Stage 2 | Policy

Five Anti-Trafficking Lessons from Your Peers

  1. Deliver a persuasive case to your Board of Directors to build company investment

Institutions want to invest in combating human trafficking, but compliance teams are stretched thinly addressing a variety of financial crimes. Securing Board and executive buy-in is a crucial step towards a sustainable, company-wide anti-trafficking initiative. A strong business case can influence the institution’s relative prioritization of trafficking among other initiatives by directing budget, time, and/or headcount toward the issue. To make an effective case:

  • Include the prevalence of human trafficking;
  • Describe the emphasis placed on human trafficking by other organizations;
  • Present data on trafficking activity that’s been missed;
  • Propose a plan that balances impact and reasonable investment;
  • Highlight direct impacts to the cause and benefits to the company; and
  • Show the legal risk posed to financial institutions for neglecting trafficking.

2. Include anti-trafficking in your institution-wide training and education materials.

Institutions have financial crimes and customer exploitation staff training. However, standard training often does not focus on human trafficking, its specific indicators for financial institutions, nor guidance for staff to take action. Institutions can increase staff attention on trafficking by incorporating anti-trafficking lessons into existing staff training programs and schedules. For example, institutions can add a module to the general financial crimes and customer exploitation training they already host or use human trafficking examples in broader training scenarios.

Institutions can develop training leveraging guidance from industry working groups. They should revisit lesson plans at least twice annually to ensure the latest insight from FinCEN, governing bodies, and industry groups is incorporated.

3. Assign a team member to oversee the anti-trafficking initiative and connect it to broader institution initiatives.

Assign ownership to specific staff within the compliance or AML team to propel the effort forward. Staff should set and report on key milestones to keep the initiative on track, attend industry events on behalf of the team, serve as point-of-contact to external groups like law enforcement, and plan internal workshops with AML or data teams. Additional responsibility to connect with company-wide initiatives will allow for broader impact. Ownership keeps the team and institution, as a whole, accountable for progress.

4. Identify your program’s core focus by partnering with local law enforcement.

Some institutions are not ready to share trend data and experiences with peer institutions, or may not know how to prioritize their anti-trafficking program. Many institutions operate in high-risk trafficking geographies, and can identify their focus by communicating with local law enforcement to learn about specific common challenges. Compliance leaders should begin by contacting their local or state anti-trafficking task force and asking for a referral to law enforcement, who is available to share community problems. They can also connect with their security department – typically a global department – to access contacts. This can be an effective strategy for AML teams seeking a targeted monitoring effort that resonates with the institution’s community. Building these relationships with law enforcement may also create training and awareness opportunities through law enforcement speaking to the institution.

5. Build a network to identify trusted peers with similar goals.

Information-sharing between industry peers is the only way for compliance and AML teams to learn about indicators and typologies to combat trafficking, but teams are concerned about maintaining data privacy. Compliance teams can alleviate concerns about privacy by building a trusted network of true peers. The easiest way to do this is by attending industry events and networking with peers in guided sessions. Building a network and community and regularly sharing experiences under 314(b) keeps institutions aware of their common mission. STAT uniquely offers institutions a digital resource to build the braintrust and collaborate in a secure environment.