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SHRM and its affiliate, the Council for Global Immigration (CFGI), submitted comments in response to a proposed definition of "recruitment fees" that federal contractors would be prohibited from charging their employees. Our comments note that the current approach taken by the Federal Acquisition Regulatory (FAR) Council merely attempts to list all activities which could potentially be related to human trafficking but ignores the key element of whether the employer intends to defraud or deceive the employee.
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