“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

Reflections/T-Visas/Thanks in dark times

Be humble

Its thanksgiving in half an hour –probably will be by the time this publishes- and I am left with a swirling pool of thoughts. On the one hand this week has marked multiple school shootings, riots, and sewn racial divide in my own country. Something I don’t want to see. I believe in progress and mistakes will always be made its how we respond that matters. On the other hand it’s hard to be thankful and enjoy this holiday season knowing the toll it will take on millions of people living in slavery, poverty, and war torn refugee societies.
Don’t get me wrong. I have a lot to be thankful for. My life is in all reality at the best point it has been in years. Work is going exceptional and I’ve scheduled the last of the classes for degree number two to graduate this coming summer. I remind myself daily of the words of St Augustine.

quote-find-out-how-much-god-has-given-you-and-from-it-take-what-you-need-the-remainder-is-needed-by-saint-augustine-8590

So what I am thankful for today, is my country. Problems aside, we make strides daily. Let’s talk T-visa. The T-visa is an interesting piece of legislation. One of the problems with trafficking cases is that the victims are often no longer in the country when it comes time to prosecute the traffickers. This is interestingly, a problem that occurs worldwide (and in some of the lower tier countries actively deporting victims for the sake of stopping trials does occur). The T-visa is a two pronged idea. It grants victims a visa to stay in the country. Not just the victims though, victims often have families in another countries. Many of them get sucked into trafficking by willingly immigrating thinking they can send money back home. Instead they become slaves who daily hear their families threatened. The T-visa allows for the family members to come into the countries as well. They just have to make it to a US Embassy in their home country. The other side of the T-Visa? It requires that victims take the stand against their captors and traffickers. Now, personally I would be a fan of losing the second requirement. I understand it though. Trafficking cases are hard to prosecute as it is and without victims it’s near impossible. The T-visa was sort of a first of its kind effort. A government truly taking measure to aid the people who had fallen victim within its borders.
Now it is not without its problems. The law allows for Five Thousand T-Visas to be issued yearly. In its history since it was passed through congress in 2001, it has not been issued to five thousand people in a year. In fiscal year 2012-2013 including victims and family members it was issued to less than two thousand people. In total from 2002-2012, including family members, less than 5 thousand visas have been approved. –That’s less than the amount allowed per year-
Why is this the situation? In many cases because trafficking victims are terrified of law enforcement and terrified of their traffickers. Some don’t talk out of fear the traffickers will make good on all the threats they’ve been making to the victims. Other victims don’t speak because they’re afraid police will charge them with criminal offenses (another bit of fear instilled by traffickers). Some victims are afraid the law enforcement might be working for their traffickers, which is most regrettably true in some circumstances. You also have to consider that some of them just want to leave their victimization behind. The atrocities, the torture, and the shame. Psychologically many just can’t stand to face their captors again.
All of that said, the T-Visa is a beautiful piece of legislation. It was an attempt, progress, a step forward and for the most part we seem to be on an upward trend of approvals.
If you’re interested in learning more about the T-Visa please look here and here for official gov webpages.
Stay Tuned to the blog currently planned: Organ Trafficking and a discussion on how trafficking cells actually function.

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The Tips Report/Hate Evil and Love what is good.

One of the things people don’t always understand about the trafficking field (and other international criminal enterprises) is how they got so out of control. A huge part of that reason is that the ability to move people from place to place exploded in the 1990s as international travel and communication exploded. The internet alone has proven to be a huge game changer in trafficking as websites operating in the “dark net” routinely sell trafficking victims. With elements of these criminal enterprises being so new, it takes time for law enforcement and governments to establish the effective protocols for dealing with the situations. In many ways, the United States has led the fight World Wide in establishing laws to fight trafficking. I’m going to use this time to talk about some of the important laws that have come about in the US as a result of trafficking. The program with the longest reach is the Trafficking in Persons Report, commonly referred to as the tips report. Though you could spend countless hours examining the tips report and its effectiveness…we’ll just go with a brief intro.

The Tips report first began in 2001 (check out the 2014 report intro here and country rankings on page 58). The report was a requirement of a congressional passed law the Victims of Trafficking and Violence Protection Act of the year 2000. Tips examines key elements of trafficking in individual Countries and ranks them into three tiers (read as categories, and really there is 4 but two of them are considered as the same tier). So what are the three tiers?

Tier I: Countries are fully compliant with TVPA (Trafficking Victims Protection Act) standards.

Tier 2: Countries that are making progress to become compliant with the TVPA

Tier 2.5(tier 2 watch list): Countries that are not meeting tier 1 requirements and are failing to supply compelling evidence for increased efforts usually while also having an increase in the amount of trafficking going on in the country. This is also common if the country is making pledges for improvement. –Countries that remain on this list for two years and would be placed on it a third time are automatically dropped to tier 3.

Tier 3: Countries are not TVPA compliant and are making no significant efforts to become compliant.

The motivation for countries to become compliant is monetary. Countries in the tier 3 category are ineligible for non-humanitarian and trade related funds. This also means the United States will vote against loans from the World Bank for these countries.

So what are the TVPA minimum standards? Well essentially this:

Trafficking Victims Protection Act of 2000, Div. A of Pub. L. No. 106-386, § 108, as amended.

(A) Minimum standards for purposes of this chapter, the minimum standards for the elimination of trafficking applicable to the government of a country of origin, transit, or destination for victims of severe forms of trafficking are the following:

(1) The government of the country should prohibit severe forms of trafficking in persons and punish acts of such trafficking.

(2) For the knowing commission of any act of sex trafficking involving force, fraud, coercion, or in which the victim of sex trafficking is a child incapable of giving meaningful consent, or of trafficking which includes rape or kidnapping or which causes a death, the government of the country should prescribe punishment commensurate with that for grave crimes, such as forcible sexual assault.

(3) For the knowing commission of any act of a severe form of trafficking in persons, the government of the country should prescribe punishment that is sufficiently stringent to deter and that adequately reflects the heinous nature of the offense.

(4) The government of the country should make serious and sustained efforts to eliminate severe forms of trafficking in persons.

But check out the State Dept. Page for more info on the TVPA.

Read the full TIPS report and country profiles here.

Now there is all sorts of controversy surrounding the TIPS reports. That said, can we not be satisfied that the attempt is being made and that it does promote an active fight against trafficking?

That concludes my brief info of the TIPS report, stay tuned for the T-Visa, a fantastic improvement(also part of the TVPA though)

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