How To Approach The New Anti-Human Trafficking Rule

Law360, New York (October 17, 2013, 4:01 PM ET) -- On Sept. 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[1] and nearly nine months after the 2013 Defense Reauthorization Act was enacted with largely analogous requirements.[2]

Simultaneously, the U.S....
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