London Partner Lucy Blake Discusses UK Forced Labor Due Diligence Proposal in Law360, POLITICO Pro, and Forward Law Review
Publications
November 13, 2026
London-based Partner Lucy Blake spoke with Law360 UK, POLITICO Pro, and Forward Law Review about the UK government’s announcement that it will introduce mandatory human rights due diligence for large businesses, including a new power to remove goods made with forced labor from the market. The regime would apply to UK businesses with global turnover of more than £350 million and to non-UK businesses with more than £350 million in UK turnover.
Lucy emphasized that the compliance exposure extends beyond regulatory enforcement: “A due diligence statement is itself a record and can expose a company to litigation and media scrutiny.”
Lucy noted that the proposal identifies no financial penalties, with the power to remove goods from the market as the sole enforcement mechanism, which she described as “a backstop, not a gate.” She also observed that the UK threshold of £350 million is well below the revised threshold under the European Union’s Corporate Sustainability Due Diligence Directive (CSDDD), meaning some businesses outside the EU regime may still be captured. For companies operating in both the United Kingdom and United States, she advised that due diligence statements must satisfy UK regulators, withstand scrutiny in UK courts, and avoid controversy in the current US political environment.
Lucy is a partner in the firm’s Investigations, Compliance and Defense Practice and Co-Chair of the firm’s Human Rights and Global Strategy Practice. She advises on ESG risks arising from human rights and climate impacts in companies’ supply chains and on multijurisdictional issues involving conflicts of laws.
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© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.
Publications
November 13, 2026
London-based Partner Lucy Blake spoke with Law360 UK, POLITICO Pro, and Forward Law Review about the UK government’s announcement that it will introduce mandatory human rights due diligence for large businesses, including a new power to remove goods made with forced labor from the market. The regime would apply to UK businesses with global turnover of more than £350 million and to non-UK businesses with more than £350 million in UK turnover.
Lucy emphasized that the compliance exposure extends beyond regulatory enforcement: “A due diligence statement is itself a record and can expose a company to litigation and media scrutiny.”
Lucy noted that the proposal identifies no financial penalties, with the power to remove goods from the market as the sole enforcement mechanism, which she described as “a backstop, not a gate.” She also observed that the UK threshold of £350 million is well below the revised threshold under the European Union’s Corporate Sustainability Due Diligence Directive (CSDDD), meaning some businesses outside the EU regime may still be captured. For companies operating in both the United Kingdom and United States, she advised that due diligence statements must satisfy UK regulators, withstand scrutiny in UK courts, and avoid controversy in the current US political environment.
Lucy is a partner in the firm’s Investigations, Compliance and Defense Practice and Co-Chair of the firm’s Human Rights and Global Strategy Practice. She advises on ESG risks arising from human rights and climate impacts in companies’ supply chains and on multijurisdictional issues involving conflicts of laws.
Related Lawyers
Related Capabilities
Related Locations
© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.
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