ATII Exclusive Special Report: How Human Traffickers Exploit the International Economy: Underground Banking and Cash Flow (part 1 of 4) – CFCS



By Mackenzie Martinez
Special contributor, ATII
June 14, 2021

With minor edits by ACFCS VP Content, Brian Monroe

This story was originally published earlier this month by the Anti-Human Trafficking Intelligence Initiative. Republished with approval and appreciation. To read the original piece, click on here.

The rise of the cyber, digital and virtual worlds as a means of communication, payment and international securities settlement since 2000 has dramatically altered the global financial system, causing a major shift towards the online economy.

Unfortunately, the expansion of the web-based economy has allowed a variety of human trafficking tactics that allow crimes to go virtually unnoticed. New and developing methods of facilitating trafficking have led to growth in profits and criminal networks.

This blogging series delves into the many avenues used by traffickers to hide their crimes and highlights the criminal cases that exemplify such efforts.

Some methods have been in use for a long time, while others are just starting to emerge.

Understanding how human traffickers exploit the international economy will help us determine how we can most effectively track money to fight slavery. Much of the information in this blogging series comes from “Trafficking in Persons and the International Financial System” by Louise Shelley, which can be found here (link).

This report was among the statements prepared by many of the foremost minds in financial crime investigation and compliance discussed in a virtual hearing – “Ending the Exploitation: How the Financial System Can Work for dismantle the activity of trafficking in human beings ”.

The hearing took place on March 25 before the House Committee on Financial Services, a subcommittee on national security, international development and monetary policy.

To read the full list of prepared statements and view a recording of the hearing, click here.

Basically, human trafficking is described as the illegal transport of people from one country or region to another, in many cases for the purpose of forced labor or sexual exploitation, according to analyzes and media. . reports.

According to the UN-backed International Labor Organization (ILO), globally, it is estimated that some 40 million people have been affected by this industry, both intentionally trying to improve their lives and, in other cases, profiting by illicit organized criminal gangs.

The profits from this crime are also huge.

In one ILO Report 2014, human trafficking brings in nearly 150 billion dollars a year, more than half of which comes from sexual exploitation.

According to the ILO and the nonprofit Polaris Project, the sex and labor trafficking industry is only overtaken by drug trafficking, national and international investigative bodies and international banking groups .

Over the past decade, through a multitude of public-private partnerships around the world, law enforcement agencies and banks have shared general and specific red flags to help uncover companies pulling party of forced or sex labor.

A key tactic for uncovering potential links to gangs of traffickers in your institution is to look for accounts with no standard income sources and credit cards, which are frequently canceled, according to several financial compliance professionals. Speaking at a conference for the Association of Certified Financial Crime Specialists.

Here are some examples :

Cash deposits

  • Excessive deposits, especially for round amounts like $ 50, $ 150, and $ 200.
  • Deposits at abnormal times, for example between 10 p.m. and 6 a.m.
  • Large denominations of deposits. If a normal cash intensive business, you will have a mix of denominations. Coins. $ 5 and $ 10. If it is human smuggling, most of you will earn $ 50, $ 20, and $ 100 bills. Illicit groups believe that banks are not looking for this, but cuts in deposits are recorded at the branch level.
  • Depots in multiple cities, especially if they are close to each other, over a period of time. The traffickers will take the victims from town to town and rotate across the country to urban centers across the country. Look for the impossible trip, Halifax and Vancouver in the same day. If you see this as an AML analyst, it means multiple people are using the same account as a funnel account.

Peer to peer payments (EMT, Venmo, etc.)

  • Payments in consistent rounded amounts. An account that takes a lot has telltale signs as well. The fact that the payments are sort of incremental. $ 150, $ 300 and $ 50, that means someone is buying something in hour increments.
  • Multiple authors with some repetitions. Many different parties pay to the same account over time and repeat customers. Look for customer drift in multiple cities. Look for a single email address associated with multiple bank accounts or vice versa, a single bank account associated with multiple email addresses and those related to online advertising or escort sites.
  • Funnel accounts and peer-to-peer transfers. They know it’s a vulnerable area, used accounts to collect the P2P transfer, then immediately hit an ATM and withdraw the money.
  • They know the correct behavior, so when a P2P transfer reaches a bank account, they withdraw it immediately, sometimes in as little as 30 minutes. It’s a smurf account. If this is detected and stopped, they will not lose much value. A key red flag is 5-10 money transfers via email, then 5-10 withdrawals made periodically.


  • Multiple payroll deposits to one account, which could be related to forced labor. It would look like several government benefit checks on the same account. Clearly aimed at more than two or three people, which means that one person controls the work and takes the money and pays for it – but much less to those who actually do the work.
  • Multiple processor repositories for adult online content, such as Fenix, Onlyfans and others.



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