Human trafficking is in the news more and more. When it is mentioned, many have a picture in their minds of Asian women working in nail salons. However, this stereotyping of human trafficking is deadly as it blinds people to the trafficking that occurs in their own local community and the ill-gotten monies that may be passing through their bank unnoticed. After learning of a community bank in the Mid-Atlantic region with an obvious sex trafficking case and performing research on the topic of human trafficking myself, I was shocked at what I learned.
Trafficking involves various forms including trafficking of organs, trafficking of people for forced labor, child soldiering, trafficking in women, girls and boys for sexual exploitation, and commercial sexual exploitation of children in tourism. This is not just in isolated locations but is happening on a global scale. Here in the U.S., we have various forms of trafficking, but sex trafficking is the focus of this article as it threatens even your children and grandchildren.
Sex trafficking can be found in every community of America and affects American boys and girls as young as 11. These children come from good homes, while others are runaways and foster children. Traffickers actually search for children on Facebook and in places that children frequent such as malls, after school events, bowling alleys, movie theatres, and foster homes. The traffickers are highly trained in how to lure children into a relationship of trust and friendship that eventually snares them into trafficking. Three hundred thousand American children are in danger of being sexually trafficked each year. This could be your child or grandchild and you might not know until it is too late.
Globally, the monies involved in this heinous crime are estimated at $150 Billion based on a 2012 report.[1] Compare this to the global sports market in 2015, which generated about $145 Billion[2] and you see the staggering amount of money flowing through financial institutions. Is it any wonder that monies from this crime can flow through your bank? There are red flags issued by FinCEN and other sources, but red flags are often indicative of multiple crimes. So how can you identify monies tied to sex trafficking flowing through your bank?
Here are some red flags taken mainly from an actual situation in a community bank. The bank had two cleaning companies open accounts. The cleaning companies were not doing any transactions such as purchasing cleaning supplies that would indicate they were actually providing cleaning services. They did numerous other things as seen in the red flags below that indicated sex trafficking. Of course, some of these red flags could also be indicative of other types of abuse.
Red Flags for Tellers and Branch Personnel
- Round dollar payroll checks being cashed by ladies scantily dressed and accompanied by a man
- The same ladies presenting foreign ID cards including international drivers’ licenses and valid passports with no visa or an expired visa, or even a student ID
- Evidence of being controlled
- Bruises or other signs of physical abuse
- Fear or depression
- Not speaking on his/her own behalf and/or non-English speaking
- Having another “handler” answering questions, holding ID, and governing the person cashing a check
- Note: The “handler” may not be at the teller window but may be in the lobby observing (as a driver, friend, etc.) or in the parking lot.
Red Flags for Account Opening Personnel
Red Flags for BSA/AML Personnel
General
- Rent payments for multiple locations within apartment complexes
- Rent payments made by unrelated business types (example: a cleaning business paying rent for several apartments)
- Multiple telephone carrier payments (traffickers must use different phone numbers on advertising sites, so they open accounts with multiple carriers and have multiple phone numbers)
- New businesses making tons of money overnight
- Round dollar payroll checks being cashed
- ACH credits received from an international trading site for imports/exports
- Wires and/or frequent travel to countries known as human trafficking hot spots such as: Mauritania, India, Syria, Uzbekistan, Pakistan, Central African Republic, Haiti, Democratic Republic of the Congo, Republic of the Congo, Qatar, Sudan, United Arab Emirates
- From an airline and/or moving company
- For rent payments for related things involving trafficking such as gas, beer/liquor, restaurants, casinos, a gentleman’s club, etc.
- Occurring in various cities over a short period of time such as a month
Check Card Debits
Prepaid and Credit Cards
- Multiple expenditures on websites like the ones listed below and followed by hotel spending
- Websites such as
- Bedpage.com
- Mobileposting.com
- Jeboom.com
- Easypost123.com
- Postfastr.com
- Cracker.com
- Fastadboard.com
- Rubmaps.com
- EroticMonkey.ch
- Eros.com
- Switter (like Twitter for sex)
- Slicksa
- Classifiedbundle.com = way to advertise on multiple platforms at one time
- Multiple payments for internet ad sites – Escort ads posted online do not obviously state that sex with children is being sold, so code words are used such as: “hobbyists” which means buyers.
- Travel out of state and multiple hotel expenses
Another resource that provides many other red flags comes directly from FinCEN. On 10/15/2021, FinCEN issued FIN-2020-a008, a “Supplemental Advisory on Identifying and Reporting Human Trafficking and Related Activity.” That advisory discusses front companies, exploitive employment practices, funnel accounts and alternative payment methods.[3]
As financial investigators, it is our desire to stop all types of crime in our institutions. As we gain expertise to do our jobs effectively, we gain valuable insights that not only benefit our institution, but help to protect ourselves, our families and our children. That is definitely true in the area of human trafficking. Share your knowledge with your family to protect your children and grandchildren. Share it with friends, your schools, and communities. Warn them of the dangers lurking in so many places especially online. Back in 2019, the police issued a warning of 15 apps that target your children in this article: https://www.audacy.com/kmox/articles/15-apps-predators-use-target-children Spread the word!
If you are interested in learning more about human trafficking, there is a wealth of information available. You could conduct a Google search for resources and information on your community and the local groups involved in fighting this crime. You will also find human trafficking cases in your area.
ACAMS published my white paper several years ago entitled “Human Trafficking Monies in the Community Banks”, which gives details of the case study I referenced in this article and an expanded picture of human trafficking. You can find a link to that here: http://www.acams.org/aml-resources/aml-white-papers-surveys/
You can also visit these web pages and find many others with the same message:
- The Blue Campaign: http://www.dhs.gov/blue-campaign
- Shared Hope International (founded by former Congresswoman, Linda Smith) – http://sharedhope.org/
- Polaris Anti-trafficking website – http://www.polarisproject.org/
- National Human Trafficking Resource Center (NHTRC) – Information by state: http://www.traffickingresourcecenter.org/states
Please get involved in some way to stop this heinous crime. Together, we can make a difference!
[1] ILO Says Forced Labour Generates Annual Profits of US$ 150 Billion. (n.d.). Retrieved November 5, 2015, from http://www.ilo.org/global/about-the-ilo/newsroom/news/WCMS_243201/lang–en/index.htm, (5/20/14)
[2] Global Sports Market – Total Revenue From 2006 to 2015 (in billions U.S. dollars)*. (2014). Retrieved November 5, 2015, from http://www.statista.com/statistics/194122/sporting-event-gate-revenue-worldwide-by-region-since-2004/
[3]https://www.fincen.gov/sites/default/files/advisory/2020-10-15/Advisory%20Human%20Trafficking%20508%20FINAL_0.pdf
