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| 11 minutes read

How Ankura’s Anti-Money Laundering Practice is Fighting Human Trafficking

An interview between Gina Parisi, Executive Director at Traffick Free, and Robert Reed, Managing Director at Ankura

Robert: How did you become involved with this organization?

Gina: My journey in the anti-trafficking world began in 2013. I had learned about human trafficking in college and knew right away I wanted to do something to help. I began volunteering with an international organization that sold jewelry and educated people about human trafficking. I then became a volunteer at a Chicago-based safe house and joined an anti-human trafficking task force to help combat sex trafficking in the city of Chicago. In 2018, I was connected to Traffick Free through graduate school and joined their Associate Board. When I first joined Traffick Free, the organization operated a drop-in center on the southwest side of Chicago. This was a place where adults who identified as female and experienced sex trafficking could come and have their immediate needs met for the day (e.g., a hot meal, a shower, or just a place to rest). During this time, I learned a lot about the impact trafficking has on a person and the importance of having trained professionals available to assist them.

Unfortunately, in 2021 Traffick Free had to close their drop-in center due to the pandemic, but the Board wanted to remain in the fight against human trafficking. I was President of the Associate Board at the time and began attending the Executive Board meetings, where I was involved in the conversations regarding transitioning Traffick Free to a fully volunteer-led organization that focused on education and awareness. It was at that time that I agreed to serve as the volunteer Executive Director.

Robert: Please tell me about the work your organization does and the program or programs you run?

Gina: Traffick Free’s mission is to raise awareness of human trafficking through education and community outreach. We provide free trainings and presentations to community members, youth, and professionals who work directly with victims, survivors, and those who are at risk. Our goal is to ensure the public is made aware of the facts surrounding sex trafficking, and that professionals who interact directly with this population are aware of how best to work with, support, and advocate for those who have experienced trafficking.

The focus of most human trafficking trainings is often on how to prevent individuals from becoming victims, how to identify a victim, and how to best work with victims and survivors. At Traffick Free, our trainings often focus on this information, and it is incredibly valuable information for the public and professionals (e.g., law enforcement, social service providers, health care workers) to be aware of as they assist victims and survivors. However, many trainings do not discuss how to identify a trafficker, or how to prevent individuals from becoming traffickers or sex buyers. This conversation is had in certain circles where it is relevant to a person’s work (e.g., financial crimes, trafficking investigators), but it is typically not the focus of anti-trafficking work.

 At Traffick Free, we strongly believe that identifying traffickers and preventing individuals from becoming perpetrators is just as important as identifying victims and preventing individuals from being trafficked. We have a slogan that we use in our trainings that summarizes these efforts: end the demand, stop the supply. The work done in anti-money laundering or AML is vital in the fight against sex trafficking – it not only helps identify traffickers, but it also helps investigators identify victims. Since human trafficking is such a well-hidden crime, it is incredibly difficult to track and identify victims. In addition, the severe impact that trafficking has on a person coupled with the psychological and physical abuse inflicted on many victims by their traffickers makes it incredibly difficult for them to seek help and/or be identified.

Gina: How does Ankura help fight human trafficking?

Robert: Ankura focuses on different services to assist organizations in identifying or fighting human trafficking. Financial institutions can identify this type of activity in the various transactions they are required to monitor by law or regulations, as well as through customer interactions. The Bank Secrecy Act, referred to as BSA, requires financial institutions to monitor for, detect, and report suspicious activity conducted or attempted by bad actors through the institution. Consequently, identification of suspicious transactions in an efficient and effective manner is key to the success of their BSA / AML Program. However, results generated can have a negative impact on an institution causing a lot of false positives and a significant amount of work effort without any real results if proper management or tuning of that transaction monitoring system doesn’t occur. This is where Ankura steps in to assist institutions. There are also regulations requiring the education or ongoing training of BSA / AML personnel, which is one of the five pillars of a successful BSA / AML Program. As a result, Ankura assists with technology enhancements and training.

From a transaction standpoint, Ankura focuses on creating algorithms that look for red flags or certain types of transactions that investigators can then examine and further review for possible reporting to the government. Sometimes Ankura assists with tuning the current algorithms used by institutions’ transaction monitoring software. This would be what the financial institution would already have in place to ensure they capture the proper type of activity in an efficient manner. However, our services don’t stop there. Yes, it is key to have technology assisting in the identification of this activity but without proper training things may go unreported. Ankura’s next steps are ensuring that the financial institution’s investigators or analysts are aware of the red flags and what to look for when reviewing the alerts generated by transaction monitoring systems for proper identification and ultimately reporting the activity to the government.

There is also the customer interaction side of the transaction process in which customer-facing employees are trained on red flags to be aware of in order to probe further when an interaction seems suspicious. This training focuses on the behavior of the individuals in front of you conducting a financial transaction or opening accounts for later use. This training also includes “Know Your Customer” or KYC red flags, for example, things like inexplicable lifestyles compared to the customer’s background or temporary or new identification provided to open multiple customer accounts. You can also simply do things like search an individual’s email address or phone number to see if it corresponds to online classified ads known to cater to the sex industry. I once identified this activity by searching the phone number of a new customer who was soliciting for sex online through “craigslist” advertisements.

Gina: What do you mean by red flags?

Robert: A red flag is usually an anomaly in someone’s transaction history that could be a warning or indicator suggesting that there is a potential problem or threat with that particular transaction. After the transaction monitoring system identifies a transaction that seems out of place, an analyst or investigator looks for additional similar transactions or transactional behavior to determine if this is a one-time situation or a pattern. To assist financial institutions, Financial Crimes Enforcement Network or FinCEN issues advisories and guidance containing examples of red flags. The Federal Financial Institutions Examination Council or FFIEC released a manual in 2014 called the Bank Secrecy Act / Anti-Money Laundering Examination Manual which also explains and lists various types of red flags throughout the manual to help financial institutions identify those transactions for further human review to determine if there should be further investigation or reporting.  

For example, when it comes to human trafficking or human smuggling with transaction monitoring, if the financial institution sees multiple charges to hotels using the same credit / debit card in one day, that could indicate there is sex trafficking occurring.  Also, if several checking accounts are co-owned by the same individual with the same ownership address, this could also mean prostitution is taking place. Other indicators include constant taxi or transportation payments or a significant number of transfers from third persons to a single owner’s account.

In the situation of face-to-face interactions, if a non-related third party speaks on behalf of the customer or does not allow the customer to speak for themselves, this could indicate a problem. There could also be instances of a non-related third party being present for every aspect of their transactions. Another indicator to be aware of would be when a third party insists that they are related to the customer but does not know significant details about the individual that the financial institution would have access to under the course of opening an account.

Gina: What results would a financial institution see when activity is identified?

Robert: In most cases, the financial institutions do not see any results from their reporting. However, as required by FinCEN, financial institutions are required by law to report under rule 12 CFR § 21.11 Suspicious Activity Report. This means failure to do so could result in findings during an exam, consent orders, fines, or even cease and desist orders.

In some cases, the financial institution may or may not close the account with questionable activity dependent on various factors. In other cases, the financial institution, if filing a suspicious activity report, may hear back from a government agency asking for more information. Other times, you may just read about things in articles or see things in the news. 

Gina: You mention human smuggling, what is the difference between that and human trafficking?

Robert: The most distinctive difference between the two is consent. The movement of migrants via human smuggling is a consensual act by both parties, while human trafficking victims have never consented to being taken for trafficking purposes. Exploitation would be the second difference. Smuggling’s exploitation ends when the individual arrives at their destination. In the case of trafficking, exploitation never ends for those being trafficked.

There is also a significant amount of psychological abuse that occurs. As the Polaris Project, a not-for-profit that focuses where they think they can make the most change with data and worldwide collaboration, states, “people in active trafficking situations always want help getting out” is actually a myth. They say, “Fear, isolation, guilt, shame, misplaced loyalty and expert manipulation are among the many factors that may keep a person from seeking help or identifying as a victim even if they are, in fact, being actively trafficked.” This means, not all victims understand they are a victim and want to be removed from the situation for one reason or another.

Robert: What do you think your constituents or beneficiaries would say is the best thing about your organization?

Gina: At Traffick Free we understand that our trainings will only be impactful if the content is relevant and applicable to audience members, so we tailor each presentation based on the audience we are speaking to. The content we share with youth is very different than the content we share with social service providers, medical professionals, and law enforcement, among others. Although the facts about human trafficking are the same, the content related to how different community members or professionals will interact with victims, survivors, and those at risk will vary. I think our constituents understand that we are focused on providing relevant and accurate information to those we train and ensuring that there are no barriers to receiving training, thus why all our trainings are provided at no cost.

Robert: What results does your organization achieve? How has your program improved over time? 

Gina: Our organization consistently receives positive feedback from trainees. Many of the groups we train are unfamiliar with or have no previous knowledge about human trafficking. Those who attend our trainings are either made aware of human trafficking or provided tools and resources to assist them in their job/work with trafficking victims and survivors.

Traffick Free has always provided education and awareness about human trafficking, even while operating the drop-in center. We have primarily focused our work throughout the city of Chicago, but it has become obvious over the past couple of years that education and awareness about sex trafficking is not as prevalent in the surrounding suburbs and rural communities. We are currently focused on spreading awareness and education about human trafficking throughout Chicago and not just in the city. Part of the reason for this is that human trafficking is happening all around us – in the city, local suburbs and rural communities. We think it is important that all communities are made aware of trafficking and professionals in every area are trained on how to best work with this population.

Robert: What are your goals for the next three to five years? What priorities will help you achieve them? What barriers are in your way?

Gina: Our goals for the next 3-5 years are to expand our educational efforts and become one of the primary organizations people contact to conduct human trafficking training. We really want to provide awareness and education to communities less familiar with human trafficking, as we believe it is important that all communities become aware of this well-hidden crime and are provided the tools and resources to help combat it. We would also like to partner with other anti-human trafficking organizations to host community events and trainings that are focused on educating people about human trafficking as well as raise funds to assist organizations that provide direct services for victims and survivors. One of our biggest barriers currently is that we are a volunteer-led organization, so we have limited resources to accomplish our goals.

Gina: What are Ankura’s goals as it relates to combating human trafficking?

Robert: The simple answer is to reduce or eliminate as much of this behavior as possible by aiding financial institutions in the identification of these transactions for reporting. Similar to your organization’s goals, our professionals seek to educate and assist organizations in identifying the type of transactions, behaviors to watch for, and organizations to be aware of that could imply trafficking and prostitution. Partnering with an organization such as Traffick Free to continue to add to our training is something we are working on so that both we and our clients are current in understanding human trafficking trends and red flags. We are interested in maintaining an open dialogue.

Ultimately, we accomplish our goal by assisting organizations with various tools to identify behavioral red flags and make sound judgments to file reports to the proper authorities for review. We have this in our current work with the various training programs we lead for financial institutions, law firms, boards, and internally while testing for the type of transactions during our independent audits of the BSA / AML Programs. Insight articles and interviews also go a long way in engaging others to be aware and think about ways to fight the problem.     

Robert: What are your most urgent needs?

Gina: We are currently seeking volunteers to help with our marketing and community outreach efforts. Since we are a fully volunteer-led organization, we rely on the generous support of volunteers to help us run the organization. As we continue to rebuild Traffick Free and expand our educational efforts, having volunteers assist with spreading awareness about human trafficking and Traffick Free would be incredibly helpful!

Robert: Thank you for your time, Gina. It is helpful for those of us in the consulting and financial industry to understand the issues from individuals like yourself that work and live on the front lines of human trafficking.

© Copyright 2022. The views expressed herein are those of the author(s) and not necessarily the views of Ankura Consulting Group, LLC., its management, its subsidiaries, its affiliates, or its other professionals. Ankura is not a law firm and cannot provide legal advice.

Tags

anti-corruption, anti-money laundering, afc

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