Enforcement at Both Ends of the Chain: Forced Labor Compliance for Suppliers and the Clients Who Buy from Them

Forced labor enforcement has changed its object. For most of the twentieth century it aimed almost exclusively at the direct exploiter — the farm, the factory, the labor recruiter — through criminal law and labor inspection. In the last decade, the major importing jurisdictions have added a second front: the client. Import prohibitions enforced against the buyer of the goods, rebuttable presumptions that reverse the burden of proof at the border, and conduct-adjustment settlements imposed on companies that never employed the victims have made the purchaser of supplier output an enforcement target in its own right. This article reviews enforcement at both extremes of the supply relationship. At the supplier end, it examines the mechanics of coercion (recruitment debt, document retention, tied housing) and the enforcement instruments aimed at them, taking Brazil's inspection and public-listing regime as the most developed example. At the client end, it analyzes the U.S. regime built on Section 307 of the Tariff Act and the Uyghur Forced Labor Prevention Act — more than 16,700 shipments detained and US$3.69 billion in goods reviewed between June 2022 and July 2025 — and the European Union's product ban under Regulation (EU) 2024/3015, applicable from 14 December 2027. The 2023 Bento Gonçalves case, in which 207 workers were rescued from a labor contractor serving three Brazilian wineries that then paid R$7 million under a conduct-adjustment agreement, is used to show how the two extremes meet: enforcement reached the clients through their supplier. The article concludes with a compliance architecture calibrated to each end — prevention controls where coercion occurs, and evidence controls where liability lands.