National Money Laundering Risk Assessment
border.
146
Human traicking victims in the United States may be U.S. citizens, foreign nationals who have lawful
immigration status, or individuals who are unlawfully present. Human traickers take advantage of poverty,
conflict, natural disaster, breakdowns in the rule of law, dislocation, disruption of social support systems, and
other global crises that can intensify victims’ vulnerabilities to recruitment and exploitation. Corrupt government
oicials also enable human traickers (e.g., by accepting bribes from labor brokers engaged in deceptive
practices).
147
Human traicking is also one of the most profitable crimes and a predicate oense for money
laundering.
148
In 2020, a total of 11,193 situations of human traicking were identified through the U.S. National
Human Traicking Hotline,
149
and globally, an estimated 24.9 million people are subjected to human traicking,
generating an estimated $150 billion in illicit profits annually.
150
Financial activity from human traicking activities can intersect with the regulated financial system at any point
during the recruitment, transportation, and exploitation stages. The illicit proceeds from human traicking
can include income associated with logistics, such as housing and transportation of victims, as well as earnings
from the exploitation of victims.
151
In the United States, human traicking occurs in a broad range of industries,
including, hospitality, agriculture, janitorial services, construction, restaurants, care for persons with disabilities,
salon services, massage parlors, retail, fairs and carnivals, peddling and begging, childcare, domestic work, and
drug smuggling and distribution.
152
Illicit proceeds from human traicking can be paid or transferred in cash,
electronic funds transfers/remittance systems, credit card transactions, payment apps, or virtual assets.
Sex traicking, in particular, may be perpetuated by TCOs
153
and facilitated through online platforms.
154
For
example, in June 2020, U.S. law enforcement seized CityXGuide and its related websites. In August 2021,
Wilhan Martono, the creator, owner, and operator of CityXGuide, pled guilty to promotion and facilitation of
prostitution and reckless disregard of sex traicking and conspiracy to engage in interstate and foreign travel
and transportation in aid of racketeering enterprises. Martono created, owned, and operated a network of
websites, including CityXGuide, that posted hundreds of thousand of prostitution advertisements in locations
across the United States and around the world. CityXGuide allowed pimps, prostitutes, and brothels to post and
pay for advertisements that featured an explicit list of “intimate activities,” along with nude or partially nude
photographs, a physical description, work hours, methods of payment, and contact information for the female
146 “DHS, Blue Campaign, Myths and Misconceptions,” https://www.dhs.gov/blue-campaign/myths-and-misconceptions.
147 UNODC, Issue Paper: The Role of Corruption in Traicking in Persons, (2011), https://www.unodc.org/documents/human-
traicking/2011/Issue_Paper_-_The_Role_of_Corruption_in_Traicking_in_Persons.pdf. See also U.S. Department of
State, Traicking in Persons Report, (2020), https://www.state.gov/wp-content/uploads/2020/06/2020-TIP-Report-Complete-
062420-FINAL.pdf.
148 State, Treasury, Report to Congress on An Analysis of Anti-Money Laundering Eorts Related to Human Traicking. (Oct. 7, 2020),
https://www.state.gov/report-to-congress-on-an-analysis-of-anti-money-laundering-eorts-related-to-human-traicking/.
149 Polaris, 2019 U.S. National Human Traicking Hotline Data Report, (2019), https://polarisproject.org/wp-content/
uploads/2019/09/Polaris-2019-US-National-Human-Traicking-Hotline-Data-Report.pdf.
150 State Department, Traicking in Persons Report. (June 2021), https://www.state.gov/wp-content/uploads/2021/07/TIP_
Report_Final_20210701.pdf.
151 The White House, The National Action Plan to Combat Human Traicking. (December 2021), https://www.whitehouse.gov/wp-
content/uploads/2021/12/National-Action-Plan-to-Combat-Human-Traicking.pdf.
152 FinCEN, “Supplemental Advisory on Identifying and Reporting Human Traicking and Related Activity,” (Oct. 15, 2020),
https://www.fincen.gov/sites/default/files/advisory/2020-10-15/Advisory%20Human%20Traicking%20508%20FINAL_0.
pdf. This advisory is a supplement to FinCEN’s 2014 advisory on Human Traicking and Smuggling, and highlights financial
and behavioral red flags and typologies related to human traicking.
153 DOJ, “Five Defendants Convicted of Sex Traicking, Alien Smuggling and Money Laundering,” (Mar. 14, 2020), https://www.
justice.gov/usao-edny/pr/five-defendants-convicted-sex-traicking-alien-smuggling-and-money-laundering.
154
DOJ, “U.S. Attorney’s Oice Shuts Down Website Promoting Prostitution and Sex Traicking, Indicts Owner,” (Jun. 19, 2020),
https://www.justice.gov/usao-ndtx/pr/us-attorney-s-oice-shuts-down-website-promoting-prostitution-and-sex-traicking.
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