Mandating Change
The fastest growing and second largest criminal industry in the world today, human trafficking is a $32 billion industry and growing. Federal government agencies across the country are taking aggressive new efforts to address the problem.
As of March 2, 2015, all companies with a government contract are mandated to immediately comply with newly enacted human trafficking regulations. The new requirements come from the just-released Federal Acquisition Regulation provisions and stem from the 2012 Executive Order 13627 “Strengthening Protections Against Trafficking in Persons in Federal Contracts.” Companies with government contracts that exceed $500,000 are additionally required to have a tailored compliance program and provide certification.
Many other companies, even if not federally mandated, take a proactive approach against human trafficking to demonstrate corporate responsibility in addressing this quickly growing problem.
Husch Blackwell is the only firm in the nation to offer tailored anti-human trafficking government compliance programs.
Our services include:
- Develop and draft tailored corporate policy manuals
- Provide required certifications for the prime contractor, subcontractors and agents
- Conduct training of employees, subcontractors and agents to assist with implementation of compliance plans and policies
- Conduct audits to help companies comply with the new government regulations
- Analyze, review and update policies and plans as needed for ongoing compliance
The federal government wants to ensure that any company or agency it is doing business with has a supply chain free from human trafficking. Failure to comply will result in the possible loss of government contracts, fines, civil and criminal exposure, consumer boycotts, and negative publicity. The new regulations create an environment ripe for whistleblowing claims and false claims act liability.
Leading our Human Trafficking Compliance team is Partner Cynthia Cordes. A former federal prosecutor for almost a decade, she prosecuted more human trafficking cases than any other assistant U.S. attorney in the country. In addition to leading human trafficking compliance programs for businesses nationwide, Cordes leads the firm’s Human Trafficking Legal Clinic, which provides pro bono legal services to victims of human trafficking.