Banking professionals run across many types of transactions pointing to human trafficking. Here are tips to spot them from Love Never Fails Founder Vanessa Russell.
Some financial transactions flag human trafficking because they are from websites notorious for this behavior.
Other transactions point to human trafficking but require more digging on the part of financial industry professionals.
Besides reporting transactions with suspected ties to human trafficking, you can support victims in other ways.
According to the National Human Trafficking Hotline, working in the financial industry provides you the opportunity to report suspicious behavior involving 92% of the various types of human trafficking. When you come in contact with transactions that just don’t feel right, don’t hesitate to file Suspicious Activity Reports (SARs) and call the National Human Trafficking hotline at 888-373-7888.
Some transactions on customer accounts, such as those from OnlyFans and Pornhub, are blatantly exploitative. These sites are notorious for human trafficking. PornHub and sites like it are “infested with rape videos. They monetize child rape, revenge pornography, spy cam videos of women showering, racist and misogynist content, and footage of women being asphyxiated in plastic bags,” according to New York Times Columnist Nicholas Kristof.
Several financial agencies such as Visa, Mastercard and PayPal have started to take a stand by refusing to process transactions from these types of sites. However, these transactions are continuing on cryptocurrency platforms. As a community, we need to place more pressure on all currency providers (fiat and crypto) to embrace digital ethics and refuse to engage and/or do business with organizations that fail to protect innocent and vulnerable people.
Some transactions require a little more digging. They seem normal but have one odd element that makes you wonder. Trust your gut and investigate it. Here are examples.
A banker recently shared a story of a pastor who was promised citizenship and housing if they came to the U.S., only to be labor trafficked and held in debt bondage upon arrival. The red flag was a large amount charged to the pastor by a U.S. company for a conference. Conference fees generally should be less than $1,000 and not recurring. You can determine the validity of this transaction by seeing if anyone else is attending this conference and paying the same amount at the same time. If it is a lone transaction, it is very likely there is no conference.
Another banker shared that a restaurant deposited multiple checks with varying amounts from $3,000 to $7,000 in a two-month period. Deposits under $10k must be immediately flagged as potential structured deposits. To look into this further, evaluate the account’s cash flow and see if this pattern is normal. Also evaluate the withdrawal patterns. If there are immediate transfers or checks written against these deposits this could be more of an intermediary account and might point you to more transactions and evidence that can help you determine what’s going on and who’s involved. Consider searching Google or Yelp to learn about the restaurant. Even analyzing their dish prices can help you determine whether the level of deposits is even feasible. For example, if the restaurant was depositing $7,000 every week, they are open 6 days and the average price of their dishes is $10, they would have to serve 700 customers a week or 116 people a day. Perhaps this is likely if the business caters but probably not valid, especially during a pandemic.
While we are moving toward a 100% digital currency world, most businesses, especially restaurants with high customer engagement, must continue to receive cash to meet the needs of their customers. Some businesses involved in human trafficking are no longer depositing cash to avoid the red flags. Instead, they purchase merchant cards with cash and use them to buy things they need. This business process could be a legitimate measure taken for cash-loss prevention, especially if the business has low trust with their employees. Even so, it warrants a deeper look because the potential for cash loss usually does not compare with the fees the employer will pay for purchasing the cards.
Another area to investigate are businesses who appear to be flourishing but have:
Employees who are paid under the table do not have access to standard employment benefits such as unemployment insurance, disability, workers compensation, etc. The employee’s willingness to forgo their benefits and rights demonstrates their vulnerability and the employer’s willingness to take advantage of them is a classic display of the abusive relationship that human trafficking flows from. As a member of the financial industry, you can intervene before trafficking happens and make employers aware and accountable for treating people equitably.
You may feel overwhelmed by the growing number of potential human trafficking transactions you find. It’s gut-wrenching to think of the torture and abuse that sits behind these transactions. The good news is there are data scientists designing ways to detect these patterns without human intervention. Soon we will be empowered to find data that can free victims in minutes instead of years.
While we are waiting, you can make a difference in the lives of victims of human trafficking by reporting suspicious activity even if you think nothing will be done with the information. Each report sends a message to a survivor that they are seen and valued. SARs tied to trafficking went from 109 in 2018 to 3,384 in 2019 – U.S. Treasury Financial Crimes Enforcement Network (FinCEN) and analytics by Dynamic Securities Analytics and banks accounted for 70% of these reports. Let’s keep it going!
Also, remember that victims of human trafficking are often rescued and then left to rebuild their lives on their own. Exploiters do not just rent out their victim’s body for personal gain, they use the victim’s identity to buy cars, purses, shoes, food, gas, and even houses. They also force victims to commit crimes, creating a criminal background that is not easily overcome when trying to obtain work. You can help by supporting organizations like Love Never Fails that are housing and empowering survivors with professional training that will assist them in obtaining sustainable careers in industries such as tech, health care, and finance.
Lastly, consider creating “clean slate” banking products and services so that survivors of human trafficking can present details on their victimization and have a chance to open a bank account, purchase homes, and participate freely in society without shame. Providing this opportunity communicates to survivors that their victimization was not their fault and that they deserve a chance to live their best life!
Vanessa Russell is Founder and Executive Director of Love Never Fails, a non-profit dedicated to the restoration, education and protection of those involved or at risk of becoming involved in domestic human trafficking. Russell has developed children in the area of dance, teaching hundreds, ages 3-25, lyrical, flags, hip hop, and mime, since 2000. In 2010, one of her 15 year old dance students was sold into human trafficking. Although the student was eventually located and is now being restored, Russell encountered many others who, like her student, were U.S.-born women, men, and children trapped in modern day slavery. Her response was to launch Love Never Fails, which has educated thousands of children and community members on the issue of human trafficking, opened a home that provides long-term safe housing and restorative services for over 100 women survivors and their children and launched an IT Academy connecting under-served community members with financially sustainable careers.
Abrigo enables U.S. financial institutions to support their communities through technology that fights financial crime, grows loans and deposits, and optimizes risk. Abrigo's platform centralizes the institution's data, creates a digital user experience, ensures compliance, and delivers efficiency for scale and profitable growth.
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