Anuja Chowdhury

Anuja Chowdhury

January 23, 2023 | New York Law Journal

Ninth Circuit Limits Extraterritorial Reach of Trafficking Victims Protection Act

The TVPA has been amended several times. Two relatively recent amendments provide a private right of action for victims under 18 U.S.C. §1595, as well as extraterritorial application to offenses taking place outside the United States under 18 U.S.C. §1596. The most recent circuit court to offer its reading of these provisions is the Ninth Circuit in 'Keo Ratha v. Phatthana Seafood Co., Ltd.'

By Samuel Estreicher and Anuja Chowdhury

9 minute read