ATEST Asks USAID to Postpone C-TIP Policy Rewrite to Allow for Thorough Stakeholder Engagement and Adequate Public Comment Period



Mr. John Barsa, Acting Deputy Administrator,  US Agency for International Development (USAID) | Via Email: [email protected]

Mr. Max Primorac, Deputy to Acting Deputy Administrator, USAID | Via Email: [email protected]

Mr. Chris Milligan, USAID Counselor | Via Email: [email protected]


December 14, 2020


Dear Mr. Barsa, Mr. Primorac, and Mr. Milligan,

We are writing to you today as a coalition of U.S.-based non-governmental organizations (NGOs) to urge you to develop a more comprehensive and holistic engagement plan in the development of the updated USAID Counter-Trafficking in Persons (C-TIP) policy. We are deeply concerned that USAID did not engage in necessary stakeholder consultations prior to the release of the draft policy and is now providing only five (5) days for public comment. This limited review period, scheduled when many Americans are planning to take year-end/holiday leave, does not meet USAID’s principles of partnership and will result in a less comprehensive, effective policy.

The Alliance to End Slavery and Trafficking (ATEST) is a leading U.S.-based coalition that advocates for solutions to prevent and end all forms of human trafficking and forced labor around the world. We promote lasting solutions to prevent forced labor and sex trafficking, hold perpetrators accountable, ensure justice for victims and empower survivors with tools for recovery. Our collective experience implementing programs at home and abroad gives us an unparalleled breadth and depth of expertise. ATEST members also engage with partners and stakeholders from countries in every region of the world. We urge you to delay the planned January launch date for the updated policy to provide stakeholders like ATEST adequate time to review the draft and provide meaningful feedback.

The ATEST coalition believes foreign assistance is a pivotal and underutilized avenue for U.S. government impact on preventing and ending human trafficking overseas and protecting and supporting victims of this crime. Effective integration of a robust USAID C-TIP policy and concrete C-TIP activities across the range of assistance programs is critical, with a particular focus on programs directed at the promotion of governance and democracy, economic development, public health and humanitarian response. ATEST has consistently advocated to Congress for resources and support for USAID C-TIP Integration initiatives in foreign assistance.

We see the effective integration of a robust C-TIP Policy across the range of assistance programs, issue areas, Bureaus and Missions to be of critical importance. Such integration can a) ensure that foreign assistance efforts do not inadvertently leave vulnerable community members behind, or even increase their vulnerability; b) generate new avenues and opportunities to maximize the impact on trafficking issues of U.S. interventions, budgetary investment and activities, and enhance the impact of existing interventions; and c) help reinforce and support broader development objectives. Foreign assistance programs relating to humanitarian assistance, food security, poverty reduction, social and economic growth and development, education, gender-based violence, and democracy and governance contribute to decreasing vulnerability to or prevalence of forced labor and other forms of human trafficking.

Given the crucial role of the USAID C-TIP policy, we urge you to  implement a more thoughtful and participatory process for stakeholder input that includes a series of consultations with diverse stakeholders (including USAID implementers and leading anti-trafficking, human rights and development organizations with expertise in these areas). We request that you delay the launch of the policy by three months. We also ask that you extend the time for the public comment period on the draft policy until January 30, 2021. A participatory process must provide sufficient time for all stakeholders to review and comment on a draft policy. We appreciate your consideration of our request and look forward to hearing from you.


The Alliance to End Slavery and Trafficking

Contact:  ATEST Steering Committee Co-Chairs


Ms. Anita Teekah, [email protected]

Mr. Terry FitzPatrick, [email protected]


ATEST member organizations include: Coalition to Abolish Slavery & Trafficking (CAST), Coalition of Immokalee Workers (CIW), Free the Slaves, HEAL Trafficking, Human Trafficking Institute, Humanity United Action (HUA), McCain Institute for International Leadership, National Network for Youth (NN4Y), Polaris, Safe Horizon, Solidarity Center, T’ruah: The Rabbinic Call for Human Rights, United Way Worldwide, Verité and Vital Voices Global Partnership.



Ms. Michelle Bekkering, Assistant Administrator of the Bureau for Development, Democracy and Innovation (DDI), [email protected]

The Honorable Senator James E. Risch, Chairman, Senate Foreign Relations Committee (c/o [email protected]  and [email protected])

The Honorable Senator Bob Menendez, Ranking Member, Senate Foreign Relations Committee (c/o [email protected], [email protected], and [email protected])

The Honorable Representative Eliot Engel, Chairman, House Foreign Affairs Committee (c/o [email protected], [email protected] and [email protected])

The Honorable Representative Michael McCaul, Ranking Member, House Foreign Affairs Committee (c/o [email protected])


Downloadable .pdf here.