December 02, 2011

Jenner & Block Partner Martina E. Vandenberg, Government Contracts Emerging Issues Attorney Cynthia J. Robertson and Associate Damien C. Specht authored an article titled “Monitoring Compliance With Human Trafficking Rules,” recently published in Law360.  In it, the authors review the U.S. Department of Defense final rule “Administering Trafficking in Persons Regulations,” issued in November 2011.  The rule does not alter contractor responsibilities, but amends the DFARS to require government surveillance of contractor compliance with human trafficking rules.  The authors discuss the background and historical administration of the trafficking rule, and the effects of the new surveillance rule.  The authors conclude that contractors should review their compliance programs to strengthen systems to prevent, identify and remedy forced labor and trafficking violations, especially when operating in “heightened risk” areas.