Bass, Berry & Sims attorney Todd Overman provided comments for a Law360 article on the requirements faced by government contractors related to combating human trafficking. With standards implemented by a 2012 executive order and final regulations in 2015, many government contractors are still developing compliance plans and unsure about the due diligence required to vet supply chains. As Todd points out in the article, “‘[t]here’s still a bit of uneasiness out there, given it’s not defined what ‘due diligence’ really means. It’s not defined in the regulations, and I think there’s been some willingness on the part of government to provide some parameters of what due diligence is … but I think that’s where contractors are still a little bit in the gray.'”
The full article, “Contractors Ignore Anti-Trafficking Rules At Their Peril,” was published by Law360 on September 19, 2016, and is available online.