White Paper Offers Guidance to Financial Institutions, Law Enforcement Agencies in Identifying Financial Transactions Linked to Human Trafficking
Manhattan District Attorney Cyrus R. Vance, Jr., and Monique Villa, CEO of the Thomson Reuters Foundation, today issued international guidance aimed at helping the wider industry to identify and report irregularities in financial transactions that might be linked to human trafficking activity. The document is the product of a unique collaboration with some of the world’s leading financial institutions, and is the key outcome of the financial working group initiated last year on 25 April by DA Vance and Ms. Villa.
The group liaised closely with leading non-governmental organizations working with human trafficking survivors to understand the financial behavior of human traffickers and the types of transactions that may be linked to trafficking. The paper contains investigative guidance and identifies customer and transaction traits that may indicate a higher risk for human trafficking. The paper is being widely distributed to top financial institutions and law enforcement agencies, both in the U.S. and internationally, with the aim of assisting the financial industry in its efforts to identify and expose human traffickers.
“Prosecutors need every available tool in the fight against this terrible crime, and financial forensics are amongst the strongest in our arsenal,” said District Attorney Vance. “Human trafficking, at its core, is a business. Like other businesses, it leaves a financial paper trail that can be tracked and used to identify trafficking networks. With the help of banks and other financial institutions, my Office has been able to secure convictions against traffickers without having to rely solely on the testimony of victims who often suffer emotional, physical, or sexual abuse. These institutions can flag suspicious activity and transactions that may assist in identifying a trafficker who otherwise would have gone undetected. Human trafficking is not a problem that law enforcement can tackle alone. It requires the close collaboration with many concerned groups looking at this crime through different lenses. I am thankful to the financial institutions that have worked with us to identify new ways to combat trafficking. I also thank our partners at the Thomson Reuters Foundation for helping bring us all to the table.”
The list of financial behaviors identified in the document includes: regular transfer of funds from the employees’ accounts back to the employers (indicative of labor trafficking), recurrent business transactions taking place outside the time of known business operations, cross-border transfers of funds that are inconsistent with the stated business purpose of the financial institution’s customer, and a high number of individual accounts opened and closed simultaneously. The document also identifies a number of industries whose workers are more easily exploited by traffickers.
While estimates of human trafficking vary widely from country-to-country and even state-to-state, there is consensus that this crime is on the rise. The International Labour Organisation estimates that there are 20.9 million men, women and children held in forced labor and servitude around the world, generating as much as $32 billion. The most recent U.S. Federal statistics also suggest that as many as 14,000 foreign nationals are trafficked into the U.S. each year, and thousands of youth born in the United States are at risk for trafficking into the commercial sex industry.
The Thomson Reuters Foundation, which has launched and co-hosted the initiative with the Manhattan District Attorney’s Office, will replicate the efforts in Europe and Asia, working with top financial firms, leading anti-trafficking NGOs and international prosecutors.
“Data is the ultimate tool in the global fight against human trafficking. If you follow the data, you can get to the criminal organizations behind it. In this day and age, any attempt to take on human trafficking successfully must include concerted efforts among financial institutions, prosecutors and NGOs active in the field,” said Monique Villa, CEO of the Thomson Reuters Foundation. “The response to this initiative has been tremendous, with a number of leading European and Asian financial corporations expressing strong interest in joining the group. The efforts implemented by DA Vance to effectively tackle the trafficking business, and the remarkable cooperation among financial institutions to work together to produce this document are both outstanding and potentially scalable. We are now taking the know-how of this working group to Europe and Asia, replicating the exact model successfully adopted in the U.S.”
Representatives from the following corporations and foundations participated in the working group, organized by the Thomson Reuters Foundation and the Manhattan District Attorney.
Bank of America
Human Trafficking Pro Bono Legal Center
JPMorgan Chase & Co.
Theodore S. Greenberg
About the Manhattan District Attorney’s Office’s Human Trafficking Program
In March 2012, District Attorney Vance created the Human Trafficking Program within the Office’s Special Victims Bureau to investigate and prosecute sex and labor trafficking cases, better identify trafficking victims, provide greater support for victims and their families in partnership with those in the victims’ advocate community, and educate law enforcement and the public about trafficking and related issues through community outreach, workshops, and seminars. The Program also works to identify cases that may involve elements of trafficking from hundreds of street arrests that come in through other areas of the Office.
Additionally, prosecutors specialized in human trafficking are also cross-trained in white-collar investigations in order to identify suspicious financial activity linked to these types of crimes. For example, on December 16, 2013, the Manhattan DA’s Office secured a Sex Trafficking and Promoting Prostitution conviction against defendant Taye Elleby in part through the introduction of financial evidence at trial. Elleby was a brutal pimp who frequently posted ads on Backpage.com, advertising his victims and the sex acts they would perform. Prosecutors were able to trace information contained in the ads back to the defendant’s financial records, connecting Elleby to the advertisements for his 17-year-old victim.
District Attorney Vance strongly encourages victims of sex and labor trafficking to call the Office’s Human Trafficking Hotline at (212) 335-3400, regardless of immigration status.
About the Thomson Reuters Foundation
Established in 1983, the Thomson Reuters Foundation leverages the skills, values and expertise of Thomson Reuters to run a number of programs that trigger change and empower people across the world: free legal assistance, media development, and in-depth coverage of the world’s under-reported stories. The Foundation stands for human rights, women’s empowerment, anti-corruption and for the rule of law.
Last December, the Thomson Reuters Foundation and the International New York Times hosted in London the second annual Trust Women Conference, bringing together business, government and civil society leaders, sparking concrete commitments to action to help women defend their rights. The financial working group against human trafficking represents one of the key outcomes of the Trust Women Conference. Other actions resulting from the event and related to the same issue include: the development of tools to map supply chain risks and to raise alerts accordingly, the creation of a global human trafficking hotline and the set up of a portal to record and archive stories of trafficking survivors.
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