When goods arrive from India, the importer of record carries the burden of proof. To obtain an exception from the presumption under the Uyghur Forced Labor Prevention Act (UFLPA), an importer has to show by clear and convincing evidence that the goods were not made with forced labor, backed by a documented trace of the supply chain. Other questions, such as country of origin, mean showing where and how the goods were made. A supplier’s certificate rarely meets that standard.
I investigate in person in India: the supplier’s site, its records and the people around it. An inspector checks a factory against a standard and relies on the paperwork. An investigation, by contrast, assumes the paperwork may be staged, and tests it.
An inspection report is an ordinary business record, and a damaging one can later be used to show that the importer knew. Because I am a US-admitted lawyer, you can engage me directly as counsel, and the work can be set up to support privilege.
The result is evidence prepared for whoever will judge it: US Customs and Border Protection on a submission, your own team on whether to keep or drop a vendor, or a court.
An engagement can cover:
Every engagement is set out in a written engagement letter, scoped to the question you need answered, and it can run under your existing outside counsel if you prefer. If a shipment or supplier in India is in question, do reach out and I will take a look.