“New Anti-Trafficking Rule Presents Significant Challenges for Government Contractors,” 3 Mar 2015

[A] new Anti-Trafficking rule will substantially change and increase federal contractors’ compliance and certification requirements…The new rule amends the FAR [Federal Acquisition Regulations] to codify trafficking-related prohibitions involving federal contracts, including new compliance and certification requirements, and puts contractors on the hook for disclosing violations to the government…These changes will have an immediate and significant impact on federal contractors.  Most significant is the thorny position contractors are placed in by having to perform due diligence on their subcontractors (at every tier), and then continuing to monitor them for violations…Given the uncertainties and costs of compliance, and severe penalties for non-compliance, it is imperative that government contractors fully appreciate and understand the import of this new rule and its requirements, and take appropriate steps to ensure compliance...