• In this ACFCS Member Spotlight, a longtime compliance professional and thought leader shares his journey over the past 15 years from fighting fraud as an intern to spearheading the creation of a non-profit to fight human trafficking.
• August 2020 will be the one-year anniversary that Aaron Kahler became the Founder and Chief Executive Officer of the Anti-Human Trafficking Intelligence Initiative (ATII).
• ATII is a 501(c)(3) tax exempt non-profit organization combating global human trafficking by leveraging corporate social responsibilities directly through advocacy awareness, intelligence integration, technology advancement and strategic data collaboration.  
• The group is designed to be a hub helping to better knit together the at-times disparate groups of public and private entities divining the red flags of human trafficking.
• With a background in financial crime investigations, compliance and consulting, Kahler is helping the various groups see the bigger picture, from customer actions and transactional tells in bank monitoring systems to the law enforcement agencies on the ground putting all the pieces together to identify and crush larger domestic and international trafficking networks.
• Kahler’s mission to fight human slavery in all of its forms, while not an easy goal, is a worthy one. Human trafficking is one of the most profitable crimes in the world, generating some $150 billion annually. There are estimated to be more than 40 million victims of human trafficking globally.

For Aaron Kahler, the spark that caused him to devote his life to fighting one of the world’s most sinister and soaring crimes, human trafficking, started early in his career with internships fighting fraudsters and protecting consumers – a common theme that would foreshadow a mission to safeguard other vulnerable groups.

While he didn’t know it at the time, Kahler’s stints more than 15 years ago with the New York State Office of the Attorney General and MasterCard as a fraud investigator – helping individuals taken advantage of by unscrupulous corporates and individuals – would set him on a path to create a non-profit devoted to counter human trafficking and human slavery.

August 2020 will be the one-year anniversary that Kahler became the Founder and Chief Executive Officer of the Anti-Human Trafficking Intelligence Initiative (ATII).

ATII is a 501(c)(3) tax exempt non-profit organization combating global human trafficking by leveraging corporate social responsibilities directly through advocacy awareness, intelligence integration, technology advancement and strategic data collaboration.  

The group is designed to be a hub helping to better knit together the at-times disparate groups of public and private entities divining the red flags of human trafficking.

With a background in financial crime investigations, compliance and consulting, Kahler is helping the various public and private sector groups see the bigger picture, from customer actions and transactional tells and the law enforcement agencies on the ground putting all the pieces together to identify and crush larger domestic and international trafficking networks.

As a point of context, human trafficking is a global problem generating billions of dollars annually, a horrific figure indeed, but one that has forced these illicit groups to interact with the financial system – a dynamic that allows specially trained anti-money laundering (AML) teams a chance to identify, interdict and report those instances of human slavery.

Human trafficking is one of the most profitable crimes in the world, generating some $150 billion annually. There are estimated to be more than 40 million victims of human trafficking globally.

The issue of human trafficking and its connections to financial institutions – and what those nuanced and undulating red flags may look like – is also on the minds of top regulatory and investigative watchdogs.

Over the past decade, groups like the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) and the Paris-based Financial Action Task Force (FATF) have released guidance pieces to better help financial institutions understand when human traffickers might be attempting to move sullied funds through their institution.  

ATII will build on the analyses from FinCEN, FATF and others and combine their conclusions with insight from banks, law enforcement and other counter-trafficking groups in a bid to filter down to the latest schemes used by human trafficker operations to launder their ill-gotten proceeds.

Some examples include delving into and dissecting current flashpoint issues such as trafficking groups weaving together transactions in crypto coins and anonymous prepaid cards before transacting with banks.

Their tacit aim in such a tactic: making financial institution identification of human trafficking trends all the more difficult, which is why there is such a fincrime compliance industry push for more information sharing between the AML teams at brick-and-mortar operations and their counterparts at virtual coin exchange vaults.

Not surprisingly, one of the most important skills for those working to fight human trafficking is the ability to react, adapt and overcome, to what criminal groups are doing, what investigators say they are seeing and what regulators want as a compliance response, Kahler said.

“The financial crimes field, related typologies and governing regulations are changing regularly and having the ability to adapt both proactively and reactively is at the forefront of necessary abilities needed in the industry,” he said.  

Another underrated characteristic in the financial crimes space that is necessary for true success in the field: creativity – and a relentless desire to grow, voraciously capture knowledge and share that as widely and broadly as possible to help others.

“I encourage practitioners to dig deeper in whatever aspects of their career they are passionate about (i.e., writing, speaking, problem solving, building programs, investigation) and use it as a platform to express their professional creativity,” Kahler told ACFCS.

He added that taking a holistic, convergent approach to compliance, learning and training can help professionals go more quickly from learning to doing.

Achieving the Certified Financial Crime Specialist (CFCS) credential can bolster and “solidify your existing experience in the field with a specialized designation in financial crimes, which will make you more effective and knowledgeable while setting you apart from others in your field who have not made the commitment to invest further in themselves.”

One of Kahler’s favorite quotes, though, evinces the duality that every financial crime compliance professional must ascribe: the ability to have a singular focus on a problem, but also demonstrate the capacity to be flexible enough to inculcate new ideas and strategies to counter the enemy of narrowminded thinking.

“I fear not the man who has practiced 10,000 kicks once, but I fear the man who has practiced one kick 10,000 times.” – Bruce Lee.

“Although this is not advice I received directly, it is absolutely a quote I apply across the board in both a professional and personal capacity as an individual passionate about a number of different activities (i.e., Brazilian jiu jitsu, scuba & free diving),” Kahler said.  

The quote emphasizes the importance of a high level of focused practice and proficiency.

“Early on in my career I was given the opportunity within financial services consulting to work with a number of different groups practicing a variety of disciplines, but stayed focused on AML and Financial Crimes, honing this craft and advancing my career path,” he said.  

Today he still sees tremendous value in this quote within the early years of developing a craft (professional or personal), but with a caveat: one should use focused practice and proficiency early on as a strategy to grow, but ultimately evolve to understand the fluidity and adaptability of the focused strategy.

“This will prevent a narrow perspective and further enable growth in their professional or personal path,” Kahler said. “In other words, understand the strategy is part of your base as a practitioner of your craft and evolve the application of said craft outside the original use case.”  

With focus, drive, determination and passion, some risks – such as starting your own non-profit with high hurdles and lofty goals – can also have unexpected rewards.

“Launching ATII has been the most creative, rewarding and fascinating endeavor I have ever taken on both personally and professionally,” Kahler said.

To visit ATII’s website, please click here or to start a dialogue on LinkedIn, please click here.

Kahler was kind enough to share some of his insight in our latest ACFCS Member Spotlight:

I am the Founder and Chief Executive Officer of the Anti-Human Trafficking Intelligence Initiative (ATII).

We are a 501(c)(3) tax exempt non-profit organization combating global human trafficking by leveraging corporate social responsibilities directly through advocacy awareness, intelligence integration, technology advancement and strategic data collaboration.  

As the Founder of the organization, my goal is to get our anti-human trafficking program, data, technology and training in as many financial institutions as possible, directly resulting in Suspicious Activity and Suspicious Transaction Reports being filed specifically on human trafficking.

This ultimately will result in saving lives, bringing traffickers to justice and disrupting global trafficking operations

I was very fortunate to be able to get practical experience in the financial crime industry through my college major in Economic Crime Investigation at Utica College (at the time, part of Syracuse University) and internships in the field for several years while studying.

Having a specialized background and some prior experience in the field allowed me the opportunity to get into the anti-money laundering field right out of college and gain exposure to investigations with Citibank in New York City.

As I gained experience in the field working within the bank, I transitioned into financial services advisory consulting on AML and Financial Crimes.

Working in the advisory consulting space early in my career was a very enjoyable and rewarding experience that allowed for exposure to many different financial institutions of all types, sizes, locations and products/services while also experiencing extensive travel in the US and abroad (I have been to every continent other than Africa and Antarctica).  

I spent most of my 15+ year career working in advisory consulting as I advanced in the field with several firms over the years, while branching out on my own several times in between roles.

Taking the time to step away from the corporate umbrella to fly your own flag as an entrepreneur is not for everyone.

But I found that being accountable for my own professional development, salary, business relationships, media/marketing and everything else under the sun are the experiences that helped accelerate my career, build a brand for myself and evolve as a professional.

“I fear not the man who has practiced 10,000 kicks once, but I fear the man who has practiced one kick 10,000 times.” – Bruce Lee

Although this is not advice I received directly, it is absolutely a quote I apply across the board in both a professional and personal capacity as an individual passionate about a number of different activities (i.e., Brazilian jiu jitsu, scuba & free diving).

The quote emphasizes the importance of a high level of focused practice and proficiency.

Early on in my career I was given the opportunity within financial services consulting to work with a number of different groups practicing a variety of disciplines, but stayed focused on AML and Financial Crimes, honing this craft and advancing my career path.

Today I still see tremendous value in this quote within the early years of developing a craft (professional or personal), but with a caveat: one should use focused practice and proficiency early on as a strategy to grow, but ultimately evolve to understand the fluidity and adaptability of the focused strategy.

This will prevent a narrow perspective and further enable growth in their professional or personal path. In other words, understand the strategy is part of your base as a practitioner of your craft and evolve the application of said craft outside the original use case.

The financial crimes field, related typologies and governing regulations are changing regularly and having the ability to adapt both proactively and reactively is at the forefront of necessary abilities needed in the industry.

I also think an underrated characteristic in the financial crimes space that is necessary for true success in the field is creativity.

I encourage practitioners to dig deeper in whatever aspects of their career they are passionate about (i.e., writing, speaking, problem solving, building programs, investigation) and use it as a platform to express their professional creativity.

In my case, as someone who is in the middle of a career transition from the corporate sector to nonprofit leadership, it is clear that the many years of experience adapting to different client institutions needing various compliance, investigation and advisory services has prepared me for this next chapter of my career.

Launching ATII has been the most creative, rewarding and fascinating endeavor I have ever taken on both personally and professionally.

I am thankful that I have held prior roles within the financial crime space that have given me the encouragement and autonomy to develop creatively.

There has been a great deal of evolution in the financial crime field in the last 15 years that have had significant impacts on the profession.

Technology is a major one that comes to mind and I am sure everyone has not only seen but lived through these changes as a professional and an individual these days navigating through all of the dangers presented by fraudsters on a daily basis.

A major impact in the evolution of the financial crimes field and related compliance climate comes from changes in the regulatory environment, most notably following 9/11, the US PATRIOT ACT and the 2008 financial crisis.

I would not be doing my job as an anti-human trafficking advocate if I did not talk about the current state of evolution and road to eventually having specific regulations around anti-human trafficking that financial institutions will be required to comply with.

In 2014, FinCEN released guidance indicating that specific verbiage was required in the SAR narrative, so that accurate tracking of HT and HS reports could occur. In June of 2018, FinCEN had updated the U.S. suspicious activity report (SAR) to include a Human Trafficking Checkbox within the SAR form.

(Thank you to Joanne Alicea, an ACFCS Scholarship recipient who lobbied for seven years and was instrumental in this change!)

As FinCEN continues showcasing the importance financial institutions play in anti-human trafficking through guidance and key changes to reporting mechanisms, it is my hope that institutions will realize bigger changes are on their way and begin practicing corporate social responsibility now rather than waiting until mandated to do so.

A major challenge in both the fight against financial crime and anti-human trafficking is maximizing financial intelligence through collaboration and information sharing.

A key challenge is the regulatory barriers that deter institutions from better utilizing and more actively collaborating through their collective financial intelligence.

How to improve?

Further catering regulations and corresponding guidance to decrease obstacles that can get in the way of promoting financial institution collaboration with law enforcement, other financial institutions and non-governmental organizations.

By working more closely together to share information, trends and data, these public and private sector groups can more quickly identify the criminal networks that support various financial crimes including but not limited to, terrorism, drug-trafficking, money laundering, elder abuse and modern slavery.

I originally had planned on becoming a Criminal Justice major and was able to transition to the Economic Crime Investigation program I mentioned in a previous question above.

What solidified my interest and motivation in financial crimes were internships early in my career with New York State Officer of the Attorney General and MasterCard.

I worked as a Consumer Frauds Investigator with the AG’s Office helping people who were taken advantage of by a variety of different corporations and other individuals (such as landlords).

For many years following the internship I continued receiving Christmas cards from grateful folks I had helped when they needed it.

At MasterCard I worked with their Fraud Management group in liaison with Federal law enforcement investigation websites dealing in child pornography and accepting credit card payments.

This was a very sad but rewarding experience that I would not know at the time, but has shaped my evolution as a financial crime professional, eventually culminating in what I am doing with my expertise today at ATII.

Pretty much everything about my current role surprises me. I find myself feeling the most passionate, fulfilled and forward-looking about my work to counter human trafficking and support victims. Those have resulted in some of the most rewarding experiences of my life.

The amount of support pouring in from my family, friends and network has provided both incredible motivation and confirmation that I am on the path I should be on.  

I reached out to the ACFCS after seeing how active they were in releasing content, interviewing experts and covering best practices in the anti-human trafficking effort.

ACFCS is dedicated to educating their members on the topic and was as excited as we were to partner together to raise human trafficking awareness and educate on how financial crime professionals can help.

As part of our collaborative efforts, ACFCS has generously donated Associate Memberships, materials and the testing fees allowing our team to become CFCS-certified.

I am in the process of becoming CFCS-certified and am taking advantage of the downtime many of us have due to the Corona virus.

My first jobs in the field were internships while still in college. I was in a financial crimes specific major and very active in leveraging networking opportunities with organizations that were affiliated with my college program as well as prior graduates working in the financial crimes field.

I credit my acceptance for early internships with the New York State Officer of the Attorney General and MasterCard’s Fraud Management Department to creatively using the resources available to me, prioritizing the importance of networking and good old-fashioned persistence.

The experience gained from these internships in combination with my degree was what ultimately helped me land my first full-time role.

Ensuring that you can gain some form of practical experience in your field to supplement your education (college and professional organizations like ACFCS) is the biggest advice I would give in helping to land your first position.

Ideally, your practical experience would be a paid opportunity but even taking a part-time, non-paid role that you can squeeze in around your other obligations will give you invaluable experience that differentiates you from others when applying for your first job.

The Anti-Human Trafficking Intelligence Initiative (ATII) is still in its early stages but it has been amazing to see so many individual contributors, partners and socially responsible organizations ready and willing to collaborate with us in combating modern slavery.

We recently received word from a large global financial institution that an early proof of concept involving our High Risk Human Trafficking Data has led to uncovering several large networks of trafficking rings.

Knowing that our work will give financial institutions, corporations, law enforcement and other agencies the resources to better tackle human trafficking and contribute directly to protecting the vulnerable is my reward.

Investing in yourself to further develop your expertise in the space is a big piece of advice I would give.

Some simple ways to do this is to write industry articles or blogs (co-authoring is an option to get your foot in the door), speaking in industry round-tables, webinars or small chapter events (to build confidence initially) and joining industry thought leadership groups, committees or consortium’s catered to your field.

Getting certified as a CFCS particularly to solidify your existing experience in the field with a specialized designation in financial crimes will make you more effective and knowledgeable while setting you apart from others in your field who have not made the commitment to invest further in themselves.

Also, looking beyond just the financial crimes aspect of your role and taking courses or getting certifications deeper in the products, services or specilaiazation of your particular industry is also something that can help you grow and differentiate you in your field.

Some examples: CRCM in the banking field, CipherTrace Certified Examiner (CTCE) or Certified Cryptocurrency Investigator in forensic cryptocurrency/blockchain, Series 7/23 for Broker Dealer, Casino education, etc…