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“Human trafficking is a multi-billion dollar industry where perpetrators profit from the control and exploitation of others. While it can be found during the Super Bowl, it can also be found at motorcycle rallies in South Dakota, in the fields of Florida, in gangs in California, and in brothels in Washington, D.C. It’s modern slavery, and it affects every corner of the country.” Distinct yet under identified aspect of human trafficking is forced criminality forced to commit commercial sex acts …and then prosecuted by officials for prostitution Victims are PEOPLE SMUGGLING DRUG TRAFFICKING CORRUPT PRACTICES THEFT ARMS TRAFFICKING TAX EVASION TERRORISM “Banks asleep at the switch need to wake up. . . Bank Secrecy Act applies to more than just drug and terrorist financing.” Now that’s a warning… Aimed at addressing growing problem of domestic sex trafficking of children in U.S. 74 dedicated task forces and working groups involving federal, state, local law enforcement and U.S. Attorney’s Offices with Over 100 Victim Specialists assigned 6000 children rescued 2500 pimps, madams, and their associates convicted lengthy sentences including 30 life sentences $3.1 million seized assets (property, vehicles, monetary) • 25 defendants indicted in sex trafficking organization in GA • 35 year old leader sentenced to life in prison • • • Trafficking ring traded women like slaves throughout southeastern U.S. As many as 30 migrant workers stood in line outside shacks on farms in NC and GA, waiting to have sex with women Women were shuttled to other farms to relive the horror "I'm happy at the sentence but at the same time I'm sad, because I know for every 10 women rescued, there are 50 to 100 more women brought in by the traffickers. Unfortunately, they're not 18 or 20 year-olds anymore. They're minors as young as 13. They're little girls." • 14 defendants and 12 victims • Matriarch running enterprise paid smugglers to bring victims to U.S. • • Victims were undocumented Mexican and Honduran nationals as young as 14 years old Matriarch determined rates for sex acts based on age and attractiveness of female • Charged $500/hour or $250/half hour for youngest and prettiest victim • Another victim’s rate was $70 for 15 min. • • • For every sex act, enterprise also charged $20 fee ($5 admission and $15 for access to prostitution room and condoms) In 18 months, enterprise acquired $1.2M from $20 fee alone Conspirators laundered money and used cashier’s checks totaling less than $10,000 to avoid reporting requirements • Sixteen children as young as 13 rescued • More than 45 pimps and associates arrested • Some pimps travelled from other states to force women and children to have sex with Super Bowl tourists “High-profile special events . . . have become lucrative opportunities for child prostitution criminal enterprises." Ron Hosko, FBI Human trafficking is a "specified unlawful activity" under U.S. primary money laundering law Transactions conducted with proceeds from trafficking humans, or used to further trafficking operations can be prosecuted as money laundering offenses. Director - criminal prosecutor for 15 years IT modernization & FinCEN Query Enhanced data mining & analytical capability New reports - slice and dice information in much more advanced way Tie together threats that before seemed separate Committed to making this central role for FinCEN “Follow the money” First line of defense: “you” “financial institutions simply cannot cut corners on compliance… failing to adopt and maintain a real compliance structure will have serious consequences.” former USDOJ Criminal Chief Lanny Breuer News reports of arrests, searches, indictments and prosecutions 314(b) notifications from another bank Subpoenas National Security Letters Open source information Powerful analytical programs to make links Transactional observations • Training and awareness • Adopt FinCEN Red Flags • Join ongoing law enforcement sharing initiatives to refine indicators and red flags • Analytics to identify networks • Convergence of AML and Fraud • Use of 314(b) • Operation Cornerstone (ICE)