An AML Mom’s View on Human Trafficking

The subject of human trafficking first caught my attention when I incidentally found out that Romania is the main source of slaves for the Western Europe (EU TRACE Project). Until then it was just a theoretical subject about whom I thought it happened far, far away.

I have been working in the AML Department of a Romanian bank for the past 5 years. Thus, I started to mentally analyze how many SARs I had filed on Human Trafficking suspicions. If Romania is a major Origin country for human trafficking victims, then I should have filed quite many STR’s. And yet…

In my 5 years of AML experience I can only recall 1 situation when we reported suspicions of human trafficking.

If Romania is one of the main Origin Countries for human trafficking, shouldn’t AML specialists see more? And how come we don’t?

Part of the answer lies in the fact that we, AML specialists from banks, only see a piece of the money laundering puzzles. We see that something is “fishy”, we analyze it and report it in the absence of reasonable explanations. But the reality is that in many cases we don’t know the predicate crime beneath. The techniques used in money laundering are the same for various types of predicate crimes, so, as long as we only see crumbs of the whole picture, it is difficult to understand what is really happening. Add to this a very fast working environment and a lack of feedback from the Authorities … and you get the picture.

The other part of the answer is the lack of informative, practical resources from National Authorities – specific, applicable “red-flags”. We have a national FIU, we have a National Agency against Human Trafficking and yet we don’t have red-flags that apply to our specific, national situation.

Reading materials provided by international organizations on human trafficking are useful, but not enough. Because, in order to be aware and effective, you must understand the specifics of your country. As FATF so clearly states in its 2018 Human Trafficking Report, there are Origin, Transit and Destination Countries and the red-flags differ in each type of country.

There are also differences in the modus operandi of criminals based on their nationality and background. And there are differences between the financial instruments used in money laundering in different countries (for example, in Romania individuals do not use cheques or money orders as they do in the USA).

Thus, general information on human trafficking is not enough for AML specialists to spot suspicious transactions linked to this crime. They need practical and applicable red-flags. The National Authorities are the first which should make a risk assessment on this crime and provide practical information to involved entities – and not just to financial institutions, but also to legal professionals, airports, hotels, hospitals, schools, etc.

Until now I have presented my AML view on human trafficking. But, besides being an AML specialist, I am also a mother of two. And the mother’s view on human trafficking is invariably more dramatic.

As a mother, first of all I am shocked that I don’t see prevention. I don’t see prevention in the school that my son attends, nor for children, nor for their parents. And I don’t recall them in my childhood, either. Now I understand why until recently I thought that this phenomenon only happens far, far away. Because, when we talk about prevention in Romania …. human trafficking simply doesn’t exist.

As a mother, I cannot leave things like that. I have already talked to my older son, although he is not even 7 years old. Many parents consider that making children aware of the dangers around them means destroying their innocence. I believe that on the contrary, by informing our children of the perils around them we protect, not destroy their innocence.

I will tell you my own experience from talking with my child on this subject. Our latest discussion on this subject was on a bench in the park, while eating an ice-cream. We were talking about different, small things and I reminded him that:

• He must NEVER leave school with an unknown person, no matter what he/she tells him. I will never send an unknown person to pick him up from school without announcing at least his teacher.
• He must NEVER leave the park with an unknown person – no matter the reason. No nice dogs or cats, or sweets, or anything.
• If someone ever tries to take him by force he must scream, struggle, fight and bite as hard as he can so that people can notice that something is wrong.
• Nobody is allowed to see or touch his intimate parts, except mom, dad and the doctor under the parents’ supervision (he knows that since he was 4).
• I love him no matter what happens and he must never be afraid to tell me anything. I will love him no matter what.

How do you think he reacted? Do you think he was scared and wanted to go home and lock himself inside? No. He talked to me on this subject while happily eating his ice-cream and then he showed me his karate moves that should scare everyone away. He remained as innocent as before, but more informed.

For the parents reading this, talk to your children. Uninformed children are the best victims for sex abuses and human trafficking.

Prevention should be done at a larger scale. It should be taught in schools by informed, trained people. It should address children, teenagers, but also parents, so that we all understand that human trafficking doesn’t happen just far, far away.

Who should do it? National Authorities, Non-profit Organizations, teachers, parents.

And with this in mind, this week I tried to contact non-profit organizations that I found dealing with human trafficking in Romania. I wanted to offer my service as speaker for school children or if they needed free help in any other way. I wrote 7 emails and made several phone calls. Nobody answered the phone, nobody replied to my emails. I believe and hope that it is just because it’s summer and people are on vacation and that soon, somebody will answer and we will start a good collaboration.

Until then, the fact is that:

“A woman in forced sexual exploitation is estimated to generate approximately 100.000 USD in profit per year. A child is estimated to generate approximately 160.000 USD in profit per year from begging, stealing or sexual exploitation. The average price paid for a trafficked child in UK is 20.000 pounds.” FATF Money Laundering Risks Arising from Trafficking in Human Beings and Smuggling of Migrants, 2018

I don’t want my children to have price tags.

By Andreea Tampu, ACAMS