A long-awaited final rule significantly augmenting existing human trafficking-related obligations for federal contractors and subcontractors becomes effective on March 2, 2015. The rule broadly applies to all federal contractors and subcontractors, including contractors providing commercial items, commercially available off-the-shelf items, or goods on the Federal Supply Schedule. In addition, certain contractors providing goods and services abroad will be required to make new certifications and implement compliance plans.

Although the rule’s goals are undoubtedly praiseworthy, numerous commenters and industry groups have observed that the rule is overbroad, unclear and will be difficult and expensive to implement. Because of its breadth, potential penalties, and compliance costs, the rule may necessitate fundamental risk assessments about contractors’ business practices and the practices within their supply chains.

The Covington Government Contracts group will provide insight on the following common questions:

■ What are the new obligations imposed by the revised human trafficking rule?

■ Is the human trafficking rule applicable to my company?

■ When and how will the rule go into effect?

■ What must my company do to comply with the rule?

■ What penalties result from noncompliance?

■ What are the risks and issues to watch?