Human trafficking is a highly profitable crime that generates an estimated $150 billion per year worldwide. A significant portion of these profits may be laundered through legitimate businesses to conceal the original source of the money.
Investigators can follow the financial evidence trail to identify money laundering, fraud, and human trafficking and collect reliable evidence that can be used to hold perpetrators accountable. In the United States, federal laws, like the Bank Secrecy Act and the USA PATRIOT Act, have led to the creation of robust systems for financial institutions to monitor and report suspected illegal activity associated with human trafficking and other financial crimes. Using these laws to conduct financial investigations can help police and prosecutors detect and disrupt human trafficking.
In human trafficking cases, it is common to see the use of multiple bank accounts and credit cards under multiple identities and addresses; front companies, false identity documents, or straw purchasers (a person who makes a purchase on behalf of another person); cash to invest in real estate or high value goods; frequent money transfers to “risk” countries; third-party cash deposits made at various bank branches and ATMs; and frequent deposits or withdrawals with no apparent business source. All of these are potential indicators of trafficking, but this is not an inclusive list; traffickers may change tactics and find new ways to conceal profits so that they can continue to traffic victims and collect ill-gotten gains.
| NW3C, in partnership with the IACP, the National Association of School Resource Officers, and OVC, developed a curriculum designed to educate high school students on identifying and preventing human trafficking called TraffickSTOP (Signs to Observe and Prevent). The program is available now at www.traffickingstop.org. |
When financial institutions report suspicious activity and police launch financial crime investigations, human trafficking cases can be fortified and expanded. Financial investigations bolster criminal prosecutions by corroborating victim testimony or eliminating the need for testimony entirely. In addition, many financial crimes carry more severe punishments than human trafficking. Financial crime investigations can be conducted simultaneously with sex trafficking or labor trafficking investigations to help identify victims and co-conspirators; provide further intelligence and investigative leads; clarify the force, fear, or coercion elements of human trafficking; and seize assets to use toward restitution for victims. Conducting financial investigations as part of a human trafficking case can reveal the root cause of illegal activity and therefore disrupt and dismantle criminal organizations; demonstrate defendants’ motives for the behavior; show knowledge and consciousness of guilt; and refute defendants’ arguments and criminal defenses that they may try to use to avoid criminal liability.
The International Association of Chiefs of Police (IACP), in collaboration with the National White Collar Crime Center (NW3C) and the Office for Victims of Crime (OVC), will release, in June 2024, Financial Crime and Human Trafficking, a free, online, self-paced training on the intersection of financial crime and human trafficking. This training highlights how financial investigations can reinforce human trafficking cases and assist with prosecuting offenders at the local, state, and federal levels. By the end of this training, participants will be better able to
-
- understand intersections between human trafficking and financial crime;
- integrate financial investigations into human trafficking investigations;
- explain how the FinCEN and the Bank Secrecy Act can be useful investigatory tools;
- identify financial crimes that can be used to prosecute criminal networks;
- name various methods used to launder money;
- gather evidence that can be used to prosecute financial crimes;
- frame investigations to prove illicit intent in business practices;
- describe various financial indicators of human trafficking; and
- comprehend how asset forfeiture and restitution are important for recovery.
This resource was created in consultation with subject matter experts who have experience investigating and prosecuting human trafficking and financial crime cases, as well as lived experience and backgrounds in victim advocacy. The training was developed for human trafficking investigators, but any police, prosecutor, or criminal justice professional may use the training to enhance their knowledge and skills on financial investigations and human trafficking.
