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Human Trafficking on Government Contracts

The U.S. government has adopted a “zero tolerance” policy to human trafficking on U.S. government contracts. A series of laws, regulations and an Executive Order have been passed in recent years in an effort to mitigate the use of forced labor to perform U.S. government contracts, with a focus on contracts performed in contingency areas. Contractors are now required to have compliance programs to mitigate human trafficking, to make a certification to that affect and to notify the U.S. government of any credible information of violations. These mandates apply both to the U.S and foreign prime contractor and their subcontractors. Violations create significant risk exposure for the company in the areas of the False Claims Act, Anti-Kickback Act of 1986 and False Statements in violation of 18 U.S.C. §1001. The practice of human trafficking on U.S. government contracts is prolific in contingency environments, including places of performance of LOGCAP task orders, but it can be stopped with an effective compliance program. Sam W. McCahon is the recognized authority in this field. Don’t risk the reputational and legal exposure of non- compliance with these mandates. We can assist you in developing a human trafficking compliance module that will meet or exceed the U.S. Government expectations.

Reasons This Atrocity Persists

The United Nations and the United States have described trafficking in humans as modern day slavery and the most rapidly growing organized criminal activity in the world. When it comes to gross revenues, modern slavery is second only to the trafficking of illegal drugs. For the most part, trafficking goes unnoticed and is seldom investigated or prosecuted. For all of these reasons, it flourishes.

How We Are Fighting Human Trafficking

Located in Washington, DC, McCahon Law is an internationally recognized leader in developing strategies and taking action to mitigate this category of misconduct in corporations and countries. It is not merely a humanitarian issue, it is criminal fraud. Sam McCahon is a recognized expert on the identification, assessment, and prosecution of human trafficking enterprises and individuals. He has served as a frequent consultant to governments and corporations, both in the United States and abroad, on measures necessary to abolish the practice.

Mr. McCahon has served as a consultant and advisor to the United States Congress, Department of State, Department of Defense, and the White House concerning human trafficking abolition strategies. A version of the executive order prohibiting human trafficking on government contacts initiated and drafted by Mr. McCahon was signed by President Obama on September 25, 2012.

Sam McCahon has also worked internationally with other subject matter experts, such as Sindhu Kavinamininnl, the founder and CEO of Compliance Consulting Services, Pvt. Ltd. of India. Together, they sought to establish corporate compliance programs with internal controls that are necessary to prevent human trafficking. Where warranted, they have also conducted internal investigations on behalf of corporate clients and provided recommendations for corrective actions.

Speaking Engagements on Human Trafficking

Sam is a frequent speaker and published author in the anti-trafficking effort. If you are interested in securing either a public speaking engagement, training or consultation services concerning measures for combating human trafficking in persons, or human trafficking information, do not hesitate to contact us or email us.

Videos & More Information

For a brief documentary on the subject of human trafficking on government contracts, please see the film Indentured, which was filmed in Iraq. You can also listen to President Obama talk on the subject matter. We also recommend you watch "On the Frontlines in the Acquisition Workforce's Battle Against Taxpayer Waste".

To view a podcast featuring Sam McCahon and Sindhu Kavinamininnl elaborating on the subject of human trafficking on government contracts, please see the Project on Government Oversight. With the help of the Observer Research Foundation in Mumbai, India, Sam McCahon and Sindhu Kavinamininnl worked together to create a video entitled "Labor Trafficking to the Middle East: Why if Flourishes and how to stop it!".