The Department of State (“State”) recently announced the upcoming release of the model anti-human trafficking compliance plan. State and Verité, a global NGO, developed this highly-anticipated model compliance plan in response to the amendments to FAR 52.222-50, which require contractors to perform supply chain due diligence and implement a compliance plan for contracts exceeding $500,000 that are for the acquisition of services or non-COTS goods outside the United States.  Because the rule contains relatively little guidance regarding these requirements, the model could provide the contracting community much needed direction regarding supply chain due diligence and compliance plan obligations.

In addition to releasing the model compliance plan, State will also unveil a new resource to assist contractors in complying with the FAR’s anti-human trafficking rule. According to State and Verité, this internet-based resource (to be available at incorporates input from “key stakeholders in the private sector, civil society, government, and contractor communities” gathered over the past year and a half.  The resource is said to contain “information, analysis, and practical guidance necessary to effectively address human trafficking,” as well as downloadable risk-management tools.

State and Verité will host the following sessions to debut the model compliance plan and

  • May 16, 2016; 9:30 a.m. to 11:30 a.m.; Dupont Circle Hotel
  • May 17, 2016; 9:00 a.m. to 11:30 a.m.; Sheraton Tysons Hotel
  • May 17, 2016; 1:30 p.m. to 4:00 p.m.; Sheraton Tysons Hotel

Those interested in attending may RSVP to by May 10, 2016. Following their release, we will provide an update on the model compliance plan and the resource.