AML CHALLENGES
sionals the proper “first responders” to this
firestorm? The answer: probably not.
actually perceive his/her traffickers or new
“owner” as a savior, someone to be trusted
and relied upon. The trafficker or owner
provides for the victim’s basic needs (food,
shelter, clothes). When the victim is a child,
conflicting emotions such as attachment
to the trafficker, fear of punishment and an
inherent desire to trust adults may prevent
reporting, even in those few instances when
reporting is feasible. In some societies, trafficking is widely accepted and encouraged
(think forced marriages), which essentially
extinguishes any hope by the victim of rescue.
John Byrne, executive vice president for
ACAMS states “that human trafficking is
a crime that resonates everywhere. Trafficking is going on all around us and begs for
a response.” Byrne also stated that ACAMS
is the perfect forum for open discussions
with law enforcement about how antimoney laundering professionals can assist
with detection of a crime that is not necessarily money-based. With more than 10,000
members, ACAMS will continue to provide
helpful guidance and thoughtful responses
to law enforcement as they lead the effort
to eradicate this horrible crime. In addition, ACAMS launched a web site dedicated
to fighting Human Trafficking and Human
Smuggling in November 2010.10
Education and support are definite roles antimoney laundering officers should assume
as the human trafficking drama continues
to unfold. As with any hot button topic,
AML professionals should take this opportunity to validate their detection processes
and training program to ensure information regarding human trafficking typologies
is considered for appropriate integration
into AML programs. Because it is unlikely a
Adding to the difficulty in finding and
successfully prosecuting human trafficking
cases is that many victims are hesitant to
come forward. Given time, a victim may
specific automated detection scenario will be
developed to ferret out activity indicative of
human trafficking, integration may consist
solely of educating staff on the underlying
trafficking activities to foster a comprehensive understanding. Effective training which
incorporates information on red flags such as
payroll or taxes not matching staffing levels
and the attributes of funnel accounts takes
on added significance to investigators.
While human trafficking remains a human
rights issue, AML professionals can certainly
lend moral support to the cause by raising
awareness and understanding that trafficking
is the predicate offense to some of the SAR
reportable activity seen on a daily basis. Financial institution investigators must continue
to report suspicious or unusual activity to
provide the necessary leads law enforcement
will use to track down human traffickers.
Jean-Ann Murphy, CAMS, USA, send
comments to [email protected]
Dirty secrets of human trafficking:
Funnel accounts15
• Families sometimes calculate how
much debt they can incur based on
their tradable family members.11
Funnel accounts is a relatively new term in anti-money laundering circles.16 Though the use of funnel
accounts was found in a major human trafficking case, investigators and anti-money laundering profes
sionals cannot lose sight of the fact that human trafficking exists in so many forms that the identified