Who bears primary responsibility for CTIP compliance in a federal contract?

• A. The prime contractor bears primary responsibility; the contracting officer ensures compliance and flow-down to subs.
• B. The subcontractor bears primary responsibility.
• C. The contracting officer bears sole responsibility.
• D. The government agencies.

Answer: (A)

In federal contracts, the prime contractor has the central responsibility for CTIP compliance. This means they must implement and maintain a compliant anti-trafficking program, provide required training, conduct due diligence, and actively monitor and address trafficking risks within their own operations and in their supply chain. The prime is also the one who must flow the CTIP requirements down to subcontractors, ensuring they understand and meet the same obligations. The contracting officer represents the government and ensures these requirements are properly included in the contract, oversees enforcement, reviews reports and certifications, and can take corrective actions if noncompliance is found. Subcontractors must comply because of the flow-down, but the day-to-day responsibility for the CTIP program lies with the prime contractor.