Collective Culpabilities
It is that time of year again when the President issues the annual Proclamation on National Human Trafficking Prevention Month. The Proclamation might carry more moral weight if its promises to “prevent trafficking, prosecute perpetrators, and protect survivors” were not being undone by other government policies that cede control of our sovereign borders to transnational criminal organizations conducting migrant smuggling and human trafficking, selectively enforce anti-trafficking laws, decriminalize some forms of trafficking, defund the police, implement bail reform, directly and indirectly fund and assist child trafficking, etc. As Matt Walsh has written, “these are serious times and we are led by unserious people.”
Though slavery has long been outlawed and human dignity and human rights espoused, modern slavery and human trafficking (MSHT) are more persistent and prevalent today than ever. Its products and services have become endemic in the global marketplace. Our post-Christian and postmodern society has adopted a worldview that has left many objective truths passed from one generation to another over thousands of years far behind in its proverbial secular dust. Many of us choose to see/hear/say no evil while others do nothing to address it.
Whether we accept or acknowledge it or not, everyone benefits from MSHT products and services to some extent. We all consume goods produced by child labor or forced labor – we wear shoes and clothes made by slaves, we eat fresh fruit and vegetables picked by people who have been bought and sold, etc. The U.S. Department of Labor, Bureau of International Labor Affairs (ILAB) List of Goods Produced by Child Labor or Forced Labor comprises 159 goods from 78 countries and areas, e.g. lithium-ion batteries (electric vehicles, cell phones, wind turbines, hearing aids, etc), palm oil products (hundreds of everyday products, from soap to cosmetics to margarine), and solar products (solar panels and other polysilicon products). Everyone takes advantage of the lower prices, availability, and convenience of MSHT.
Much of today’s MSHT would not be possible without financial firms processing its proceeds. The financial flows from MSHT crimes move through our banking system allowing criminals to profit, conduct and expand their activities and further exploit vulnerable people.
Moral Imperatives
Our traditional American values call for everyone to recognize evil when they see it and say or do something to stop it. Everyone can do their part by holding unserious government officials who speak out of both sides of their mouths accountable during elections. As informed consumers, we can use the ILAB Reports and Publications and its Tools and Apps to learn how to identify and reduce demand by avoiding specific goods produced by child labor or forced labor in supply chains.
Jessica Ramos’ article, Financial Firms Have a Moral Duty to Help Eradicate Modern Slavery, The Banker, 14 Dec 2023, addresses the financial industry’s role in recognizing and stopping MSHT. It details a European Women Payments Network (EWPN) annual Oct 2023 event that discussed tools to detect suspicious behavior, suspicious transaction reports on related parties, the need for continuous and comprehensive education and awareness programs, collaboration, observable contextual indicators, etc. It cites an excellent resource, Spot the Funds, Stop the Trafficking, jointly produced by RedCompass and EWPN and available via both their websites.
The RedCompass Labs RedFlag Accelerator (RFA) data model is openly available to banks and other financial organizations, expert MSHT NGOs and other key stakeholders, including law enforcement and financial intelligence units, industry associations and academic research partners who sign up via the RFA website (www.redflagaccelerator.com). The RFA base model is formed of 170 unique indicators and 18 scenarios which are further broken down into data fields to allow financial institutions to reveal patterns in their data smarter, faster and cheaper. The full version of RFA Typologies provides 343 unique indicators, eight key typologies, and 33 key scenarios. Each persona-driven scenario contains a list of relevant, weighted red flags, and is further complemented with a description summarizing key characteristics and behaviors. The list is broken down into two main categories – retail and business banking specific red flags – and 16 activity type groups, that can ease navigation.
While most of us are not in banking compliance roles, we should all be aware of some of the basic observable contextual indicators involved in the various forms of MSHT. To this end, RedCompass provides a list of 11 Follow the Money Scenario Infographics with the following red flags:
Sexual Exploitation (Victim)
Scenario #1001, 29 Sep 2022
🚩 Customer Details in Adult Ads
🚩 Address in Red-light District
🚩 Frequent incoming payments at night (2200-0600)
🚩 Incoming payments at night and predominately from males
🚩 High Turnover Low Balance
Multi-Victim Housing Trafficker
Scenario #1004, 16 Feb 2023
🚩 Control over multiple bank cards
🚩 Same third party linked to multiple accounts
🚩 Excessive amounts of living expenses
🚩 Frequent purchases in pharmacies
Labor Exploitation (Trafficker)
Scenario #2002, 1 Dec 2022
🚩 Same third-party for multiple individuals
🚩 Frequent Transactions with High-Risk Human Trafficking Countries
🚩 Inadequate stated personal income
🚩 Transacting with Employment Entities with Violations
‘Epstein’ Scenario
Scenario #3003, 24 Aug 2022
🚩 Frequent change in spending locations
🚩 Multiple lump sum cash withdrawals
🚩 Frequent payments to modelling agencies, luxury rental vehicles, and/or multiple municipalities
🚩 Frequent transactions with offshore entities
‘Loverboy’ Sex Trafficker
Scenario #3004, 22 Mar 2023
🚩 Frequent change in online account access location
🚩 Inexplicable spending on luxury goods
🚩 Frequent payments to advertisers for adult ads
🚩 Spending on plastic surgery/beauty enhancement
Business Facilitating Labor Exploitation
Scenario #4003, 17 Jan 2023
🚩 Inadequate payroll expenditure
🚩 No employment or payroll taxes
🚩 Same owner for multiple businesses
🚩 Related entities in adverse media
How to Identify a Trafficking Victim via Remote Onboarding
Scenario #5003, 7 Sep 2023
🚩 Multiple Applicants’ Videos from Same Device
🚩 Third Party Presence at Remote Onboarding
🚩 Suspicious Background in Onboarding Video
🚩 Multiple Customers with Same Account Details
Online Child Sexual Exploitation Offender
Scenario #7001, 25 Apr 2023
🚩 Purchases on adult entertainment and/ or dating platforms
🚩 Registered Sex Offender
🚩 Frequent low-value payments to high-risk child sexual exploitation country
🚩 Payments to VPN and/ or privacy software providers
Online Child Sexual Exploitation Facilitator
Scenario #7002, 27 Jun 2023
🚩 Receiving frequent low value cross-border payments
🚩 Activity related to cryptocurrency
🚩 Payment references received in high-risk CSE country
🚩 Receiving payments from adult entertainment sites
Elderly Financial Exploitation Victim
Scenario #8002, 15 Nov 2023
🚩 Senior Confused about Financial Status
🚩 Significant Cash Withdrawals from Senior’s Account
🚩 Savings Suddenly Withdrawn
🚩 Senior’s Activity Related to Gift Cards
US-Based Commercial Front Brothels
Scenario #9001, 17 Jan 2023
🚩 Business-related Details in Adult Ads
🚩 Frequent Payments to Commercial Sex Advertising (CSA) Sites
🚩 Beauty-related Business with Predominantly Male Clientele; Receiving Customer Payments Outside Business Hours
🚩 None or Very Low Payroll Expenditure
Disclaimer: The views expressed in this article are solely those of the author.
Human Trafficking: Collective Culpabilities and Moral Imperatives
John Caulfield
Chief, International Strategy at Zero Trafficking LLC
December 22, 2023
Open Immersive Reader
Collective Culpabilities
It is that time of year again when the President issues the annual Proclamation on National Human Trafficking Prevention Month. The Proclamation might carry more moral weight if its promises to “prevent trafficking, prosecute perpetrators, and protect survivors” were not being undone by other government policies that cede control of our sovereign borders to transnational criminal organizations conducting migrant smuggling and human trafficking, selectively enforce anti-trafficking laws, decriminalize some forms of trafficking, defund the police, implement bail reform, directly and indirectly fund and assist child trafficking, etc. As Matt Walsh has written, “these are serious times and we are led by unserious people.”
Though slavery has long been outlawed and human dignity and human rights espoused, modern slavery and human trafficking (MSHT) are more persistent and prevalent today than ever. Its products and services have become endemic in the global marketplace. Our post-Christian and postmodern society has adopted a worldview that has left many objective truths passed from one generation to another over thousands of years far behind in its proverbial secular dust. Many of us choose to see/hear/say no evil while others do nothing to address it.
Whether we accept or acknowledge it or not, everyone benefits from MSHT products and services to some extent. We all consume goods produced by child labor or forced labor – we wear shoes and clothes made by slaves, we eat fresh fruit and vegetables picked by people who have been bought and sold, etc. The U.S. Department of Labor, Bureau of International Labor Affairs (ILAB) List of Goods Produced by Child Labor or Forced Labor comprises 159 goods from 78 countries and areas, e.g. lithium-ion batteries (electric vehicles, cell phones, wind turbines, hearing aids, etc), palm oil products (hundreds of everyday products, from soap to cosmetics to margarine), and solar products (solar panels and other polysilicon products). Everyone takes advantage of the lower prices, availability, and convenience of MSHT.
Much of today’s MSHT would not be possible without financial firms processing its proceeds. The financial flows from MSHT crimes move through our banking system allowing criminals to profit, conduct and expand their activities and further exploit vulnerable people.
Moral Imperatives
Our traditional American values call for everyone to recognize evil when they see it and say or do something to stop it. Everyone can do their part by holding unserious government officials who speak out of both sides of their mouths accountable during elections. As informed consumers, we can use the ILAB Reports and Publications and its Tools and Apps to learn how to identify and reduce demand by avoiding specific goods produced by child labor or forced labor in supply chains.
Jessica Ramos’ article, Financial Firms Have a Moral Duty to Help Eradicate Modern Slavery, The Banker, 14 Dec 2023, addresses the financial industry’s role in recognizing and stopping MSHT. It details a European Women Payments Network (EWPN) annual Oct 2023 event that discussed tools to detect suspicious behavior, suspicious transaction reports on related parties, the need for continuous and comprehensive education and awareness programs, collaboration, observable contextual indicators, etc. It cites an excellent resource, Spot the Funds, Stop the Trafficking, jointly produced by RedCompass and EWPN and available via both their websites.
The RedCompass Labs RedFlag Accelerator (RFA) data model is openly available to banks and other financial organizations, expert MSHT NGOs and other key stakeholders, including law enforcement and financial intelligence units, industry associations and academic research partners who sign up via the RFA website (www.redflagaccelerator.com). The RFA base model is formed of 170 unique indicators and 18 scenarios which are further broken down into data fields to allow financial institutions to reveal patterns in their data smarter, faster and cheaper. The full version of RFA Typologies provides 343 unique indicators, eight key typologies, and 33 key scenarios. Each persona-driven scenario contains a list of relevant, weighted red flags, and is further complemented with a description summarizing key characteristics and behaviors. The list is broken down into two main categories – retail and business banking specific red flags – and 16 activity type groups, that can ease navigation.
While most of us are not in banking compliance roles, we should all be aware of some of the basic observable contextual indicators involved in the various forms of MSHT. To this end, RedCompass provides a list of 11 Follow the Money Scenario Infographics with the following red flags:
Sexual Exploitation (Victim)
Scenario #1001, 29 Sep 2022
🚩 Customer Details in Adult Ads
🚩 Address in Red-light District
🚩 Frequent incoming payments at night (2200-0600)
🚩 Incoming payments at night and predominately from males
🚩 High Turnover Low Balance
Multi-Victim Housing Trafficker
Scenario #1004, 16 Feb 2023
🚩 Control over multiple bank cards
🚩 Same third party linked to multiple accounts
🚩 Excessive amounts of living expenses
🚩 Frequent purchases in pharmacies
Labor Exploitation (Trafficker)
Scenario #2002, 1 Dec 2022
🚩 Same third-party for multiple individuals
🚩 Frequent Transactions with High-Risk Human Trafficking Countries
🚩 Inadequate stated personal income
🚩 Transacting with Employment Entities with Violations
Epstein Scenario
Scenario #3003, 24 Aug 2022
🚩 Frequent change in spending locations
🚩 Multiple lump sum cash withdrawals
🚩 Frequent payments to modelling agencies, luxury rental vehicles, and/or multiple municipalities
🚩 Frequent transactions with offshore entities
Loverboy Sex Trafficker
Scenario #3004, 22 Mar 2023
🚩 Frequent change in online account access location
🚩 Inexplicable spending on luxury goods
🚩 Frequent payments to advertisers for adult ads
🚩 Spending on plastic surgery/beauty enhancement
Business Facilitating Labor Exploitation
Scenario #4003, 17 Jan 2023
🚩 Inadequate payroll expenditure
🚩 No employment or payroll taxes
🚩 Same owner for multiple businesses
🚩 Related entities in adverse media
How to Identify a Trafficking Victim via Remote Onboarding
Scenario #5003, 7 Sep 2023
🚩 Multiple Applicants’ Videos from Same Device
🚩 Third Party Presence at Remote Onboarding
🚩 Suspicious Background in Onboarding Video
🚩 Multiple Customers with Same Account Details
Online Child Sexual Exploitation Offender
Scenario #7001, 25 Apr 2023
🚩 Purchases on adult entertainment and/ or dating platforms
🚩 Registered Sex Offender
🚩 Frequent low-value payments to high-risk child sexual exploitation country
🚩 Payments to VPN and/ or privacy software providers
Online Child Sexual Exploitation Facilitator
Scenario #7002, 27 Jun 2023
🚩 Receiving frequent low value cross-border payments
🚩 Activity related to cryptocurrency
🚩 Payment references received in high-risk CSE country
🚩 Receiving payments from adult entertainment sites
Elderly Financial Exploitation Victim
Scenario #8002, 15 Nov 2023
🚩 Senior Confused about Financial Status
🚩 Significant Cash Withdrawals from Senior’s Account
🚩 Savings Suddenly Withdrawn
🚩 Senior’s Activity Related to Gift Cards
US-Based Commercial Front Brothels
Scenario #9001, 17 Jan 2023
🚩 Business-related Details in Adult Ads
🚩 Frequent Payments to Commercial Sex Advertising (CSA) Sites
🚩 Beauty-related Business with Predominantly Male Clientele; Receiving Customer Payments Outside Business Hours
🚩 None or Very Low Payroll Expenditure
Disclaimer: The views expressed in this article are solely those of the author.
Published by
Chief, International Strategy at Zero Trafficking LLCChief, International Strategy at Zero Trafficking LLC
Published • 17h
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