Scholarship Spotlight: Countering human trafficking takes combination of learning criminal patterns, sharing knowledge, helping survivors rebuild, says Emily Bejarano

The Skinny:

  • One of the winners of the ACFCS certification scholarship for fincrime professionals fighting human trafficking shares what drives her in this mission to thwart criminal groups through follow-the-money sleuthing and directly helping victims and survivors rebuild one-on-one.
  • For Wells Fargo anti-money laundering consultant Emily Bejarano, the mission to counter trafficking goes beyond the digital battlefields of transaction patterns through correspondent banking portals, with some of the most decisive skirmishes happening in the human heart as victims must pick up the pieces of shattered lives.
  • That’s why she pairs a passion to aggressively gather knowledge on the nuanced financial trails of trafficking – and share that thought leadership with other public and private partners – with compassion by volunteering to sit with survivors and teach them hard and soft skills to help regain their dignity, and humanity.
  • While Bejarano has mentored and counseled countless victims who have endured trials and trauma at the hands of criminal groups, their tenacity has humbled her at the same time. Human trafficking survivors “are the most resilient people I have ever encountered and they never cease to amaze me.”

By Brian Monroe
bmonroe@acfcs.org
April 27, 2020

For Emily Bejarano, countering the financial tendrils to potential human trafficking activities is more than analyzing data points, linked accounts and red flags behind a computer screen as a financial crime compliance professional working for one of the country’s largest banks.

Beyond her work as a Financial Crimes Consultant for Wells Fargo focusing on mitigating the risks and addressing any concerns related to anti-money laundering (AML) compliance tied to Asian correspondent banking relationships, the Chicago resident also volunteers to help victims rebuild their lives through an initiative called “Stop-It.”

Bejarano sees firsthand the human aftershocks of trafficking groups, strengthening her resolve to counter the crime and broadly share knowledge on transaction patterns and red flags.

When she volunteers at Stop-It, part of the Salvation Army, her time is spent trying to support victims by “assisting individuals looking for housing, finding jobs, building resumes, teaching life skills (cooking, crafting, money managing), and my personal favorite, styling hair and makeup.” 

The objective of the program is to “provide support services through case management and resources, as well as assisting them with goals to help them in overcoming their trauma and having a safe place for them to come and feel supported.”

Prior to Wells Fargo, Bejarano worked at BMO Harris, where she began her career in financial crime compliance reviewing high-risk clients as an Analyst, Investigator, and then an AML Specialist. 

Investigating financial crime is a longstanding dream and running theme for Bejarano.

She originally planned on becoming a police officer after four years of being a Police Explorer, a program for young adults to learn about law enforcement.

But after entering the banking field in 2006, while going to school for her associates in criminal justice, that changed. Initially, Bejarano worked in the branch directly with customers, handling transactions and performing branch audits.

But eventually, “I became more interested in the operations aspect and discovered AML (group all of 30 people at the time),” she told ACFCS. “Thankfully, I was able to connect with an internal employee who allowed me to shadow them and led to the beginning of my cherished AML career.” 

Overall, Bejarano has been in dedicated AML roles for nearly a decade.

Aside from her work and volunteer efforts with Stop-It, she is also a Corporate Ambassador for Cause Gear, a Chicago company that offers unique design and quality merchandise with the purpose of creating sustainable social reform for people vulnerable to extreme poverty and human trafficking in India.

While talking to victims and hearing their stories of survival can be emotional, Bejarano is also humbled by their strength and ability to rise and overcome adversity.

“The participants (survivors/victims) in the space are the most resilient people I have ever encountered and they never cease to amaze me,” she told ACFCS. “The fact that I was able to enter this space after seeking a way to help within my community and be welcomed with open arms is something I will always be grateful for.” 

It was for those and many other reasons ACFCS chose Bejarano as one of the recipients of the association’s inaugural Human Trafficking Scholarship Program. 

The selection process centered on individuals in roles combating human trafficking, an effort to share broad thought leadership on the issue as part of the association’s “Quarterly Focus” on human trafficking in the second quarter of 2019.

In recent quarters, ACFCS has tackled fincrime focus topics covering human trafficking, cryptocurrency and sanctions. The current Quarterly Focus topic for Q2, informed by the global COVID-19 pandemic, is “Fincrime Resiliency.”

In collaboration with its members, partners and the community as a whole, ACFCS will provide a series of trainings, tools and initiatives to help build resilient programs for compliance, investigations and enforcement.

A few highlights of the Quarterly Focus are:

·       Increased Online Learning with a Focus on COVID-19 – ACFCS will bring you a packed webinar calendar in the coming weeks, with events honing in on the compliance and investigative impacts of the coronavirus. Beyond webinars, we’re expanding our online content to include video chats with experts, virtual networking events, and much more. View the calendar here.

·       Online Exam Access for the CFCS Credential and Changes to Certification Policies – Starting soon, ACFCS will make the CFCS exam available online for candidates. We’re also changing recertification and exam scheduling deadlines to relieve pressure on anyone affected by the coronavirus. Look for more details in the coming days!

·       CFCS Scholarships to Foster Resilient Programs – This quarter, ACFCS is offering 20 CFCS scholarships, its highest number ever, to individuals who are helping their organizations adapt and stay strong in the fight against financial crime. Learn more about the program below and apply today.

·       Community-Curated Tips and Comprehensive News Coverage – We’ve launched a new FinCrime Resiliency Tips series to gather and share guidance with members – learn more and submit your tips today! You’ll also see intensive coverage and guidance on coronavirus-related issues on our news page.  

To read more about the resiliency quarterly focus, click here.

The scholarship offers complimentary registration for the Certified Financial Crime Specialist (CFCS) certification, the full suite of prep materials, and a year of membership in ACFCS.

In the case of the Quarterly Focus on human trafficking, those chosen for the scholarships submitted applications with compelling professional and often personal experience related to human trafficking – from running investigations and creating transaction monitoring rules, to advocating for legislation and working directly with survivors.

After receiving more than 130 applications from professionals across 20 countries, ACFCS selected 15 recipients of its scholarship program. 

To view an ACFCS human trafficking resource page, click here

Bejarano stated that information sharing on investigative resources and analyzing trafficking and other financial crime trends across institutions is one of the favorite things about her job.

 “I love the benefit of speaking directly with other financial institutions and making that connection to better understand the measures they are taking to adhere to regulatory requirements, mitigate risks within emerging industries, and listening to success stories.”

The ACFCS certification can only further those efforts, acting as a bridge to collaboration for banks and other public and private sector entities, many that typically are not subject to formal AML rules and requirements to look for the telltale signs of human trafficking, she said.

Fighting human trafficking and helping victims and survivors is “my passion,” Bejarano said, adding that she is working diligently to raise awareness around the topic and join the fight in putting it to an end. Specifically, I look forward to bridging gaps and assisting with collaboration between various sectors.”

Collectively, there is “so much information that can be utilized to identify HT and staying abreast of emerging trends involves all of us, most importantly, FI’s, LE, Nonprofits, Medical Field, Hospitality, and Transportation sectors.”    

Bejarano was kind enough to share some of her knowledge in our latest ACFCS Scholarship Spotlight:

1. How do you work to detect, prevent and/or raise awareness of human trafficking, in your job role or outside of it?

In my current role, I review correspondent banks and ensure they have strong compliance and AML programs in place so we can allow them to use our products and services while also identifying and mitigating the risks associated through their customer base.

Outside of work, I volunteer with a program here in Chicago, called “Stop-it.” In this space, I am a mentor who attends 1-2 times per month working directly with survivors/victims.

The objective of the program is to provide support services through case management and resources, as well as assisting them with goals to help them in overcoming their trauma and having a safe place for them to come and feel supported.

My time here is spent assisting individuals look for housing, finding jobs, building resumes, teaching life skills (cooking, crafting, money managing), and my personal favorite, styling hair and makeup. 

2. What do you see as key challenges related to human trafficking detection/prevention in your role or in the sector overall?

For FI’s, while it is more likely to detect something unusual, it is difficult to tie [that aberrant activity] back to human trafficking specifically, which makes it very important in all cases to follow the money.

While there are measures in place to assist in collaboration across various sectors like law enforcement (LE), FI’s and nonprofits, there are still gaps when crossing conversations.

This could be due to many reasons, including work language, LE’s limitations on sharing information from their [active, ongoing investigations and cases], as well as confidentiality when discussing with nonprofits. (FI’s having little to no connection to them at all). 

For the nonprofit organization, it’s most difficult to detect because many survivors do not identify as victims. This is based on lack of information, or out of fear instilled from their trafficker, and sometimes immigration status. 

3. What is the most rewarding part of your job?

I love the benefit of speaking directly with other financial institutions and making that connection to better understand the measures they are taking to adhere to regulatory requirements, mitigate risks within emerging industries, and listening to success stories.

There are so many different factors such as, customer base, geography, size of the financial institution (FI), products, etc. So, it makes everyone unique and all around makes my job really interesting and exciting. 

 As part of my involvement with Stop-it over the last four years, I have an immense amount of respect for the people that work within the program, they are extremely passionate about what they do and constantly put their heart into all they do.

The participants (survivors/victims) in the space are the most resilient people I have ever encountered, and they never cease to amaze me. The fact that I was able to enter this space after seeking a way to help within my community and be welcomed with open arms is something that I will always be grateful for. 

4. When it comes to human trafficking detection/prevention, what do you think is going well, and where could we get better?

Artificial Intelligence is an area that Human Trafficking is being detected more efficiently and many industries are considering to help prevent/ detect/report transactions. 

Organizations such as Polaris and initiatives such as STATs, a technology-armed platform (formed through Enigma) are aimed to highlight trends of HT, where information is captured, and shared for the purpose of dismantling systems connected to trafficking. 

It’s important for all financial institutions to stay abreast of new trends, ensure KYC is informative and comprehensive and that conversations among law enforcement is communicative and thorough. 

One area that I strongly believe requires careful consideration and improvement is the language in which we address HT.

Each industry has a different vocabulary, some considered derogatory in nature (e.g., HT should not be referenced as prostitution, being it is against ones will/ by use of force, etc.). 

It’s time for society as a whole (especially those with direct exposure) to take responsibility for updating outdated/biased language, by considering HT from a place of empathy.

There is much to learn from the approach taken by those that are providing resources and dedicated support to the front lines (i.e.,nonprofits). In turn, I believe this perspective will improve our communication and effectiveness.  

5. Why did you apply for the CFCS certification scholarship?

 I applied for this scholarship after discovering it through a colleague. I am committed to doing everything I can to help in this area specifically, because it is my passion to raise awareness around the topic and join the fight in putting it to an end.

I believe my experience with FI’s around AML and at the forefront with individuals who have had to endure this terrible epidemic offers an alternative to putting less victims on the stand and holding perpetrators accountable through financial statements.

Through this, victims will not have to relive their trauma and the statements serve as stronger evidence. 

6. How do you think the CFCS credential will impact your career, especially your work to combat human trafficking?

I am looking forward to this credential because it will provide me with a deeper level of certainty and knowledge to work on this topic in a specialized area within the financial institution.

Specifically, I look forward to bridging gaps and assisting with collaboration between various sectors.

Collectively, there is so much information that can be utilized to identify HT and staying abreast of emerging trends involves all of us, most importantly, FI’s, LE, Nonprofits, Medical Field, Hospitality, and Transportation sectors.