Modern Slavery Compliance For U.S.-based (and Other) Multinationals: A Review of Recent Compliance and Disclosure Developments in the United States and Abroad

Modern slavery compliance is becoming a bigger focus at U.S.-based and other multinationals. Compliance continues to evolve at a rapid pace. Over the last several months, there have been a number of important compliance and disclosure developments, some of which require action now, and others which will play out over a longer time frame.

For example, a federal Modern Slavery Act recently took effect in Australia, while the New South Wales Modern Slavery Act is expected to take effect mid-year. In the United Kingdom, the Home Office is putting additional compliance pressure on multinationals, has issued additional Modern Slavery Act guidance and is conducting a compliance review of Modern Slavery Act statements. In addition, the U.K. Modern Slavery Act is undergoing independent review, which may, over time, result in a strengthening of that Act.

Closer to home, the U.S. Federal Acquisition Regulation’s anti-human trafficking Rule was recently amended, modern slavery in supply chains is creating trade compliance risk and legislation that would require additional modern slavery disclosures has been proposed in Washington State. This year also has seen an uptick in modern slavery-related shareholder proposals. In addition, corporate modern slavery legislation has been proposed in Canada, and the Canadian government is taking other steps to strengthen corporate modern slavery compliance.