Human Trafficking Awareness and Prevention Month Update: In celebrity sex trafficking cases, power, influence, dreams of music, modeling careers, stardom used to manipulate, exploit, silence victims

By Brian Monroe
January 11, 2025
bmonroe@acfcs.org

January is Human Trafficking Prevention Month, a sobering yet vital annual reminder designed to refocus the fincrime compliance lens on a vile, emotional and cruel crime with soaring human costs and growing financial dimensions – billions of dollars in stolen innocence built on human suffering.

While organized criminals engaging in human trafficking are always adapting to evade law enforcement traps, there have been some more recent trends revealing that it is not just large international threat actor groups and domestic low-level opportunists using intimidation or false promises of support or protection to exploit women.

It is also the rich, powerful and famous entertainers, influencers and the c-suite that anti-money laundering (AML) teams should worry about and give added scrutiny to strange payments for “events,” unusual and hefty cash withdrawals for “parties” and wires to exotic foreign locales for “modeling” services.

Some of these names have dominated news cycles in recent months, with former fans recoiling at such a stunning fall from grace.

While we will cover more names in this piece, some examples include investigators puncturing Puffy Daddy, or P. Diddy, or Sean Combs, real estate family influencers from Miami, the former CEO of Abercrombie and Fitch, social media lout Tristan Tate, former pop powerhouse R. Kelly and others, just to name a few.

But how do these powerbrokers dupe and denigrate women? Is it similar or different from illicit trafficking groups?

In civil and criminal cases that have come to light in recent years, these individuals use a combination of classic tactics in human trafficking – fear, manipulation and threats of violence – while leveraging their own charm, status, and influence to woo and deceive with promises of money, fame and stardom.

These former high-flying stars – some arrested, others convicted, and in a few cases deceased – targeted and took advantage of mostly women, but some men, to suit their twisted desires and illicit inclinations. 

In this piece, we will review some of the tactics these celebrities have used to engage in human trafficking, sexual abuse and violence against women, a high society microcosm of a terrible crime leaving a traumatic physical and psychic imprint on the modern world.

“Across the world, nearly 30 million people, including thousands in the United States, are subjected to the shameful, abhorrent abuse of human trafficking and forced labor,” representing an estimated $150 billion to $245 billion, according to a presidential proclamation released in December.

“Human trafficking targets the most vulnerable in society and exploits them — denying their human rights, freedom, and dignity,” former President Biden said in the statement.

“It is a stain on our collective conscience and an affront to basic human dignity. Any form of trafficking in people — from forced labor to sex trafficking — must not be tolerated, in the United States or anywhere around the world.”

In this updated primer story for Human Trafficking Prevention and Awareness Month, and Human Trafficking Awareness Day, Saturday January 11, ACFCS will share insight culled from recent government investigations and association events, webinars and interactive training sessions.

To read ACFCS’ 2024 story tied to Human Trafficking Prevention month, click here.

To read a special ACFCS Training Corner sidebar story detailing many of the complex and nuanced red flags of human trafficking, please click here.

This photo is a still from the documentary “A Rare Look Inside Diddy's $65 Million Superyacht,” from the Luxoria channel. To see the full story, click here.

The downfall of Diddy: A rise to fame, a hitmaker who enjoyed regal finery, excess 

To say Sean Combs was a famous musician would be a drastic understatement.

He was considered for decades hip-hop royalty.

He wielded great power and authority across the entertainment, music and business sectors, with hopefuls clamoring and clambering for just a moment of his time – realizing that with his approval and support, it could lead to fame and fortune.

But there was a price.

Your support. Your allegiance. Your subservience. Your silence.

Sometimes – your soul.

But that side of him was a far cry from his glittering, polished and practiced public persona.

Before the scandals, Sean John Combs, also known as Diddy, and formerly Puff Daddy, Puffy and P. Diddy, was and technically still is “an American rapper, record producer, and record executive,” according to online searches.

More specifically, as of just a few years ago, Diddy’s “decorated music” career included “11 No. 1 songs, three Grammy Awards, an [American Society of Composers, Authors and Publishers (ASCAP)] Songwriter of the Year, and producer credits on hundreds of songs,” according to a Nov. 2022 article in hip-hip news site, Revolt.

His Bad Boy label was responsible for 27 platinum and 15 gold albums, including 23 platinum singles, 28 gold singles, three number one albums and nine number one singles, according to the story.

Diddy was also immensely wealthy, with Forbes just a few years ago – before the civil lawsuits and criminal indictments – stating he had reached billionaire status on the back of such musical hits as “I’ll be missing you.”

As well, he was known for being flamboyant, excessive and always associating himself with only the finest things that life had to offer.

“On the rap scene since the 1990s, the Harlem-born performer, 54, sang about being ‘all about the Benjamins’ as he built his hip-hop empire,” according to a Sept. 2024 story in Yahoo News.

“His brand became synonymous with a lifestyle of excess – mansions, yachts, private planes, luxury cars, women, Cristal, furs and over-the-top gifts for mom Janice.”

“There’s a meme of him staring at a $1 bill looking puzzled by its existence among the $100s, and so many GIFs of him making it rain,” according to the story, an ironic preview that his finances would soon plunge by more than half to an estimated $400 million today.

He was also known for being charitable, giving back to the cities he operated and giving opportunities to the youth, so much so that New York City Mayor Eric Adams gave him the Key to the City in September 2023 during a ceremony in Times Square.

The Key to the City was given to Combs to recognize his contributions to music, business, and philanthropy.

But that honor was short-lived.

Adams sent Combs a letter in June of 2024, asking for the key to be returned after a video surfaced of him attacking R&B singer Cassie, which he did just days later.

Prior to his plunge, Diddy could afford to be charitable.

The corporate entities under the Diddy umbrella included, among other things, record labels, a recording studio, an apparel line, an alcoholic spirits business, a marketing agency, and a television network and media company.

And this vast empire, according to prosecutors, was also a perfect cover to move people, props and money for prostitution, trafficking sexual excess – and exploitation.

This photo is a still from the documentary “Prime Crime: The Rise and Fall of P. Diddy,” from the Law & Crime Network. To see the full story, click here.

The downfall of Diddy: from tales of secret freak offs to baby oil laced with date rape drugs

The glitz, glamour and high life came crashing down for Diddy when federal authorities arrested him in New York in Sept. 2024 and charged him with racketeering conspiracy, sex trafficking and transportation to engage in prostitution.  

The Indictment alleged that between 2008 and the present, Diddy abused, threatened, and coerced women and others, and led a racketeering conspiracy that engaged in sex trafficking, forced labor, kidnapping, arson, bribery, and obstruction of justice, among other crimes.

In 2024, he also faced multiple lawsuits – one attorney alone represents 120 possible victims – including allegations of sex trafficking.

As it stands now, former music mogul Sean "Diddy" Combs faces multiple lawsuits alleging a pattern of sexual abuse, sex trafficking, and using his business empire and vast resources to facilitate exploitation spanning decades.

“Combs ensured participation from the women by, among other things, obtaining and distributing narcotics to them, controlling their careers, leveraging his financial support and threatening to cut off the same, and using intimidation and violence,” according to court records.

Diddy’s violent outbursts – whether verbal or physical – were also “not limited to these women. It extended to his employees, witnesses to his abuse, and others,” according to the indictment.

The civil and criminal allegations breaking mainly over the past year paint a picture of an elaborate operation with an entourage of enablers and enforcers that allegedly used his businesses, Bad Boy Records, and other companies to recruit and transport victims.

According to court documents, Combs allegedly used his private jet, luxury properties in multiple cities, and a network of employees to coordinate what prosecutors describe as a trafficking operation disguised as an entertainment industry business.

The goal of those involved: “Preserving, protecting, promoting, and enhancing the power of the Combs Enterprise, including the power of its leader, Combs, through violence, use of firearms, threats of violence, coercion, and verbal, emotional, physical, and sexual abuse,” according to the indictment.

So what are some parts of the unofficial job description to work for Diddy, you might wonder?

“Fulfilling the personal desires of Combs, particularly those related to Combs’ sexual gratification, including through the exploitation of women and the use of commercial sex workers,” according to the federal indictment.

In addition, the civil lawsuits detail alleged patterns of financial transactions including regular payments to a consistent group of "party planners," bulk hotel bookings under various company names, and wire transfers to talent agencies that allegedly helped recruit victims with promises of music industry careers.

Bank records cited in the complaints allegedly show large cash withdrawals preceding private events at his homes in Los Angeles, Miami, and New York.

The court filings outline how Combs allegedly leveraged his position as a music industry powerbroker to exploit victims, using a combination of career opportunities, luxury lifestyle access, and according to the complaints, intimidation.

The civil lawsuits describe an alleged pattern where his businesses would issue contracts or agreements for music projects that were allegedly used as cover for trafficking activities.

Financial investigators noted suspicious patterns of payments to young "artists" or "performers" that didn't align with typical industry compensation structures.

In many cases, these ostentatious parties and events – many with other actors, musicians, politicians and celebrities – eventually devolved into “freak offs.”

What exactly were these?

Bacchanalian trysts? Steamy make-out sessions? Simply a way for those with wealth, power and beauty to “blow off” some steam?

Not exactly, according to prosecutors.

These freak offs were a combination of consensual and illicit sex acts, actions and unknowing invitees, commercial sex workers and others that required nearly as much planning, resources and props as a Hollywood production, according to the 14-page indictment.

“Freak Offs were elaborate and produced sex performances that Combs arranged, directed…and often electronically recorded,” with his direct participation or simply for his viewing and self-pleasure, according to the indictment.

“During Freak Offs, Combs distributed a variety of controlled substances to victims, in part to keep the victims obedient and compliant,” prosecutors said.

But he couldn’t do it alone.

“Members and associates of the Combs Enterprise, including high-ranking supervisors, security staff, household staff, personal assistants, and other Combs Business employees, facilitated the Freak Offs by, among other things, booking hotel rooms for the Freak Offs,” according to the indictment.

These staffers also made sure to stock the hotel rooms in advance with the “required Freak Off supplies, including controlled substances, baby oil, lubricant, extra linens, and lighting,” according to court documents, with some reports noting that the baby oil was laced with the date rape drug, Rohypnol.

They also had to clean the room, to try and “mitigate room damage” and arrange travel for victims, commercial sex workers, and Diddy to and from Freak Offs, along with “delivering large sums of cash to Combs to pay the commercial sex workers.”

Some could say prosecuting Combs was a slippery situation.

In March 2024, during searches of his residences in Miami, Florida and Los Angeles, California, law enforcement uncovered some items evincing the expansive scope and illegal acts going on during the Freak offs, uncovering “narcotics and more than 1,000 bottles of baby oil and lubricant.”

This photo is a still from the documentary “Prime Crime: The Rise and Fall of P. Diddy,” from the Law & Crime Network. To see the full story, click here.

More stick than carrot: Just like trafficking groups, persuasion through intimidation

But if Diddy didn’t get what he wanted through wining, dining, cajoling and promising love, affection and career advancement, he mimicked the moves of classic human trafficking operations – using fear, threats, physical harm and fiscal deprivation to achieve his goals, court documents said.

“Combs subjected victims to physical, emotional, and verbal abuse to cause the victims to engage in Freak Offs,” the indictment stated. “Combs maintained control over his victims through, among other things, physical violence, promises of career opportunities, granting and threatening to withhold financial support.”

During and separate from Freak Offs, he, among other things, “hit, kicked, threw objects at, and dragged victims, at times, by their hair,” according to the indictment. “These assaults often resulted in injuries that took days or weeks to heal.”

Other control tactics included engaging more psychological and chemical levers.

Diddy allegedly kept close tabs on victims by “tracking their whereabouts, dictating the victims' appearance, monitoring their medical records, controlling their housing, and supplying them with controlled substances.”

But what if someone spoke up, talked back or tried resisting an order, demand – or participation in the dreaded Freak Offs?

They were typically swiftly put in their place, with Diddy threatening victims' careers and livelihoods, prosecutors allege, noting that he and his enforcers used kidnapping, arson and waving guns at victims to ensure their lips stayed sealed.

He also allegedly forced victims “into hiding” with staffers watching them for days to make sure the wounds and bruises healed and couldn’t be visible to the person’s friends, family – or paparazzi.

When certain allegations of his violent nature started to surface, he also called victims and coached them on what to say to sow doubt – even recording conversations in an attempt to “change the narrative,” court documents stated.

“Victims believed they could not refuse Combs' demands without risking their financial or job security or without repercussions in the form of physical or emotional abuse,” the indictment stated.

“Combs also used the sensitive, embarrassing, and incriminating recordings that he made during Freak Offs as collateral to ensure the continued obedience and silence of the victims.”

 

Here is a collection of still images from the YouTube channel, Law & Crime Network.

To see the full story on the allegations against the Alexander Brothers, “15 Disturbing Claims in Wealthy Real Estate Brothers’ Rape Lawsuits,” click here.

Alexander Brothers – real estate wranglers for uber Rich – arrested for sex trafficking

Using their wealth, looks and status to manipulate women by flying them to exotic locales, fancy restaurants and exclusive events was also the alleged strategy of the “Alexander” brothers.

This case of trafficking and sexual assaults involved three siblings: a pair of twins and former real estate agents to the wealthy and famous, along with their brother, an executive in a private security firm owned by their wealthy family. 

Last month, federal authorities arrested Tal, Alon and Oren Alexander in Miami, charging them with three counts of sex trafficking, according to a recently unsealed indictment.

Tal and Oren Alexander, at one point top real estate agents for the lux crowd, and their brother Alon, are accused of using ritzy travel, luxury locales and other lures to “draw dozens of women to isolated locations and then gang rape them in a sex trafficking operation lasting from 2010 to 2021,” according to Forbes.

Some women were allegedly “enticed to be alone with one or more of the brothers under the guise of starting a relationship, others were participants in trips and events organized months in advance and others were chosen at random, and sometimes assaulted within hours of meeting,” the article stated, citing the indictment.

To carry out and facilitate their sex trafficking scheme, the Alexander brothers used “deception, fraud, and coercion to cause victims to travel with them or meet them in private locations for various trips and events,” prosecutors said.  

How did they find these women?

They found the victims “to invite to these events through, among other things, social media, dating applications, in person encounters, or through the use of party promoters who would recruit women for these events,” the indictment stated.

The brothers – similar to the allegations against Diddy – stand accused of using a bevy of legal and illegal chemicals to make their victims more complacent and compliant, including alcohol, cocaine, mushrooms and GHB, a "date-rape" drug.

The indictment stated the drugs impaired some women to the point they couldn’t fight back, passed out and blacked out – not remembering certain events.

Prosecutors also state the men deliberately ignored women’s pleas to stop when they were coherent enough to resist and, in some cases, egged each other on while physically restraining victims – laughing afterward about their conquests. 

Forbes also noted that they allegedly engaged in these actions with little remorse.

The report cited a motion filed in court last month that included text messages allegedly sent between the brothers discussing pooling their resources to fly "bitches" to parties, what illicit and prescription drugs they should bring along and safeguarding their reputations if "some hoe" spoke out about their actions.

The charges come after the brothers were accused of rape in March and June of 2024.

“The Alexander brothers allegedly conspired using their wealth and status to prey on innocent women, coercing them into engaging in sexual acts,” FBI Assistant Director in Charge James E. Dennehy said.

“We will not allow this type of alleged behavior to go unimpeded,” he said in a press release. “Predators forcefully coercing victims into sexual acts cannot and will not be tolerated.”  

More than skin deep – the downfall of Abercrombie & Fitch and its shallow, craven CEO

Abercrombie & Fitch, founded in 1892, was an elite outdoor retailer before becoming a dominant mall brand in the 1990s and 2000s under CEO Mike Jeffries under the auspices that shopping in the store made you part of the good looking, cool kids club.

But Jeffries faced intense criticism for the controversial "looks policy" in the stores that required employees to fit a narrow aesthetic standard and led to multiple discrimination lawsuits.

The company's exclusionary marketing approach, combined with changing youth fashion trends and scandals, including allegations of sexual exploitation against Jeffries in 2023, led to declining sales and forced the brand to dramatically overhaul its image.

The store continues to operate today, but with a more inclusive and welcoming marketing strategy – that employees and shoppers of all body types are welcome.

Federal authorities investigated the allegations and arrested Jeffries, along with Matthew Smith and James Jacobson, for charges including sex trafficking and engaging in interstate prostitution.

The 16-count indictment alleges that between December 2008 and March 2015, Jeffries, Smith and Jacobson used a combination of force, fraud and coercion to traffic men while operating a prostitution enterprise.

The indictment highlights the alleged “abhorrent behavior of Michael Jeffries, Matthew Smith, and James Jacobson,” said Dennehy, the FBI Assistant Director, in a prepared statement.

“The defendants allegedly preyed on the hopes and dreams of their victims by exploiting, abusing, and silencing them to fulfill their own desires, with insidious secret intentions,” he said.

The indictment notes that from 1992 to 2014, while Jeffries was the CEO of Abercrombie, he and Smith – his life partner – employed Jacobson to “recruit, interview and hire men to perform commercial sex acts” for them.

And this expanded to a well-oiled international sex trafficking operation from 2008 to 2015.

Jeffries and Smith not only “relied on their financial resources and Jeffries’ power as the CEO of Abercrombie, but also on numerous others, including Jacobson and a network of employees, contractors and security professionals, to operate this venture, which was dedicated to fulfilling their sexual desires,” the indictment stated.

Jeffries and Smith paid for dozens of men to travel within the United States and internationally to places like the Hamptons on Long Island, New York City and hotels in England, France, Italy, Morocco and Saint Barthélémy, for the purpose of commercial sex, prosecutors stated.

During “tryouts” of potential candidates, Jacobson typically required that the candidates first engage in commercial sex acts with him, according to the indictment.

For example, Jeffries, Smith, Jacobson and other facilitators acting at their behest:

• Employed a referral system and interview process that did not inform men of the details of the Sex Events before they attended, including the full extent and nature of the sexual activity that would be required of the men at the Sex Events;
• Caused men to believe that attending the Sex Events could yield modeling opportunities with Abercrombie or otherwise benefit their careers – and that any resistance or non-compliance could de-rail their future;
• Required men to relinquish their personal items, including clothing, wallets and cellular phones, and store them in an inaccessible location during the Sex Events, while also requiring them to sign non-disclosure agreements to keep them quiet;

They were also not above using threats and actual violence to get what they wanted.

“On more than one occasion when men did not or could not consent, Jeffries and Smith violated the bodily integrity of the men by subjecting them, or continuing to subject them, to invasive sexual and violent contact by body parts and other objects,” according to prosecutors.

They also forced chemicals and drugs on the men, whether it was their bodies or minds that were unwilling.

Jeffries and Smith “directed others to inject, or personally injected, men with an erection-inducing substance for the purpose of causing the men to engage in sex acts the men were incapable or unwilling to engage in,” according to the indictment.

Many of the victims, at least one of whom was as young as 19 years old, were “financially vulnerable and aspired to become models in the fashion industry,” with some being plucked right from stocking store shelves to the equivalent of sex slaves.  

This case is yet another example of rich elites using their “wealth, power, or reputation to manipulate and control others for their personal gratification,” Dennehy said. “The FBI and our partners won’t allow these criminal acts to go unchecked.”

The celebrity sex trafficking hit list: Once rich, respected industry titans, now jailed, jilted – or dead

Here is a wrap-up of some of the notable wealthy, politically-connected and/or entertainment powerbrokers who have come crashing down and are either jailed, sentenced, cancelled – or potentially perished.

Harvey Weinstein – The former Hollywood producer’s downfall began with explosive 2017 reports in The New York Times and The New Yorker revealing decades of sexual assault allegations, leading to the "Me Too" movement.

The investigations and revelations ultimately resulted in Weinstein's conviction and imprisonment on multiple sexual assault charges in both New York and Los Angeles. In 2024, New York’s highest court thew out his rape conviction on procedural grounds.

NXIVM founder Keith Raniere – Convicted in 2019 of sex trafficking, racketeering, and forced labor conspiracy. Sentenced to 120 years in prison.

Jeffrey Epstein – Charged with sex trafficking of minors and conspiracy to engage in sex trafficking. He was arrested in 2019 and died in custody while awaiting trial.

Peter Nygard – Canadian fashion executive arrested in 2020 on sex trafficking charges spanning decades. Faced charges in both the US and Canada. Sentenced to 11 years in prison in September.

Ghislaine Maxwell – Convicted in 2021 of sex trafficking minors and conspiracy charges related to her role in Epstein's activities. Currently serving a 20-year prison sentence.

R. Kelly – While primarily convicted of racketeering, his charges included sexual exploitation of children and forced labor which constituted trafficking elements. Sentenced in 2022 to 30 years in prison.

Jean-Luc Brunel – French modeling agent charged with rape and trafficking in connection with Epstein's case. Died in custody in 2022 while awaiting trial.

Andrew and Tristan Tate – Arrested in Dec. 2022 with two other defendants and subsequently charged in Romania with human trafficking, rape, and forming an organized crime group.

Authorities alleged that the brothers formed an organized criminal group in 2021 to commit human trafficking in Romania, but also had tendrils and illicit acts in other countries including the US and the UK.

In prosecuting documents, the seven alleged victims stated they were recruited by the Tate brothers through false promises of love and marriage and were later taken to buildings in Ilfov county in Romania where they were intimidated, placed under constant surveillance and control and forced into debt.

The brothers and other defendants allegedly then forced the women to take part in pornography which was later shared on social media.

In his high-profile social media channel, where Tate acts the part of a buff, popular, cigar-chomping Alpha male with big houses and fancy cars, he actually laughed at how easy it was to take advantage of women – including tricking them to get naked, get on a live stream and do his bidding.

Lifestyles of the rich and shameless: Champagne wishes and caviar dreams – turned nightmares 

Here is a look at the playbook of tactics, tricks and transactional tells used by celebrities in their sex trafficking schemes that could help AML teams uncover and report on suspected illicit activities:

Legitimate Business Front Tactics

• Modeling agencies: Brunel's MC2 Model Management and Nygard's fashion empire used "scouting trips" to recruit victims, often targeting minors from economically disadvantaged areas. Watch for agencies making regular payments to "scouts" in high-risk regions.
• Entertainment companies: Look for irregular payment patterns to "dancers," "actresses," or "models" that don't match industry standards or legitimate talent contracts.
• Fashion brands: Monitor for excessive expenses for "private casting calls" or "exclusive photoshoots" in residential properties rather than professional studios.
• Recording studios, real estate: Diddy allegedly used his vast business and real estate holdings to conceal the trips were for illicit sex acts and trafficked victims. Similarly, the Alexander brothers allegedly used the cover of flying to connect with real estate sellers and buyers – when the real goal was luring and exploiting women.

Power Dynamic Exploitation

• Career promises: Traffickers like Epstein used promises of educational scholarships and modeling contracts, visible through irregular tuition payments or model contract advances.
• Exclusive access: Watch for large cash withdrawals or luxury purchases before private events, especially when paired with bulk hotel room bookings.
• Industry influence: Monitor for suspicious patterns of payments to young "personal assistants" or "interns" well above market rates.
• Ticket to ride: Monitor for excessive purchases of things like expensive airline tickets to multiple female names in middle class jurisdictions and bookings in high-end hotels, accompanied by bills in the hundreds of dollars in fancy restaurants and bars.

Financial Typologies to Monitor

• Structured wire transfers just under reporting thresholds to overseas "talent agencies"
• Regular payments to travel fixers who book private jets and handle immigration paperwork
• Complex networks of shell companies moving money between jurisdictions known for trafficking
• Suspicious patterns of hotel bookings, especially multiple rooms at luxury properties under different company names
• Large cash withdrawals followed by luxury goods purchases (often used to groom victims)

Detection Strategies

• Cross-reference visa applications with wire transfers to identify potential victim recruitment
• Monitor for irregular flight manifests on private jets, especially with changing passenger lists
• Track payments to "party planners" or "event coordinators" in multiple jurisdictions
• Look for property rentals in luxury areas with high utility usage but minimal visible business activity
• Watch for sudden increases in payments to specific regions known for trafficking

Key Contrasts with Traditional Organized Crime

• Celebrity traffickers often use high-end hotels versus safe houses
• Transaction values are typically higher ($10,000+ vs. smaller amounts)
• More sophisticated use of corporate structures and offshore accounts
• Better document forgery and visa fraud schemes
• Higher focus on reputation management through legitimate business activities

Red Flag Transaction Patterns of the Stars

• Regular payments to massage parlors or wellness centers that don't match business profiles
• Frequent use of cryptocurrency to pay for luxury services
• Multiple credit cards issued to different "assistants" with unusual spending patterns
• Regular payments to reputation management firms and private security
• Suspicious patterns of gifts or payments to immigration attorneys

While recent victories against the powerful and corrupt bring hope – sex trafficking still a global challenge

In recent years, countries like the U.S., United Kingdom and others have updated and upgraded certain laws, in some cases directly related to country-wide AML objectives, to better uncover, report, investigate and prosecute human trafficking.

Here are some examples:

In 2021, the U.S. Financial Crimes Enforcement Network (FinCEN) formally designated human trafficking as one of eight national anti-money laundering priorities under the Anti-Money Laundering Act of 2020. This significant move required financial institutions to specifically incorporate human trafficking detection more forcefully into their AML compliance programs.

Key elements of the U.S. approach included:

·      More, better SARs: Enhanced suspicious activity reporting requirements focusing on specific human trafficking indicators, like structured deposits at multiple branches, funnel account activity, and unusual patterns involving hotels, massage businesses, and labor recruiters.

·      Information sharing: Required collaboration between financial institutions and law enforcement through trafficking-focused information sharing under Section 314(b) of the USA PATRIOT Act.

·      Crypto connections: New guidance for banks to look for intersections between human trafficking and other financial crimes, particularly cryptocurrency transactions, trade-based money laundering, and real estate investments.

·      Risky businesses: Specific focus on monitoring transactions involving high-risk business types often associated with trafficking, including temporary staffing agencies, nail salons, small retail businesses, and cash-intensive service industries.

As well, in June 2023, FinCEN provided updated guidance to financial institutions about specific transaction patterns and customer behaviors that may indicate human trafficking activity, particularly emphasizing the convergence with cryptocurrency and online payment platforms.

Here are some examples of other countries following suit:

• Canada (2024): The Canadian government released the "2024 Annual Report to Parliament on the Fighting Against Forced Labour in Supply Chains Act," detailing efforts to address forced labor within Canadian supply chains. As well, in 2021, The Canadian government enacted the "Fighting Against Forced Labour and Child Labour in Supply Chains Act," which requires businesses to report on measures taken to prevent and reduce the risk of forced or child labor within their supply chains.
• United Kingdom (2024): The UK government announced plans to introduce a new sanctions regime targeting individuals and entities involved in human trafficking and organized immigration crime, aiming to disrupt these networks by freezing assets and restricting movements. In tandem, last year, the UK and Germany signed a "joint action plan" to combat people-smuggling gangs, focusing on intelligence sharing and targeting the financial operations behind these networks.
• Australia (2024): Australia appointed an Anti-Slavery Commissioner and reformed the Modern Slavery Act to strengthen measures against forced labor. Prior to that, in 2022, the Australian government initiated a review of the Modern Slavery Act 2018 to assess its effectiveness and consider potential amendments to strengthen compliance requirements for businesses and enhance protections for victims.
• Netherlands (2023): The Dutch government proposed amendments to existing legislation to increase penalties for human trafficking offenses and enhance victim support services, aiming to improve the country's response to trafficking. Moreover, 2023 saw Dutch courts convict 57 traffickers, including 41 for sex trafficking and five for labor trafficking, reflecting ongoing efforts to prosecute human trafficking offenses.
• Germany (2024): Germany agreed to close a legal loophole that allowed human traffickers to store boats used for crossing the English Channel, making it a criminal offense to facilitate the smuggling of migrants to the UK. Further, Germany prohibited convicted traffickers from being selected for public contracts and provided funding to several anti-trafficking programs to enhance prevention and support for victims.

With so many countries focusing on this crime, and AML professionals working more closely than ever with other banks and local, domestic and international law enforcement, it gives hope that more victims can be saved or more criminal trafficking groups – including those run by celebrities – will be crushed.

Key to stamping out trafficking will also be shielding those most at risk of being trafficking and arming them with knowledge.

In many cases, traffickers pluck victims at their most physically and emotionally vulnerable and financially desperate: someone who ran away from home, a teen in foster care, a drug addict, a recent immigrant duped into thinking they owe a life-debt to traffickers and others.

By countries more aggressively investigating this crime and creating more resources to care for those who could be trafficked – preventing them from being victimized in the first place – along with stronger laws and more bank investigation teams allied together, the fight against this dread scourge will continue and possibly even turn in favor of he good guys, with more opportunities to change, and even save lives.