Tag Archives: certifications

Sample Human Trafficking Compliance Plan Finally Released

This week, the Department of State (“State”), Verité, and other global NGOs, unveiled a sample human trafficking compliance plan and online resource to help contractors comply with the FAR’s anti-human trafficking rule (the “Rule”).  As we have previously summarized, the Rule requires contractors to implement a compliance plan for contracts exceeding $500,000 that are for … Continue Reading

Human Trafficking Model Compliance Plan and Internet-Based Compliance Tools Set for Release this Month

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 … Continue Reading

Efforts to Define Recruitment Fees Move Forward as Newly-Revised Human Trafficking Rule Goes into Effect

Late last week the House Foreign Affairs Committee approved H.R. 400, which would require the Department of State and the United States Agency for International Development (USAID) to propose a definition of recruitment fees within 180 days of the statute’s enactment.  H.R. 400 explains that “contractors sometimes employ foreign workers who are citizens neither of … Continue Reading

New Human Trafficking Rule Imposes Compliance Obligations on All Government Contractors and Subcontractors Starting March 2015

On January 29, 2015, the Federal Acquisition Regulation (“FAR”) Council published the long-awaited  final rule (“the Final Rule”) implementing Executive Order 13627 and title XVII of the National Defense Authorization Act of 2013, significantly augmenting existing human trafficking-related prohibitions for Federal contractors and subcontractors.  The Final Rule is similar to the previously summarized proposed rule.… Continue Reading
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