What’s the CAPTA List?
The Correspondent Account or Payable-Through Account Sanctions List (“CAPTA” List”) is a list maintained by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”). The CAPTA List identifies foreign financial institutions that are prohibited or in some way restricted from maintaining a correspondent account or a payable-through account in the United States.
Effective February 4, 2019, Customs and Border Protection (CBP) has ordered the detention at all U.S. ports of entry of tuna and any such merchandise manufactured wholly or in part by the Tunago No. 61, which is a fishing vessel owned by Tunago Fishery Co., LTD a company located in Vanuatu. According to the CBP press release of February 6, 2019, importers of detained shipments are provided an opportunity to export their goods or demonstrate that they were not produced with forced labor. The Tariff Act of 1930 (19 U.S.C. § 1307) bans imports of merchandise or food produced in whole or at least in part by forced labor, including convict labor, forced child labor, and indentured labor.