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Law360 Quotes Michael Navarre on Anti-Trafficking Regulation and Compliance

September 30, 2013

Law360 quoted Michael Navarre in an article titled “Anti-Trafficking Rules Raises Contractor Compliance Concerns.”  The article, published on September 26, discusses new proposed anti-trafficking regulation. The proposed rules implement parts of the 2013 National Defense Authorization Act and a September 2012 executive order on trafficking that require greater compliance systems for prime contractors to deal with issues of human trafficking in their supply chain.

“Contractors that take a risk-based approach to anti-trafficking compliance will have to consider whether the type of work they're doing is a particular risk for trafficking violations,” Mr. Navarre says.  Low-skilled personal services; the relative strength or weakness of local employment regulation, which posed challenges in Iraq and Afghanistan; and the ethics of the subcontractors and labor recruiters they use in performance of the contract “are risk factors that contractors are going to have to look at,” he adds.

The full article can be read at Law360 (subscription required).