Supply Chain Compliance
Supply chain compliance extends trade compliance obligations beyond the direct transaction to cover suppliers, subcontractors, freight forwarders, and distributors. OFAC's guidance on third-party risk is explicit: using an intermediary doesn't insulate a US company from liability for a sanctions violation if the company had reason to know the goods would reach a sanctioned party. The UFLPA created a parallel obligation for forced labor: importers must trace goods back through the supply chain to demonstrate no Xinjiang-origin inputs. BIS holds exporters responsible for the ultimate end use of their products even when sold through distributors. Supply chain compliance means knowing your supply chain — who your suppliers' suppliers are, where inputs originate, and what happens to the goods after the first sale.