Expeditors International of Washington, Inc. (EXPD) Earnings Call Transcript & Summary

Okay. It's at the top of the hour, so we can get started. Welcome, everyone, to the Forced Labor webinar. Today, we are going to go through about 45 minutes of presentation material, more or less. And then at the end, we will reserve some time for some question and answer. And I'm sorry, I actually forgot this one is a 90-minute webinar. So we have a bit longer for the session. [Operator Instructions]. We will also share a copy of the slides presented today following a quick feedback survey that will be sent out after the webinar. So without further I do, I'm going to go ahead and introduce our speakers. Today, we have Brenda Smith, Global Director of Government outreach; Kim Myskewitz, Director of Trade Compliance for the Americas; Madeleine Veigel, Director of Customs for the Americas; and Ted Henderson, Director of Customs for the United States. So I will go ahead and pass it off to the group to get us started. Thank you.

All right. Thank you, Nicole, and thanks for giving us a few more minutes than the 45 you originally mentioned there because we do have a little bit more than 45 minutes of content today. So definitely appreciate everyone jumping on and joining the conversation today. So thank you kindly for joining us. We are going to speak about forced labor in a larger overview sense, briefly, and then we're really going to focus on the Uyghur Forced Labor Prevention Act. These are the primary topics that we've got up on the screen for the agenda. For those of you who participated in our Forced Labor webinar in April, let me just offer a couple of quick comments, please, about today's webinar. We will begin with a high-level overview of forced labor and the current enforcement actions that are on forced labor under Section 307. But I do assure you, we really are going to devote the bulk of the webinar to the latest information that we have related to the Uyghur Forced Labor Prevention Act and how CBP and government agencies will be implementing the act and the information that we're getting from them on this. So I do hope that this will be informative and definitely a lot more information than we understood back in April. So this information that we put together is really based on public outreach from CBP and some of the other government agencies a little that they've offered, and it's also based on our own direct conversations with CBP and DHS officials. So we've tried to pull all this together. Our goal here really, we don't intend to offer a lot of opinion here. We're really offering this and make this as fact-based as possible. We may, at times, offer our opinions on something, but we'll certainly make that clear when we do so. As Nicole said, we will be providing a copy of the slides that we do cover today. So all the material that you see, you'll be getting that shortly. Typically, that goes out less than an hour after we conclude these. So hang in there, and you'll get this material as it goes. So let's keep going with the Forced Labor overview, and I will turn this over to my colleague, Brenda Smith, to get us started.

Thanks very much, Ted. I appreciate the opportunity. This is a huge issue for many of us in the trade community. If you've been tracking the forced labor issue, you know that really starting in 2015, 2016, there was a significantly increased profile among government agencies and the U.S. Congress around forced labor. At that time, the international labor organization estimated that nearly 25 million people were in situations of forced labor around the globe. Situations ranging from private sector situations, forced sexual exploitation and in state-managed economies. But what does it look like really? I think many of us have focused on those 2 words forced labor. But what's really important, I think, for those of us trying to manage supply chains is to have an understanding of what forced labor looks like. And the International Labor Organization's framework around forced labor has actually been very helpful to many of us trying to understand exactly what are the conditions of forced labor. So on the right side of the slide, you see a list of indicators, isolation, physical sexual violence, excessive overtime, debt bondage, withholding of wages, abusive working conditions and the retention of identity documents. All are situations which may occur in facilities, manufacturing, agricultural facilities around the world. So we've had a lot of activity since that time. We have a significant legal framework around forced labor here in the United States. And there are many other countries that are working on their legal framework as well. In the United States, our requirement to be aware of and to manage goods made with forced labor really goes back to at least the Tariff Act of 1930. And right now, the statutory provision that we're very interested in is 19 U.S.C. 1307, which in a nutshell, prohibits the importation of merchandise produced with forced labor, wholly or in part. And it's that in part that often takes us many layers down into the supply chain to really get back to original raw materials input -- or inputs. There was a change in the law in 2016 when a small provision was changed around what's known as consumptive demand, which essentially meant that if the United States could not produce a particular good domestically, then the requirement to exclude goods -- those goods made with forced labor did not apply. But they've removed that. And so as we go forward, any goods made with forced labor that looks like, whether it's slave labor, prison or convict labor, forced child labor or indentured labor under penal actions are all covered by the United States exclusion. This is a complementary set of provisions that goes along with a number of other laws and sanctions that we see in things like the U.S.-Mexico-Canada trade agreement, the Trafficking and Victims Protection Act and what we're here to talk to today, the Uyghur human rights -- well, I'm sorry, I'm mixing my legislation, but we are here to talk about the Uyghur Forced Labor Prevention Act. So let me turn it over to Madeleine to talk about what we've seen in the past.

Okay. Thank you so much, Brenda. So yes, so under 19 U.S.C. 1307, there are kind of 2 paths, right, that CBP has used to enforce on forced labor, and there's the withhold release orders and there's forced labor findings. Withhold release orders in general, we've seen quite a bit of activity on I'm sure many of you have within the trade. Those are issued by the CBP commissioner, and those instructions are issued to the court directors. And basically, the instruction is, hey, under this withhold release order admission into commerce of the U.S. is prohibited or we will not allow admission into U.S. commerce. And these withhold release orders, you can find them. They're all posted on CBP's website. If you go to the CBP website, you can do a search and all the withhold release orders are listed there. And if your goods are subject to withhold release order, then that's the issue. You cannot bring them into the U.S., and you have -- but you do have a couple of options. One is you can put -- and we've seen this in the past. Many importers will say, hey, I know. Actually, my product is not manufactured by forced labor. So they will put a packet together of information, and it's got to include a certificate of origin signed by the foreign seller with a lot of detailed statements and other information proving that their goods were not manufactured by forced labor. And this is provided to CBP. You have up to 3 months to do this. Within CBP, we've seen that the centers have been involved, the ports and headquarters and ultimately making a determination. But that is one way you can deal with this. If your goods are -- have been detained or have been held due to a withhold release order. Withhold release orders are normally issued against entities, so specific companies in most cases. And we've also seen that importers who do decide to put a packet together and try to prove to customs that the goods are not manufactured by forced labor, most of the time -- I mean, at least with what we've seen, right, more often than not, the packet is denied. So it's tricky. And it's tricky to know exactly the right level of information to provide customs. You maybe don't want to give them everything in the kitchen sink. You do want to make sure that there's a clear story that you're telling with the right amount of evidence. So you want to make sure it's detailed, but you don't want to give so much that no one can follow the story. But in general, we've seen with those companies that have gone that route more often than not, unfortunately, the request has been denied. Importers also have the option under withhold release order to re-export their goods. So they have that option or they can destroy the goods. And so that's what we're seeing more with the withhold release orders. And again, there have been may issue, especially as of CBP's latest fiscal year. And unfortunately, we haven't seen a lot that -- a lot of success in terms of importers being able to prove that their goods have not been manufactured by forced labor. Kind of the other level, one level above that or becomes a little stricter are the forced labor findings. So the findings, if it's a forced labor finding, then the port directors may actually seize the imports and initiate for future actions. So that's the difference with the withhold release order. With the forced labor finding a port director can actually seize those imports. These findings are also made public. They're on CBP's website. So along with the WROs, you will also find all of their findings -- forced labor findings. And with a finding, you can also put a packet together if you are sure that your goods have not been manufactured by forced labor and try to persuade customs of that. One of the big differences with the findings is that your goods cannot be reexported after they've been detained under a finding. And with the finding, too, customs has quite a bit of proof that there really was forced labor involved at the origin in terms of the manufacture of that good. So one thing that's kind of interesting in regards to the withhold release orders and the findings, and I think we can go to the next slide -- please, thank you, is this data that was recently published on CBP's website. And the last time it -- and again, it was -- you see at the bottom of the slide here, it was updated on the 18th of April, so just a couple of months ago. But it's interesting to look at withhold release orders and findings in this way, to see where the concentration of them can be found There are currently 54 active withhold release orders and 9 findings across the world or across the globe. You'll see too that the withhold release orders are in kind of a yellow gold circle and then the red ones are findings. So of course, there's a lot more withhold release orders than there are findings. And again, those are issued most of the time against entities, companies within those particular countries. So in Mexico, we see there's one withhold release order, but there are 2 findings. And we see some others in Africa, and then we start moving into Asia. And as we see here, the bulk of the withhold release orders are definitely in China as well as the number of findings. One other note I would make is that in general, we've seen under the Director of the Trade Remedy Enforcement Division at headquarters at customs they have invested in additional personnel. And so I -- we believe that probably going forward, we will continue to see withhold release orders and findings coming forth and maybe not just in China, but in other parts of the world. But of course, the bulk are in -- 35 withhold release orders are in China and 5 findings. And so I will now turn it over to my colleague, Ted, to talk more about forced labor, specifically in China.

All right. Thank you, Madeleine. So again, as Madeleine highlighted in the preceding slide, you can see that China has clearly been the main focus of forced labor enforcement under the existing act the 19 U.S.C. 1307 statute that CBP enforces against. The major area within China now is really the Xinjiang Uyghur autonomous region, and that's based on allegations of how China is treating the largely Muslim population that's in that region. There have been several nongovernment organizations, news agencies that have really produced quite a bit of information on alleged forced labor actions that are being managed by the Chinese Communist Party in Xinjang region through a variety of mechanisms. So this has been building over several years, the concern within the U.S. government on -- U.S. government foreign agencies, the Department of State, Treasury commerce and Homeland Security, put together as Xinjiang Supply Chain Advisory several years ago. They updated it again in 2021. we have a link to that in our resources that we'll provide with this discussion. Take a look at that advisory if you have not already done so, but that gives you the background of the general concern from a U.S. perspective about what's going on in the Xinjiang region. The initial WRO is that we did see for the region were for specific entities. One very large entity, the Xinjiang Production Construction Corporation, XPCC. That actually is more of paramilitary-type organization that oversees a lot of activity within the Xinjang region and has actually hundreds of sub entities underneath it. So that one is a bit challenging to work with. But other than that, some of them are pretty specific, as you can see on the upper portion of the slide we've got up right now. There was one that was outside of Xinjang region recent -- in the last year or 2. But by and large, the concentration of concern and enforcement activity has been focused again in the Xinjiang-Uyghur autonomous region. So this is all prior to the legislation that we're really going to focus on after this. It's that, again, the U.S. government had concerns about this area all along and has been taking enforcement actions. They expanded those initial entity WROs to actual geographic region WRO. So basically, there are several out there, ones for cotton and downstream products, another for tomato and downstream products that originate anywhere within the Xinjiang-Uyghur autonomous region. So this is when we started to see an expansion of enforcement focus that was not entity-based, but was much broader and spoke to anything coming from the region as it goes. So if you look at some of the recent CBP statistics that are posted on shipment detentions, they post this on the website. If you look at what they did in FY 2021, they were at almost 1,500 detention, individual shipment detentions; in FY 2022, they're pushing well over 1,200. The vast majority of those detentions are related to the items that we're talking about on the screen, the WROs that are focused on the Xinjang region. Cotton, the Xinjiang Production Construction Incorporation, WRO. So keep this in mind that CBP's enforcement action under the current legislation is heavily focused on the Xinjiang-Uyghur autonomous region. And that leads to a lot of the concern about what's going forward under the Xinjiang -- under the UFLPA that we're going to talk about here in a second. The thing I do want to highlight is that China absolutely denies there is any forced labor activity in Xinjiang or any other region in China. There's always a lot of commentary from the Chinese Communist Party, either through some of their official newspapers like the People's Daily or in actual statements that are put out by government officials that speak to their adamant belief that there is no forced labor. So consequently, because of China's position on this, as for some of you know, it is very difficult to have a real opportunity to conduct effective validation of companies, either by the U.S. government or private sector compliance monitor. So there are already inherent challenges under the existing framework and those are just going to be magnified as we talk about the UFLPA. China has implemented a law that will impose consequences on individuals and organizations directly or indirectly participating in foreign sanctions against Chinese systems, citizens and organizations. So that law certainly could be implemented or actions could be taken based on that law against perhaps Chinese vendors or who are trying to comply with U.S. requests, things along that line. And when the actual entity list is posted under the new UFLPA, I think we're going to see some action there. And the final thing I would highlight is just last week, Chinese foreign ministry spokesperson stated that if the U.S. is really bent on implementing the Uyghur Forced Labor Prevention Act, then China will take forceful measures to defend its own "interest and dignity". So it is obvious that, again, China does not appreciate the activities being taken by the U.S. on this and other countries that are also taking actions related to the Xinjiang-Uyghur autonomous region. And so we're clearly going to -- we're going to see some friction here shortly about this. As we migrate to talking about the Uyghur Forced Labor Prevention Act, please keep in mind that nothing changes with the existing statutory framework about forced labor enforcement. That will continue on. But we're going to see the emphasis on the Xinjiang-Uyghur autonomous region with this new statutory framework for customs and Department Homeland Security, Department of State, Department of Labor. A lot of agencies are now going to be tasked with enforcing this act. So let's talk about the act. The rest of this conversation is going to be about the act. The Uyghur Forced Labor Prevention Act was a bipartisan example, one of the rare bipartisan examples these days within Congress, both the House of Representatives and the Senate of this thing passing pretty much almost unanimously all the way through both houses. It went forward to President Biden and he signed it at the end of last year in December. The act has 120 -- 180 days, sorry, period for government agencies to pull everything together and the act becomes effective, then on the 21st of June, which is just a couple of weeks away. So here are some of the key things about it. And I will say, when you listen to CBP, personnel and DHS and when you listen to us, we're going to refer to this, perhaps by the full name, perhaps by UFLPA. Some people say UFLPA, some people will call it the act. But at the end of the day, we're talking about the Uyghur Forced Labor Prevention Act. So the key thing is this act really imposes a complete and extensive ban on imports of any goods that are mined, produced, manufactured in whole or in part just as under the current legislation, 1307, in whole or in part that are connected to the Xinjiang-Uyghur autonomous region. And that could -- or also be made with forced labor from the Xinjiang-Uyghur autonomous region. So in instances where individuals may have been forcibly transferred from Xinjang to another area in China and are working in a factory that can be linked back -- that activity could be linked back to this act, all right? So it's not just goods that are originating specifically from Xinjiang. This is also reflective to goods that are manufactured from individuals who were forcibly transferred from Xinjiang to work elsewhere. It really expands the U.S. ability to impose sanctions. So we're going to see a -- when the forced labor enforcement task force, which is the government task force that was put together to implement this act, and it actually comes from the USMCA, but their focus right now is implementing this act. DHS heads that task force. when they published their strategy on the 21st of June, they're also going to publish a list of foreign entities. So we can safely assume that sanctions are going to be imposed against those entities. The act does have something called a rebuttable presumption about goods originating connected to the Xinjiang-Uyghur autonomous region. And this idea of rebuttable presumption is the government does indeed presume that anything coming from there or connected to the region is manufactured by forced labor, but the imported does have an opportunity to rebutt that and to try to prove that the goods in the instant specific situation are indeed okay. Basically, the way to do that is importers need to show that they have clear and convincing evidence of a clean supply chain. And through that, you can request an exception to the ban. If that exception is granted, CBP must notify Congress and the -- basically the general public through that notification that an exception was granted, and that's again to a specific shipment. So this is at the shipment level. And then finally, as I said, all government agencies that are tied -- that are connected to this act have to publish their strategy and get all the additional information out by the 21st of June, which is also just when the implementation date will go into effect. And a lot of frustration in the trade about this because there's -- It'd be nice if we had some advanced warning and some understanding of how this act will be implemented. But by the way the statute is written, the delivery date for all of that is unfortunately the same date as the implementation date. So we -- there is a responsibility for the government to -- the forced labor enforcement task force to develop that strategy. They've done and solicited public comment, public hearings to do that. Then ultimately, they'll produce that list of entities that are of concern. They're going to provide other information about how the government will go forward to implement the act. They're going to do some -- they have some other responsibilities about an enforcement plan to address things. They're going to provide a list of high priority sectors, which would go beyond what we've seen for cotton, tomatoes, polysilicon, for example. And then there's also a responsibility within the act for government agencies to issue guidance -- to provide guidance to us about how to -- about due diligence, effective supply chain tracing, supply chain management measures to ensure that none of us are involved in the importation of violative goods. We do know that CBP is working to be ahead of the 21st of June in their own technical guidance. They keep committing they're going to get it out any day. But really, their technical guidance is going to be very narrow. It's not going to be the broader strategy that we're looking to see from the forced labor enforcement task force. Again, you can get an exception if you have goods detained under the act, and we're going to get really into the detail of the detention here momentarily. But if there is a detention, it is possible to gain an exception. The determination right now it -- sits at the hands of the CBP commissioner, but there are 3 elements that an importer has to comply with in order to gain an exception for goods that are deemed to be subject to the UFLPA, to the act. First, you have to fully comply with all the due diligence and evidentiary guidance that's associated with the act. So again, the strategy that will be coming out in 21st of June, any related information from other government agencies, you have to demonstrate you fully comply with all of that. You have to demonstrate that you've completely and substantively responded to all of CBP's inquiries related to a specific shipment or goods however, but the big hurdle is the clear and convincing evidence, the component of this, that the importer has to provide that the goods are not produced wholly or in part with forced labor. And we're going to talk about that more in a minute. The thing -- the other thing that I do we really want to call out here is, like I said earlier, CBP must notify Congress in 30 days of any time they grant an exception for a shipment. And again, not only do they notify Congress, but this is a public report. Realistically, that requirement to notify Congress is likely going to influence them to be very cautious. And here, this is an opinion, if you will. But you have to think about the fact that if you're going to be held accountable for each individual shipment that you do grant an exception on, you're going to think very carefully before you do granted an exception knowing that this is going to go to Congress and be publicly stated. So here's just some general highlights that our general concerns at this point. Certainly, there's no question. There will be shipment detentions, exclusions based on what we already have seen under the WRO activity for goods related to the Xinjiang region. We absolutely expect that sanctions are going to be imposed on folks on the entity list. There's a reasonable expectation, again, that these are not going to just be goods coming directly from the Xinjiang-Uyghur autonomous region. They certainly could be coming from anywhere in China, and they could do -- coming from locations beyond China. What we've already seen for WRO enforcement for goods connected to the Xinjiang region or Xinjiang-Uyghur autonomous region are indeed the detentions are for shipments originating from Thailand, originating from other -- Vietnam, other countries near China. So because there's -- in that case, there was an expectation that Chinese cotton or Xinjiang cotton was specifically in those goods. So don't just think in terms of the Xinjiang-Uyghur autonomous region. We really -- we think it's pretty unlikely that we're going to get clear guidance that we've all been asking for in the trade. It's very likely that under the UFLPA, we're going to be operating in a similar scenario that we do under 19 U.S.C. 1307 forced labor enforcement. This is one of the major requests from the trade is give us more information please, give us more guidance, tell us who the bad guys are, and we're not really sure we're going to see more in this scenario. Certainly, there's quite a bit of pressure that the government feels from nongovernment organizations, NGOs and the media that provide a lot of information about connections between companies in the region. So that's going to continue. And we know that CBP does indeed take in some of that information for consideration that they get from NGOs. So that's going to probably ramp-up a little bit more. And then, like I said before, is likely that China may choose to implement actions or take other measures as well. One more time before we move on to the real specifics of what we know about how this act is going to go forward. I just want to remind you that the act does not change the activity -- the enforcement activity that customs is required to conduct under 19 U.S.C. 1307. The only real change we will see is that the existing WROs that are related to the Xinjiang-Uyghur autonomous region will now be flipped over and be subject to the UFLPA on the 21st of June. So whereas goods might have been that were connected to the Xinjiang region cotton WRO, the enforcement previously has been under 19 U.S.C. 1307 requirements, on the 21st -- the 22nd of June, the enforcement then will -- then flip and be under the UFLPA. And the UFLPA, as we'll see, is much more stringent than the existing requirements and statutory language that's under 19 U.S.C. 1307. So with that, let's really dig into what we know about how the act will be enforced and where things are going. And with that, Brenda, it's all yours.

Great. Thanks very much, Ted. Thanks for setting us up for a good detailed walk through what we know and what we don't know. For those of you that have read the legislation, if you haven't, I highly recommend a good bedtime reading, it's not that long, and it is pretty clear on what the expectations are. It starts out really with a direction to the forced labor enforcement task force, which is chaired by the Department of Homeland Security, and includes many other government agencies that touch on forced labor concerns. They have forced labor expertise or they are in a position to help carry out the executive branches forced labor or human rights policy goals. And so with all of those agencies sitting at the table, their task was to develop a strategy on how to collaborate with both the private sector and with nongovernmental organizations built around human rights. They are also directed to publish guidance to importers, a list of entities that are associated with goods from the Xinjiang-Uyghur autonomous region or individuals that facilitate the use of forced labor. They are expected to identify a list of high-priority sectors and directed to include, at a minimum, cotton, polysilicon and tomato products on that list. They are also asked to have a sector-specific plan for enforcement as well as a plan for supporting CBP with resources and processes. That is quite a bit of information, and I know everybody is anxiously waiting to get the guidance and understand who's on the entity list. What CBP has been pretty specific about though is that the entity list is not -- is not only a set of companies or facilities or individuals that CBP will be taking action on. So while it is definitive, it is not the be all and end all. We have also seen in the run-up to full implementation on June 21. CBP issuing, I would call them warning letters. And they are letters issued to importers that have already been identified as having previously imported merchandise that may be subject to the act. Our understanding is that the scope of those letters really did focus on importers whose goods have previously been detained where the detention was sustained or products were reexported or excluded. The desire on CBP's part is that they expect with this advanced knowledge that importers will address any potential forced labor issues or the gaps in their information that they may previously brought to CBP. The agency has also been pretty clear that just because an importer didn't get a letter does not mean that CBP is giving them the good housekeeping seal of approval. We would expect CBP to take action outside companies or entities that have received these advanced importer letters. The other thing that we ought to be really clear and Ted has already stated it, but CBP has emphasized this a number of times, the goods that were previously subject to a withhold release order will be -- sorry, withhold release order that's related to the Xinjiang autonomous Region. And we just gave you some good information around those, will now be subject to enforcement under the Uyghur Act. If there were enforcement actions taken under 19 U.S.C. 1307 prior to June 21. Those enforcement actions will continue under the previous statutory provisions. But going forward, what this means in practicality is that if you are bringing cotton textiles or cotton apparel or tomato goods into the United States that may have come from the Xinjiang region that were previously covered by a withhold release order. Your ability to operate or to get the release of those goods will now have to meet the standards of the Uyghur Act. So that's something to pay attention to if you previously knew that your goods were at risk of detention. Another thing we'd like to raise is a question that has been debated pretty extensively over the last few months heading towards the implementation of the act and that is so what is the standard for enforcement? And the response is that there is no de minimis provision to this new law. It is essentially an across the board comprehensive wholly or in part goods that may have incorporated on either goods made with Xinjiang labor or with raw materials or manufacturing inputs that come out of the Xinjiang region. That also means that any goods that are connected with the Xinjiang autonomous region forced labor structure and for goods that are subject to release under Section 321 procedures will be subject to enforcement. Again, no de minimis provisions there. And then the last question that has come up fairly frequently is whether CBP will take a phased-in approach. We're all familiar with CBP's often used approach of informed compliance and then enforce compliance. But what they've indicated that in this case, they've really tried to give as much communication and education without the technical guidance as possible. And so that people should be ready with their information, with their supply chain mapping, with their explanation of their due diligence efforts by June 21. So let's go on to the next slide. A little bit more about what we know. We have talked pretty extensively with CBP and with DHS. And for those of you that have -- can't get enough of this information, you've probably also watched CBP's recent webinars. And there's one more. For those of you that have time on your calendar on June 16, I highly recommend registering for that and listening just so that you get the latest on what CBP's approaches as well as you get a good understanding of what they're thinking in terms of implementing this new law. They are hoping to get further technical and operational guidance out to the trade community in advance of the trade strategy, which we -- sorry, the [indiscernible] strategy, which we understand will be published by June 21. So we are keeping our fingers crossed that we at least get a couple of days to absorb and understand that guidance. The guidance itself will be complementary. So if you think of the forced labor enforcement task force strategy as the strategic document and the overarching umbrella of guidance, CBP's guidance will be operational, technical in nature, and it will kind of nestle underneath that larger strategic umbrella. At the end of the day, it's probably what we will look to in terms of that day to day, how is this actually going to work with my shipment that's heading for a U.S. port. Whereas the task force strategy and guidance will probably be what will help you with your risk management assessments. So one of the very specific details that we have gleaned over the last couple of weeks is that CBP views the detention process under the Uyghur Act as the same as what they use under 19 U.S.C. 1499, CBP's existing authority to detain goods and make an admissibility decision. As most of you know, this statute allows CBP to detain goods for 30 days from the exam date. And under the statute, CBP can really go 1 of 2 ways if they are not satisfied by the importers response, they can exclude goods or seize goods under the statute. And our expectation and what CBP has communicated is that primarily they will be excluding goods unless they believe that there is some sort of evasion going on. And the example that they've used is a good came in and it was a country of origin label -- country of origin Malaysia, or Vietnam, yet when they open the container, they found goods were actually from China. Clearly, some evasion going on, some transshipment going on. And in that case, they may take the action of seizing the goods. If CBP does not make that determination in 30 days, then the goods will have -- will be deemed to be excluded and the importer will be expected to take action. Importers do have the option of exporting goods at any point during those 30 days or if CBP ultimately determines that the goods should be excluded or if the goods are deemed excluded. And importer can request an extension to those 30 days for an additional 30 days, CBP can also extend that detention time by 30 days. It's -- 30 days goes by in the blink of an eye. And so our recommendation is that as much information as you have about your supply chain and your ability really to tell in a clear and convincing fashion, what your supply chain looks like, what due diligence practices you have exercised and what validations you have brought into play such as you can, all should be ready to go when and if your goods are detained. Another opportunity that you have to make your case is to petition for an exclusion by filing a protest within 180 days in accordance with 19 U.S.C. 1514. Again, it's a process that you should be very familiar with. If you work in the customs environment, but it does give you another opportunity to tell your story. And finally, another thing that is a good option for taking proactive approach is to request a binding ruling from customs and border protection to basically get CBP's assessment of your specific fact pattern, your specific supply chains and whether they believe that, in fact, you've met the clear and convincing level of evidence. Ted has already referred to a binding ruling that CBP issued related to another rebuttable presumption that is actually found in the Countering America's Adversaries Through Sanctions or CAATSA, which is focused on goods and trade from North Korea. So if you -- we will have a link to that in our resources. But if you do believe you have a good story to tell and you want to lay that out for CBP in advance of your shipments arriving or future shipments, you might want to take the binding ruling approach. I think at this point, I have walked through what we know, and I'm going to turn it over to Madeleine to focus on what we still have questions around.

I regret to inform you, Brenda, that you actually get to continue to chat about this.

Excellent. Thank you very much. So we know more, Ted, that's good news. Thank you very much.

Breaking news, I just inserted this slide into the deck, just -- here's what we got, go for it.

Well, thank you. We are trying to share everything that we've gathered over the last couple of months. So another thing that we did want to raise to you is that clear and convincing evidence really is a higher standard than a preponderance of the evidence, which is the legal standard under the 1307 provisions. As I've just mentioned and clear where I got the idea from, there is a binding ruling available on CBP's website that does walk through their assessment of a fact pattern related to a rebuttable presumption and the evidence that must be provided in order to meet the clear and convincing standard. So if you still have questions about what that looks like, this binding ruling may provide you a good path to really build your story around. A lot of our colleagues in the importing community have asked about the actual hands-on management of shipments that are subject to detention. And what CBP has indicated is that if you have goods that are co-mingled, goods that are subject to detention co-mingled with goods that are not subject to the detention, they will allow that the nondetained goods can be manipulated and released. As we have seen, they have implemented in the current WRO model. We've also indicated that FTZ admissions are subject to the Uyghur Act, but that CBP is still looking to review the applicability of the UFLPA provisions to all types of FTZ declarations. Another area that we want you really to be aware of -- and my opinion is that this is likely to be an evolving scenario. CBP has stated that if the goods are detained under the Uyghur Act provisions, the detention notice that we generally expect to receive with detentions will not contain any specific information about the entities or other information that led CBP to their rebuttable presumption decision. I think this is going to make this somewhat difficult to really target your story and target the information that you provide. It may be worth having a conversation with customs and border protection, to see if you can glean any additional information, and thus target your response back to CBP. But I expect -- and again, this is my opinion. I do expect that CBP will be looking at the best way to communicate and focus this conversation about goods of concern. There is quite a bit of training going on, I'm sure, within your organizations as well as within ours, and within U.S. Customs and Border Protection. Over the last 10 years or so, CBP has done Yeoman's work and ensuring that the personnel at ports of entry as well as at the centers of expertise -- excellence and expertise have been well trained and actively trained and are up to date on the regulatory, statutory and policy provisions around 19 U.S.C. 1307. They are doing a full-on training effort as well around the provisions related to the Uyghur Act. You can expect there to be a little bit of a shakedown period, but our belief is that they have fairly good procedures in place and that they are training their personnel on what to expect. We also wanted to be sure that you are fully aware of the provisions or of the materials that CBP has put out related to forced labor and the implementation of the Uyghur Act and would call to your attention for those of you in the chemicals apparel and textiles and agricultural goods industries that CBP has specifically highlighted these 3 sectors as being of concern in the forced labor realm. So if we can go to the next slide, we'll give you a highly unreadable version of CBP's fact sheet, but would note that we have a link to this fact sheet, which for those of you trying to make your entire organization aware that this is a very good overview of the effort around implementation of the Uyghur Forced Labor Prevention Act and is a good kind of one-page overview of the act. The other good piece of information may be more helpful for your customs experts as well as your legal experts is a very nice concise comparison that CBP recently put out in early June related to the comparison between the Uyghur Forced Labor Prevention Act provisions and the provisions of 19 U.S.C. 1307, which covers withhold release orders and findings. So with that, Ted, I think I'm done and can turn this back over to Madeleine.

Okay. Thank you so much, Brenda. Okay. So as you see everyone, there is a lot that we know or that we have learned recently, but there is still quite a bit of information, that we don't know and that we're hoping we will get more information about either through the guidance document that should be coming out, hopefully, very soon or additional guidance that hopefully will come out very soon from CBP and of course, the strategy that will be issued by the forced labor enforcement task force. So we wanted to go through -- at least review what we still don't know, what are still open questions. And of course, the first one is what is clear and convincing evidence. And of course, Ted talked about this a little bit as well as did Brenda. And this still is not super clear, convincing evidence is not yet very clear, meaning, there hasn't been anything issued yet, specifically in regards to the Uyghur Forced Labor Prevention Act on what would be considered clear and convincing evidence. The only thing we have learned is what CBP, and they talk about this actually in there -- if you're able to join the webinars they are currently hosting that they refer back to, as Brenda talked about, the Countering America's Adversaries Through Sanctions Act, CAATSA because in regard to North Korean nationals, there's also the regulation to produce clear and convincing evidence. So again, there is a binding ruling that Brenda referenced earlier that talks about clear and convincing evidence. So that gives you kind of an idea of what -- when you go through that ruling of what customs may be looking for. But again, we don't have anything super specific just for the Uyghur Forced Labor Prevention Act. But hopefully, more will come in terms of defining that. We also don't know exactly how this chain of review process will be implemented by CBP. If you decide -- let's say you have goods coming into the U.S., it's after June 21 and they're subject to the act, the Uyghur Forced Labor Prevention Act, we don't exactly know how this review process is going to work from CBP. So in other words, we do know what WROs, the centers are involved, that ports are involved, headquarters are involved. We would assume all 3 would be involved again under the act, but we're not exactly sure how that process is going to work. We also don't know too much yet about the process for applying for a binding ruling because you do have that option to apply for a binding ruling related to your goods and the absence of forced labor, but what will that process look like? And of course, how quickly would you get a response to your binding ruling from customs. So how much will it assist importers in order to establish a supply chain of -- free of forced labor. So again, that is still an open question. We do know you can request a binding ruling, but how will that process really work. And then we do know, of course, the government is taking a whole of government approach, but how will the other agencies support companies to manage their supply chains or support them in managing their highly compliant supply chain. So again, don't know how the other agencies are going to support. That's still an open question. And then, of course, will Congress allocate additional funding to the Department of Homeland Security and CBP for greater enforcement actions. Remember, the one thing, and I think Ted touched on this earlier, is one thing we do know is that this particular issue is one of the only issues, the sole issues where the Democrats and the Republicans do agree on. So there is broad support by the government as a whole on this issue. So will that assist or help in getting additional funding. That's a question, but we don't know that yet. Other things that we still don't know yet, what specific situations would customs use additional enforcement actions such as penalties on an individual shipment basis. So we do know that they would -- they may issue penalties, but we don't know what are those specific cases where they will issue a penalty. So that is still a big question. It's possible that they may use it under the next bullet. And again, I think Brenda talked about this. CBP headquarters has issued known importer -- considered known importer letters, to importers who have possibly imported goods that may have been or that goods that may have been subject to forced labor or being manufactured by forced labor possibly. Those letters did go out. So if you received one of those letters and then you import those same goods after June 21, will you be issued a penalty? They do reference that in the letter so that's a possibility. So that may be an area where a penalty is issued. But aside from that, we're not quite sure what will happen. So that's still an open question as well in terms of what additional enforcement might be used with those importers. And then as Brenda talked about as well, if you're importing a container of all different commodities. And there is one of those commodities that is tied to the Xinjiang-Uyghur autonomous region and you receive a detention notice after June 21, will CBP provide some information on which product exactly is linked to the Xinjiang-Uyghur autonomous region? And that -- again, it doesn't appear that they will be providing a lot of specifics, but we don't know whether that will change or will there be some information forthcoming. So that's still a big question right there, and that could cause quite a bit of confusion. So we're awaiting more information from that perspective. And then what industries will be designated as high priority under the Uyghur Forced Labor Prevention Act and how will those industries be impacted by information provided by nongovernmental organizations. So as Brenda talked about earlier, and there was a -- the screenshot showed the Uyghur Forced Labor Prevention Act fact sheet that CBP has issued. They talk about the 3 major types of products, and they talk about chemicals, apparel textiles and agricultural goods. Those are considered high risk. So they've identified those 3 high level -- from a high-level perspective, those product areas. But the other thing that customs does rely on and the government does rely on are nongovernmental organization information. And there's one particular NGO, it's called C like the letter C, as in cat, for ADS. That's an NGO that a recently issued a report called the Xinjiang Goods Entering Global Supply Chain. It's everybody's business. But what's interesting in that report is that there are 9 products listed that are products that are manufactured in the Xinjiang-Uyghur autonomous region. And those 9 products are cotton, tomato products, pepper products, walnuts, rayon, calcium carbide, polysilicon, wind turbines and beryllium. So you can assume if -- when reading this report that, hey, those 9 products would probably be considered high risk and probably subject to the Uyghur Forced Labor Prevention Act, if they're coming from the Xinjiang-Uyghur autonomous region. So it would be a good idea to probably familiarize or look at some of the NGO reports in particular, this one, to see what they have highlighted. Again, because we know the government does utilize information that is published by the NGOs. And then will -- another big question is still will the detained goods -- if your goods are detained under the act, will you be allowed to move them to an FTZ during that 30-day period? And again, that's still a question. There's nothing specific that has come out about that so that we still don't know. And we also don't know yet what are going to be the final requirements for CTPAT participants with respect to forced labor. We do know that CBP is working very actively on this right now in terms of what will be those requirements, but when will those be issued is still a question mark. And we still don't know exactly what those requirements will be. And then, of course, I think Ted talked about this earlier on. But we -- what forceful measures will China take in response to the Uyghur Forced Labor Prevention Act, and they've hinted at or actually stated, as Ted talked about earlier, that when this is implemented, they are going to take forceful measures, but what will those forceful measures be. So that's still a big question mark and one that we'll all be looking at. Again, because China claims, there is no forced labor within their country. And then, of course, when is customs going to publish the technical guidance and that we're hoping will come out very, very soon, but we don't know when, hopefully, any day now. So those are still a lot of the questions that we have that we don't know and that we hope to find out very soon. And so with that, I will pass it on to my colleague, Kim, who will talk about what we're doing, Expeditors, in the midst of all this. So Kim, go ahead, please.

Thank you. Okay. So a little bit about what Expeditors is doing. So we are delivering information and outreach with things like our news flash, our global customs market updates. So if you are not already on the distribution list of one of these outreach, then please reach out to your Expeditors contact and let them know, and they'll make sure that they get you signed up. And then we're also doing webinars, such as this one and the one we did previously in order to spread the word, both internally and externally to make sure that everyone is aware that what's coming at them and can start their planning. Where possible, we're using our systems, our operating systems to set up customs entry edits and also do Denied Party Screening. We're engaging directly with DHS and CBP. We have quarterly meetings with key individuals with both of the agencies, the headquarters on priority issues. We also have specific meetings with DHS and CBP headquarter leadership on forced labor and UFLPA. And then we're also meeting with CBP leadership at the port level so we can understand what the local detention practices for forced labor is and would be in those situations as they come up. We're supporting our customers such as yourselves by monitoring CBP hold statistics and helping navigate the local port detention procedures. Our Professional Services division, Tradewin can help train on forced labor requirements, assist with responses for shipments detained under a WRO or review social compliance documents for forced labor language. Trade flow, which is our web-based software suite, to help with the maintenance of the suppliers and documents used to support your know your supplier process as well as screen parties against published forced labor entity list. Next slide, please. So what can you do as an importer. So you want to make sure that you're educating your suppliers in regards to forced labor. You don't want to assume that they're going to self-educate themselves because most likely that's not going to happen. And then also, you wanted -- you could make forced labor language a part of your contracts and orders. That's something that's been suggested across the board in order to help with this. You could try and reach beyond your first -- to your suppliers. So you want to know your full supply chain, not just that first tier. You want to look at all components from raw materials all the way to the finished goods. You want to understand where do each component come from and who was involved in the production. The last thing you want is any surprises in this process. You want to establish an audit trail from your [indiscernible] inception all the way to production. You want to ensure your record-keeping process supports the sourcing at all levels. And implement a compliance monitoring program, consider using independent third-party verifications such as the human rights experts or auditors. You want to start to gather your evidence now. So that 30 -- I think it's been mentioned a couple of times now, that 30-day detention period is going to go really quick. You're not going to have enough time during those 30 days to gather all the required information. And then just another thing to remember is that all shipments that is on the water now may arrive on or after June 21 and will be subject to UFLPA. So you need to have a plan for how you're going to handle those shipments. Preparation is definitely key with this whole process. And then some resources that may be able to help you, the U.S. government agencies such as Customs and Border Protection, Bureau of Industry and Security, Department of Labor, Department of Homeland Security and Department of State, all of these agencies have forced labor information available on their websites. On Customs website, you can find the preparing for an audit document to help review your supply chain. And as mentioned previously, CBP has committed to issuing known importers letters. So if you receive one of those, make sure you investigate your supply chain. International organizations, such as organization for economic cooperation in development, international labor organization in the United Nations post all sorts of publications, statistics, press releases, articles and videos on their sites. You want to pay close attention to the nongovernmental organizations or the NGOs, looking at their sites and their releases. There are many third-party -- Denied Party Screening software vendors, laboratories, technology-based tracing and other verification service providers available, ask around, do a Google search, to find those parties. And then the one thing that you don't want to do is to continue to import the same goods for the same suppliers and manufacturers when CBP has found your goods to be inadmissible. This is definitely not the time to do nothing. And then the next slide, yes, thanks. To give you a head start, we've included a good variety of resources that you can use to start your due diligence such as the responsible sourcing tool that CBP continues to refer to. The CBP link for the UFLPA questions. And the CAATSA ruling that my colleagues have mentioned a couple of times now that references clear and convincing evidence just to name a few. So that wraps up our content portion. We hope that we continue to give you a better understanding of UFLPA, and we will take any questions.

Thank you, Kim. Ted, go ahead.

No, I was saying. Thank you, Kim, and the floor is yours, Stephanie, to lead us through this. So please do.

I look forward to this. So Kim you briefly touched on this and anyone else, feel free to jump in. But do people -- I mean Kim you were saying you need to go beyond your first-tier suppliers. So if your suppliers are using components or buying from people in this region, will that impact you? Are you ultimately responsible as the importer to make sure that, that does not have components from the Uyghur region?

Yes. Absolutely. You have to look beyond that first tier, anything core component. Anything that's included in your final product as you're recording it is subject to UFLPA. So you would need to look beyond that initial layer.

That's really hard. And I think that's where a lot more of these questions are coming from. So some folks have said, is it sufficient enough to have a certificate issued from my supplier? Is that -- what would customs think about a certificate?

I'll jump in real quick. I mean certainly, a certificate has some value. But to expect that a certificate in and of itself will be sufficient even for -- under the evidentiary standard of the WROs, the existing legislation that won't work, and there is no question it will not work in and of itself under the UFLPA. There really is -- Customs will take the position that anyone can create a certificate, and it may or may not be valid. So that's why they're going to want to see a whole lot of backup information where you really have drilled down and having to -- have a nice example of whatever the -- depending on how complex your product is, the levels all the way through of transactional records of where components came from, how they were acquired by each tier in your supply chain, they're going to want much more bottom line than a certificate of origin. That just won't be sufficient. It's not sufficient quite frankly, under the current 19 U.S.C. 1307 enforcement, and it's no question won't meet the evidentiary standard of clear and convince any evidence. So...

And one thing just to add on I've heard Customs say over and over again, is I think sometimes we're like, we'll kill them with info, right? We send off reams of paper, and I think Brenda and Madeleine and Ted all of our presenters kept using the story -- or using the word like tell your story. But it has to be told in a very concise, efficient way. And I know a lot of our products are very complex, which is what Ted was saying. But just to dump time copies of time cards on Customs is not going to do the trick because it makes sense. Let's use logic here, right? They just have to sort through it. It's not helpful. So if importers go down that road of trying to convince them, it needs to be very clear and to the point. Understanding it's a very complex situation. Let's see, another question that came in, is there an example of a questionnaire that they could use to send to importers or that importers could send to their vendors?

So if you look at some of the resources that we provided to you, Customs does provide some guidance as to the information that they're looking for in these instances. So you can look at the informed compliant clients publications that we've got in the link and they're prepping for an audit, things along that line. That will guide you to the types of questions that you want to ask as a questionnaire. And a questionnaire, again, is a starting point. That's a chance for you to a, educate and inform your suppliers and your sourcing personnel as things go, but -- and maybe -- and that's going to be a starting point for you to really understand the exact, perhaps, challenges and the risks that are within your supply chain and may cause you to dig a little bit deeper based on the responses to that questionnaire. But again, take a look please at some of the information we've provided as resources. Customs, to their credit, has tried to put out a fair amount of information in general under their obligations to inform the trade, so not just specific to forced labor.

Thank you, Ted. Okay. I'm going to read this question as it is because I think it's a little loaded and so just bear with me. Hopefully, I don't butcher it. Are the same standards for clear and convincing and rebuttable presumption applied for binding rulings as would be applied in detention responses? So essentially, are the same people/departments at Customs reviewing both?

So basically -- I mean -- oh go for it, Brenda, please.

Okay. So I would say the short answer is yes. They will be the same standards. The question about are they the same people is a good one. Typically, as many of you know, binding rulings are developed by the rules and regulations, attorneys at Customs and Border Protection. So clearly, they're more likely to take a legal approach. My assumption is that detention responses, especially in the early days until the CBP sort of gets the rhythm going will be worked very closely with CBP's legal team to make sure that, in fact, everyone is very clear on what the standard is and what the standard actually looks like in practice. And so I think on whether it's binding ruling or a detention response evaluation, you're going to have legal lines involved.

Thank you, Brenda. Let's see here. If goods are imported and they're identified and are not going to be allowed into the country, do we know what's going to happen with the goods? Do they have to be reexported back to the supplier? Do they have to be destroyed? Can it be sent elsewhere? What is an importers options?

So we'll start. Basically, if Customs has excluded your goods or have detained the goods and you choose not to pursue an exception or to try to establish the absence of forced labor, you are welcome to reexport -- to export the goods from the United States. You're not obligated to do anything further than that. And there really isn't any specific direction as to how those goods need to be exported. Typically, you would return that to the country of origin, the source, the original supplier. I would add as a caveat to this as some people have talked about, well, how about if I export them to Canada or Mexico? I would say, be cognizant that under the U.S.- Mexico-Canada free trade agreement, there is a specific obligation for both of those countries to take a similar approach as the United States on forced labor enforcement, and Canada has already started doing that. So I would not advise necessarily sending something up to Canada because you may likely face a similar situation there. So my guidance would be to send it back. You certainly can destroy the goods. There are other opportunities like that, you would have to prove because there's a process that you would go through with CBP to go through a destruction. So that is an option as well.

Thank you, Ted. I think this gentlemen, summed it up very well. It seems like it takes very little evidence for the shipment to get held, but an active god to get it released. So I do think that's a fair assessment, unfortunately. What -- is anybody -- does the act have anybody overseeing customs or are they just the end-all authority? Is there any independent monitoring that is built into their decision-making process, I guess?

Take it away, Brenda.

Okay. So a couple of things. First of all, the law itself was crafted after a pretty significant number of rounds of discussion on Capitol Hill in both the House of Representatives and the Senate. And if you watch the debate, as I did fairly closely, you saw, I believe, in the house, that the passage was something like [indiscernible] with similar numbers in the Senate. And so there was very broad agreement, not only that action needed to be taken, but that the standard for exclusions of goods made in this area needed to be very high. And the expectation was that CBP would be very aggressive in enforcing. I've already seen a letter from the 4 original sponsors of the legislation to the President, essentially demanding active enforcement starting June 21. And so I think that's where you start is that the expectation is that the standard is high, and there will be very, very few exclusions. They were looking to send a message, and CBP and the forced labor enforcement task force is charged with carrying out those instructions. In terms of oversight, I think one of the reasons that the Congress wanted there to be an inter-agency collaboration around these provisions is for 2 reasons: one, so that they would work together and would bring the full resources and authority to U.S. government to bear on this issue and that there would be collaboration and conversation around the effectiveness and the level of enforcement. And I'll just -- I'll leave that there. But I would tell you another option that we haven't really discussed here that importers almost, always have recourse too is going to the court of international trade. If you have a legal disagreement about CBP's actions or any other trade-related actions by the government, that is always sort of a final option.

Thank you, Brenda. Very thorough answer. Appreciate that. Somebody is asking, and I think this is a great question. Is there any accommodations for small- to medium-sized business? Obviously, supply chain mapping even for large businesses going beyond that first year is extremely difficult, very expensive or can it be. Is there anything outlined or understanding at customs or the U.S. government level for those folks?

I'll start with a couple of points here. As we've talked about throughout the discussion, the act covers anything and everything remotely related to the Xinjiang autonomous region and puts, again, personnel who were forcefully transferred from the region, et cetera. There's nothing in the act that requires the government to support small, medium-sized enterprises versus large enterprises or anything else like that. The act is blanket in terms of banning these goods. We may see something in the -- the act also does require the development of a strategy, some guidance to importers for due diligence, things along that line. I would be surprised if we see something specific to SMEs. Certainly, CBP does recognize their responsibility to small, medium-sized enterprises for other -- under other statutes and reasons. So I don't think CBP would -- they're certainly not going to ignore this, but the expectation is, if you're an importer, you have the same responsibility, whether you're a big multinational or you are Ted Henderson that you have the same responsibility to exercise reasonable care and to demonstrate effectively that you do have a clean supply chain. I don't know anything from your side, Brenda, would like to add to that?

No, I think that's fair. I think they're sympathetic. I know that CBP often has a little bit of difficulty hearing from small businesses that, frankly, don't have a lot of time to talk actively to the government. If you're interested in providing a small business perspective to CBP, we are happy to connect you with the Office of Trade relations at CBP and they will take your input with open arms.

Thank you. So this is a little bit of a broader question, pull our heads up just a bit. Clearly, this is focused on one region in China. But I guess, in your opinions or what you guys are seeing, do we think that this is going to potentially expand to other countries, where forced labor is generally, I don't want to say it seem to be used, but is more likely to be used?

So we chatted about this a little bit earlier. The existing requirement for CBP to prohibit the importance of forced labor. That remains regardless of the Uyghur forced labor prevention act. So the 19 U.S.C. 1307 language still is in place. We do anticipate that there will be continued issuance of new WROs, new withhold release orders and perhaps new findings for China and back outside of the Xinjiang-Uyghur autonomous region and certainly anywhere else in the world. That element that exists in Customs will continue to in the trade [indiscernible] law enforcement directorate. Those folks will continue to enforce under 19 U.S.C. 1307. -- the Uyghur Forced Labor Prevention Act, that will stand on its own, the enforcement of that. But again, do keep in mind, we go back to what we saw on the enforcement of WRO that are related to the Xinjiang-Uyghur autonomous region. Customs did not just detain goods that were directly connected to the region. They detained goods that were exported and clearly, it appeared to be manufactured elsewhere in China and also from other countries. So again, we saw goods just within our customer base that were detained from Vietnam, Thailand, Indonesia, some other things and the detention was linked back to a WRO from the Xinjiang-Uyghur autonomous region. So CBP, along with the forced labor enforcement task force, they clearly will be looking at any and all connections to the Xinjiang region when it comes to the UFLPA enforcement. But the general idea is we still will expect to see CBP to enforce the general statute that says no goods connected to forced labor can be imported in the United States.

Thank you, Ted. I think we have time for 1 or 2 more. This participant is asking, if you received a known importer letter from CBP and you've analyzed your supply chain and you can't find any link, of course, to this region. Do we anticipate CBP is going to be holding greater -- do we have any other intel on how they -- what they used as their criteria to send these letters? And I guess one other thing too, I mean, do we know importers that have received these?

So yes and yes. So yes, we have importers in our customer base who have received these letters. And if you haven't seen these letters, they are -- the generic version is posted on CBP's website. So if you have not received one, you can take a look and see how they're phrased. But it's a very good question because I will tell you as a customs compliance nerd that I am, when we did see customers receiving WROs and WRO detentions, we did try to pick those apart, and that was one of my things I entertained myself between midnight 3 a.m. and my free time was trying to find a connection somehow to the named parties in a shipment and doing Internet searches and looking at other sources of information to try to say, why? What was the connection? How did this get back to the Xinjiang-Uyghur autonomous region for cotton, for example. So customs clearly has a variety of information sources that they use. They have people that are connected through Department of Homeland Security agencies that are as well as CBP personnel who are scattered around the globe doing investigatory work. They're relying on other sources of information. And this is -- this kind of gets back to the request from the trade. Can you tell us, please, customs what led you to stop my freight? What's your concern? Who was the bad guy in this relationship, so I can stop doing business with them? But unfortunately, again, they're using the information in their targeting system, they, CBP, to develop these letters in the first place. And some -- of course, some letters would go to people who did have freight detained under WRO, but some of them have gone to people who have not had freight detained, and we'd all like to know why. And it goes back to -- and if we have freight detained under UFLPA in the future, please tell us why? Who's the bad guy? So unfortunately, the long answer is, no, we don't -- you won't easily be able to get to the source as the -- who's the bad entity that you shouldn't be working with somewhere in that supply chain that's caused CBP to act. So it is -- the targeting is done based on customs investigative work and the information that they hold private because either there's an active investigation in process or the information is protected under other mechanisms, and they're not allowed to release it. The best I think we can hope for is to see the entity list that comes out in the strategy that's released on the 21st.

Thank you, Ted. And I went ahead and put a link everybody. Hopefully, I said it to everyone, yes, I did, to the known importer letters that CBP had posted on their website that Ted referenced. As a complete bonus, there's also a link for their June 16 webinar. So I think -- as Brenda said or Ted said, if you can't get enough of this topic, there are more webinars out there to give more perspectives on it. So I think we are out of time. Any other final -- Nicole, I don't know, do you want to just go through real quick how -- our number 1 question is, can I get a copy of the [indiscernible]. So help us out with that.

Of course. And I just want to thank everyone again for joining today, and I want to thank our presenters for the great information. We look forward to future webinars, which we will be sending out along with a recap of the webinar today with a quick feedback survey upon completion of that survey, you will be directed to a new landing page where you can download the presentation that you saw today in a PDF format. So that will be going out within the hour. Please stay tuned for that. And if we didn't get to your questions, we will certainly follow up with you after the webinar. So thanks again, everyone.

Thank you all.

Thank you.