In Short:
qui
tam cases predicated on alleged human trafficking
violations has begun to emerge.
The Result: Potential exposure to qui tam
claims heightens the risk of allegations of human trafficking in
business operations.
Looking Ahead: Companies contracting with
the federal government should consult with counsel to ensure
compliance with contractual and regulatory obligations related to
human trafficking and should implement risk mitigation strategies
where reasonably feasible.
Two recently unsealed
qui tam actions reveal
efforts by former employees of government contractors to bring
False Claims Act ( FCA ) actions predicated on claims of
human trafficking. Under the FCA, whistleblowers
( relators ), can file