On November 4, 2026, the UK Government published a statement announcing the outcome of its responsible business conduct review (“RBC Review”), which it launched in its Trade Strategy 2025 (for background, please refer to our previous blog post here).
The Government found in the RBC Review that the UK’s
Continue Reading UK Government Commits to Mandatory Human Rights Due Diligence Law: Outcome of the Responsible Business Conduct ReviewThis alert summarizes recent developments in relation to the UK sanctions.
First, the UK introduced a substantial expansion of its Iran sanctions regime, including new trade, financial and transport restrictions. These measures are scheduled to enter into force on 29 September 2026.
Second, the UK announced a new package of
Continue Reading UK Adopts New Iran Sanctions and Announces Measures Relating to Israeli SettlementsOn 23 April 2026, the Council of the European Union adopted a new package of economic sanctions against Russia, marking the twentieth sanctions package introduced since the start of Russia’s full scale invasion of Ukraine.
Click here to read the full alert on cov.com.
Continue Reading EU Adopts Additional Sanctions Against Russia and Belarus & UK Adopts Sanctions End-Use ControlsWhen the UK Modern Slavery Act (“MSA”) came into force in 2015, it was hailed as a landmark for supply chain transparency on a key human rights risk. Today, there is widespread recognition among stakeholders that the UK may have fallen behind in its approach to corporate human
Continue Reading UK Business and Human Rights Landscape: 2026 Outlook
Now that the Trump Administration has cleared the six-month mark, its approach to white collar enforcement is starting to come into focus through multiple policy announcements and an emerging track record. After a flurry of policy announcements from Attorney General Pam Bondi in the early weeks of the new administration
Continue Reading DOJ White Collar Enforcement Six Months into the Trump AdministrationThose in the business of fast‑moving consumer goods (“FMCGs”) are likely aware of the plethora of environmental and product stewardship regulations applicable to the FMCG sector. These laws are set to increase and expand in application. What FMCG companies also need to get to grips with are a range of broader (and also fast‑moving!) environmental, social and governance (“ESG”) developments and consequent risks and opportunities. Companies need to understand how the new world of ESG impacts their supply chains, key ingredients and components, consumer choice and confidence, competitive advantage, market accessibility, and marketing.
Designed as a ‘primer’ for FMCG companies, in this piece, we cover a range of key trends in the emerging UK and EU ESG legal landscape as relevant for the FMCG sector, from farmers to Food Business Operators (“FBOs”) and from manufacturers to retailers. We also discuss some key legal and reputational risks; as well as pointers to help companies decipher and prepare for the ESG storm.
We focus on the UK and the EU (first movers on many ESG issues), but the landscape in other jurisdictions (including, for example, the US) is also evolving and becoming more complex.
Key ESG Issues for FMCGs
We think there are four categories of key ESG developments for FMCGs to watch: (I) corporate reporting and disclosure regimes; (II) green/sustainability claims and labelling; (III) supply chain obligations; and (IV) product packaging and presentation.
Many emerging ESG frameworks cut across sectors. This may be efficient for regulators, but can make identifying sector-specific risks and opportunities more challenging. We have sought to do that below.
Continue Reading Green Groceries: Key ESG Issues for the FMCG Industry (including FBOs)The focus of this year’s UN Forum on Business and Human Rights was “putting rights holders at the centre” of business’ human rights due diligence efforts. In this post, ahead of Human Rights Day, we distill the important takeaways for business, drawing on Forum discussions among a range of stakeholders, including corporate representatives, governments, NGOs and rights-holders themselves.
1. The business and human rights legal landscape continues to evolve at a rapid pace and this trajectory will continue.
Many governments worldwide are considering and implementing new human rights due diligence legislative initiatives. Aside from laws already passed and the EU sustainability due diligence initiative (see our earlier alert), there are similar proposals on the table in Spain, Belgium, Netherlands, Brazil, and other countries. Japan recently published non-binding guidance for business, intended to drive good practice. Other countries are developing “National Action Plans” (“NAPs) under the UN Guiding Principles on Business and Human Rights (“UNGPs”), which can be a pre-curser to binding regulations. While legislative initiatives to date have largely been found in the Global North, we are also seeing movement in other regions: The African Union recently convened the first African Forum on Business and Human Rights.
While at varying stages of development and implementation, the fundamental tenets of these due diligence laws generally are similar. Companies are required to implement due diligence programs to identify and mitigate adverse human rights (and often environmental) impacts in their own operations and global supply or value chains.
Continue Reading The 11th UN Forum on Business and Human Rights: Key Takeaways for BusinessThere have been several recent developments in international efforts to combat trade in goods made with forced labor, with important implications for responsible sourcing and global trade compliance programs.
On September 14, 2022, the European Commission (“Commission”) published a proposal to ban products made with forced labor from the EU market. The proposal notably goes beyond banning the importation of such products and would also create a ban on the export of products produced with forced labor and require their withdrawal from the EU market.
Meanwhile, enforcement by U.S. Customs and Border Protection (“CBP”) of the U.S. forced labor import prohibition has continued to intensify, including under the Uyghur Forced Labor Prevention Act (“UFLPA”). In early August 2022, CBP clarified the process for updating the UFLPA Entity List. In addition, CBP recently announced that it intends to integrate forced labor compliance requirements into the Customs Trade Partnership Against Terrorism (“CTPAT”) “trusted trader” program.
We discuss these developments and their implications below.
The European Commission has proposed a Regulation prohibiting products made with forced labor from being imported to, exported from, or sold in the EU, following an announcement by Commission President Ursula von der Leyen during her State of the Union address in September 2021.
The Commission’s proposal is the first step in the EU’s formal legislative process. The Regulation will now have to be agreed by the European Parliament and Council to become law, following which there will be an agreed delay—the Commission has proposed two years—before it applies in EU Member States. As it usually takes at least 12 months, and often closer to 18 months, for the European Parliament and Council to agree on a legislative text after a proposal by the Commission is published, it is unlikely that the Regulation will be adopted before the end of 2023, and it is therefore unlikely to become applicable earlier than late 2025.
Continue Reading Breaking Developments in Forced Labor Trade Enforcement—the EU’s Proposed Forced Labor Product Ban and Recent Developments in U.S. Customs EnforcementIn this series of posts, our Africa Anti-Corruption Practice will be focusing on the key takeaways from the DOJ Guidance through the