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Human Trafficking Model Compliance Plan and Internet-Based Compliance Tools Set for Release this Month

The Department of State (“State”) recently announced the upcoming release of the model anti-human trafficking compliance plan. State and Verité, a global NGO, developed this highly-anticipated model compliance plan in response to the amendments to FAR 52.222-50, which require contractors to perform supply chain due diligence and implement a compliance plan for contracts exceeding $500,000 that are for the acquisition of services or non-COTS goods outside the United States.  Because the rule contains relatively little guidance regarding these requirements, the model could provide the contracting community much needed direction regarding supply chain due diligence and compliance plan obligations.

In addition to releasing the model compliance plan, State will also unveil a new resource to assist contractors in complying with the FAR’s anti-human trafficking rule. According to State and Verité, this internet-based resource (to be available at incorporates input from “key stakeholders in the private sector, civil society, government, and contractor communities” gathered over the past year and a half.  The resource is said to contain “information, analysis, and practical guidance necessary to effectively address human trafficking,” as well as downloadable risk-management tools.

State and Verité will host the following sessions to debut the model compliance plan and

  • May 16, 2016; 9:30 a.m. to 11:30 a.m.; Dupont Circle Hotel

  • May 17, 2016; 9:00 a.m. to 11:30 a.m.; Sheraton Tysons Hotel

  • May 17, 2016; 1:30 p.m. to 4:00 p.m.; Sheraton Tysons Hotel

Those interested in attending may RSVP to by May 10, 2016. Following their release, we will provide an update on the model compliance plan and the resource.

© 2020 Covington & Burling LLPNational Law Review, Volume VI, Number 126


About this Author

Jennifer Plitsch, Litigation attorney, Covington

Jennifer Plitsch is co-chair of the firm’s Government Contracts practice group where her practice includes a wide range of contracting issues for large and small businesses in both defense and civilian contracting. Her practice involves advising clients on contract proposal, performance, and compliance questions as well as litigation, transactional and legislative issues. She has particular expertise in advising clients on intellectual property and data rights issues under the Federal Acquisition Regulations and Bayh-Dole Act, and has significant experience in...

Alexander Hastings, Litigation and e-discovery lawyer, Covington

Alex Hastings advises clients across a broad range of government contracting issues, including advising clients in transactional matters involving government contractors and assisting defense contractors and pharmaceutical companies in securing and performing government contracts.

Mr. Hastings also advises clients concerning best practices in e-discovery. He assists in investigations and litigations that involve complex e-discovery issues and has represented clients in matters involving the U.S. Department of Justice, Securities and Exchange Commission and the United States International Trade Commission.