September 21, 2021

Volume XI, Number 264

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September 21, 2021

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September 20, 2021

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Human Trafficking Is Forbidden by Government Contracts. But What Is “Human Trafficking”?

FAR 52.222-50 prohibits “human trafficking.” To quote the current GEICO TV commercials, “Everybody knows that.” But do you know exactly what the FAR prohibits? The answer includes some obvious pernicious acts, but it also covers some related activities that might not necessarily jump immediately to mind. Remember, these prohibitions apply to all contractors – large and small, commercial and non-commercial, whether the contract was awarded via sealed bidding or negotiation – and to their employees and agents, and they must be flowed down to subcontractors. Moreover, there is an obligation to conduct “due diligence” and certify to subcontractor compliance with the prohibitions if the subcontract exceeds $500,000 and any portion is for non-COTS supplies acquired or for services performed outside the United States.

So, click here to see the ten types of activities that could earn you a default termination, suspension or debarment, forbearance in the exercise of contract options, suspension of contract payments, or loss of award fee, or that might require you to discharge non-compliant employees or terminate non-compliant subcontractors, or garner you some unflattering publicity in the media.

Copyright © 2021, Sheppard Mullin Richter & Hampton LLP.National Law Review, Volume VI, Number 27
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About this Author

John W. Chierichella, Sheppard Mullin Law Firm, International Trade Attorney
Partner

John Chierichella is a partner in the Government Contracts and Regulated Industries Practice Group in the firm's Washington, D.C. office.

Areas of Practice

Mr. Chierichella has a broad range of experience in government contract matters, including bid protests, claims and appeals, cost and CAS issues, teaming disputes, GSA's Multiple Award Schedule (MAS) Program, compliance reviews and internal investigations, and qui tam and other False Claims Act litigation.

202-218-6878
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