Proposed Anti-Human Trafficking Regulations Mean Stricter Requirements for Government Contractors and Subcontractors

On September 26, 2013, the Federal Acquisition Regulatory (FAR) Council published a proposed rule imposing significant responsibility on contractors and subcontractors to act affirmatively to prevent human trafficking and forced labor. The proposed regulations came a year and a day after President Obama issued the groundbreaking executive order, "Strengthening Protections Against Trafficking in Persons in Federal Contracts," aiming to eliminate human trafficking by government contractors and subcontractors, and nearly nine months after the 2013 Defense Reauthorization Act was enacted with largely analogous requirements. Simultaneously, the Department of Defense (DoD) also published a new proposed rule amending the Defense Federal Acquisition Regulations System (DFARS) to further implement DoD's anti-trafficking policy and supplement government-wide changes proposed in connection with the Executive Order. Comments from the public on the proposed FAR and DFARS regulations are due no later than December 20, 2013.