Human Trafficking, Law Enforcement, and Financial Institutions: An Informative Blog Series, Part 1 of 3

Written by Daniel Lane, CFE, on behalf of the Anti-Human Trafficking Intelligence Initiative (ATII)

Part 1 of a 3 Part #FollowMoneyFightSlavery Blog Series

Introduction to Human Trafficking and Law Enforcement


In 2013, the United Nations’ Office on Drugs and Crime (UNODC) and Europol estimated that the global drug trade was worth nearly $435 billion a year and the United Nations has estimated that $1 trillion has been spent on drug interdiction and incarceration efforts in the past decade.[1] Drug traffickers have garnered the attention of both the United States and foreign law enforcement agencies due to the massive effect that the narcotics trade has on society. In recent years, another illicit trade has begun to spread its’ destructive roots across the globe, accounting for nearly $150 billion in illicit funds; Human Trafficking.

The relationship between human traffickers and money is intrinsic; being the fundamental motivator for carrying out harm amongst the world’s most vulnerable populations. As the global economy continues to expand due to digital commerce and ever-evolving technology, law enforcement has been scrambling to keep pace with the methods human traffickers are employing to carry out their operations. However, law enforcement is not solely responsible for identifying, tracking, and ultimately apprehending these individuals. Financial institutions, of all sizes, play a crucial role in identifying and preventing suspicious transactions from ending up in the wrong hands. But before a more granular view can be undertaken, a broader discussion of agency relationships is necessary.

What Is Human Trafficking?

“Human Trafficking involves the use of force, fraud, or coercion to obtain some type of labor or commercial sex act. Every year, millions of men, women, and children are trafficked worldwide. Traffickers use violence, manipulation, or false promises of jobs or relationships to lure victims into trafficking situations.” [2]

The ILO and Walk Free Foundation estimated there were a total of 25 million victims of forced labor or sexual exploitation in 2016. 16 million people fell victim to private sector forced labor that included domestic, construction, and agricultural work. 4.1 million victims were forced into state-imposed labor and 4.8 million were sexually exploited.[3]

Federal Law Enforcement

This blog installment will cover the federal agencies that are tasked with identifying, disrupting, and apprehending the purveyors of human trafficking. These agencies were selected due to their jurisdictional reach and the important role they play in bringing justice to victims and their families. However, it cannot be stressed enough that these agencies cannot do their critical duties without assistance and communication with state, local, tribal, and international law enforcement agencies.

U.S. Department of the Treasury

Due to the direct impact human traffickers have on the financial system, the United States Department of the Treasury has several tools in their arsenal to assist efforts in eradicating human trafficking. The Treasury Department aims to prevent, protect, and prosecute human traffickers using information gathered through the required Bank Secrecy Act (BSA) reporting that is controlled by the Financial Crimes Enforcement Network (FinCEN). When a financial institution identifies a suspicious activity, they are required to report the transaction(s) using the Suspicious Activity Report (SAR) form. In 2018, FinCEN updated the form to include a checkbox for reporting entities to identify if the potential activity is related to human trafficking.Between August 1, 2018, and August 31, 2019, 10,881 SARs were filed by financial institutions reporting potential human trafficking activity.[4]  We will revisit the BSA, SARs, and FinCEN in the second installment of this blog series, stay tuned!

The Office of Terrorism and Financial Intelligence (TFI) is the intelligence and enforcement function of the Treasury Department and aims to safeguard the financial system and combat terrorist financiers, money launderers, drug, and human traffickers. There are three offices and one bureau that comprise the TFI, and together, coordinate with other federal, state, and local law enforcement agencies to investigate and prosecute human traffickers.

Internal Revenue Service Criminal Investigation Division (IRS-CID)

Although when mentioned, the IRS conjures up nightmares of filing one’s taxes by April 15th, the IRS, is an integral piece of the investigative puzzle. The IRS is largely tasked with determining, assessing, and collecting internal revenue (taxes) in the country, but the IRS employs nearly 2,300 Special Agents within the CID that are tasked with investigating and recommending prosecution for tax evasion and related offenses.[2] More notably, IRS agents assist the Federal Bureau of Investigations (FBI), Drug Enforcement Administration (DEA), U.S. Immigration and Customs Enforcement Homeland Security Investigations (HSI) and Diplomatic Security Service (DSS) with drug and human trafficking investigations from a financial perspective. Agents identify and trace cash, electronic funds, virtual currency, real estate, and other assets that are generated by human and drug traffickers to build strong criminal cases.

U.S. Department of Justice Agencies

Image 2: U.S. Department of Justices as overseen by the U.S. Attorney General [6]

Federal Bureau of Investigations (FBI)

The FBI is perhaps the most famous law enforcement agency in the world and has jurisdiction over federal crimes within the United States. As the principal law enforcement agency operating under the Department of Justice (DOJ), the FBI reports to both the Attorney General and the Director of National Intelligence. Among the 56 field offices, the FBI employs nearly 13,000 Special Agents that are tasked with conducting intelligence, cyber threat mitigation, and investigative operations. Specifically, the Criminal Investigative Division (CID) is the largest within the Criminal, Cyber, Response, and Services Branch of the FBI and employs 4,800 Special Agents. CID has the primary responsibility for investigating violent crime, white-collar crime, and public corruption. [7]

Inter-Agency Collaboration

The FBI strongly believes in a multi-agency approach when investigating human trafficking, which is evidenced by the task forces that are active across the country. The FBI primarily handles Human Trafficking investigations under its Crimes Against Children and Human Trafficking Program. The Child Exploitation and Human Trafficking Task Forces operate in nearly all FBI field offices and are used to collaborate with state and local law enforcement agencies to recover victims and apprehend traffickers at the state and federal levels.

Perhaps the most effective initiative undertaken by the FBI is the Anti-Trafficking Coordination Team which enhances access to specialized Human Trafficking subject matter experts, leads, and intelligence. The results created are high-impact federal investigations and prosecutions. The initiative is a collaborative effort between the FBI, DOJ, DHS, and the Department of Labor (DOL). Currently, 12 FBI field offices participate in the program, including Boston, El Paso, Miami, and Portland. [8]

Over the past decade, the FBI’s Human Trafficking investigations have been responsible for the arrest of nearly 2,000 traffickers and the recovery of numerous victims. It should be noted that the FBI take a victim-centered approach and work to remove victims from a violent environment. The agents work closely with victim advocates and organizations that can provide victims with immediate assistance (i.e. food and shelter) and long-term care services (i.e. education and job training). Once the victims are recovered and cared for, the agents then focus their efforts on seeking arrests and successful prosecution of traffickers.

U.S. Drug Enforcement Administration (DEA)

Known for its involvement in the “War on Drugs”, the DEA was created by President Richard Nixon on July 1st, 1973, and is a Federal law enforcement agency tasked with combating drug trafficking and distribution within the United States. It is the lead agency for the domestic enforcement of the Controlled Substances Act (CSA), sharing concurrent jurisdiction with the FBI, ICE’s HSI, and U.S. Customs and Border Protection (CBP).[9] Currently, the DEA maintains 23 domestic field divisions with 222 field offices and 92 foreign offices in 70 countries.[10] The DEA employs nearly 5,000 Special Agents and 1,000 Intelligence Analysts that are tasked with identifying and disrupting narcotics trafficking operations. But, do not let the narcotic trafficking interdiction efforts fool you, the DEA is a key player in the fight against Human Trafficking.

El-Paso Intelligence Center (EPIC)

The El-Paso Intelligence Center (EPIC) was established in 1974 to provide tactical intelligence support to federal, state, and local law enforcement agencies on a national scale. The center is composed of 21 participating agencies that share the common goal of identifying threats to the U.S., with a focus on the Southwest border. EPIC is an “all threats” center with an emphasis on providing tactical, operational and strategic intelligence support related to illegal drugs, weapons trafficking, human trafficking, human smuggling, illegal migration, money laundering and bulk cash smuggling by Mexican-based Cartels.[11]

U.S. Department of Homeland Security Agencies

Image 3: Department of Homeland Security Agencies [12]

U.S. Immigration and Customs Enforcement (ICE)

Formed by President George W. Bush in 2003 under the Homeland Security Act of 2002, U.S. Immigration and Customs Enforcement is primarily tasked with the mission of protecting the United States from the cross-border crime and illegal immigration that threatens national security. Their focus is on immigration enforcement, preventing terrorism, and combating the illicit movement of people and goods. [10] ICE contains two major components: Homeland Security Investigations (HSI) and Enforcement and Removal Operations (ERO). Contrary to popular belief, ICE does not patrol the U.S. borders with Mexico and Canada. This function is performed by the U.S. Border Patrol, which is a subunit of U.S. Customs and Border Protection.

Homeland Security Investigations (HSI)

HSI is the major investigative and intelligence arm of ICE and consists of nearly 10,500 employees spread across 26 domestic field offices and 80 international offices in 53 countries.[14] The HSI employs over 7,000 Special Agents that investigate violations of more than 400 U.S. laws that include human smuggling and trafficking, weapons smuggling, and narcotics trafficking.[15] According to ICE’s Human Trafficking website, in 2019, HSI initiated 1,024 investigations related to human trafficking and recorded 2,197 arrests, 1,113 indictments, and 691 convictions. Most importantly, 428 victims were identified and assisted. [16]

U.S. Customs and Border Protection (CBP)

The U.S. Customs and Border Protection was also formed in 2003 as a restructuring of several agencies to strengthen operational functionalities. Surprisingly, or maybe not when one considers the vastness of the Mexico and Canadian Borders, CBP is the largest federal law enforcement agency, employing almost 42,000 sworn agents and officers. There are 328 ports of entry into the United States and nearly 25,000 CBP Officers inspect and examine passengers, vehicles, and cargo crossing the border. Another 20,000 Border Patrol Agents protect the 1,900 miles of border with Mexico and 5,000 miles of border with Canada.[17]

Of all the agencies, CBP has the most direct view into possible human trafficking due to the daily interaction its officers and agents have with individuals entering and exiting the borders, either legally or illegally. In recent years, the CBP has implemented comprehensive training for its personnel through the local field and sector offices. The training instructs agents to recognize potential instances of human trafficking and to take necessary actions when encountering trafficking victims. [18]


The crime of human trafficking has become an illicit, multi-billion-dollar global enterprise. It affects millions of people every year and wreaks havoc on financial systems. As the perpetrators become more creative in hiding profits, by using cryptocurrencies and complex money laundering schemes, law enforcement has had to increase the collaboration between different levels of agencies and the private sector.

The FBI, DEA, CBP, and ICE are leading the charge in the fight against human trafficking, but they certainly cannot do it all themselves. Communication and collaboration between all levels of law enforcement, not-for-profits, and financial institutions are imperative. The information generated by banks concerning suspicious accounts, transactions, and patterns can be the key piece of evidence when prosecuting a trafficker. After all, #FollowMoneyFightSlavery.

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