Policy Brief: Fighting Illicit Labor Practices and Protecting American Interests in Federal Procurement

Today, the United States government procures through complex, opaque global supply chains that source goods and services across multiple jurisdictions around the world, many of which may have limited local human rights protections or remedies for workers. Competition between bidders to be able to offer the “best value” contract at the lowest price with the quickest turnaround means that there is a strong incentive to source from jurisdictions with weaker protections or factories with lower wages and unsafe working conditions. These perverse incentives, combined with the lack of transparency surrounding the web of contractors, subcontractors, processing plants and factories that make up global supply chains mean that companies can more easily claim ignorance of human rights risks further down the chain.

This puts law-abiding businesses and U.S. workers at a competitive disadvantage when it comes to securing government contracts and allows abuses like forced labor to flourish in U.S. government supply chains, ultimately making our supply chains less stable and posing serious threats to U.S. economic and national security. Investigations by independent journalists have already found that at least some of U.S. seafood spending for school lunches and the military has gone to importers sourcing from Uyghur forced labor,  but considering the prevalence of forced labor across industries, it is likely that this is just the tip of the iceberg. 

But as the largest single purchaser in the global economy, the U.S. government is uniquely positioned to leverage its purchasing power to secure its supply chains and drive significant changes in the ways that goods are sourced and produced globally. On April 15, 2025, President Donald Trump issued an Executive Order entitled “Restoring Common Sense to Federal Procurement,” directing the FAR Council to amend the Federal Acquisition Regulation (FAR) to ensure that it contains only provisions required by statute or that are otherwise necessary to “support simplicity and usability, strengthen the efficacy of the procurement system, or protect economic or national security interests.” 

This brief argues that as the FAR Council aims to bring the Federal Acquisition Regulation more in line with the administration’s priorities it must ensure that provisions like the human trafficking and forced child labor prohibitions remain in the FAR in order to protect law-abiding U.S. businesses from unfair competition, secure U.S. supply chains, and ensure U.S. taxpayer dollars are not funding egregious abuses around the world. This administration also has the opportunity to further strengthen the FAR’s efficacy in a variety of ways, including lowering supply chain risks by strengthening transparency, instituting more effective monitoring and enforcement mechanisms, and strengthening protections for U.S. law-abiding businesses and their workers from unfair competition.

Read the full policy brief here.