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 this was just a theoretical subject about which I had learned while preparing for the ACAMS and thought that it predominantly happened in other countries, far, far away.
I have been working in the Anti Money Laundering Department of a Romanian bank for the past 5 years. Thus, I started to mentally analyze how many Suspicious Transaction Reports 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 that we reported suspicions of human trafficking. An older woman, very anxious and scared, wanted to send money to another woman in a Western Europe country. She told our front-office colleagues that the money had to arrive to her daughter immediately and that she had been instructed to send it to the receiving woman.
If Romania is one of the main Origin Countries for human trafficking, shouldn’t we, 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 what we have seen. The techniques used in money laundering are often the same for various types of crimes, so, as long as we only see crumbs of the whole picture, it is difficult to understand what is really happening beneath. Add to this a very fast, energy-consuming working environment in itself, with many alerts and suspicions to analyze daily 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”. In my entire career I have never received an informative material with red-flags for human trafficking from the Romanian Authorities. 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 is useful, but not enough. Because, in order to be truly aware and effective, you must understand the specificities of your country in this matter. 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 on different continents of the world (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. AML specialists need concrete, practical and applicable red-flags. And they need them from their National Authorities. The National Authorities are the first which should make a risk assessment on this crime and provide useful and 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 ever having participated to a prevention presentation in my childhood, either. Now I understand why until recently I thought that this horrible phenomenon only happens far, far away. Because, when we talk about prevention in Romania …. human trafficking simply doesn’t exist. We are all safe … although Romania is the main source of sex slaves for the Western Europe, both women and children.
As a mother, I cannot leave things like that because the stake is too big. I have already talked to my older son, although he is not even 7 years old and never unattended (we take him to school, the school has a guardian and the children aren’t allowed to exit the school yard, the afterschool comes and picks him up from school and we take him from the afterschool; he doesn’t go alone in parks, etc.).
Many parents consider that making their children aware of the dangers around them means destroying their innocence. They consider that telling children about the possibility of being kidnapped might frighten them and they would like their children to live in a fairy world as long as possible. 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. I didn’t talk just once, we had 3 discussions this summer. None of them was official, or very serious so as to scare him. For example, the last one was on a bench in the park, while eating an ice-cream together with my almost 3 year-old. 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, if not him. If an unknown person tells him that something bad happened to his parents and he must go with him/her immediately, he must announce his teacher or the guardian immediately to investigate. We also amused ourselves by establishing a password that only we know.
- He must NEVER leave the park with an unknown person – no matter the reason stated. 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 years old).
- I love him no matter what happens and he must never be afraid to tell me anything. I will love him no matter what happens.
How do you think he reacted? Do you think he was scared and wanted to go home and lock himself inside? No. He talked with me on this subject while happily eating his ice-cream and then he showed me his karate moves that should scare everyone away. I reassured him several times that this will surely never happen, but I just wanted him to know. It never happened to me, it never happened in the town we live in, but there are situations when it does happen so it is better for him to know these safe steps. He remained as innocent as he was 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.
My child is somehow informed. I talked to him and will continue to do so from time to time, as children tend to forget quickly. But how about the other children around us?
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 the non-profit organizations that I found dealing with human trafficking in Romania. I wanted to offer my service as speaker for school children on human trafficking. 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 is August and people are on vacation and that soon, somebody will answer and we can 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
Great article and a very important issue for Romania. I have met with many victims and heard many reports from friends. The recently published FATF Report on Financial Flows from Human Trafficking provides a number of examples related to Romania. It would be wonderful if ANITP would work directly with banks to raise awareness with even more local information. Actually, it would be nice if ANITP would get around to publishing some more recent reports; the most recent is from 2015. Luckily they do have some recent information regarding cases in 2017 in an article under recent activities: 76.4% of victims were female and 51.4% were minors. 68.8% were sexually exploited, 12% were for forced labour, 6.5% were forced to perform thefts, and 5.3% were forced to beg.
Great article, Andreea! I too have spoken to my child about the dangers of human trafficking. It’s not something that happens in movies or in some obscure location, it’s happening in all our communities.
Look forward to reading more of your articles to come.
Hi, thank you for your article.
From my experience, I think that it is not enough useful to be focused on a specific predicate crime (like the human trafficking) but we must consider who can put in place this kind of offense. For this reason I think that all the AML specialists must study the history of the criminal organizations, the criminal activities, their business and how they carry out the money laundering.
If the AML departments can understand in general how the criminal organizations invest the illegal money in the legal business, and all the AML specialist are also “specialized” in criminal organization, all the AML departments will be defeat all the predicate crimes (e.g. corruption, extortion, weapon trafficking, drug trafficking, human trafficking)
Echoing your last line, Andreea, obviously I won’t want to see my children having price tags. This article will go a long way to create awareness against sex/child/human trafficking. Merci beaucoup !