“Enter the light of your own will, or be dragged to it.”

This past week I had the pleasure of taking the AML (anti-money laundering) course at ACAMS (an accrediting body for AML professionals). While exploring the site I discovered a Human Trafficking section, I’ve decided to share a select piece here. As I’ve mentioned before the key to breaking networks is data and the financial industry is ripe with data.

“In its 2014 Trafficking in Persons (TIP) Report, the department highlighted efforts by the Financial Crimes Enforcement Network (FinCEN), New York investigators and eight financial institutions to better identify transactional red flags linked to the crime, including unusual cross-border transfers and simultaneous openings and closings of accounts.

The financial institutions—Bank of America, American Express, Barclays, Citigroup, JPMorgan Chase & Co., TD Bank, Wells Fargo and Western Union— spoke with representatives of the Manhattan District Attorney’s Office in an April 2013 roundtable on identifying human traffickers.

“I don’t see bankers as people with money, but as people with data,” said Martina Vandenberg, founder and president of The Human Trafficking Pro Bono Legal Center, in a statement on the roundtable. “We have never before bridged this idea of financial crime and human trafficking. Bringing these two worlds together will increase the number of trafficking prosecutions in the United States and around the world.”

That trend should only strengthen, said Louise Shelley, director of the Terrorism, Transnational Crime and Corruption Center at George Mason University and author of Dirty Entanglements: Corruption, Crime and Terrorism.

“Many more banks should be mining their data and working with law enforcement to find patterns of human trafficking,” said Shelley. “There would be many more cases [if they did].”

…“We started to approach the financial institutions and educate them as to what we’re seeing,” said Stephenie Lord Eisert, chief of the Illicit Finance and Proceeds of Crime Unit at HSI. The effort has contributed to approximately 100 arrests and the seizure of some $14 million, she said.

Some banks have also adopted new compliance measures that can thwart human traffickers. In March, JPMorgan Chase instituted a new policy that prohibits cash deposits unless the depositor’s signature is on the account.”

Excerpt from Growing Role of Banks in Identifying Human Traffickers Seen as Crucial by U.S. Officials

By Kira Zalan, readable in full here

Please check out the main ACAMS page on the issue here. If you are interested in learning more about ACAMS or money laundering, there are free webinars available to non-members on their page.

It’s great to read also that major banks are taking steps further than those required by law to try and detect these suspicious networks. The financial industry is really in a great place to do work against organized crime because at some point or another the money feeds into the financial system. Identifying it allows for seizure and arrests of attached parties. It’s also great to discover an organization like ACAMS is taking the time to make sure trafficking awareness is part of their community. Members of ACAMS after all are the AML compliance officers (not all compliance officers are members of ACAMS but it is common) that do the reviews of suspect transactions and accounts. I couldn’t find an exact number member wise on their website, by Wikipedia is saying it was over ten thousand worldwide in 2009. That’s ten thousand financial professionals seeing this issue raised in newsletters, on the webpage, and the community forums.

“Enter the light of your own will, or be dragged to it.”

This is a quote from the game Skyrim. I think it’s actually referring to the hunt of vampires but that’s pretty off topic and I love the quote. Human trafficking is an industry that thrives in the darkness but we can bring light to the issue. Expose it and end it.

Cell Networks/Can you hear me now/Samuel Adams

It’s interesting how the popularity of the term “sleeper cell” drastically increased the public awareness of cell structure networks. Yet the vast majority of people really don’t know how these networks function or understand why on earth it is so hard for us to bring them down. This is really true in human trafficking and drug trafficking cases, international cell networks are very hard to beat. Let’s go over some reasons.

First of all cell networks are not the Mafia style networks. There is usually no “don” running the show. Cell networks are loosely affiliated groups and typically there is no boss overseeing the entire network. The cells work together for mutual benefit and don’t require a mutual leader to accomplish their goals.

The interesting thing about these cells is they are usually totally unaware of any members of the cells they do direct business with. Let’s say Cell A produces a product, cell B ships the product, and cell C sells the product on arrival. In cell networks, Cell A and Cell C have no direct contact, neither cell knows any members of the other cell. In all three cells there is probably a single person that interacts with the cell they directly contact. One person in Cell A knows one person in Cell B. In cell B one person knows one person in cell C and so on. This highly insulated structure allows cell networks to survive if a single cell is targeted by law enforcement and removed. Let’s say cell c is operating out of Houston Texas and is brought down by a law enforcement raid. When law enforcement questions that cell there is literally only one person who actually has information to give them regarding the network and that person can at the very best reveal the name of one other individual (who would likely be dead or moved by the other cell at this point). This makes gathering intelligence on these networks extremely difficult because to bring down the entire network, you have to map the entire network without arresting or revealing yourself to any part of the network.

Here is a simple graph:

network

Replacement cells. This comes into play really heavily in international cells. Let’s stick with the above scenario and say Houston/cell c is compromised. Our international network simply replaces cell c with a new cell in a new city. The tragic reality is, there is no shortage of arms/drug dealing gangs in cities all across the world. These gangs readily accept the new income from trafficking and already have the necessary precautions to protect shipments, buy off law enforcement, and move products in place.  Even when a cell that is actually selling people is brought down it is replaced quickly and the other cells in the network likely will not have even been aware of the momentary market loss. Complicating this issue is that the cells that law enforcement are usually able to uncover are the end cells, the ones selling the victims/products. In human trafficking, it is very hard to catch the cells that transport victims. This is because people can hide in plain sight, it’s not like an illicit drug or a weapon that immediately raises red flags. You can walk right past a transported human and not be aware there is anything wrong.

In all aspects of hunting cell networks jurisdiction between law enforcement agencies becomes a huge problem. If cell A exists in Africa, cell B is an international crew from Europe running victims in a cargo ship, and cell c is in Houston. How do cops from Houston stop Cell A even if they retrieve intelligence on Cell A? Then you’re looking at Interpol, Europol, The United Nations Office on Drugs and Crime, local authorities in Africa as well as national law enforcement in the United States that can arrange the sharing of intelligence and resources with the above groups. Mostly you’re looking at your cells being long gone before appropriate international action can take place because you have had to involve dozen of agencies and many people have had the opportunity to leak information. What about cells operating state side? It’s the same issue really. If cell A is in Kentucky then the cops from Houston who brought down cell C still can’t address Cell A because they do not have the jurisdiction to do so.

What I am getting at is that fighting cell networks is hard. They thrive without structure, recover easy, and individual cells often have no useful information to lead back to the other cells. Though it can be controversial an emerging trend is to observe the cells and try to bring down multiple cells in simultaneous raids (this has also been done for the more structured mafia networks with simultaneous raids in Sicily and the United States). Controversial because this involves knowing a cell is operating and not stopping it until the information on the other cells is in place. Though operations of that scale are usually left at the federal level.

To expose it is to kill it.

It does not take a majority to prevail… but rather an irate, tireless minority, keen on setting brushfires of freedom in the minds of men.

Samuel Adams