Law360, New York (January 29, 2015, 4:26 PM EST) -- The just-released Federal Acquisition Regulation provisions — arising out of President Barack Obama's 2012 Executive Order 13627 — mandate that all federal contractors take certain actions related to combating human trafficking and slavery in their supply chains. It is no overstatement that the FAR provisions will have an immediate and significant impact on the 300,000 or so prime contractors (as well as the quite literally countless subcontractors and lower-tier subcontractors) for the world's largest consumer of goods and services, namely, the U.S. government. The compliance playing field just got much larger — and, unfortunately, many will now be forced to play catch-up or risk severe penalties, including potential debarment, as well as criminal and civil sanctions for false certification....
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