor. Ideally, those are the companies that should be added. It's not necessarily the companies that are being added to the UFLPA
entity list. But ideally, I think that is the target and what was intended. And so yes, for seafood purposes, there has been a lot of reporting, a lot of public reporting around seafood processors in
Eastern China that have weavers employed. And the evidence is actually quite compelling. You know, they find a lot of indicators of weaver presence on social media in China, weavers posting sort of these veiled sort of communications, posting pictures on themselves and videos of themselves with these mournful patriotic songs, mournful, you know, traditional songs into the league or culture.
I mean, it's really quite devastating when you actually sit down with the evidence and you look through it, you read through it, and you understand what's actually happening in these environments. Now, we noted the Senator Wyden chairman of the Senate Finance Committee taking interest in auto parts. And that seems to be a big door to open. Our friends at Napa say that there are 30,000 parts in a typical automobile. It's one car, 30,000 parts. So, you know, this really gets big in a
hurry. And frankly, I'd experienced what is happening with the Lacey Act. Lacey Act was an act passed by Congress in 1900 to protect against basically invasive mammals. It was only mammals and birds, but it was to exclude things like wild boars and disease carrying birds, human disease carrying that were, you know, genuine public health concern. It got expanded, but and changed from USDA to fish and wildlife, in which is Department of Interior. But I note in the 1981 revisions to
the Lacey Act, they added fish, which tripled the number of species. There were about 6,000 species of mammals, there were about 10,000 species of birds, 32,000 species of fish. And so all of a sudden we're into fish and we're enforcing everyone's treaties. So Lacey Act instead of being a public health matter for USDA became a, if there's a treaty on endangered species, whatever they might be, the Lacey Act can be used to enforce it. Then in 2008 we added plants, which was another 380,000
species. And so I do remember some of the meetings in 2008 where one of the auto companies was looking for guidance about important cars because when you covered plants and all the derivatives, the owners manual in the glove box was covered by the Lacey Act. You know, so what do I have to declare? How do I prove that the wood pulp was not from an endangered species? I can't. And so this happens enough in Washington that I think it's worth raising the concern about.
Where do you think this is going? Yeah, I appreciate the question very much. And I think the answer that I'd give to it is the reason why you are talking to a trade compliance lawyer, a customs lawyer about UFLPA, which is that the question of a supply chain link to forced labor is a very detailed and fax-specific question. Supply chains are, as we know, large and
very complex, almost organisms, right, which result in the production of merchandise. And if what is in scope of enforcement, and what is in scope of enforcement, is anything with a supply chain link to force we or labor or to force labor generally. And that is what's in scope of enforcement under the force labor import ban, then the answer sort of of what you're paying attention to is highly fax
specific. And in the absence of specificity about what the supply chain looks like, in the absence of visibility into the supply chain, inevitably more merchandise is going to be suspected of a link than is going to actually ultimately have the link. So I think you see that in the context of how customs is approaching enforcement. It's in the detention statistics and the disparity that
exists there. Like this is just a phenomenon of trying to enforce a law that prevents the importation of a very specific category of merchandise, but also tries to bring in the depth of the entire supply chain into the scope of enforcement. So what I have not yet seen, I have not seen an expansion, you know, topically category to category in ways that are objectively untethered
to credible concerns about forced labor. Generally what I have observed as you go category by category, you say, wow, like there really are credible concerns about the connection to either this region where there is a full on surveillance state and the programs of ethnic subjugation, or there is credible evidence of forced labor itself happening. And that is inherent
in the nature of supply chains. It's inherent in the nature of the concept of taint and the concept of well, once this merchandise sort of gets consumed at the next stage or tear in the supply chain, then sort of everything at that stage is potentially tainted and so on and so forth. It has an inevitable snowball effect unless you are able to be specific unless you are able to be precise.
And quite frankly, the law is not well suited to precision. If you spend any time sort of listening to anything I've had to say or write about this law, it's that message over and over, which is that the law was not built for this purpose. It is a powerful idea of a law, 54 words worth from the forced labor import ban that has now been sort of subject to an important application, arguably the most important application, which is a large instance of state sponsored forced labor,
targeting millions of individuals in a key geopolitical rival of the United States. But the United States has not yet built a law that is capable of a great deal of granularity and specificity. And therefore, there's a lot of potential for collateral damage as you go about trying to enforce the law against something for which there is a broad amount of popular support, certainly a broad amount of political support. Let's talk a little bit about compliance developments and
supply chain audits. One of the issues in the automobile parts and components case raises the question that I think you've alluded to, which is, how far back up the supply chain do people have to go and how feasible is it for them to get there? A lot of other things, it seems that we are now having a little bit of a college industry of people who will do supply chain audits for you. I guess one question, there's a bunch of questions. One is, are those real or is
that a scam? Does it help? Is it possible to do audits? How are people coping with the compliance responsibilities that they have? In this case, with the presumption burden being put out of them,
rather than on the producer or on the custom service? Great question. What I would say is that one of the really interesting and great consequences, I think, a great consequence of a lot of work that has been done now in the Section 307, Post-UFLPA environment, is that there is a much more coherent understanding of the state of play regarding supply chains and enforcement and sort of how these two different things are intersecting. How enforcement is intersecting with
a complex global supply chain. A couple of the key principles that I'll say have really broad uptake in my observation on the part of industry, CBP, and even the NGO community. One is the concept of supply chain mapping, which is just identifying the parties that are a part of the supply chain, right? Beyond tier one, tier two, tier three. However far back you need to identify that concept, who is in the supply chain? That concept is just referred to as supply chain
mapping. Then there comes the question of, well, can you prove what a supply chain looks like? And in US Customs view, the way you prove what's in a supply chain is you produce it through commercial documentation. You show things like purchase orders and invoices and proofs of payment and trucking records and warehouse receipts and bills of lading and all the commercial documentation
that gets generated in the ordinary course of business. Customs is doing the really difficult work of taking that information in, looking at it, digesting it, and deciding whether or not it is a depiction of reality. That supply chain traceability. The question of audits is a little bit different because the question of audits is about whether or not a particular supplier has engaged in forced labor. Now this is a really difficult question in the context of forced
weaker labor and forced labor in China specifically. If a company wants to sort of rely on a Chinese supplier that perhaps there have been allegations that that company has participated in forced labor, the question is, well, how could you go about continuing to do business with that supplier? And one potential approach as well, we could try and do an audit. But I think the critique on doing audits of that supplier for social compliance purposes for forced labor purposes is that this
is obviously disfavored activity in China. So if the government does not approve of auditors coming in sort of having free and fair access to interview employees, actually look for the evidence of the indicators that would demonstrate that there are weaker workers present who may have come in through one of these social programs that again present an offer they cannot refuse. Well,
what are you doing if you're trying to do this audit? And the answer is, there is no credible way to do an audit in China to rehabilitate a supplier for which there is credible evidence that that supplier is engaged in forced labor, particularly involving the weaker community. At the same time, the NGO community has tried to sort of push this bridge further and say actually all social compliance audits are a waste of time. They aren't delivering value. They aren't sort of helping
actually change outcomes for workers. And therefore there is no value at all. And that to me is a slightly different question than the question in China than the question of forced labor. It's an interesting question. And I guess my reaction to it is like, I think you ought to be very careful before you say there is no role for having an independent auditor come in to a working environment and evaluating conditions in that working environment and providing an independent report that
sort of justifies what is or is not happening in that context. So there's certainly an agenda out to kind of discredit all audits, all social compliance audits, all supplier audits that try to touch on the forced labor issue. It seems to me perhaps ill-advised because I think there is a lot of value that can be achieved, that can be unlocked by hiring an independent third party to come in and evaluate working conditions. I think it's also just important to be realistic though about
the limitations associated with that. And those limitations include obviously most importantly instances where the state is engaged in trying to prevent that type of auditing from happening. But also I think it's important to recognize the critique of these social audits which is simply to say if you try to look for evidence across a long time scale and I think the folks at Cornell
ILR school have done a really great job of publishing and documenting this. If you try to look at the private efforts of regulating global supply chains and you say is there any tangible evidence that you know workers have done better as a result of these kinds of programs. The answer is the evidence is difficult to come by. I think in individual instances anybody who runs a program of these could point to examples and say hey here we got an audit. It was bad results. We remediated. We developed
a compliance action plan and it generated a better result for the workers in question. But if you try to look at it on a macro scale it's much more difficult to sort of observe those patterns and those trends in process. And it's hard to sustain or transfer from one category of products to another. I remember conflict diamonds which was relatively successful in achieving its objectives.
They tried to translate into conflict minerals and because of the differences in the way those supplying networks worked the simplest thing for purchaser of minerals was to just be ended all purchases from those geographies and it actually harmed the people it was intended to help. That happens too often in my view but is there any way to manage that job.
What your question highlights to me is it highlights the complexity associated with trying to sort of build a law that is capable of responding to such radically disparate instances of what we hang under this umbrella which is forced labor. When you're talking about a program of state sponsored forced labor, ethnic subjugation in China and you're talking about migrant workers in Southeast Asia who are in search of a better lives for themselves and are vulnerable and exposed
to exploitation. When you're talking about children engaging in the worst forms of child labor in a minerals extractive capacity in Africa there are many many many very different varieties and what we are trying to do with this law is we are trying to sort of craft a tool that is capable of cognizing all of these very disparate instances of forced labor and action all of it. In my view it's one of the most credible things to try and do in trade. It's a different type of
thing that we've tried to do in trade before. It's a different genre entirely. This doesn't have to do with protecting a domestic industry. It doesn't have to do with advancing U.S. national security objectives. You're hard pressed to even really make a credible argument that this is about U.S. economic security really at the end of the day what this is about. This is about consumer
protection. It's about protecting U.S. consumers from consuming merchandise or more specifically allowing their their spend their commercial outlay to actually be the cause or be the attenuated cause the source of the commercial demand that allows and gives rise to conditions of forced labor deep within a global supply chain. That's the purpose of a forced labor trade law. It's challenging because there are so many different kinds of forced labor and so many different contexts
and so many different industries, individual vessels, fishing vessels. We didn't even talk about fishing vessels but there's so many different ways but I do think that the law is sort of capable of differentiating in between these different cases but it will require some serious effort in order to achieve that. Well last question. What do you foresee? What's the trend here? What's going to happen going forward? You said there's a new strategy coming out shortly. What are you expecting
for the next year or so? I think the first thing to appreciate is that new strategy coming out. The designation of new high priority sectors will be probably the most important headline,
most important takeaway from it. I think another sort of key thing to watch is if there is a shift in the presidential administration, if President Trump returns, I think that what you have observed even though you see a lot of polysilic and detentions on the part of CBP, a lot of solar panel detentions, there's obviously I think a counterveiling concern within the Biden administration that may have limited the impact of enforcement. I would expect that to disappear entirely if Trump
comes back into power. I would say on the legislative front, we see a lot of bills that get introduced that sort of look at the last, what people think is the last great idea, which was the UFLPA and try to replicate that and apply that into a new context. Whether or not you think the UFLPA was a great idea or whether you think it was important and a great idea but just not well executed, probably has a lot to do with how you feel about these new proposals but they're certainly quite popular
right now. There's a lot of effort, a foot to sort of attach, you know, additional consequences. Ultimately, what I think has to happen is I think there has to be a reckoning with does the United States actually want to enforce trade laws against goods that are made with forced labor? If the answer to that question is yes, there is a more coherent, more rational way to do it, but it would require some real innovation and some actual output generation from Congress on that
front. I don't know whether there is appetite to do that. So I certainly expect that the present state will continue. You know, the other thing that I should just mention is the expansion of the
entity list. You know, just recently we had a really significant expansion. 26 new companies were added to the entity list and it had a dramatic increase in the number of Chinese companies that were added to the list but it also had a really important conceptual sort of shift and what it has done is created, I think, a lot more uncertainty around UFLPA than existed there in the past. You know, the entity list is the list of companies that is subject to the presumption, right?
It's the region plus the companies. I've already told you I thought the most important use of that list is to capture companies outside of Xinjiang that have participated in forced labor. That's what we want to be capturing with the enforcement. Well, a lot of the companies that were already on the entity list are companies in Xinjiang that have participated in forced labor, which is
arguably duplicative of the regional presumption. But now almost all of the 26 entities that were just added to the entity list are not actually accused of participating in forced labor. They're simply accused of having received content from the Xinjiang region at one point in time. So the US government found evidence that cotton was shipped from Xinjiang to these companies. They've now been added to the entity list, which potentially increases the extent of enforcement.
But there's a significant mismatch because these companies are not involved in any sort of production mining or manufacturer capacity. And that's the only thing that's in scope of the UFLPA. And if you actually read the section three to rebuttable presumption of the UFLPA, it only applies to companies on the entity list that are involved in producing a good.
And you can arguably say if you're just in a bicell capacity or your warehouse or cotton sort of passes through that particular node in the supply chain, they're not engaged in a production capacity. And this is just another example of the many that I've highlighted, which is that this law is
incongruous with the balance of title 19. It's incongruous with section 307. It's incongruous with everything because it wasn't sort of thoughtfully crafted to capture exactly what it intends to capture, which is forced labor in individual supply chains to incentivize identification of that forced labor and to incentivize the eradication of that forced labor. So at some point, some of these latent defects or uncertainties or incongruities within the law
are going to become more manifest. And I think that's going to inspire some folks to do this in a different way. Well, I smell litigation, which would be good for you, John, since you're a lawyer, and also a good reason to have you back in the future. Exactly. In other words, hold on tight. It's going to get interesting. But John, thank you for coming on the program again, we've enjoyed this update and we realize both how important this law is and our appably is
changing. So having your expertise is a huge value. Now, if our listeners want to find more information about you, they can obviously hire you as an attorney at Kelly Dry. But where else do you publish? Should work on it here from you? Yeah, thanks Scott. So I publish a newsletter on forced labor trade enforcement. Again, I think this is one of the most interesting sort of cutting edge areas of trade law. You know, how do you use a trade law to actually combat supply chain
links to forced labor? How do you use it to incentivize the identification of forced labor and ultimately the eradication of forced labor? So I publish a newsletter on this. It's on the sub-stack. You can find it at forced labor trade dot substack dot com. I'm also active on LinkedIn's so you can find me on there. Thanks so much guys for having me. It's really great to be with you. Thank you. It's been a pleasure.
To our listeners, if you have a question for the trade guys, write us at tradeguys at csis.org. We'll read some of your emails and have the trade guys react to it. You've been listening to the trade guys, the csis podcast.