Relating to the prosecution and punishment for the offense of trafficking of persons; increasing a criminal penalty.

Contracts

• Master Service Agreements (MSAs): Immediate review of all third-party labor and staffing contracts is required.
• Indemnification: Update clauses to specifically cover costs related to criminal investigations or trafficking allegations arising from vendor personnel.
• Audit Rights: Insert "Right to Audit" clauses allowing unannounced inspections of vendor I-9s and age verification data to mitigate "strict liability" risks.

Hiring/Training

• Universal Age Verification: Implement mandatory ID verification for *all* workers on premises, including subcontractors. Visual assessment is no longer a valid legal defense.
• Red Flag Training: Frontline staff (hotel clerks, site foremen) must be trained to identify signs of coercion (e.g., lack of possession of ID, restricted movement) to prevent "participation in a venture" charges.

Reporting & Record-Keeping

• Incident Logs: Establish a formal, documented internal mechanism for reporting suspicious activity. Documenting a report and your subsequent investigation is your primary defense against "knowingly receiving a benefit" allegations.
• Due Diligence Files: Maintain records of audits performed on staffing agencies to demonstrate a lack of criminal intent.

Fees & Costs

• Direct Fees: None.
• Indirect Costs: Increased legal spend for contract revision and potential increases in liability insurance premiums (though criminal acts are generally uninsurable).