Human Trafficking: Understanding the Changing Hotel Compliance Landscape

AGG Global Trade & Sanctions attorneys Allison Raley and Nikita Kulkarni authored an article for Hotel Executive discussing how hotel executives can protect themselves from human trafficking allegations by preventing exploitation on their properties through employee education and, when red flags arise, action. 

The Trafficking Victims Protection Act of 2000 (“TVPA”) was expanded in 2008 to include any business or individual that knowingly benefits from participating in a trafficking venture, whether or not they were directly involved, making them potentially liable in civil litigation.

The attorneys provided insight into a recent case in which a global hotel brand was being sued for failure to act on trafficking warning signs. Allison and Nikita discussed the key red flags that the company missed, as well as the federal court’s decision to deny dismissal. They also provided guidance on how other companies could learn from the outcome of the global hotel brand’s suit and better protect themselves against a suit involving TVPA. 

“For hotel operators, effective anti-trafficking measures must sit at the core of any credible compliance framework. Policies should remain clear, enforced, and regularly updated,” said Allison and Nikita. “Training must reach every employee — from the front desk to housekeeping — and occur routinely, with a practical focus on recognizing and reporting trafficking indicators.” 

Please click here to read the full article and learn more about anti-trafficking compliance frameworks.