Human Trafficking

Criminals derive illicit proceeds by exploiting individuals through forced labor, sexual exploitation, or other coercive means. They frequently rely on front or shell companies – such as massage businesses, bars, or recruitment agencies – to co-mingle illicit funds with legitimate revenue. Funds may also be hidden through false payroll and underreported wages, especially in high-risk labor markets. Adversaries commonly structure or layer transactions across multiple jurisdictions through wires or funnel accounts, complicating detection and tracing. Financial institutions struggle to detect such activity due to the unremarkable nature of many transactions and unreliable risk-factor automation, which traffickers exploit. The ultimate objective involves reintegrating illicit funds into the financial system while masking connections to trafficking victims.

[
Code
T0058
]
[
Name
Human Trafficking
]
[
Version
1.0
]
[
Parent Technique
]
[
Risk
Customer Risk, Jurisdictional Risk
]
[
Created
2025-02-13
]
[
Modified
2025-04-08
]

Modern Slavery

Sex Trafficking

Forced Labor

Tactics

Human traffickers forcibly exploit victims for labor or sexual services to generate illicit proceeds, forming the raw capital that must subsequently be laundered.

Risks

RS0001
|
Customer Risk
|

Traffickers use front or shell companies (e.g., massage parlors, recruitment agencies) to conceal the true ownership and nature of activities tied to forced labor or sexual exploitation. By falsifying payroll records and underreporting wages, they blend illicit proceeds with legitimate revenue, exploiting vulnerabilities in customer due diligence that fail to identify the real controllers and beneficiaries of these businesses.

RS0004
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Jurisdictional Risk
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Traffickers frequently move and layer funds across multiple jurisdictions, particularly those with weaker AML enforcement. This complicates detection and limits authorities' ability to trace proceeds back to forced labor or sexual exploitation.

Indicators

IND00207
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Rapid investment in high-value assets like real estate, luxury vehicles, or other expensive property shortly after receiving large, unexplained deposits.

IND00216
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Reluctance or failure to provide thorough documentation regarding the source of funds or nature of business operations during customer due diligence procedures.

IND01858
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Funds deposited in one region and quickly withdrawn in another, lacking a clear business rationale.

IND01859
|

Frequent large cash deposits followed by immediate transfers with no clear economic purpose or explanation.

IND01860
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Multiple cross-border wire transfers sent to and received from jurisdictions known for weak AML controls or high incidences of human trafficking.

IND01861
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Wires to high-risk jurisdictions or personal accounts not clearly tied to the business.

IND01862
|

Frequent international remittances from individuals with no documented or verifiable income streams.

IND01863
|

Multiple accounts in the same address, with high-volume transactions inconsistent with the stated business/profile.

IND01864
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Frequent cash deposits/withdrawals, especially round sums just under reporting thresholds.

IND01865
|

Hotel, hospitality, agriculture, construction, or manufacturing businesses with unusually high payment volumes at irregular hours and frequent employee turnover lacking formal HR records.

IND01866
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Frequent or large transaction flows from or to border or port cities known for trafficking, without legitimate business justification or corresponding documentation.

IND01867
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Multiple cross-border transfers from different male payers to a single female recipient in a high-risk jurisdiction, lacking any clear personal or commercial relationship.

IND01868
|

Unexplained or inconsistent payroll patterns, including deposits to accounts not belonging to verified employees and recurring wage payments under various employee names.

IND01869
|

Recruitment or staffing agencies with minimal documented placements yet significant wage disbursements to individuals lacking legitimate employment records or verification.

Data Sources

  • Consolidates information on regions and countries known for weak AML controls or prevalent human trafficking.
  • Supports transaction monitoring by highlighting high-risk corridors or suspicious geographic flows.
  • Assists in prioritizing reviews of funds passing through trafficking hotspots or poorly regulated jurisdictions.
  • Provide comprehensive records of deposits, withdrawals, wire transfers, and other account movements.
  • Enable identification of recurring structuring or layering patterns typical of trafficking networks.
  • Help detect funnel account usage and apparent co-mingling of illicit funds from forced labor or sexual exploitation.
  • Provide details of employee identities, roles, and payroll data.
  • Help identify false or suspicious wage payments, non-existent employees, and underreported labor in potential forced-labor fronts.
  • Enable cross-checking payroll expenses against actual workforce operations to detect exploitation patterns.
  • Detail revenue figures, operational capacity, and expenses for businesses.
  • Reveal discrepancies in claimed operations, such as bars or massage parlors, when fronts are used to launder trafficking proceeds.
  • Highlight unusual operational patterns or inflated revenues indicating forced labor exploitation.
  • Document job postings and candidate placements through recruitment agencies.
  • Detect minimal legitimate hires but significant wage flows indicative of human trafficking fronts.
  • Uncover nonexistent positions or misrepresented roles used to funnel illicit proceeds.
  • Contains verified customer identities, beneficial ownership details, and risk profiles.
  • Allows verification of inconsistent or incomplete documentation, especially when customers claim legitimate business while concealing proceeds from forced labor or sexual exploitation.
  • Supports detection of atypical or unexplained changes in customer information and account activities.
  • Document ownership and transactions of real property and valuables.
  • Enable detection of sudden acquisitions funded by unexplained deposits potentially tied to trafficking proceeds.
  • Help trace beneficial owners of real estate or luxury items used to launder illicit funds from forced labor or sexual exploitation.
  • Provide details of funds transfers between different jurisdictions, including amounts, participating institutions, and settlement processes.
  • Help identify large or frequent transnational movements inconsistent with normal business activities, which are common in trafficking networks.
  • Aid in tracing layered transactions across multiple borders to obscure illicit origins.
  • Capture transactional origin and destination details with associated geolocation.
  • Highlight frequent remittances or financial flows to zones at high risk for human trafficking.
  • Cross-reference with other records to confirm suspicious movement of funds tied to exploitation networks.

Provides official registration details, ownership structures, and historical changes for businesses. By reviewing these records, investigators can:

  • Identify undisclosed beneficial owners or shell companies concealing proceeds from forced labor or sexual exploitation.
  • Verify the legitimacy of corporate entities presented as recruitment agencies, bars, or massage parlors commonly used to funnel illicit funds.
  • Detect connections between entities and higher-risk individuals or suspicious business networks, aiding in uncovering human trafficking operations.

Mitigations

Conduct thorough checks on businesses operating in the hospitality, entertainment, or labor recruiting sectors to detect forced labor or sexual exploitation. This includes verifying employee rosters, comparing payroll data to actual staff, confirming beneficial ownership for front or shell companies, and reviewing wage disbursement patterns for anomalies that may signal trafficking-related financial flows.

Configure scenario-based alerts for unusual cash deposits and withdrawals, frequent transfers to high-risk jurisdictions lacking a clear economic purpose, and payroll distributions to unverified recipients. Analyze patterns of low-value payments made repeatedly at odd hours, track funneling activity across multiple jurisdictions, and detect interactions with known human-trafficking hotspots or high-risk industries, such as bars, massage parlors, and unlicensed labor agencies.

Use public records, media reports, and external databases to verify the legitimacy of businesses and labor agencies suspected of masking human trafficking operations. Confirm operating permits, actual employee counts, and real corporate addresses or phone numbers. Identify mismatches in local records versus claimed operations to uncover shell entities exploiting forced labor or sexual exploitation networks.

  • Regularly recheck high-risk accounts or businesses exposed to labor or sex trafficking indicators.
  • Review payroll data to confirm employee legitimacy.
  • Monitor sudden shifts in ownership or wages.
  • Escalate new red flags, such as abrupt spikes in international wires to personal accounts.
  • Continuously update risk assessments as operational or employee patterns evolve.

Instruments

  • Human traffickers open multiple bank accounts under the names of shell or front companies (e.g., bars, massage parlors), depositing funds from forced labor or sexual exploitation alongside legitimate revenues.
  • They structure deposits below reporting thresholds or use funnel accounts across jurisdictions, making it difficult to trace the original illicit source.
  • Repeated inter-account transfers further layer the funds, masking the links to trafficking victims and complicating oversight by financial institutions.
IN0013
|
|
  • Offenders invest human trafficking proceeds, such as profits from forced labor or sexual services, in properties, converting illicit cash into seemingly lawful assets.
  • Ownership under personal or corporate names enables them to claim legitimate rental income or future capital gains, obscuring connections to trafficking activities.
  • Real estate investments serve as long-term stores of value, helping traffickers distance illicit funds from the exploitation that generated them.
  • Shell or front businesses accepting card payments label them as legitimate sales, effectively co-mingling funds from trafficking with standard commercial income.
  • Debit cards tied to funnel accounts allow traffickers to withdraw or transfer proceeds across multiple locations, reducing transparent audit trails.
  • Traffickers exploit repeated card transactions to integrate illegal profits into normal commerce, obscuring the actual source of funds tied to forced labor or exploitation.
IN0051
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  • Traffickers often receive cash directly from forced labor sites or sexual services, granting them immediate control over illicit funds.
  • By depositing smaller amounts into multiple bank branches or mingling it with lawful proceeds from front businesses, they avoid raising red flags.
  • The anonymity and portability of cash enable quick placement and layering, reducing transparency and direct associations with trafficking victims.
IN0053
|
|
  • Traffickers purchase high-end vehicles, watches, or other upscale items using illicit cash or through seemingly legitimate front business transactions.
  • These items hold significant value and can be resold or transported, providing traffickers with the flexibility to move, store, or conceal illicit proceeds.
  • Labeling expensive purchases as business expenses or ordinary personal acquisitions helps traffickers mask the true origin of funds derived from forced labor or sexual exploitation.

Service & Products

  • Facilitate fictitious or inflated payroll records, disguising illegal proceeds as wages for coerced labor.
  • Allow traffickers to underreport wages or create phantom employees, making forced labor appear like legitimate employment expenses.
  • Operate under the guise of recruitment or staffing agencies, enabling traffickers to channel exploited laborers and funnel illicit funds through false wage disbursements.
  • Minimize verifiable employment records, increasing the difficulty of tracing and prosecuting forced labor revenues.
  • Serve as the primary account for shell or front businesses to deposit proceeds from trafficking victims, blending illicit and legitimate income streams.
  • Appear as routine commercial activity, reducing AML flags despite underlying forced labor or sexual exploitation revenues.
  • Facilitate cross-border layering of illicit proceeds through funnel accounts, obscuring the flow of funds generated by human trafficking.
  • Complicate detection by swiftly moving money among jurisdictions, breaking transactional links to exploitation sources.
  • Manipulate financial statements to mask revenue generated by forced labor or sexual exploitation as legitimate business transactions.
  • Produce false payroll reports and underreported wages, concealing the real extent of trafficking-related income.
  • Enable the formation and management of front or shell companies (e.g., massage businesses, bars) to co-mingle illicit proceeds of forced labor or sexual exploitation with lawful revenue.
  • Obscure the true owners via complex corporate structures, hindering authorities’ ability to link proceeds to trafficking or exploitation.

Actors

Human traffickers directly generate illicit proceeds from forced labor and sexual exploitation. They:

  • Exploit victims under coercive conditions, profiting from forced services.
  • Channel or conceal these proceeds within the financial system by layering transactions and fabricating corporate records.

Shell or front businesses—such as massage parlors, bars, or recruitment agencies—are used to:

  • Commingle illicit proceeds from forced labor or sexual exploitation with legitimate income.
  • Generate false payrolls or underreport wages, masking the true source of funds and obscuring connections to trafficked persons.

Financial institutions are unwittingly exploited to:

  • Receive deposits and process payments disguised as ordinary commercial transactions.
  • Facilitate cross-border transfers that layer proceeds from forced labor or sexual exploitation, hindering detection due to the routine nature of account activity.

References

  1. FATF (Financial Action Task Force). (2018, July). Financial flows from human trafficking. FATF.https://www.fatf-gafi.org/en/publications/Methodsandtrends/Human-trafficking.html

  2. FINTRAC (Financial Transactions and Reports Analysis Centre of Canada). (2021). Updated indicators: Laundering of proceeds from human trafficking for sexual exploitation. FINTRAC. https://fintrac-canafe.canada.ca/intel/operation/oai-hts-2021-eng

  3. Keatinge, T., Barry, A.M. (2017). Disrupting human trafficking: The role of financial institutions (Whitehall Report 1-17). Royal United Services Institute for Defence and Security Studies. https://www.rusi.org/explore-our-research/publications/whitehall-reports/disrupting-human-trafficking-role-financial-institutions

  4. Financial Crimes Enforcement Network (FinCEN). (2020). Supplemental Advisory on Identifying and Reporting Human Trafficking and Related Activity (FIN-2020-A008). FinCEN.https://www.fincen.gov/resources/advisories/fincen-advisory-fin-2020-a008