Since 2019, the Illinois Lodging Services Human Trafficking Recognition Training Act (820 ILCS 95/, “the Act”) has required Illinois lodging establishments (such as hotels, motels, and casino hotels) to provide employees with training on how to recognize human trafficking and protocols for reporting suspected human trafficking to authorities.  Recent amendments, which became effective January 1, 2022, have ostensibly expanded the scope of covered employers to include other businesses that serve transient populations:  restaurants and truck stops.

While the legislative intent of the new requirement appears to be to ensure that workers at restaurants and truck stops, as well as hotels, motels, and casinos, are taught to spot and report signs of possible trafficking activity, the amendments leave some questions about the scope of the Act’s coverage. Even as amended, the statute’s plain language defines covered workers as persons “employed by a lodging establishment” who have “recurring interactions with the public.” It is unclear whether the new amendments extend the Act’s purview to stand-alone restaurants and truck stops whose employees are not employed by a lodging establishment.

The Illinois Department of Human Services (IDHS) has developed guidance, including downloadable model training materials, though employers are not required to use those specific materials. For full compliance, all human trafficking recognition training must be at least 20 minutes in duration and meet the following minimum content requirements:

  • A definition of human trafficking and commercial exploitation of children;
  • Guidance on how to identify individuals who are most at risk for human trafficking;
  • The difference between human trafficking for purposes of labor and for purposes of sex as the trafficking relates to lodging establishments; and
  • Guidance on the role of lodging establishment employees in reporting and responding to instances of human trafficking.

Covered employees must complete such training within six months of beginning employment and every two years thereafter.

The Act does not specify what the penalties are for covered employers who fail to compliance with the training requirement. However, the amendments to the Act include new language to Illinois’ criminal code, specifying that a company that receives anything of value from activities related to involuntary servitude, e.g., room rental income, service fees, or other sales, commits an offense that is punishable by a fine of up to $100,000.

It is clear that Illinois lodging establishments need to provide their customer-facing workers with training under this law. However, due to the ambiguity of the amendments as to Illinois employers operating restaurants and truck stops not affiliated with lodging, such employers should watch for additional guidance from IDHS, or even additional amendments to the law that may clarify which employers are covered.

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