preventing human trafficking indicators
TRANSCRIPT
Preventing human trafficking: Global issue, calling Canada
Understanding, identifying and ending trade in human lives
PR
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CT In an effort to support our collective on-going education and
awareness, our team at Grant Thornton has worked to further understand and identify relevant indicators of Human
Trafficking activity. This document provides information organized by both industry and by participant role.
This document is meant to be a contribution, we know there is more to learn and much to do. Please review, share and
contribute; please act and support Project Protect.
Have you seen and read:
FINTRAC's operational alert:
http://www.fintrac.gc.ca/publications/operation/oai-hts-eng.asp
Grant Thornton's backgrounder:
http://www.grantthornton.ca/resources/insights/reports/Human_Trafficking_10-11-16_WEB.pdf
Human Trafficking: How to recognize and report suspicious activity 2
Red flag indicators
by industry
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Hospitality & Accommodation
Property Management
Automotive
Financial Services
Transportation & Travel
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Indicators to assist with the detection of Human Trafficking activity:
• Individuals who are making multiple hotel/ motel bookings in unreasonable patterns such as 2 /3 times a day, 4/5 times per week, or 15/20 times a month
• Individuals with minimal or no personal items when checking in• Clients who have excessive visitors during their stay• Clients who appear to be in a very young age group accompanied by
other individuals• Individuals who pay in cash or pre paid credit cards and repeatedly
request same suite or floor• Individuals who have no control over possession of money or
identification• Patrons that are apprehensive about providing their full names,
home address or vehicle information when registering • Refusal of cleaning services for multiple days• Several individuals loitering in hallways or in the vicinity of the
rooms• Individuals who enter/exit through the side or rear entrances• Rooms are stocked with excessive amounts of computers, cell
phones, pagers and point of sale machines• Clients who exhibit signs of fear, anxiety, tension, submission,
and/or nervousness
Hotel/motel staff, housekeeping, maintenance and room service staff
often are in a position to see potential signs of Human Trafficking
as they have direct or indirect interaction with both Traffickers and
Victims/Survivors.
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Property Management / Rental PropertiesWhile the list below is not exhaustive, these are several indicators to watch out for:
• Multiple units rented by same individuals or numbered companies• High traffic at all times of the day• Large cash payments for rental fees, either upfront or on monthly
basis• Young individuals renting multiple units or rental units that appear to
be beyond their expected source of funds, just does not make sense
For some time now, the hospitality industry has increased its awareness in educating staff and owners on what to watch for if they observe signs that someone is being trafficked. Discussions with law enforcement have identified that Traffickers are changing tactics and shifting to using rental properties to conduct the criminal activity.
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Automotive / Car DealershipsThrough discussions with law enforcement, it was learned that Traffickers will have Victims/Survivors lease vehicles on their behalf to obscure their identity and association with the vehicle or have a credit check performed.
The following are indicators to assist with the detection Human Trafficking activity:
• Individuals who appear to be young applying for leases on high end luxury vehicles
• Large cash payments for luxury vehicles• Applicants who have no income or proper credit history
applying for a lease with considerable upfront funds (cash)• Trade in of vehicles for higher end-models• Individuals who throughout the lease application process
appear to be unable to answer questions regarding personal finances, identification, income and personal details (i.e. address)
• Individuals accompanied by other individuals who do not appear to be related or co-signers, who respond to all questions being asked
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The following are indicators to assist with the detection of Human Trafficking activity:
• Transactional review of client accounts looking for the booking of hotels, motels, and rental condos (e.g. Airbnb) to identify if client is making bookings in the same geographic location or area of residence stated in their client profile/account
• Repeated transactions which appear excessive for the period (daily / weekly / monthly)
• Multiple purchases for VISA and MasterCard pre-paid cards
• Review of client profile with multiple rental properties (whose stated net worth does not seem appropriate for multiple rentals) with high volume of cash payments, or payments to real estate agents
• Transactions of property management companies who are regularly depositing cash
• Account reviews reveal multiple payments to virtual advertising companies or sites such as:
Backpage EMP Media Vibe Media
Darkside Productions Madom Fox seekingarrangement .com
whatyourprice.com
Many Financial Institutions have been focusing efforts to combat Human Trafficking by making use of rigorous transaction monitoring and partnerships with IT and software
companies to create reliable alerts and rules to detect potentially criminal activity.
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When reviewing the profiles of clients in the age group of (approx.) 17-23, and analyzing the flow of funds and transactions, focus on:
• How many accounts does the client have?
• More than one or two accounts? Does this make sense considering the client's age?
• Is there a high velocity of transactions, money moving in and out of the account?
• Are there multiple ATM cash deposits? At different times a day? Occurring at odd times throughout the day and at night?
• Is there depletion/disbursement of funds? Usually done via email money transfer.
• Does a client in a younger age group have an account showing multiple payments or transactions for leasing and purchasing high end vehicles? Sometimes used to obscure the true user and owner of the vehicle.
• Client accounts show high multiples of transactions with food delivery companies such: Ubereats, Doordash, Justeats and others.
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• Individuals that lack control or possession of identification and travel documents
• Traveler appears to be coached on what to say to law enforcement and immigration officials
• Individuals that are unable to answer seemingly basic questions about travel plans (i.e. itinerary, individuals they are visiting, address where they are staying during their trip)
• Individuals unable to provide details of their departure location, destination, or flight information
• Traveler who can't move freely in an airport or on a plane, or they are being closely watched or followed
• Individuals wearing clothing and/or overall appearance that does not align with route of travel, weather
The number of individuals trafficked across international borders each year keeps growing as global criminal infrastructures engaged in human trafficking continue to benefit from the illicit activity.
Airports, train and bus stations are hubs for human trafficking where some of the following indicators can be observed:
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Discussions with law enforcement officers have identified the following indicators particular to the behaviors of Traffickers:
• Traffickers generally answer questions for victims/survivors and/or provide evasive answers
• They observe the victim/survivor persistently
• When forced to interact with others, the trafficker will often pose as a relative
• Individuals usually buy food with cash & pre-paid cards. The pre paid cards are used as payment for hotel rooms at hotels as cash is typically not accepted
• Traffickers advertise the victims/survivors through online advertising sites
• Traffickers will use a currency exchange provider, or various different ones, to take cash and convert it into digital currency. If the currency exchanger provider accepts cash or email money transfers, the individual sets up a digital wallet to receive the digital currency.
Participant Role
in the Criminal
Activity:
Trafficker
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Discussions with law enforcement officers have identified the following indicators particular to the behaviors of Victims/Survivors:
• While the age groups of victims fluctuate, these are potential indicators:
o 14 – 17 age – funds are deposited and then quickly or repeatedly dispersed/depleted to other individuals; not used as savings/accumulation accounts.
o 18 – 23 age –account activity is atypical; money comes in and goes out right away, no evidence that the account is being used for expected living, day to day expenses
• Individual makes multiple cash deposits via ATM into their own account or the accounts of others
• Money moves (often repeatedly) from the individual's account to another party (e.g. the Trafficker), often via email money transfer, or money is pulled out from the account directly by the Trafficker
Participant Role
in the Criminal
Activity:
Victim/Survivor
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Discussions with law enforcement officers have identified the following indicators particular to the behaviors of Buyers:
Potential indicators or pattern of activity for the buyers of human trafficked activity:
• Hotel/Motel bookings in repetitive patterns, same day of the week or same hotel, and occurs within the same city/geographic location of where they reside
• Cash withdrawals (payments) and email money transfer to individuals where no apparent relationship seems to exist
• Transactions on internet sites where Traffickers advertise; e.g.:
Whatyourprice.com
Madom Fox
Backpage.com
Participant Role
in the Criminal
Activity:
Buyer
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We can all make a difference and speak out when unusual behavior and risk factors of human trafficking are observed in our daily lives. The Royal Canadian Mounted Police recommends that any instances where suspicion of human trafficking, individuals should do one of the following:
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• If you or someone you know is being exploited, contact your local police.
• If you or someone you know needs help, speak to a trusted adult (family member, teacher or school counselor), or contact a counselor anonymously at the Kids Help Phone at 1-800-668-6868 or online at www.kidshelpphone.ca
• If you wish to report a crime anonymously, call Crime Stoppers at 1-800-222-TIPS (8477)
4http://www.rcmp-grc.gc.ca/ht-tp/q-a-trafficking-traite-eng.htm#q13
Note: A single indicator is not necessarily indicative ofhuman trafficking. Indicators and other facts surrounding afinancial transaction or activity should be considered as awhole.
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For more information on how you can recognize suspicious activity please
contact a Grant Thornton advisor:
Jennifer Fiddian-Green, CPA, CMA, CA-IFA,
CFE, CFI, BA (Hons)
Partner
T +1 416 360 4957
Robert Osbourne, CAMS, Ad. Dip, BSc
(Hons)
Senior Manager
T +1 416 360 5031
Caroline Hillyard, CPA, CA, CA-IFA, CFF
Senior Manager
T +1 416 607 2716
Sandy Boucher, BSc, CFE
Senior Investigator
T +1 416 369 7027
Patrick Ho, CPA, CA, CFF,
CBV, CAMS
Senior Manager
T +1 416 369 6427
Albina Alimerko, CAMS, CFE
Manager
T +1 416 369 7138
Adina Dediu, CFE, BA (Hons)
Senior Associate
T +1 416 369 6423
Samantha Zive, BA, MIS
Senior Associate
T +1 416 777 6149
Andres Betancourt, CAMS, CFCS
Senior Associate
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