Combating Trafficking in Persons

Trafficking in Persons (TIP) is a modern form of slavery involving the control of a person through force, fraud, or coercion. Unfortunately, in the development industry, we often operate in contexts and countries at higher risk for TIP. This course is designed to help CNFA's employees understand the different types of TIP, identify TIP or risk of TIP in a project context, develop protocol to address instances of TIP, and comply with required United States Government regulations.

This is a required course under CNFA's Ethics Program. At the close of this training, there will be a brief assessment to ensure employees completed the course material. 

What is TIP?


"Trafficking in persons," "human trafficking," and "modern slavery" have been used as umbrella terms for the act of recruiting, harboring, transporting, providing, or obtaining a person for compelled labor or commercial sex acts through the use of force, fraud, or coercion. 

- United Nations Office on Drugs and Crime

Countries of Origin for Human Trafficking


Key Elements of TIP

There are three Key Elements which can be used to define and identify TIP:

  1. Force
  2. Fraud, or
  3. Coercion

The Trafficking Victims Protection Act of 2000 (TVPA) defines "severe forms of trafficking in persons" as:

  1. Sex trafficking in which a commercial sex act is induced by force, fraud, or coercion, or in which the person induced to perform such an act has not attained 18 years of age; or
  2. The recruitment, harboring, transportation, provision, or obtaining of a person for labor or services, through the use of force, fraud, or coercion for the purpose of subjection to involuntary servitude, peonage, debt bondage, or slavery.

A victim need not be physically transported from one location to another in order for the crime to fall within these definitions. 


Did you know?

  • The private economy reaps some $150 billion in illicit profits each year from human trafficking
  • 20.9 million people are human trafficking victims
  • 55% of all victims are females
  • 26% of victims are children (under 18 years of age)

- International Labour Organization (ILO)

  • Human Trafficking represents the second-largest criminal industry worldwide
  • It is the fastest growing criminal industry

- Department of Health and Human Services, 2006

Types of TIP


While many people think human trafficking only takes the form of sex trafficking, there are multiples types of TIP to be aware of. This section will define the various forms of TIP, as well as identify common circumstances and environments where TIP occurs. 

Sex Trafficking

Sex Trafficking occurs when a commercial sex act is induced by force, fraud, or coercion, or in which the person who is induced to perform such an act is under the age of 18.

Victims of sex trafficking can be found working anywhere, but are most often found in:

  • Massage parlors;
  • Brothels;
  • Brothel systems that operate out of residential homes;
  • Depending on the country, certain nightclubs and hotels that attract foreigners.

Forced Labor

Forced Labor, also referred to as labor trafficking, is defined as the recruitment, harboring, transportation, provision, or obtaining of a person for labor or services, through the use of force, fraud, or coercion for the purpose of subjection to involuntary servitude, peonage, debt bondage, or slavery.

Forced labor can occur in various forms:

  • Domestic servitude, such as nannies and maids;
  • Sweatshop factories;
  • Janitorial jobs;
  • Construction sites;
  • Farm work;
  • Restaurants;
  • Panhandling.

Case Study

PHILIPPINES | A Palawan fisherman recruited 25 other men to work as fisherman on a neighboring island in the Philippines. The workers met with the recruiter twice before moving to the island, and they received money at each meeting that reaffirmed their belief that well-paying jobs awaited. At their new job, however, the men were not paid at all. Instead, their traffickers charged them P60,000 ($1,360) each for room and board. 

They forced the men to fish illegally and physically abused them if they did not catch enough fish. The men endured forced labor for two months before being released. Both the recruiter and fish trader face charges of human trafficking, and the owner of the boats remains at large. 

In the picture above, fishermen raise their hands when asked who among them would like to go home, after their release was secured from a situation of forced labor on a fishing vessel. 

- Department of State Trafficking in Persons Report, 2015

Child Soldiering

The term child soldier applies to:

  • Any person under 18 years of age who takes a direct part in hostilities as a member of governmental armed forces;
  • Any person under 18 years of age who has been compulsorily recruited into governmental armed forces;
  • Any person under 15 years of ago who has been voluntarily recruited into governmental armed forces; or
  • Any person under 18 years of age who has been recruited or used in hostilities by armed forces distinct from the armed forces of a state.

The term child solider also includes any person as described in the above who serves in a support role capacity other than combat, such as cook, porter, messenger, medic, guard, or sex slave.

- Section 402 of the Child Solider Prevention Act of 2008

Risk Factors and Trends

Common Risk Factors

Common environments at higher risk for TIP include jobs and situations that are dirty, dangerous, and difficult. These jobs are commonly low-paying and undervalued by society, and are often filled by socially marginalized groups including migrants, people with disabilities, or minorities. 

In these industries, the demand for labor increases drastically at the time of harvest or when a new product - be it a smartphone or a roadway - must be manufactured within a strict timeframe. TIP responds to the laws of supply and demand. Consider East and South Asian migrant workers in the garment sector who are vulnerable to forced labor and labor exploitation, including long working hours and forced overtime, especially during periods of high consumer demand. This disconnect means that employers can be unaware of bad practices related to hiring within their operations, leaving workers exposed to exploitation.

While these factors alone do not cause Trafficking in Persons, a combination of factors in these environments certainly increases the risk of exploitation.

At-Risk Environments

At-risk environments and situations where individuals may be exploited could include:

  • Ongoing violence in a country, leading to a lack of job opportunities;
  • Corruption and collusion between traffickers and elected officials;
  • Absence or lack of enforcement of civil rights;
  • Prior history of sexual abuse or chronic poverty;
  • Industries which rely upon low or unskilled labor, including the migrant workforce;
  • Industries of a seasonal nature or where the turn-around time for production is extremely short;
  • Long, complex, and/or non-transparent supply chains;
  • Urgency to hire employees, resulting in use of labor recruiters and agents, creating an additional layer of separation between the employer and worker;
  • Industries where fierce competition leads to downward pressure on prices, causing employers to reduce wages or ignore safety protocols. 

Risk to CNFA and Prevention

The Development Industry tends to work and operate in at-risk environments. Further, agriculture is one of the primary sectors with a significant risk of human trafficking, particularly due to the globalization of supply chains and the use of seasonal or contract labor. This puts CNFA, its employees, and subrecipients at frequent risk of exposure to TIP. 

CNFA's best practice is to identify at-risk situations and implement protocol to prevent any violation of TIP provisions. Consider the following scenario as an example of how to avoid risk:

CNFA is currently implementing a project in Colombia. Expats, volunteers, and other project employees use a major hotel for meetings and lodging during project support trips. The hotel is known for its great service, competitive rates, and safety. Recently, however, CNFA staff have noticed commercial sex workers also frequent the hotel to engage with foreigners. While nothing has happened, this environment puts CNFA at unnecessary risk of violating TIP provisions. 

Rather than simply informing staff of the situation, the Chief of Party assumes a more proactive role and instructs her staff to survey other hotels in the area which are within USG per diem rates, safe, offer similar amenities, and do not have a questionable reputation. Once suitable hotel options are identified, the COP issues a memo specifying the allowable hotels for use by both field and home office personnel, as well as any consultants, volunteers, or subrecipients. The staff and COP's reaction mitigated a high level of risk and removed CNFA and its staff from a potentially compromising situation.

Consider what scenarios might put your project at risk. How can you and your team enact preventative measures to avoid TIP violation?

Compliance and Regulations

Regulatory Basis for TIP

CNFA is bound to Trafficking in Persons compliance under both acquisition and assistance mechanisms. 

  • FAR 52.222-50, "Combating Trafficking in Persons (March 2015)," governs all Contracts and Subcontracts
  • Under the Mandatory Standard Provisions for US NGOs, Standard Provision "Trafficking in Persons (July 2015)," governs all Cooperative Agreements, Grants, or Subawards


The FAR and Standard Provisions mirror each other and are applicable to CNFA employees, vendors, grantees, subrecipients and subcontractors (at any tier), their employees, and any consultants or volunteers. In short, the TIP provisions apply to any person or organization receiving funding from or working on a USG project. 

Provision Contents

CNFA and all individuals or entities receiving project funds or implementing work on behalf of CNFA are prohibited from the following, as per the TIP provisions:

  • Engaging in severe forms of TIP during the period of performance of the contract;
  • Procuring commercial sex acts during the period of performance of the contract;
  • Using forced labor in the performance of the contract;
  • Destroying, concealing, confiscating, or otherwise denying access by an employee to the employee's identity or immigration documents;
  • Using misleading or fraudulent practices during the recruitment of employees or offering of employment;
  • Using recruiters that do not comply with local labor laws of the country in which the recruiting takes place;
  • Charging employees recruitment fees;
  • Failing to provide, or pay for, return transportation upon the end of employment for a TCN who was brought into that country to work on a USG contract or subcontract, for portions of contracts and subconctracts performed outside the US;
  • Failing to provide, or pay for, return transportation upon the end of employment for an employee who is not a US national and who was brought into the US for the purpose of working on a US contract or subcontract, if the payment of such costs is required under existing temporary worker programs or per a written agreement between employee and employer. 

Due Diligence

It is CNFA's responsibility to ensure all employees (including consultants and volunteers) and subrecipients are aware of the TIP prohibitions and potential consequences for non-compliance. Remedial actions could include removal of agents in violation or termination of the subaward. You can find a copy of CNFA's Trafficking in Persons Compliance Plan on SharePoint, or can request a copy from HQ Contracts. 

If you suspect any violation of the TIP provision:

  • Immediately contact CNFA's Chief Operating Officer;
  • Consider the appropriate action (i.e. remove employee, terminate award);
  • Discuss notifying the AO or CO and the OIG in consultation with HQ;
  • Consider using the publicly available hotline and email address for general assistance: 
    • Global Human Trafficking Hotline: 1-844-888-FREE

Subs and Grantees

CNFA is directly responsible to ensure our subs and grantees are compliant with TIP provisions. Some  methods include:

  • Discussing the TIP provision in the post-award start-up meeting;
  • Reviewing the subrecipient's Human Resources or Policy Manual to verify TIP is incorporated;
  • Reviewing the subrecipient's employment agreements;
  • Using the standard CNFA Subagreement/Subcontract template, which includes the TIP provision;
  • Requesting training materials, posters, etc. 

Apart from the proactive methods discussed above, CNFA's own employees should attentively monitor subs' activity and be able to prevent at-risk situations or identify violations. 

Subs or grantees with award values of $500,000 or greater cross a responsibility threshold and are held to the same requirements as CNFA. Note that this requirement does not apply to vendors that provide commercially available, off-the-shelf goods or services, regardless of value.

These recipients must:

  1. Complete the annual TIP certification statement:
    1. The annual TIP certification statement is a standard template which must be signed by the subrecipient. Templates can be found in the Standard Provisions, or provided by HQ Contracts.
  2. Have and implement a compliance plan. The minimum elements of a compliance plan include the following:
    1. Must post useful and relevant contents of the plan or related materials on its website (if one is maintained) and at the workplace;
    2. Must include an awareness program to inform employees about the trafficking related provisions, the activities prohibited, and the action that will be taken against the employee for violations;
    3. A reporting process for employees to report, without fear of retaliation, activity inconsistent with the policy prohibiting trafficking, including a means to make the Global Human Trafficking Hotline and email address available to all employees;
    4. A recruitment and wage plan that only permits the use of recruitment companies with trained employees, prohibits charging of recruitment fees to the employee, and ensures that wages meet applicable host-country legal requirements or explains any variance;
    5. A housing plan, if the recipient or any subawardee intends to provide or arrange housing. The housing plan is required to meet any host-country housing and safety standards;
    6. Procedures for the recipient to prevent any agents or subawardee at any tier and at any dollar value from engaging in trafficking in persons activities. The recipient must also have procedures to monitor, detect, and terminate any agents or subawardee or subawardee employees that have engaged in such activities. 




Congratulations! You have completed CNFA's Trafficking in Persons Compliance Training. Before you go, please complete the brief quiz on the content we have covered today.

1. True or False

  • Human trafficking requires some form of travel, transportation, or movement across state or national borders.

2. What is the proper course of action if you become aware of a TIP violation?

  • Contact your supervisor and CNFA's Chief Operating Officer
  • Consider the appropriate response, such as removing the employee or terminating the subaward
  • Discuss method of informing the CO or AO, in consultation with HQ
  • Report the incident using the Trafficking Hotline or email address

3. Fill in the Blanks

The three key elements involved in Trafficking in Persons are , or .

4. What are some common risk factors that might lead to TIP? Click as many as apply.

  • Lack of job opportunities
  • Industries with a seasonal nature
  • Long, complex, non-transparent supply chains
  • Use of labor recruiters and agents
  • Industries which use unskilled labor

5. Under contracts, where would one find regulations on TIP compliance?

  • Standard Provisions for US NGOs
  • 2 CFR 200
  • ADS 310
  • Federal Acquisition Regulations

6. What is the minimum award value requiring subrecipients to provide an annual certification and TIP compliance plan?

  • $250,000
  • $750,000
  • $500,000
  • $300,000

7. Who does the TIP provision apply to? Check all that apply.

  • Vendors
  • Grantees
  • Consultants
  • Subrecipients (contractors or awardees)
  • Staff
  • Volunteers

8. What are the three types of trafficking?

The three types of trafficking in persons include: 1) , 2) , and 3) 

9. True or False

  • Choosing not to provide or pay for return transportation upon the end of employment, for a TCN brought into that country for the purpose of working on a contract outside the United States, is considered to be a form of forced labor human trafficking.

10. Use the Drop Down to select the appropriate word and complete the definition.

Severe forms of  is defined as:

  1.  in which a is induced by  or in which the person induced to perform such an act has not attained 18 years of age; or
  2. The recruitment, harboring, transportation, provision, or obtaining of a person for , through the use of  for the purpose of subjection to , peonage, debt bondage, or slavery. 


Thank you for completing CNFA's Trafficking in Persons Compliance Training. If you have any recommendations to improve this course, please feel free to provide a response below.