Human Trafficking Regulation Compliance Services

On March 2nd, 2015 a final rule was enacted regarding US Federal contractors trafficking in persons. The General Services Administration (GSA), Department of Defense (DoD) and the National Aeronautics and Space Administration (NASA) published new reporting requirements amending the Federal Acquisition Regulation (FAR) in order to strengthen protections against human trafficking. Prior to the amendments outlined by the GSA, DoD and NASA, there were limited securities in place to protect victims of human trafficking violations in the United States. With the implementation of Executive Order 13627 “Strengthening Protections Against Trafficking in Persons in Federal Contracts”, the new FAR stipulations could affect approximately 300,000 US Federal contractors, both domestically and internationally.

The Assent Compliance Manager Software Suite includes a new FAR Human Trafficking module which has been developed with your business in mind. Our turnkey module can be customized to fit your individual business requirements while significantly reducing compliance risk.

• Manage FAR Human Trafficking Compliance For All Subcontractors
• Track FAR Human Trafficking Violations Throughout Your Contractor Network
• Act as a Centralized FAR Human Trafficking Management Solution
• Identify Contract Compliance Trends in Your Contractor Network
• Enable You to Extract Multifaceted Reports on All Salient Information

On a macro level, the new regulation can be broken down into two main components. The first set of rules apply to all government contractors regardless of dollar value and type. These build on the existing FAR law and include new guidelines which prohibit contractors from charging recruitment fees, employing fraudulent recruitment practices and destroying identification document – to name a few.

The second set of rules apply to any portion of government contracts that are not for Commercially Off-The-Shelf (COTS) items, conducted outside the US and valued over $500,000. If these criteria are met, then all contractors must provide a certification that validates they have implemented an appropriate

compliance plan. In addition, contractors must certify through their due diligence process that to the best of their knowledge, they nor any of their subcontractors have not engaged in human trafficking violations and that remedial actions will be taken if prohibited activities occurred.

Trafficking in persons is a serious offence and the penalties for non-compliance are substantial and steadfast. Remedies for any untoward activities can range from suspension of contract payments to criminal liability. As such, it is critical for contractors to be vigilant in selecting their subcontractors and maintain a high standard of compliance.