Overview
This article is a companion to our earlier discussions of the distinction between human rights due diligence and documentary compliance in the context of forced labor import restrictions, our survey of the proliferating forced labor import bans taking root worldwide, and our reflections on key human rights governance steps in light of the Sime Darby matter. It examines a compliance challenge that has received comparatively little attention: the corruption risks that may accompany the rapid expansion of forced labor import enforcement around the world.
As our prior companion pieces have noted, the global landscape for forced labor enforcement is changing at lightning speed. For years, the United States stood largely alone in operating a comprehensive import prohibition targeting goods produced wholly or in part with forced labor. The European Union's Forced Labour Regulation, adopted in 2024, signaled the spread of this model. Events during 2026 suggest that the trend is now accelerating globally. In the wake of the recent US trade investigation into foreign approaches to forced labor import enforcement and the ensuing tariff proposals, numerous countries have adopted, implemented, or begun actively considering new forced labor import restrictions. What was once viewed as a niche intersection of trade law and human rights is rapidly becoming a mainstream regulatory expectation.
From a human rights perspective, this trend is highly promising. Forced labor remains deeply embedded in global supply chains, and a growing web of import prohibitions across the world can create meaningful economic consequences for companies that fail to address labor abuses in their operations and supply chains. Yet the emergence of these new regulatory regimes may also create an under-appreciated compliance challenge. As governments establish new import prohibitions, certification requirements, detention authorities, and investigative mechanisms, and vest customs officials with greater discretion over whether goods may enter domestic markets, they may also increase corruption risks.
The nexus between corruption and forced labor is not new. Corrupt recruiters, immigration officers, and labor inspectors have long been recognized as enablers of trafficking and debt bondage, as the UN Office on Drugs and Crime, among others, documented more than a decade ago. What is new is a second front: corruption risk that arises not from the underlying labor abuse, but from efforts to comply with, or navigate, forced labor trade regulation itself. That second front is the focus of this piece. As companies adjust their processes to address these new forced labor restrictions, it is important to consider the anti-corruption lens as well.
A Global Wave of New Forced Labor Import Restrictions
The pace and cascade of legislative activity since March 2026, when the United States Trade Representative began its Section 301 investigation into foreign approaches to forced labor trade enforcement, has been striking.
Cambodia, Pakistan, Indonesia, Ecuador, Nicaragua, Guatemala, and India have each adopted, implemented, or moved forward with new forced labor import restrictions or certification-based compliance models. Additionally, regimes have been introduced in the Dominican Republic, El Salvador, Honduras, Israel, Sri Lanka, Taiwan, Trinidad and Tobago, and Vietnam. Further proposals are under consideration in Peru, Uruguay, Colombia, Brazil, and elsewhere. Still other countries have publicly indicated that they are evaluating, drafting, or consulting on new forced labor import controls. Some of those are referenced in USTR's June 2026 determinations and the July 2026 notice of final action in the Section 301 investigations.
Together, these developments place customs authorities at the center of forced labor enforcement, giving officials new discretion over documentation, detention, and release decisions. What was once a niche human rights and customs issue is rapidly becoming a global regulatory expectation, with a network of customs authorities empowered to review supply chain information and determine whether products are sufficiently connected to forced labor concerns to justify exclusion from domestic markets.
Customs Enforcement Has Long Been a Corruption Hotspot
The expansion of forced labor import bans raises an important practical reality: increased corruption risks. For generations around the world, customs officials have routinely accepted payments to overlook smuggling, waive required inspections, or expedite the release of restricted goods. Officials and importers may collude to undervalue imports, misclassify goods, and underreport cargo weight, reducing duties. Organized crime networks have also frequently target customs agencies by placing operatives inside the enforcement ranks to protect contraband shipments and human smuggling operations.
Recent anti-corruption enforcement history shows why this risk is not merely theoretical. The Department of Justice and Securities and Exchange Commission Resource Guide to the Foreign Corrupt Practices Act repeatedly emphasizes customs interactions, import-export compliance, licensing, and related government touchpoints as areas of concern. The groundbreaking Panalpina enforcement actions remain among the most prominent examples of customs-related corruption, involving allegations of widespread payments to customs officials in multiple countries to expedite imports, avoid regulatory requirements, and secure preferential treatment for goods crossing borders. Numerous cases involving improper payments to customs officials have followed. Indeed, just last month, the Scoular Company agreed to resolve customs-related FCPA charges, paying more than $10 million in penalties and disgorgement. Scoular employees allegedly authorized third-party customs brokers to pay more than $400,000 in bribes to Mexican customs officials over a six-year period to allow grain shipments to cross the US-Mexico border despite inspection failures. The payments were allegedly disguised as "reinspection fees," with portions of the payments apparently benefitting criminal organizations operating near the border.
As these cases and many others underscore, customs authorities create elevated risks of corruption in many jurisdictions. As new forced labor import restrictions emerge around the world, they inevitably create additional opportunities for government officials to exercise discretion over inspections, certifications, detentions, investigations, and release decisions, increasing the risk that payments may be solicited or offered along the way.
High-Risk Jurisdictions, New Powers, and New Opportunities for Corruption
The corruption implications become more pronounced when considering where many of these new regimes are emerging.
Many of the jurisdictions that have adopted or proposed forced labor import restrictions have historically faced significant governance and corruption challenges. Many score poorly on Transparency International's Corruption Perceptions Index and have long struggled with corruption concerns involving customs administration, trade enforcement, licensing authorities, and border controls. The overlap is not coincidental: as Walk Free's Global Slavery Index correctly observes, modern slavery is most prevalent in states that are conflict-affected or where the rule of law is weak, placing them at the intersection of elevated forced labor risk and elevated corruption risk.
As referenced in our prior articles, many of the new regimes contemplate substantial and technical documentation obligations, importer declarations, supply chain verification requirements, or investigative procedures that can directly affect whether goods are permitted to enter a country. Customs officials may gain new discretion to review documentation, assess the thoroughness of supply chain inquiries, or decide whether an importer has satisfied due diligence requirements. At each of these steps, businesses may encounter increased pressure to make improper payments, retain local customs brokers or other third-party intermediaries, or engage in other practices that create significant anti-corruption exposure. In environments where customs and border authorities already present heightened corruption risks, these new authorities may create additional opportunities for abuse.
Origin-based designations add a further incentive. The UFLPA's rebuttable presumption for Xinjiang, the EU Forced Labour Regulation's forthcoming database of high-risk areas and products, and the EUDR's country benchmarking each tie the level of scrutiny to where goods are said to originate. That creates an obvious reward for transshipping goods through a third country to launder their origin, and CBP has expressly prioritized transshipped goods containing Xinjiang inputs. Because a falsified certificate of origin or a convenient re-export record usually requires a cooperative official, origin-masking and bribery can travel together.
Particularly vulnerable sectors may include mining, given the substantial volumes of imports and exports associated with mining construction and operations; electronics and apparel, both of which may involve lengthy supply chains, multiple tiers of manufacturers spread across jurisdictions, and broad consumer distribution; and food and beverage, including agriculture and seafood, given their labor-related risks, cross-border trade complexity, and the operational risks associated with border delays.
Integrating Human Rights and Anti-Corruption Compliance
It therefore becomes imperative for multinational companies to consider forced labor, trade, and anti-corruption compliance as increasingly interconnected disciplines. Supply chain mapping, traceability systems, and supplier due diligence should be coupled with evaluations of how new import-ban regimes may affect a company's corruption risk profile. Companies may consider steps such as:
- Assessing interactions with customs officials, licensing authorities, certification bodies, and third-party consultants involved in import processes in countries adopting forced labor import restrictions.
- Adopting enhanced due diligence and controls for customs brokers, freight forwarders, and local agents in high-risk jurisdictions that have adopted new forced labor import laws.
- Strengthening approval requirements for customs-related payments in jurisdictions with new forced labor import bans, increasing monitoring of border-clearance activities, and conducting targeted customs-related audits.
- Updating training to address bribery demands tied to inspections, certifications, and shipment releases.
- Establishing escalation protocols for customs detentions and government requests for unofficial payments.
More generally, companies might consider including forced labor in anti-corruption risk assessments, and vice versa, and evaluating whether existing third-party diligence adequately addresses risks associated with labor brokers and similar entities.
Several circumstances merit particular attention in the current environment. These include:
- Goods detained or excluded in the US on forced labor grounds but cleared through customs without difficulty in other countries with comparable bans may suggest that local authorities are not applying their laws.
- Unusually fast clearances, or "expediting," "reinspection," or similarly vague fees invoiced by brokers or agents in jurisdictions with new regimes.
- Opaque descriptions on bills of lading, such as "miscellaneous" or "samples," or descriptions that are inaccurate.
- Changes in a supplier's declared country of origin or routing that coincide with a new designation or presumption, which may suggest document falsification.
- Local third-party brokers claiming special expertise regarding forced labor bans and charging inflated premiums.
These concerns are especially relevant given broader enforcement trends:
- The EU is moving toward stronger anti-corruption frameworks, including its Anti-Corruption Directive, which entered into force in May 2026.
- The UK is demonstrating an increased willingness to pursue significant corruption-related resolutions and continues to sharpen its focus on economic crime enforcement.
- In the US, trade enforcement has become a key government priority, as Scoular shows, with DOJ establishing the Global Trade and Commerce Enforcement Section and the Trade Fraud Task Force to focus aggressively on customs, sanctions, trade fraud, and related offenses.
Companies that make adjustments to comply with new forced labor import bans must also consider new associated corruption risks, or they may find themselves solving one compliance challenge while creating another. Collectively, these developments suggest that regulators increasingly expect companies to identify and manage corruption risks arising from trade compliance activities rather than treating trade and anti-corruption compliance as separate functions.
Conclusion
The rapid spread of forced labor import bans represents one of the most significant developments in human rights compliance in recent years. At the same time, many of the jurisdictions that are part of this expansion face elevated corruption risks, particularly within customs and border administration. As a result, affected companies should evaluate these developments through both a human rights lens and an anti-corruption lens, and consider integrating forced labor due diligence, trade compliance, and anti-corruption controls into a single risk-management strategy.
