This Case Note summarizes the primary holdings surrounding Ninestar Corp, focusing on the resulting predicament for the FLETF. By revealing more information to regulated firms about its Entity List determination procedures, the FLETF could force firms to seek administrative remedy before they could access the courts, thereby retaining greater control over UFLPA enforcement; yet, in doing so, it may enable firms to circumvent Entity List designation. This Case Note ultimately concludes that forced labor enforcement regime is best served by greater transparency in the Entity List designation process.
June
2025