Last fall, the Federal Acquisition Regulation (FAR) Council and Department of Defense (DoD) published proposed rules to implement requirements in President Obama’s Executive Order 13627 and the National Defense Authorization Act (NDAA) of FY 2013 intended to combat human trafficking in the Government’s supply chain. These implementing rules, which have drawn extensive comments from a broad array of stakeholders, likely will take effect in 2014, and for the reasons discussed below, the interim or final rules, whichever form they take next, are likely to align closely with the proposal rules. Now, therefore, is a good time to take stock of the proposals and to assess what the regulations are likely to entail once they take effect. This update highlights the salient aspects of the proposed rules and the requirements that are likely to be of most interest to contractors, especially those with extensive overseas supply chains supporting the U.S. Government.
