Human Trafficking 101: Acquisition Workforce 

What is Human Trafficking? 

Human trafficking is modern slavery. It involves the 

exploitation of someone for the purposes of compelled labor or 

a commercial sex act through the use of force, fraud, or 

coercion. Millions of adults and children worldwide, including 

in the United States, are victims of trafficking, including in 

forced labor, domestic servitude, and the commercial sex 

industry. Many victims are lured with false assurances of wellpaying jobs or the promise of love and affection from someone 

who claims to care about them. Victims are found in both 

legitimate and illegitimate industries or businesses, including 

sweatshops, massage parlors, farms, restaurants, hotels, and 

domestic service. In government contracting some high risk 

industries include construction trades, grounds maintenance, 

food services, custodial services, natural disaster clean-up, and 

environmental remediation, to name a few. 

Human trafficking is different from migrant smuggling. 

Trafficking is exploitation-based and does not require 

movement – it is a crime against an individual. Smuggling is 

transportation-based and is a crime against the state – it 

involves the movement of people across international borders 

in deliberate evasion of immigration laws. 

Who are the Victims? Who is at Risk? 

Trafficking victims can be any age, race, gender, or nationality. 

Trafficking victims can be men or women, young or old, U.S. 

citizens or from abroad, and with or without legal status in the 

United States. 

Traffickers prey on victims who lack a social safety net. They 

look for victims who are vulnerable for a variety of reasons, 

including but not limited to: immigration status, limited 

English proficiency, poverty or economic hardship, political 

instability, broken homes or runaways, natural disasters, or 

other causes. They also seek out both Americans and foreignborn individuals who are isolated from their families or who 

have experienced trauma and abuse. 

No single indicator is proof of human trafficking. If you 

suspect that a person may be a victim, call the Immigration and 

Customs Enforcement (ICE) Homeland Security Investigations 

(HSI) tip-line at 1-866-347-2423. 

To reach a non-governmental organization for confidential help 

and information, 24 hours a day, please call the National 

Human Trafficking Hotline at 1-888-373-7888. 

How do I Identify Human Trafficking? 

Human trafficking is often hidden in plain sight. There are a 

number of red flags, or indicators, which can help alert you to 

human trafficking. Recognizing the signs is the first step in 

identifying victims, but no single indicator is proof of human 

trafficking. Some indicators specific to federal contracting 

concerning a potential victim include: 

Personal Documents. 

Traffickers may take victims' personal documents, such as 

identification papers and/or immigration documents. This 

effectively restricts victims' freedom of movement and opportunity. 

Wages. 

Traffickers may control victims by controlling wages. They may 

withhold wages, or pay workers significantly less than was 

originally promised. In addition, workers may be held in debt 

bondage when employers or agents charge an employee recruitment 

fees that can take years to repay. 

Safety. 

Traffickers may control victims by threatening potential victims or 

their families with harm. Potential victims may have bruises or 

other signs of physical abuse. Victims will also be threatened with 

deportation or arrest in order to control them. If you find that 

potential victims appear fearful, this is a red flag. 

Freedom. 

When a potential victim defers to another person to speak for him or 

her or appears to have been coached on what to say to authorities, it 

can be an indicator of human trafficking. Additionally, if a 

potential victim isn't allowed to socialize and communicate with 

family, friends, or at community events, this is also a red flag that 

the person is being controlled. 

Work Conditions and Immigration Status. 

Working and living conditions may present red flags. For example, 

you may note that potential victims in the workplace express that 

they were not given the job they were promised. You may also 

notice the potential victims appear deprived of food, water, sleep, 

and/or medical care, as well as satisfactory living conditions. 

Commercial Sex Act. 

A minor engaged in commercial sex is a human trafficking victim, 

regardless of whether the minor appears to have participated 

willingly. 

For more information, please visit: www.dhs.gov/bluecampaign 

If you suspect that a person may be a victim of human trafficking, 

please call the U.S. Immigration and Customs Enforcement, Homeland Security Investigations 

Tip-line at 1-866-347-2423.
 
  

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Human Trafficking 101: Acquisition Workforce 

What Role Does the Acquisition Workforce Have in 

Combating Human Trafficking? 

Members of the acquisition workforce have responsibilities in 

all phases of an acquisition to ensure that the U.S. Government 

is taking action to prevent, report, and remedy human 

trafficking in federal contracts. 

As a result of Executive Order (E.O.) 13627 and Title XVII of 

the National Defense Authorization Act for Fiscal Year 2013, 

the Federal Acquisition Regulation (FAR) was amended to 

strengthen protections against trafficking in persons in 

government contracts. The FAR explains the U.S. 

Government's policy prohibiting trafficking in persons, defines 

key terms, outlines compliance and reporting requirements, and 

provides remedies when allegations of human trafficking or 

trafficking-related activities are substantiated. 

What Can an Acquisition Professional Do to Combat 

Human Trafficking? 

FAR Subpart 22.17 requires that clause 52.222-50, Combating 

Trafficking in Persons, be incorporated in all solicitations and 

contracts, and that the substance of this clause shall be included 

in all subcontracts and in all contracts with agents. 

FAR clause 52.222-50 prohibits contractors, subcontractors, 

their employees, and their agents from: 

	 Engaging in severe forms of trafficking in persons 

	 Procuring commercial sex acts 

	 Using forced labor during the period of performance of 

the contract 

	 Destroying, concealing, or confiscating an employee’s 

identity documents 

	 Using misleading or fraudulent recruitment practices 

	 Charging employees recruitment fees 

	 Failing to provide return transportation or pay for the cost 

of return transportation at the end of employment 

	 Failing to provide or arrange for housing that meets 

safety standards 

	 If required by law or contract, failing to provide an 

employment contract, recruitment agreement, or other 

work document in writing 

The FAR clause requires contractors and subcontractors to 

notify employees and agents of the U.S. Government policy 

prohibiting trafficking in persons, and the actions that will be 

taken against them for violations of this policy. 

Training Available Through the Federal Acquisition 

Institute (www.fai.gov) 

 FAC-022 (FED) – Combating Trafficking In Persons 

As a Contracting Officer 

Upon receipt of credible information regarding a trafficking in 

persons violation, the contracting officer (CO): 

 Shall promptly notify the agency Inspector General (IG), and if 

appropriate, the agency suspending and debarring official, and 

if appropriate, law enforcement officials with jurisdiction over 

the alleged offense 

	 May direct the contractor to take specific steps to abate the 

alleged violation or enforce the requirements of its compliance 

plan 

Upon receipt of a report from the agency IG that provides support 

for the allegation and after a final determination that the allegations 

of a trafficking in person violation are substantiated, the CO shall 

enter the violation in FAPIIS, and consider any remedies available 

to the Government including those specified at 52.222-50: 

 Require the contractor to remove an employee or subcontractor 

employee from performing on the contract 

 Require the prime contractor to terminate a subcontract 

 Suspend contract payments until the contractor has taken 

appropriate remedial action 

 Loss of award fee consistent with the award fee plan 

 Decline to exercise available options under the contract 

 Terminate the contract for default or cause, in accordance with 

the termination clause in the contract 

 Suspension or debarment 

When considering the appropriate remedies, the contracting officer 

may consider mitigating and aggravating factors. 

As a Contracting Officer’s Representative 

A contracting officer’s representative (COR) has an important role 

in preventing and reporting human trafficking. The COR is 

designated and authorized in writing by the CO to perform specific 

technical or administrative functions. The COR may support the 

CO at the pre-proposal conference and post-award orientation 

where the requirements of the contract are discussed. The COR 

generally has authority to monitor day-to-day compliance with 

contract requirements including requirements of FAR clause 

52.222-50 that prohibits trafficking in persons. CORs may assist in 

reviewing and evaluating the adequacy of a compliance plan, 

recruitment and wage plan, or housing plan when these plans are 

required; and ensure that relevant content is posted at the workplace 

or on the contractor’s website. A COR shall immediately report to 

the CO any indicators of human trafficking during performance of 

the contract, or any credible information received from any source 

that alleges a violation of the U.S. Government policy prohibiting 

trafficking in persons, including trafficking-related activities.