I’ve recently written about how the new US tariffs create more pressure on supply chain due diligence processes and professionals (here and here, for instance). Hogan Lovells issued similar warnings:
“U.S. trade enforcement now targets the entire supply chain for Chinese entities, including indirect contributors to finished goods.
Vietnam’s growing trade profile likely will trigger scrutiny, especially as a potential intermediary for Chinese goods…
CBP indicates that it will engage in robust enforcement through its penalty authority. Specifically, CBP has repeatedly made it clear that it considers tariff avoidance by declaring incorrect information on customs forms to be a form of trade evasion, and that the agency will pursue violations to the fullest extent possible…
Trade enforcement is no longer limited to border checks – it now includes whistleblower allegations from employees and competitors, upstream audits from U.S. authorities, and reputational risk management. In 2025, simply trusting supplier statements without verifying them and unawareness of U.S. trade law can create substantial risk for companies doing business with the U.S. Companies across Vietnam, China, and the broader Asia-Pacific region must proactively ensure their supply chains can withstand scrutiny for compliance with changing laws in an increasingly hostile enforcement environment.”
The memo offers a few suggestions for reducing civil and criminal enforcement risks related to Chinese and Vietnamese supply chains.
Members can read more about about supply chain risks here.
Interested in a full membership with access to the complete range of benefits and resources? Sign up now and take advantage of our no-risk “100-Day Promise” – during the first 100 days as an activated member, you may cancel for any reason and receive a full refund. But it will probably pay for itself before then. Members also save hours of research and reading time each week by using our filtered and curated library of ESG/sustainability resources covering over 100 sustainability subject areas – updated daily with practical and credible information compiled without the use of AI.
Are you a client of one of our Partners – SourceIntelligence, TRC, Kumi, Ecolumix, Elm Consulting Group International or Impakt IQ? Contact them for exclusive pricing packages for PracticalESG.
Practical Guidance for Companies, Curated for Clarity.
