Regulatory Compliance

Identifying Human Trafficking Activity on Your Premises Do You Know the Signs?

Earlier this month, Florida Attorney General Ashley Moody spoke to law enforcement officials and hotel groups to announce a campaign aimed at human trafficking awareness surrounding this month’s Super Bowl NFL football game in Miami.  

Attorney General Moody and law enforcement officials urged the hospitality industry, ride-hailing service drivers and security personnel to be especially alert. Uber and other rideshare services are mandating drivers to complete sex trafficking awareness training prior to game day. Governor DeSantis signed legislation in 2019 requiring certain hospitality industry employees and message establishment employees to obtain annual human trafficking awareness training. Specifically, Section 509.096, Florida Statutes provides that: 

(1) A public lodging establishment shall: 

(a) Provide annual training regarding human trafficking awareness to employees of the establishment who perform housekeeping duties in the rental units or who work at the front desk or reception area where guests ordinarily check-in or checkout.·    Such training must also be provided for new employees within 60 days after they begin their employment in that role, or by January 1, 2021, whichever occurs later.·    Each employee must submit to the hiring establishment a signed and dated acknowledgment of having received the training, which the establishment must provide to the Department of Business and Professional Regulation upon request.·    The establishment may keep such acknowledgment electronically.

(b) By January 1, 2021, implement a procedure for the reporting of suspected human trafficking to the National Human Trafficking Hotline or to a local law enforcement agency.

(c) By January 1, 2021, post in a conspicuous location in the establishment which is accessible to employees a human trafficking public awareness sign at least 11 inches by 15 inches in size, printed in an easily legible font and in at least 32-point type, which states in English and Spanish and any other language predominantly spoken in that area which the department deems appropriate substantially the following: “If you or someone you know is being forced to engage in an activity and cannot leave, whether it is prostitution, housework, farm work, factory work, retail work, restaurant work, or any other activity, call the National Human Trafficking Resource Center at 888-373-7888 or text INFO or HELP to 233-733 to access help and services. Victims of slavery and human trafficking are protected under United States and Florida law.”

(2) The human trafficking awareness training required under paragraph (1)(a) must be submitted to and approved by the Department of Business and Professional Regulation must include all of the following:

(a) The definition of human trafficking and the difference between the two forms of human trafficking: sex trafficking and labor trafficking.

(b) Guidance specific to the public lodging sector concerning how to identify individuals who may be victims of human trafficking.

(c) Guidance concerning the role of the employees of a public lodging establishment in reporting and responding to suspected human trafficking.

(3) The division shall impose an administrative fine of $2,000 per day on a public lodging establishment that is not in compliance with this section and remit the fines to the direct-support organization established under s. 16.618, unless the division receives adequate written documentation from the public lodging establishment which provides assurance that each deficiency will be corrected within 90 days after the division provided the public lodging establishment with notice of its violation.

  • Some signs of a potential victim, according to YouCanStopHT, include: branding scars, burns or tattoos, serious dental issues, confusion, anxiety, and indications of physical abuse. Victims might allow someone to speak for them, respond as if coached or show reluctance to talk about their injuries. Attorney General Moody’s office encourages people to report suspicions to 911, local authorities or trafficking hotlines or to text HELP to BEFREE. The office of Miami-Dade State Attorney Katherine Fernandez Rundle operates a hotline for tips and reports about human trafficking: 305-FIX-STOP or 305-349-7867.
  • Authorities encourage all hospitality industry members to develop internal compliance policies and internal reporting policies for alerting law enforcement to suspected human trafficking activity. 

Know the Signs and if you SEE SOMETHING, SAY SOMETHING! 

Please contact us for any questions or concerns relating to implementing an awareness program.    

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The Author

Marbet Lewis

Marbet Lewis

Marbet Lewis has focused her practice on the laws governing the alcohol industry and the manufacture, importation, and sale of alcohol beverage products since 2004. She represents clients in all aspects of alcohol and business licensing in Florida including alcohol licensee mergers and acquisitions, negotiation of asset purchase agreements and required alcohol use provisions, license transfers and licensing due diligence, trade practices, alcohol product advertising and review of marketing agreements, importation agreements, label approvals, and regulatory compliance guidance. Her experience also includes enforcement action defense and administrative litigation, zoning and land use due diligence and approval processes, and state and local government regulatory compliance. She works with domestic and foreign suppliers, wholesalers and a broad range of retailers, including nightclubs, bars, movie theater operators, hotels, restaurants, supermarkets, bars, nightclubs, and pharmacy chains.

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