Targeting Human Trafficking
U.S. IMMIGRATION and Customs Enforcement (ICE), which is under the U.S. Department of Homeland Security (DHS), is reaching out to the private sector to raise awareness about the international problem of human trafficking and smuggling. As a part of that effort, ICE is holding webinars, including a recent one designed for members of the Association of Certified Anti-Money Laundering Specialists (ACAMS). Leading the webinar was Special Agent Angie Salazar, national program manager of DHS’s Homeland Security Investigations Human Smuggling and Trafficking Unit.
Salazar develops policies and initiatives for ICE’s human trafficking investigative programs, coordinates with other U.S. government agencies involved in investigations and victim services, and conducts training. She has led investigations that have resulted in many successful prosecutions, the apprehension of hundreds of illegal immigrants, and the seizure of more than $5 million in currency and assets.
Pinning down the scope of the world’s human trafficking and smuggling problem isn’t easy. According to a 2004 report by the United Nations Economic Commission for Europe, total annual revenues of traffickers were estimated to range from $5 billion to $9 billion. A 2010 U.S. State Department report estimated that at least 12 million people—primarily women and children—are trafficked annually worldwide. The report examines many of the challenges faced by law enforcement in identifying and breaking up human trafficking and smuggling rings.
Trafficking vs. smuggling. Human trafficking and smuggling often share situational components, said Salazar, but “even though the terms are sometimes used interchangeably, they are two very different crimes.”
Human smuggling involves the illegal importation of people into a country, but both parties are willing participants. Fees paid by illegal aliens to smugglers can range from $1,000 to $3,500 for Mexicans, to $40,000 to $70,000 for Chinese nationals.
Smuggling becomes trafficking when fraud, force, or coercion are introduced into the scenario, and the persons are held against their will for labor or sexual exploitation, Salazar explained. “Smuggling is transportation based; trafficking is exploitation based. Smuggling is a crime against borders; trafficking is a crime against persons.”
The United States is a top destination country. Another is Hong Kong, which has recently seen an increase in human trafficking for domestic service, Salazar said. Western Europe sees many women trafficked for prostitution.
Lured by promises of work, education, or even romance, trafficked victims quickly find themselves as modern-day slaves forced into commercial sex acts, involuntary servitude, and debt bondage. “Individuals we’re seeing from The Philippines, for example, are asked to take out a $25,000 loan [from the traffickers] to obtain a U.S. visa. There is no way that these people, once in the United States, will ever be able to pay off that loan,” she noted.
One case that Salazar discussed painted a grim picture of the lives of individuals in debt bondage. ICE was tipped off about a house in San Diego, where more than a dozen trafficked Mexicans were living in a crawl space beneath a house that had no heat, water, or power. The tip came from one of the victims, a young man from a village in Mexico. The trafficker, Mario, had gone door to door in the village, recruiting people interested in being smuggled to the United States for work.
Mario had promised the recruits housing, food, a job, and transportation. He had also told them that if they didn’t currently have the $2,800 smuggling fee, they could pay him back once they began working. When the victims arrived in California, Mario took their identity documents, told them that he would have them arrested if they tried to leave, and said that if they didn’t repay the smuggling fee and other expenses, he would harm or even kill their families.
When ICE agents interviewed the victims after raiding the home, they found that those who lived in the crawl space paid Mario $400 monthly for the privilege, but they chose this option over living in the upper part of the house and paying him $800 per month. Mario also made them pay $200 per outfit for clothes he bought them at a second-hand shop, and he charged them a finder’s fee for the low-wage jobs he arranged. If the victims needed a ride to work, he charged them $25 each way. Some of the victims had been trapped thusly by Mario for more than two years.
Salazar noted that under U.S. law, trafficked individuals are considered victims regardless of whether they initially consented to being smuggled.
Follow the money. Salazar told her audience that one of the most significant law enforcement techniques for uncovering human trafficking and smuggling has been spotting the telltale signs of financial transactions, “which is why, hopefully, this training will give you new tools and resources to focus on during your daily work to help us identify these crimes.”
She noted that the money trail often leads to the top of the criminal group, allowing it to be completely dismantled. This was the case in the one human smuggling ring broken up by ICE.
In that case, suspicious Western Union wire transfers led agents to a 20-year-old, family-run smuggling group based in Tijuana, Mexico, that bought or stole valid green cards, visas, or other documents that would allow the bearer to legally enter the United States. The smugglers had such a large cache that when they were approached by a would-be bordercrosser, they hunted through the documents to see which ID photo the person most looked like, then took him or her to a family-owned beauty shop for a makeover to increase the resemblance.
The financial investigation revealed that various family members had bank accounts fed by a stream of wire transfers, but no apparent source of the income. They had purchased four single-family homes in the United States, as well as an avocado farm and a strip mall, laundering their illegal income. To obtain mortgages on these properties, they had written notarized letters stating that they had gifted each other the amounts of the down payments. All of their utility bills were paid by wire transfer or cashier’s checks. They had also laundered smuggling money by purchasing 141 motor vehicles.
In another San Diego case, local branches of the Crips and Bloods gangs formed an alliance to traffic prostitutes. Financial records revealed more red flags of trafficking: account deposits had been structured to avoid Bank Secrecy Act-mandated currency transaction reports and deposits were almost entirely even numbered. Proving themselves perhaps not the smartest of crooks, some of the checks deposited into the accounts “had ‘For a good time’ written in the note field,” Salazar said. Additionally, credit cards that were tied to false business fronts were used to lease luxury cars and pay for extravagant vacations. There were also credit card payments for advertising on online escort service Web sites.
Seeing the signs. Last year, DHS initiated the Blue Campaign—an agency-wide effort to combat human trafficking through enhanced public awareness, victim assistance programs, and law enforcement training and initiatives. Part of this campaign involves outreach not only to the banking and financial services sector but also to the travel, agricultural, construction, entertainment, manufacturing, and hospitality industries that are used by traffickers to transport, market, and exploit victims.
Another recently launched initiative is Project STAMP (Smugglers and Traffickers Assets, Monies, and Proceeds). Under the program, DHS seeks to educate the banking and financial sector about the red flags that indicate possible money laundering by human trafficking and smuggling organizations. DHS has identified the following among the examples of suspicious financial transactions to watch for:
Large cash deposits going into one account from multiple locations across state lines.
Cash deposits totaling just under $10,000 (the amount that triggers a Bank Secrecy Act currency transaction report) made at several bank branches.
No deposits originating from customers for services the business purports to conduct.
The purchase of money orders to pay bills instead of writing personal checks.