Ana Hinojosa, Executive Director, U.S. Customs & Border Protection

Updated: Mar 2

In 2020 the United States Customs and Borders Protection (CBP) issued a withhold release order against Malaysian Palm Oil company Sime Darby following reports which reasonably indicates the presence of all 11 of the International Labour Organization’s forced labor indicators in Sime Darby Plantation’s production process.


CBP will now detain all palm oil and products containing palm oil produced by Sime Darby Plantation Berhad and its subsidiaries, joint ventures, and affiliated entities in Malaysia, at all U.S. ports of entry.


Ana Hinojosa, Executive Director for Trade Remedy Law Enforcement takes us through the history of this case, provides an overview of ILO indicators, while providing advice to companies, whistleblowers and governments seeking to take a tougher stance of human rights abuses in supply chains.


The indicators are:

  1. Abuse of vulnerability

  2. Deception

  3. Restriction of movement

  4. Isolation

  5. Physical and sexual violence

  6. Intimidation and threats

  7. Retention of identity documents

  8. Withholding of wages

  9. Debt bondage

  10. Abusive working and living conditions

  11. Excessive overtime


In September 2020, CBP issued a separate Withhold Release Order against another Malaysian palm oil producer, FGV Holdings Berhad. That Withhold Release Order was one of 13 that CBP issued during Fiscal Year 2020. All Withhold Release Orders are publicly available and listed by country on CBP’s Forced Labor Withhold Release Orders and Findings page.


CBP receives allegations of forced labor from a variety of sources, including from the general public. Any person or organization that has reason to believe merchandise produced with the use of forced labor is being, or likely to be, imported into the U.S. can report detailed allegations by contacting CBP through the e-Allegations Online Trade Violation Reporting System or by calling 1-800-BE-ALERT.



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