Skip to main content

Constant Legal Group

Legal Insights & Updates

Labor Trafficking and Corporate Supply Chains – How Businesses Can Be Held Accountable for Forced Labor

| by Dean Venizelos

If you were made to work against your will, or if you know someone who was, please know this: what happened was not your fault, and you are not alone.

When most people hear the word trafficking, they picture sex trafficking. Labor trafficking is far less visible, and survivors of forced labor often wonder whether the law even recognizes what they lived through. That uncertainty can make reaching out feel daunting, but the law does recognize it. Federal law treats forced labor and sex trafficking as two forms of the same crime, governed by the same statute and offering the same path to civil justice. Below, we explain what forced labor is, how the law can reach the businesses that benefit from it through their supply chains, and how survivors and their advocates can think about their options.

Understanding Forced Labor and Labor Trafficking Under Federal Law

Labor trafficking, also called forced labor, happens when someone uses force, fraud, or coercion to obtain another person’s labor or services. The conduct is easier to recognize once it is broken into three parts: the action, the means, and the purpose. The action is recruiting, harboring, transporting, or obtaining a person. The means is force, fraud, or coercion. The purpose is exploitation through labor or services.

This is a human issue affecting people all over the world. The International Labour Organization (ILO), together with Walk Free and the International Organization for Migration, estimated that 27.6 million people were living in forced labor on any given day in 2021. These are not distant statistics to the people behind them. They are domestic workers, farmworkers, fishers, and factory workers, many of whom were promised honest jobs.

Coercion does not always look like chains or locked doors. In many cases it is quieter: an employer withholding promised wages, confiscating a worker’s passport or other identity documents, threatening deportation or harm to a worker’s family, using debt to trap someone in a job they cannot leave, or threatening to misuse the legal process against them.

Federal law addresses these harms through several related provisions, including prohibitions on forced labor, involuntary servitude, peonage, and the seizure of documents to compel work. A person does not need to be moved across a border, or even across a state line, for the conduct to count as labor trafficking. What separates labor trafficking from an ordinary workplace dispute is coercion. A hard or unfair job is not the same as forced labor, but when fear, deception, or threats are used to keep someone working, the situation may cross that line.

How the Trafficking Victims Protection Reauthorization Act Reaches Corporate Supply Chains

The primary federal tool here is the Trafficking Victims Protection Reauthorization Act (TVPRA). Congress first passed the underlying law in 2000 to make forced labor and sex trafficking federal crimes. A 2003 update gave survivors the ability to sue their traffickers for civil damages, and a 2008 update went further, allowing claims against third parties that benefit from trafficking. The law has been reauthorized several times since.

That 2008 change is what makes corporate supply chains relevant. Under the civil remedy, a survivor may sue not only the person who directly exploited them, but also, in some cases, anyone who knowingly benefits from a trafficking venture. In plain terms, a beneficiary claim generally asks whether the company knowingly benefited, financially or by receiving something of value; whether that benefit came from participation in a venture; and whether the company knew, or should have known, that the venture involved trafficking.

Put together, this means a business that profits from goods produced through forced labor may, in some situations, face civil liability even if it never met the trafficker and never employed the worker directly. Whether that standard is met depends heavily on the facts of each case, and courts are still defining its edges.

Recent Cases Where Supply Chain Liability Is Taking Shape

Akhmad v. Bumble Bee Foods

In March 2025, four Indonesian fishers filed suit in federal court in San Diego, alleging that they endured forced labor aboard Chinese-flagged vessels that supplied tuna later sold under the Bumble Bee brand. The suit is believed to be the first of its kind brought against a U.S. seafood company for forced labor at sea. In November 2025, the court allowed the core of the case to move forward past Bumble Bee’s motion to dismiss. That ruling is not a finding of liability. It simply means the fishers may continue to pursue their claims, including the argument that the law can reach conduct that took place on the high seas.

Operation Blooming Onion

This federal investigation in South Georgia, made public through a 54-count indictment in November 2021, accused two dozen people of running an agricultural labor scheme that misused the H-2A guest worker visa program. Prosecutors alleged that workers from Mexico, Guatemala, and Honduras were brought to South Georgia farms, housed in degrading conditions, and forced to labor for little pay, in a conspiracy that generated more than $200 million. More than one hundred workers were ultimately freed, and the scheme’s organizer, Javier Sanchez Mendoza Jr., was sentenced to 30 years in federal prison after pleading guilty to conspiracy to engage in forced labor. Related civil claims have also been pursued, showing how criminal and civil paths can run alongside each other.

Ratha v. Phatthana Seafood

In this case, the Ninth Circuit Court of Appeals held that the TVPRA’s civil remedy did not reach a company that merely attempted, but failed, to benefit from forced labor overseas. The ruling exposed a real gap for survivors, and Congress responded within months, amending the statute so that an attempt or conspiracy to benefit from a trafficking venture can also support civil liability. The law, in other words, continues to adapt to close the gaps courts identify.

Federal Enforcement and the Role of the Department of Labor

Civil lawsuits do not operate in isolation. Several federal agencies investigate forced labor, and their work can shape the factual record a survivor relies on. The Department of Labor (DOL), through its Wage and Hour Division and its Office of Inspector General, regularly investigates labor exploitation and was part of the team behind the Operation Blooming Onion prosecutions.

Enforcement is also coordinated across agencies. The Forced Labor Enforcement Task Force, chaired by the Department of Homeland Security (DHS), brings multiple agencies together to address goods made with forced labor. The DOL also maintains a public List of Goods Produced by Child Labor or Forced Labor, which identified 204 goods from 82 countries as of its most recent 2024 update. The list is meant to raise awareness and help researchers and companies assess risk in their supply chains. For a civil claim, resources like this one matter because they can speak to what a company knew, or arguably should have known, about its suppliers.

The Uyghur Forced Labor Prevention Act and Its Effect on Corporate Liability

One law that has reshaped corporate awareness is the Uyghur Forced Labor Prevention Act (UFLPA). Signed in December 2021 and enforced starting in June 2022, it creates a rebuttable presumption that goods made wholly or in part in the Xinjiang region of China, or by companies on a designated entity list, are made with forced labor and therefore barred from entering the United States, unless the importer can show clear and convincing evidence otherwise.

The scale of this enforcement is significant. As of late 2025, U.S. Customs and Border Protection had reviewed more than 65,000 shipments valued at roughly $3.9 billion since the law took effect, and the associated entity list has grown to at least 144 companies.

It is worth being precise about what this law does. The UFLPA is a customs and import-enforcement statute, not a civil cause of action, so survivors do not sue a company under it directly. Even so, it affects civil liability in an indirect but meaningful way. By creating public lists, detention records, and detailed guidance, it raises the bar for what a company can reasonably claim not to have known about its supply chain. That heightened awareness may, in some cases, support the knew-or-should-have-known element of a labor trafficking claim under the TVPRA.

How Constant Legal Group Approaches Labor Trafficking Civil Claims

At Constant Legal Group (CLG), we evaluate labor trafficking civil claims nationwide, and we do so on your timeline and at your pace. We understand that telling your story can be difficult, and we work to be trauma-informed and survivor-centered at every step.

Our approach begins with listening. From there, we work to identify the venture at the heart of the harm and the parties who may have benefited from it, which can include direct employers, labor contractors, and businesses further up a supply chain. Building that picture often draws on many sources, including worker testimony, investigations by advocacy organizations, supply chain research, and government findings. Our attorneys handle the legal complexity so that you can focus on your healing and your family.

Frequently Asked Questions Regarding Labor Trafficking and Forced Labor Claims

Q: What is the difference between a labor trafficking claim and a sex trafficking claim? A: Both fall under the same federal statute and share the same core elements, the use of force, fraud, or coercion. The difference lies in the purpose of the exploitation. A labor trafficking claim involves forced work or services, while a sex trafficking claim involves a commercial sex act. In sex trafficking cases involving a minor, the law does not require proof of force, fraud, or coercion.

Q: Besides the person who forced me to work, who else can be held responsible? A: Federal law may allow claims against both direct perpetrators and third parties that knowingly benefited from the trafficking, provided they knew or should have known what was happening. Depending on the facts, that could include labor contractors, staffing companies, or businesses that profited from the goods or services produced.

Q: Do I need a criminal conviction before I can file a civil claim? A: No. A civil claim is separate from a criminal case and may proceed on its own. Survivors do not need to wait for, or rely on, a prosecution to seek civil justice, although a related criminal case can sometimes provide useful evidence.

Q: What if the forced labor happened in another country? A: In some cases, the federal civil remedy can reach conduct that occurred abroad, particularly where a company in the United States benefited from it. The Bumble Bee ruling discussed above is one example of a court allowing such a claim to proceed, though outcomes depend on the specific facts.

Q: Will my immigration status affect my ability to bring a claim? A: Survivors of trafficking may have protections available to them, including certain immigration relief such as the T visa. Because every situation is different, this is an area where individualized legal advice is especially important.

Q: How long do I have to file a labor trafficking claim? A: Federal trafficking claims generally allow survivors a number of years to come forward, but time limits vary and can depend on many factors. Because these deadlines can be complicated, it is wise to ask about them early rather than to assume a claim is too old.

We Are Here to Hear Your Story

If you were forced to work against your will, or held in exploitative labor conditions, you may have a civil claim under federal law. You do not have to be certain before you reach out, and you do not have to navigate this alone.

Constant Legal Group (CLG) evaluates labor trafficking cases nationwide. We offer free, confidential consultations with no obligation and no upfront cost, and we only get paid if we recover compensation for you. When you are ready, and only when you are ready, we are here to listen.

Need Help Understanding Your Legal Options?

If you have questions about your rights or next steps, our team is here to help you understand your options in a confidential consultation.

Get Help Now