What do financial institutions have to do with human trafficking? Well, financial institutions have an obligation to file suspicious activity reports (SARs) on a range of suspicious transactions. Historically, these reports have been primarily focused on anti-money laundering and combating the financing of terrorism (AML/CFT) activity through SARs. However, the list of reportable suspicious activities has evolved over time and now covers many other financial crimes, including human trafficking and human smuggling, both of which violate federal and international laws.
What is Human Trafficking?
Many people probably remember popular movies and television shows depicting pimps as dressing flashy and driving large fancy cars. More importantly, the women— adults— consensually and voluntarily engaged in the business of prostitution without complaint. This characterization is extremely inaccurate, nothing more than fiction.
In reality, the pimp traffics young women (and sometimes men) completely against their will by force or threat of force; this is human sex trafficking.
Human Trafficking is one of the most mysterious crimes that has ever existed! How can a human being allow herself to be “trafficked?” How can they not know they are being trafficked? Well, first of all, it happens slowly, and in stages. Every Human Trafficking case involves three elements.
- GREEDY TRAFFICKER: A person driven by greed and control,
- DESPERATE HUMAN BEING: A person in search of money, a better life, a nicer family, a bigger house, a desire to go to school, etc,
- SHAME/GUILT: Once the victim realizes that s/he was trapped, lied to, and believes they have bought horrible shame to his/her family, they will not come forward and will not ask for help.
There are vital steps a trafficker must take. Breaking the human spirit requires a methodical and deeply psychological approach. The method has developed over a long period of time, possibly for hundreds of years.
Two Types of Human Trafficking
Not only is human sex trafficking slavery, but it is also big business. It is the fastest-growing business of organized crime and the third-largest criminal enterprise in the world. The majority of sex trafficking is international however, sex trafficking also occurs domestically. The United States not only faces an influx of international victims but also has its own homegrown problem of interstate sex trafficking of minors.
Human Trafficking is a ghost crime, designed to be hidden from the public. Victims don’t walk around in chains and traffickers don’t always look like criminals.
What does this have to do with financial institutions?
Financial institutions and compliance teams have an obligation to report suspicious activity, including human trafficking. Here are a few ways you and your staff can help combat human trafficking.
Compliance Responsibility & Resources
A variety of responsibilities fall under compliance professionals including addressing investigations and issues that come up. Since compliance professionals can be pulled in many different directions, its critical that teams have access to the necessary resources to examine and take appropriate reporting action.
Provide Training
You can combat human trafficking by providing training to your entire staff, from the front line to the board room. Assign training that focuses on human trafficking risks and red flags. These training courses can be incorporated within your overall AML training framework.
As a proud education partner of Timea Nagy, Internationally known Survivor of Human Trafficking, OnCourse Learning provides over 38 courses that cover BSA/AML case studies. You can check them out here. Contact a sales rep to explore adding these to your training program.
Watch financial transactions
Financial transactions can show very clear signs and evidence that would be extremely important to provide for court. Financial transactions can provide a clear picture of their lifestyle, their route, and their trends; sometimes you can even connect them to other victims. Transactions are like a map of their operation.
Remain Diligent
Stay vigilant by scrutinizing information and doing due diligence during onboard. Financial institutions can conduct ongoing monitoring and periodic reviews to identify unusual or suspicious trends.
Financial institutions have a responsibility to report suspicious activity and behaviors. By properly educating your staff, you can help combat human trafficking.
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