Forced Labor Regulation in Automotive and Aerospace: A Shift in Enforcement

In recent months, enforcement of the Uyghur Forced Labor Prevention Act has disproportionately targeted the automotive and aerospace industries, detaining nearly 5,000 shipments with only 73 released. This dramatic increase in enforcement attention on automotive and aerospace is a new but sustained trend. Before October, “automotive and aerospace” had been the 8th-most targeted industry since the UFLPA entered force in mid-2022. By December, automotive and aerospace became the second-most targeted industry due to a significant spike in detentions. 

To understand these trends and what they mean for industry, join Kharon’s Ethan Woolley and Miller & Chevalier’s Daniel Solomon for a nuanced discussion on UFLPA and the recent shift in enforcement.

Speakers:

Ethan Woolley, Director, Kharon

Ethan Woolley is a Director at Kharon, where he leads the firm’s work on UFLPA due diligence best practices and the use of data to strengthen risk management programs. Ethan frequently works with private sector organizations in every industry and regularly speaks at conferences and industry events on forced labor risk. Ethan received his BA in International Relations and Russian from the University of Pennsylvania and an MA in Energy Politics from the European University at St. Petersburg. Ethan speaks Russian and spent time living in Moscow.

Dan Solomon, Member (Partner), Miller & Chevalier

Dan Solomon's practice focuses on international corporate compliance, internal investigations, government enforcement actions, and economic sanctions and export controls. Dan's work is integral to the firm's focus on the automotive and manufacturing sectors. Dan advises companies on compliance with supply chain due diligence laws, including the UFLPA, supplier due diligence, and risk mitigation, with a particular emphasis on automotive and consumer products. He is one of the authors of Miller & Chevalier's UFLPA trade flash, analyzing policy developments and enforcement trends in the automotive supply chain, among other areas. Dan previously held senior legal positions at a major automaker, including as General Counsel in its China business, as well as Lead Counsel of Global Compliance. Dan has substantial experience in the automotive sector and in-depth insight into the Chinese legal system and the regulatory and compliance risks encountered by multinationals doing business in China, which he leverages in the context of China-related trade matters.