Federal Manager's Daily Report

OMB has issued guidance on requirements to prevent human trafficking in agency supply chains, including anti-trafficking risk management best practices and considerations for acquisition officials and subject matter experts to take into account when working with contractors.

Under memo M-20-01, CFO Act agencies—Cabinet departments and certain large independent agencies—are to identify an agency trafficking-in-persons expert and a procurement point of contact to facilitate collaboration on implementing the anti-trafficking requirements under the Federal Acquisition Regulation and law.


“Effective implementation of anti-trafficking requirements is a shared responsibility involving all parties to an acquisition, including the customer-program office, contracting officer, contracting officer’s representative, and the senior procurement executive. To understand their [trafficking-in-persons] risk profiles, agencies should review their contract spending and ensure necessary safeguards and reviews are in place for high-risk areas,” it says.

Requirements include, for example, clearly identifying prohibited trafficking-related activities for all products and services, to replace a prior general prohibition; requiring contractors to notify contracting officers and the agency IG of any credible information they receive alleging a violation; periodic evaluations by contracting officers of a contractor’s anti-trafficking efforts; and factors to take into account in determining agency responses to violations.

The guidance also addresses certification, reporting, compliance, and other obligations of contractors.