In Issue 132 of WorldECR's Journal of Export Controls and Sanctions, Richard Mojica, Daniel Solomon, Mary Mikhaeel,* and Aditi Patil discussed the U.S. government's decision to expand the Uyghur Forced Labor Prevention Act (UFLPA) Entity List with five new additions, some concerning companies involved in critical minerals. "Tracing the provenance of minerals can be extremely difficult, especially when the product under review is a consumer product," the authors explained. They continue, "[i]n those cases, the US importer and its direct supplier usually have no commercial relationship with the mineral supplier who is several tiers removed in the product's supply chain."

*Former Miller & Chevalier attorney