Systematic Approach to Managing Human Trafficking Risks in Defense Contracting

Abstract

The Department of Defense (DoD) faces growing scrutiny over its ability to prevent human trafficking, particularly forced labor, in its overseas construction contracts. Despite promoting a zero-tolerance policy and a range of compliance measures, oversight bodies have repeatedly found that the DoD’s efforts are fragmented, reactive, and insufficiently risk-informed. This study proposes the integration of the Office of Management and Budget’s (OMB) Enterprise Risk Management (ERM) framework, as outlined in Circular A-123, into the DoD’s Combating Trafficking in Persons (CTIP) program. Drawing on qualitative analysis of policy documents, federal regulations, oversight reports, and interviews with CTIP experts, this paper maps current CTIP practices against ERM’s five core risk management phases: identification, assessment, response, monitoring, and communication. The research reveals significant gaps across the contract life cycle, particularly in pre-award planning and post-award oversight. To address these, the study presents a comprehensive ERM-integrated CTIP framework designed to shift the DoD’s approach from reactive enforcement to proactive risk management. Recommendations include implementing trafficking risk screening tools, enhancing contractor vetting, standardizing monitoring practices, and improving interagency data sharing. By embedding ERM principles into CTIP processes, the proposed framework aims to better protect vulnerable laborers, strengthen contractor accountability, and ensure the DoD’s contracting practices align with both ethical standards and legal mandates.