Battle Against Forced Labor with CBP’s Director of Forced Labor Division

Machine Automated Transcript:

Brian Hoxie  00:00

As you know, we we’re not endorsing any particular company. But what we wanted to do is bring together a number of different solutions for areas that importers could see what people are doing on either risk management or testing, or link analysis. And there’s a number of products out there from a number of different companies, so you can look at those as well.

Andy  00:55

Hey folks, we’re back for another show with simply trade and listen we are gaining momentum we thank you for your listenership your viewership, your sharing, liking us making comments, it is working very, very well. And I can’t tell you that how much we greatly appreciate all y’all. So in the expanding our show and the network. With that, I will say that we are enjoying, I guess as as things are expanding the the exposure for the show, but Lalo I gotta tell you, I am really excited to with how things are going. We’ve said this a couple times, we’ve surpassed the 10,000 Download Mark, we are approaching 100 shows published. And so with all of that, my goodness, it’s Can you believe what we’ve been able to accomplish in a year’s timeframe?

Lalo  01:47

Yeah, no, I know, we will, we will have, we will, by the time this episode airs, we would have already been on our first anniversary. And we’re really excited to bring this special series that we’re bringing on. It’s a set of shows. And as we told everybody, this is the first of several episodes on the topic of forced labor. Yeah, and so we’re taking a bunch of different points of views and perspectives, with forced labor, from the government and the private sector, even resources like software, etc. And so to kick it all off, where we’re talking to someone in the government, which is pretty awesome that we’re excited to do that we have the director of forced labor on on our show here today. And and he will let you introduce them. But what I wanted to say is that this will kick it all off, because it’ll kind of lead into all the other conversations that will have on forced labor, like maybe service providers that are helping importers, whenever they might get flagged and resources like software, how can I avoid this or, you know, be proactive, etc. So we’ll we’ll talk a lot about that with Brian here. So,

Andy  03:02

folks, for our listeners, in particular, everybody’s been talking about the forced labor, the labor force labor Prevention Act and the US you have some forced labor prevention laws and regulations that have been put in place in Canada and Mexico and Europe. And the thing is, what do you do about it, everybody knows about these regulations, you’ve talked about it, it scares you have to death on some of these things, you see some things that CBP has been very, very active on, which has been great, and we’re gonna get to talk about some of that today. But with this, what we’re hoping in this series is you’re going to be able to not only become a bit more proficient in this particular realm, but zero in on what specific actions to you as a compliance person or a transportation person or a purchasing, or legal whatever, whatever aspect of your role that you’re playing, what is the action that you need to take and in ensuring that your company is compliant with these laws and regulations? So with that, I’m gonna say we have somebody like Lalla referred to He’s the director of forced labor division out of the CVPs office of trade. We’re talking to US Customs if you don’t know what CBP that’s Customs and Border Protection, Brian Hoxie, Brian, welcome to our show. We are very excited to have you on board. And looking forward to a good discussion, my friend.

Brian Hoxie  04:29

Thank you so much for having me on the show today and to discuss such an important issue with you all that

Andy  04:35

with that, I will say that as we’re looking at we have had you know, some attorneys on we’ve had as low of may have mentioned off camera here we were talking about having some soft software providers on trying to manage this as well and the data flows and what why would you set it on camera today? Yeah, I’ll tell you my memories as long as the turtles tail Just as fast I got it. So all that to say we are looking through as we’re going through and you know, there’s a lot of attorneys that come in and say, you know, you need to do XY and Z and scare you have to death. And then the application comes into play. He’s like, How in the world with all the things are going on? You know, do I wait till it gets here? Do what do I do? And then on the front end of this and also, why don’t we go and start first off Brian by once you just give a real kind of a recap of where customs is. I mean, obviously the the the forced labor provision is anti slavery, anti forced labor type scenarios. Okay, we get that.

Annik  05:40

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Andy  06:11

Why don’t you start off Brian with what is CBP doing to take steps to implement the regulations that are have been drafted or are being still drafted, probably, and supported the legislation of the anti slavery, you know, laws that are being put forward

Brian Hoxie  06:33

to kind of highlight what CBP is working on in this space, we really take two paths of how we’re enforcing our it’s the 1307, part of the trade Trade Act 1930. And we have one one path where we conduct investigations, and we look into entities overseas. And we do that internally, where we issue with old release orders and findings on goods overseas that are made with forced labor. And so those guys are prohibited from being imported the United States. So that’s that’s one path that we work. The other path that we have is the wigger force labor Prevention Act, which is more recent one being signed about over a year and a half ago, but we implemented it shortly a year ago or more a little more than a year ago. And that says that any goods made wholly or in part, from the Xinjiang region of China, or the Schengen we are autonomous region of China are prohibited from entry. And so what we did into the implementation of that law is we started out, as soon as the the law was signed, we set up a task force internally and work those issues and develop different port policies and procedures. One of the key things to that was reaching out to all of the different stakeholders, all of the different groups and trade, trade groups, academia, and that just, I can’t even go through all the different people that we talked to in that period. But the whole point of that was is to get us to the point where this was not a completely unknown new implementation that people were gonna have to react to six months after, after the signing of the law. And in that, we saw no slowdown in Port congestion, or, or supply chain issues, or any of the things that we would that we were really looking forward to trying to make sure that didn’t happen. So I think that that’s a huge success in our efforts there. From that we’ve we’ve done a number of things to help really understand the law, but then get that information out to the trade and to different stakeholders so that they can comply with the law. This includes an enormous amount of information on our on our public websites, we also have, and that includes importer guidance, operational guidance. And in addition to that, we have frequently asked questions and some of those sorts of things that we that we put out there so that we can give as much information as possible. We continue to engage with the stakeholders, many, many different stakeholders all across the spectrum. And I think we’ve had something like around 450 engagements since the start of the implementation. So if you do the quick math that’s about this more than one a day of the types of engagements we’ve been happening and that that could be actually a low number, actually. So we’ve really been working on making sure that we get the guidance to the importers to build up our expertise internally. And I think we’ve done a great a great job at that. And so now we’re we’re we’re really looking at is continuing that engagement, continuing to supply that information out there. And in terms of implementation, and so that going forward, I think we’re looking at really continued, like I said, continuing the engagement but also working with a number of international Little efforts that are gone going in, in providing expertise and support to that those efforts from to the country like minded enforcement countries that are out there that want to learn from our our implementation of the law, especially. And I do want to point out is continuing to work with our interagency partners. This is not just a CBP effort. This is a whole of government effort. We have the Department of State that we work with, we also work with US Trade Representative, our DHS colleagues, and as well as Department of Labor. So there’s there’s a number of people involved in this force labor, enforcement and ensuring that we don’t have goods imported in the United States with forced labor.

Andy  10:38

Okay, with that, I will say that up to this point, one of the things I found now, I guess, it’s been a couple of months ago, and maybe a little bit longer than that, where there was a report that showed that in one year’s timeframe, CBP had seized, I guess, a billion dollars worth of goods that were, I guess, thought to have been made or components thereof, made with forced labor. What was fascinating about that, it to me, I think there was only $80 million of that that came directly from China, about 400. And I may have the countries and in the end, the the two countries involved were Malaysia and Vietnam, were they were direct ships from and like one of them had roughly 475 million and he only had 300, and some odd million, somewhere, give or take a little bit. So the vast bulk of that were, it appears that China is making components, shipping them to other parts of the world, people are then going through and manufacturing their widgets, if you will, and the items are undergoing a substantial transformation. So it may be, as most people will use the example maybe, you know, bicycle parts that come together now assemble, and then it comes out as a bicycle, not a tire or not handlebars, that’s the whole bicycle. With that, are you seeing that trend continue? Where the way your region there that Northwest region of Sanjay, as you said, is they’re manufacturing items, and they’re shipping them to other parts continuing on? And that are you’re able to catch them.

Brian Hoxie  12:37

Yeah, so I think what you’ve really highlighted it perfectly. I think that the the information that we show, and I think what you’re really alluding to is that we have a public dashboard, where we share our enforcement statistics on there, and you will see very clearly the countries of origin. And those are the declared countries of origin of the final goods. But what you’re seeing is the wholly or in part, right? If it’s only from Xinjiang, if it’s made in the Xinjiang region, and it’s shipped here, it’s immediately excluded. What you’re seeing is that the follow on products, because the supply chains are incredibly complex, and they change. And people are looking for different opportunities, economic opportunities to use different supplies for raw materials. And then of course, the final good, like you said, is essentially transformed into a final a final product. And, you know, I think it’s when you can say something like it’s, you know, supply chains are complex, but I think a really good example that I like to use is, and I don’t know if this is okay, but I’m gonna mention another podcast that did a story about this. Perfect.

Andy  13:45

This is not one of those were like, oh, no, no, no, he’s like, Hey, we’re all in the same boat. That’s fine. So go for it. Maybe it’ll help boost? Boost? Yeah, well, yeah, I will say

Brian Hoxie  13:57

the the planet money podcast did a did a story probably about 10 years ago now. And there was a book that somebody wrote about supply chains. And the I think, or maybe it was an article, but it was the, the life of a T shirt. A simple t shirt. I mean, if you think about it, it’s it’s such a basic commodity, there’s, there’s not really much to it, it’s cotton. And there might be some dye in there. But if you follow the supply chain of where the cotton is grown, to where the the yarn is, is milled, and then you know made into cloth and then died, and then it you know, they follow they follow that a specific t shirt that they build, and it went through five or six different countries before it came to the United States. And that’s what we see throughout the different supply chains in all of the different products that we’re looking at, and in the entities that we’re looking at the make these products so we’re really trying to I think what that dashboard we’re showing that that that is what’s happening is that like, just like you said, there’s a substantial transformation of the different paths optics and pieces for the raw materials are coming out of the Xinjiang region. And those are prohibited. So that is why understanding the supply chains and in knowing your supply chain, getting ahead of that before, before you get detained at the port is so important. And there’s nobody better to understand their supply chains than the people, the actual manufacturers and producers is good. So that’s one of the things that we continue to emphasize is that, know your supply chain, be ready for a detention before it occurs? And have that have that documentation ready?

Andy  15:37

All right, Brian, you’re you’re hitting something that, you know, we’ve talked about a little bit. But let’s stop for just a sec, I want to address for our listeners, listen to what Brian is saying. What CBP is expecting you to do is no your supply chain, that doesn’t mean that it’s like, well, I just ordered it, it’s showing up, I assumed it was this or I’m letting somebody else take care of it, you’ve got to show due diligence and go through and check out your supply chain. So with that, I’m going to challenge our listeners in that that if you’re in the compliance area, reach out to your purchasing and sourcing group. If you’re in that purchasing the sourcing group, you better reach out to your compliance side as well as your transportation logistics. All of you need to work as a team to go through and vet your appropriate, you know, parties to the transactions, the manufacturers, you know, going all the way through it. If you’ve got any wood products, I’m gonna throw in a little curveball here. Something that came up at one of the conferences we were just at I talked to a USDA person well, that winds up being part of the lysiak. Well, that’s another thing that comes in pairs like wood products. And CBP gets challenged through the Ag officers, if you will, that are working with CBP and that and so folks, you got to know where these things are coming from. And we’re talking the Origin of the Species, the origin of the cotton you just mentioned is a great example, Brian of the lifecycle of a T shirt that that show walked and look to see. Maybe it’s time for an update on that one, because that is excellent. But alright, so I know that I need to correct something too. I was saying sin Gen. It’s St. John. So it’s like in Brian, you’re correctly referenced that I’m dumb as a box of rocks. So I got it all stirred up. Lala, what were you gonna say there? But

Lalo  17:39

I was just gonna say I guess this is also do I really need to be in CT Pat, and I’m not saying everybody needs to be or should go through CT power, the best answer that we usually give is, well, even if you’re not, why don’t you why you shouldn’t be a good corporate citizen in general, and follow a lot of those things that are mandated or, or controlled or, you know, in the CT Pat, in the sense that just like what, like Brian and und said it’s know your suppliers. I mean, that is obviously the biggest thing for CT pet, you know, know, your suppliers, and not necessarily I mean, the CT pet was back in the day was created because of the threat on America and products coming into the United States and you know, just trying to avoid a mass destruction, you know, whatever, you know, but in this case, I know I know forced labor has also been added and been contemplated into CT pet. But I guess just in general what I was just trying to say is be a good corporate citizen, you know, just make sure that you do that your suppliers it’s like you said Andy Well, I mean, I know their address is in Vietnam you know or whatever even Mexico right I mean we’ve heard clients tell us you know, it’s coming through Mexico is not a big deal their factories right across the border, I know it is, you know, but it doesn’t mean that it’s it’s it’s safe or I shouldn’t say safe but you know, it’s not it’s not you know, forced labor so

Andy  19:07

it’s all said and done it’s that’s where the raw goods are coming here so this is where the issue is that in that scenario, it’s components that are made with forced labor that are getting incorporated into you know, a widget whether it’s electronics whether it’s a garment whether it’s you know whatever the widget may be but Brian you’re you’re hitting on something again that I guess I look at that I think is phenomenal. When it comes around I happen to talk to a good friend that last night she is Kelly peachy and she was working within her company to literally train some people and talk to him and say okay, how to conduct yourself this is implemented that they’re not being audited, but it’s like just as a preliminary so know your supply chain, but also you know, know how to do your and in her cases, what she was pushing for was how to conduct yourself in meetings during a customs audit and things of that nature? Well, part of the thing that I would say, I’m going to flip this around a little bit, Brian, when your team goes out, and there are some fine folks at CBP, and there’s a lot of information, you do research you you’ve already said, you’re checking out parties, if you will, entities, parties, and individuals, whatever overseas and checking things out. So that as things are coming through, and all of a sudden, a name pops up with this or that or whatever, there’s gonna be shipments that will be flagged, and it’s like, well, that you may check somebody out months ago or weeks ago, but you did your homework, and you now have a red flag in there or something or something worth looking at. Okay, great. When your team goes through and is looking at situations, when you approach a company, what would be an ideal scenario that a company can say, I this is a great way for me to show the due diligence, and then I’m active in trying to, you know, be compliant and all that, what would you like to see in that kind of scenario? So,

Brian Hoxie  21:16

the simplest phrase, I think, for what we use on that is the supply chain tracing report. So it shows from, you know, you’ve got, like we said that the we’ll use the example of a T shirt. However, I know. And by the way, if anybody’s involved in textiles, I know there’s a couple little nuances with textiles, but we’ll just keep it simple. There’s a nuance in all trade and trade processing has to be fair.

Andy  21:41

Yeah, but

Brian Hoxie  21:44

exactly. Or as what’s the legal term? It depends? We, we definitely do, we look at the supply chain tracing reports. So for instance, what you’re looking at is, you’ve made a t shirt. So where did you Where did you buy the cloth from? And can that producer tell you where the yarn was milled, and then you know, going on down to where the cotton was actually grown. And so I bring that up, because cotton is one of the areas in the Xinjiang region that we’ve seen where, you know, the wiggers are being forced to pick cotton. I think I read in the report, it’s a cure for laziness and drunkard ism. So it’s, it’s, you know, they’re really using this, you know, forcing this, these these people to do this labor on things, something as simple as cotton. And those products will make it into not just shirts, but you can think of a plethora of products that come across our borders that have cotton products in them. So

Andy  22:41

even cotton, simple as it is, I mean, the cotton balls themselves as people know.

Brian Hoxie  22:47

So if you have, really what we want is a complete verification package that we can look at, to show and trace all the way through that particular product, how it was how it was put together. And so if you have multiple different areas within that product, you want to look for the areas that are highest risk. So if you see things like cotton, you see things like poly silicon, you know, these are things that we put out in one of our strategies as priority areas, you could then you know, if you had to start doing risk management, you start looking at those areas. Some other things that you can do is use information that’s out there available publicly available through our partners in the in the government, as well as in academia as in the NGOs out there that nongovernmental organizations, they produce information on risk in different supply chain. So you can start using that information to then start putting together your case, right to basically give us a story of where each one of those different pieces came from. We have a document on our website called best practices, and it’s in our UFL pa website, it’s and if you look in that it’s a pretty short document only about three pages long. But in there, we specifically talk about some of the different documentation that you want to have available. So you’re looking for, like the documentation, get this documentation early, first of all, but we’re looking at shipment records, transportation records, there’s there’s different purchasing records, and things that basically show that if you buy X amount that goes into this particular good, it needs to make sense. And like I said, I’m speaking in a lot of generalities, because we’re responsible for enforcing across the entire, you know, 97 chapters of the Tariff Schedule. And the people that know their supply chains best is the is the people that work in these industries, and that produce these goods and purchase these goods. So they really would know the supply chains best and be able to build those tracing documents and be able to provide that to us when requested.

Andy  24:50

Okay, so with that again, let me just stop for a second. So folks, if you’re listening to this again, this is one that first off, I’m going to tell you, you need to Uh, you know, save this podcast, you probably need to listen to it and send it to some others to listen to, especially even executive management. Because from a standpoint here is looking at listen to the scenario, you’re one, when you are getting a new vendor, or a customer or a supplier or distributor, whatever you need to be doing the vetting of those people, and you’re going to hit him against the denied party screening, the restricted party screening and all that, well, then you also have to take it a step further, and look to see, you know, are they potentially involved in any, you know, forced labor scenarios? That’s one thing. Taking it a step further with Brian, I’m glad that you were talking about it. But the thing that I’m picking up on is not only do should you be vetting the parties, you’re doing business with up the chain and down the chain, is also vetting the product itself? What are the components of that product? Where did it come from the origin and all that and reverse engineering all the way back and keep digging? Well, I can’t get that from the supplier? Well, you’re going to have to, because you’re going to have to get in there and do a joint effort in that scenario, to get it down to where to be in full compliance. So I would say and the other thing that you made mention that document so folks, you know, listen to what he’s got here, Brian mentions is that CBP has a best practices document that is for forced labor. Now we’re getting into the details of what should you have? What’s it going to take? And it’s not just a case, well, let me just go check off the list. You look at what he just mentioned, you better take the time and start putting things together is gonna be your your data systems need to be in there your your documents themselves, and what how you check things out. So that if somebody were to from CBP come into a company, and if they said, Well, yeah, here’s how we did this, and you’re able to pull together, people, representatives from the different areas, again, purchasing it, logistics, supply chain, all those different compliance, all that, and they’re sitting there talking about this is how we vet this, this is what we did here, this is what we did with this customer, this is what we did with a supplier, that kind of scenario is going to show where that company is serious about trying to be in compliance. And with that, would that not come across as a positive for your your personnel?

Brian Hoxie  27:38

Yeah, definitely be a positive, I gotta say that, you know, one of the things, one of the best practices that we learned is when the company is really ahead of the game. And they’ve, they’ve done their due diligence, right? If you if you start doing your due diligence, when we detain your goods, it’s too late, right. And getting ahead of it early, and making sure that you make those connections, not only reduces your risk, but it also enables you if you are detained to have the information available, that we’re going to require to potentially clear those goods. And so we’ve seen that, when those companies are actually ahead of the game, and they’re working with, particularly with your center of excellence and expertise, those are those are with 10 other rows around the country that are organized by commodity. But when you work with your senator, and you and you use establish that communication, and you give them the information, when requested quickly, you’re going to see a quicker return on a decision of whether to release those goods. And if you’ve done your due diligence, and you know, there’s no forced labor in that supply chain, then it’s potentially good for you as well, because you can get your goods into the into commerce a little quicker. So a couple areas that you know, that I didn’t, that I didn’t actually mention, but we do have our entity list with the DHS Entity List. Those are those are a list of companies that are prohibited from importance United States, so they’ll be immediately excluded. And if any company is using in a down downward supply chain using materials from those, those are also subject right, because like I said, it’s wholly or in part. We also have you know, a lot of this this is the stuff is all free. All right, this is this is stuff we’ve we’ve put out on the web, you know, in on that you can even say a simple Google searches is is actually a good way to start because companies will have information about their efforts to to address, you know, social compliance issues. They’ll also there are companies in China that have you know, been proud of their poverty alleviation program participation, right. Which is code word for we use forced labor. We use we’re forced labor force transfers of, of labor in within China. So there’s there’s a number of those areas like I said, the State Department has a listing of information on forced labor the Department of Labor has a comply chain as well, which is is a step I step risk management framework that you can look through and start making decisions early. They also have a list of goods that are made with forced labor that they published each year. And on top of all of that, right, we’ve got, you know, the the information that I told you about on, you know, if you actually get detained by customs. And the last thing I mentioned is on technology, I know that there’s a lot of talk about technology in areas to do risk management. So we held a force labor technical Expo in in March of this year, and the videos from that are still online, I believe that you can go and watch. But those are different. We were not endorsing any particular company. But what we wanted to do is bring together a number of different solutions for areas that importers could see what people are doing on either risk management, or testing, or link analysis. And there’s a number of products out there from a number of different companies. So you can look at those as well.

Andy  30:54

Outstanding, I gotta tell you, we can keep on with this, we’re going to need to try and wrap up here on some things. I will say, though, let me go back and kind of do a recap for folks, because I’m gonna tell you, Ryan, this is one of those, I think it would be great to do some more follow up on this at some point, as we’re looking through, but I gotta tell you, you’ve hit on a lot of things. One, again, is the vetting of, you’re checking out different entities, different individuals and all that. Here’s a question on that. If I’m a compliance person, or at a company or whatever, and I’m like, oh, you know what, I found a good source for making a widget. Is there something that CBP would like to say, alright, if so, I’m working through this, or should they work through there? See, I don’t know this like, fierceness entity. This is a new potential supplier, I’m checking things out, I can’t find anything on it. But is there a way for us to be able to maybe offer some information and who we’re dealing with to somebody within CBP? And they can look at and go, you know, red flags, or no, it looks good or whatever. Yeah, that’s,

Brian Hoxie  32:03

that’s difficult. I think, for us to do that in a couple of different respects. I think one is that, like I said, there’s so many different areas about across the different tariff schedule that, you know, we there may be something we have no experience in, at least from from my perspectives. And so then we did we send to the see, the senators are pretty busy right now as it is, I would say they, they are definitely your your area to your your number one person to call. But I think it really comes down to, again, by just doing the due diligence, focusing on that information. And I think one of the things that we see that we’ve seen a couple times now is, I can’t get information on China, they won’t give it to me, or the company is unwilling to give me the information period, for whatever reason, those to me, I think, you know, that’s not going to be sufficient to say, well, we’ve got everything up until this point, but sorry, we can’t find the rest of the information and from this Chinese supplier, that’s going to be very difficult for us to to make a decision on because we don’t have the entire supply chain that we’re looking at. So if you see those sorts of things, I think that might be an area where you might want to see how you can get additional information on the company if they’re not able to provide it. But again, just keep working on going down down the path until you find areas that you can you can you can actually validate. So yeah, we’re good with this.

Andy  33:26

Well, I was just gonna say you’re hitting a good point. So I need to stop for a second because on this is that up to a certain point, there’d be a case, well, the supplier will provide it to me because they’re worried that you know, alright, it’s a distributor, I’m not going to reveal my source. But in this case, you have to get that. So as it’s going through part of the scenario, somebody is reluctant to secure, you know, the details and the information. The other side of that is, you know, what you might want to be looking for a different source. Because yeah, they’re offering you a really good price is the price of those, that transaction worth the risk of losing the whole shipment. That’s the other thing in this is like, let’s take those T shirts. Let’s say for example, that and I believe this actually happened. There were it was submitted shirts, but it wound up coming out of Mexico. It was a large container truck load of of men’s shirts that had been manufactured and customs, then an expense inspection on it did a sampling and found that the cotton was grown in the wigger region in the St. John region. And guess what? That whole thing got seized. So the scenario there, if you are a sourcing or purchasing person, or you’re moving forward, and it’s like, well, I just can’t get it. And then the goods come through and they’re at the border, get seized. Now, you’re going to have to go to upper management and say, well, they just wouldn’t give us the information and you’re out that money, you gotta have that that’s gonna be a tough communique to the upper management the ranks there. So

Brian Hoxie  35:11

I just, you know, want to go back just a little bit on that and say that, you know, right I’m not going to, I can’t give advice to how a company is going to run their business and do the risk management, right? We’re looking for to be able to trace those materials back and have confidence that that’s not made with forced labor. So in the decisions that the companies need to make, I think is right, that’s, it’s part of risk management, I think overall. And we’re trying to, you know, not trying, we provided a number of different resources and materials for people to use in order to, to help with that. Well,

Andy  35:47

continuing on, I mean, it’s like, as you’re vetting the parties, people need to do the due diligence and properly vet, not only the entities, but also at the product level and trace that back. So you’re gonna probably need to have a task force within your company, to you know, go through and do the proper, you know, searches and vetting and all that. The other thing is keeping up with the enforcement stats on your dashboard and information that you’re supplying on your CPV websites. sounds excellent, the best practices, that is a vital document, I think that that would be well worth it, establishing a good working relationship with your see, and reviewing that DHS Entity List this, folks that are denied that as shown to be problematic with forced labor. So that’s a lot of thing, anything else that you can think of to, you know, the nugget of knowledge or action that somebody should take? You

Brian Hoxie  36:49

know, no, I think that said, I think it’s just start early, don’t wait and do the pin. You know, I think one thing that we’re trying to emphasize is that you don’t have to, you just need to get started. Any any amount of due diligence is better than nothing. And I think that, you know, working through some of the the materials that we have, working through that process, you know, doing your reasonable care, doing your due diligence, just continually work on that and strengthen that it’s probably just not going to be a bad thing. If you ever get detained, then then you know, you’ve got something that you can start with, you don’t want to start from zero, right. And like I said, we’ve seen people that have been that if they’d have been ahead of the game, and they’ve they’ve been able to get their stuff cleared a little bit faster. So I just got to keep reiterating that one.

Andy  37:37

It’s really a common sense, simplistic plan. But at the same time, if you go through and do these types of things, and like you said, don’t wait and get this information together early. And it’s going to be like a living document on some of these things. And as you refine your procedures, but that whole plan of being compliant with this isn’t going to be like a shiny new penny that you get to hold on to and it’s like, there you go. Okay, Brian, again, thank you so much, sir, I had to you and your CBP colleagues, they’re great, great group of folks. I’ve had opportunity to a lot of them. I’ve retired that you know, Lau No, Lello. And I, if I can say it, I have known a lot of folks. Well, they’re getting retired and shoved out to pasture there. So it’s like I they crews coming in, and it’s like, we’re older than dirt. So it’s like, you know, it’s like, well, just us relics here, just wave at us and Pat us on the head. Keep going. But to your Hey, seriously, to the CVB. Folks, man, hang in there. I know y’all are dealing with some stuff, a lot of different things. But we greatly appreciate what you’re doing and go through and again, Brian, to you and your team. Great, great job. Thank you.

Brian Hoxie  38:58

Thank you so much. Absolutely. Appreciate that. And thank you for having me on the show. This is good to talk about and get more people out there to to hear about the mission.

Lalo  39:08

Sure. And what I was gonna say is, I’ll either reach out to you or your your staff there and get some of those links. But I do have quite a few links. I have all the links. I constantly watch the links of the replays of that March show. The only reason as we were not there is because we were at another event, but I mean, yeah, we Yeah, for some reason, two of the biggest events in customs actually culminated in those two to three days. It was crazy. But anyway, so but I do have links for that. Everybody look in your show notes for that. Look at the show notes for that document that Brian referred to and a bunch of other stuff that I’ll gather resources for you all and we talked to someone that CBP at G tech, right NDMC said, Actually, she was from BIS. She said Our job is to inform you the public we’re not keeping it for ourselves. You know, it’s not Got a secret, you know, and so we’re more than glad to get that information out. And so that’s what we’ll do. We’ll we’ll get as much as we can. And like Brian said, it’s not a secret. It’s there.

Andy  40:10

Yeah, thank you really appreciate that, folks. One more time, download this podcast and keep us, you know, in your mind’s ear as far as come back and listen to several times. So with that, we greatly appreciate it. Have a good day.

Lalo  40:25

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