In 2020, the International Labour Organization (“ILO”) estimated that forced labor generated $51 billion USD. Many profiteers are not individual bad actors, but rather, corporations. Recently it came to light that one corporate profiteer is the multinational technology manufacturing company, creator of the most awarded hair care device in 2021: Dyson Limited. While Dyson has received praise for its products, Malaysia charged Dyson’s main production factory, ATA IMS, with labor law violations. Shortly thereafter, in February 2022, UK law firm Leigh Day publicly announced its suit against Dyson on behalf of the workers in Dyson’s Malaysia factory.

This Comment analyzes the United Kingdom’s and Malaysia’s international obligations and their respective adherence to those obligations. Ultimately, this Comment finds Malaysia in compliance with its obligations and finds that the United Kingdom is in violation of the Protocol of 2014 to the Forced Labour Convention, 1930 for its failure to sanction Dyson. This Comment recommends the United Kingdom sanction Dyson and work with Malaysia to investigate whether corruption facilitated forced labor. Finally, this comment recommends that anti-slavery practitioners employ follow the money techniques to better discover and sanction corporate perpetrators of slavery.