Human Trafficking Liability Is No Longer Theoretical: TVPRA Exposure, Victim Remedies, and What Hotels Should Do Now

Human trafficking is no longer viewed solely as a criminal justice issue aimed at traffickers operating in the shadows. Increasingly, it is a corporate accountability issue, with significant legal, financial, and reputational consequences for businesses that knowingly, or recklessly, benefit from trafficking activity.

The Trafficking Victims Protection Reauthorization Act (“TVPRA”), first enacted in 2000, was designed to give the U.S. government powerful tools to combat sex trafficking and labor trafficking. Over time, and as a victim-centric approach has evolved, the statute has changed to provide victims an avenue to seek civil remedies from third parties, including corporations, franchisors, and property owners, whose conduct enabled or ignored trafficking activity.

The Government’s Message Is Clear: Follow the Money

Recent enforcement actions underscore the federal government’s aggressive posture. In December 2024, the Department of Justice announced a $215 million civil forfeiture settlement tied to the now-defunct Backpage.com. Prosecutors traced the forfeited assets to profits generated largely through prostitution advertisements that facilitated sex trafficking.

Importantly, DOJ did not stop at forfeiture. It established a formal remission process, allowing trafficking survivors whose exploitation was facilitated through Backpage advertisements to seek direct financial compensation from those seized funds. For victims, this represented more than symbolism; it was a concrete pathway to restitution.

The enforcement trend continues. In a joint DOJ–DHS press release issued earlier this month, federal leadership reaffirmed a heightened focus on trafficking investigations and prosecutions.  Attorney General Pam Bondi emphasized the administration’s commitment to expanding prosecutions and encouraging public reporting of trafficking activity. The announcement highlighted:

• Criminal convictions tied to trafficking networks
• A $15 billion civil forfeiture complaint involving forced labor
• The expansion of Joint Task Force Alpha, targeting transnational smuggling and trafficking organizations that threaten national security and public safety

The takeaway for businesses is unmistakable: human trafficking enforcement is accelerating, coordinated, and financially focused.

Civil Liability: Where Corporations Face Their Greatest Risk

Beyond criminal prosecutions and forfeiture, the TVPRA provides one of its most powerful tools in civil litigation. The statute allows trafficking victims to bring civil claims not only against direct perpetrators, but also against any person or entity that knowingly benefits from participation in a trafficking venture, where the defendant knew or should have known that trafficking was occurring.

This standard has placed the hotel and hospitality industry squarely in the crosshairs.

Victims increasingly allege that hotels financially benefited from room rentals used to facilitate trafficking, while ignoring, or failing to act on, clear indicators such as repeated cash payments, extended stays without luggage, excessive requests for linens, visible signs of abuse, or third-party control of guests. Courts have made clear that willful blindness is not a defense.

The financial exposure is no longer speculative. In 2025, a federal jury returned a $40 million verdict against the United Inn and its owners, marking the first civil jury verdict against a hotel under the TVPRA, and the largest civil trafficking award to date. That verdict has already reshaped how plaintiffs’ firms evaluate hospitality defendants and how insurers assess risk.

What This Means for Survivors — and for Hotels

For trafficking survivors, these developments matter. The TVPRA offers a pathway not only to justice, but to meaningful compensation from entities with real financial resources. Civil litigation has become a powerful tool to expose systemic failures, document patterns of indifference, and drive institutional change.

For hotels, franchisors, and hospitality companies, the message is equally stark: reactive compliance is no longer sufficient. Training modules that exist only on paper, or policies that are never enforced, will not withstand scrutiny from regulators, juries, or the public.

Why Internal Investigations Are No Longer Optional

Hospitality companies that identify potential trafficking indicators, or receive complaints from employees, guests, or law enforcement, must treat those reports as legal inflection points. A prompt, well-structured internal investigation can:

• Determine whether trafficking indicators were present and ignored
• Identify breakdowns in training, escalation, or supervision
• Preserve evidence before litigation or government inquiry arises
• Demonstrate good-faith efforts to prevent and remediate harm
• Mitigate civil exposure, punitive damages, and reputational fallout

Critically, internal investigations also serve a broader purpose: they protect people. When done correctly, they disrupt trafficking activity, safeguard vulnerable individuals, and reinforce a culture where employee reporting is taken seriously.

前进之路

Hotels and hospitality franchisors should take immediate steps to reassess their TVPRA exposure by:

• Implementing robust, victim-centered policies tailored to real-world risk scenarios
• Conducting meaningful, recurring employee training that goes beyond box-checking
• Establishing clear escalation and reporting mechanisms
• Auditing prior incidents, complaints, and law-enforcement interactions
• Engaging experienced counsel to conduct privileged internal investigations when red flags arise

The era of plausible deniability is over. Under the TVPRA, inaction can itself become evidence.