Policy Advisory

Xinjiang Supply Chain Business Advisory Warns US Firms of Regulatory and Reputational Risks

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On July 1, 2020, the Departments of Commerce, Homeland Security, State, and Treasury published an advisory describing the “risks and considerations for businesses with supply chain exposure to entities engaged in forced labor and other human rights abuses in Xinjiang.” The advisory—an effort to help mitigate reputational, economic, legal, and other risks for US companies—outlines how businesses can better conduct human rights due diligence.

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Profile

Cosme de la Torriente

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Executive Summary

Miami attorney Cosme de la Torriente almost certainly acts as a facilitator for entities and individuals with ties to Venezuela’s Maduro regime. Torriente has not been investigated for or charged with knowingly participating in or facilitating unlawful activity, likely because he removes himself as registered agent or attorney of record before these individuals and entities are designated. In addition, Torriente may not be aware that many of his clients have been linked to the Maduro regime, or that the companies he helped establish or manage were likely fronts for the Venezuelan government, but his work represents common methodologies used by gatekeepers and facilitators to help provide anonymity to malign actors seeking to obscure their identity and launder money through the US financial system and property markets.

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Policy Alert

Bureau of Industry and Security Lists 33 Chinese Entities

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On June 5, 2020, the Bureau of Industry and Security (BIS) released details on 33 Chinese entities—including government agencies, state-sponsored research institutes, universities and affiliated firms, as well as private companies involved in the general supply chain—it is adding to its Entity List, imposing stricter regulations on exports, reexports, and transfers of certain items. Nine entities were listed for contributing to human rights violations in Xinjiang, and 24 were designated for having ties to weapons of mass destruction (WMD) and military activities.

Twelve of these entities are reportedly involved in nuclear research and development (R & D) and military programs. Others are developing technologies such as cloud, artificial intelligence (AI), and 5G technology that Beijing exploits to track, surveil, and control its populace.

An examination of the nature of these 33 entities and their primary lines of business provides insight into why they may have been included on the Entity List, allowing US firms to more effectively assess their exposure to regulatory and reputational risks and be more proactive in identifying broader trends in the sanctions sphere amidst growing tension between the United States and China.

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