Posted by Brian Monroe - firstname.lastname@example.org 00/09/2019
Scholarship Spotlight: Focus on victim protection, rather than prosecution, critical to building human trafficking cases, says Joseph Scaramucci
For Joseph Scaramucci, taking down criminals, following the money and saving victims is why he got into law enforcement in the first place more than 15 years ago – a calling that has in recent years become a mission to tackle the soaring scourge of human trafficking and change the focus of investigations from prosecuting victims to protecting them.
As a result, the Texas native and detective with the McLennan County Sheriff’s Office in the last five years has arrested more than 450 sex buyers, captured some 125 individuals suspected of human trafficking and related offenses and identified more than 230 trafficking victims.
But he couldn’t have done it without intensively focusing on unraveling the complex and disparate human and financial sides of these of human trafficking networks – and aggressively sharing those best practices.
“I think education is key to detection and prevention,” he told ACFCS. “For law enforcement and the justice system, to our citizens. Until people learn to be angry about the exploitation of other human beings, it makes it difficult for them to consider someone could be a victim of trafficking.”
Scaramucci has also been relentlessly diligent to broaden his understanding of the various trafficking typologies to better identify them and crush the larger networks.
“I investigate all aspects of human trafficking, from all forms of sex trafficking, to all forms of labor trafficking,” he said. “I train law enforcement both nationally and internationally on how to conduct human trafficking operations, as well as the following investigations.”
Scaramucci has also worked to emulate and magnify those regional successes with the sheriff’s office by sharing knowledge of human trafficking red flags domestically and internationally with both state and federal investigations as a Task Force Officer with Homeland Security Investigations (HSI), part of the U.S. Department of Homeland Security.
The joint Task Force spearheaded investigations and arrests throughout the U.S., Canada, China, New Zealand, and Guatemala.
Scaramucci, however, didn’t stop there.
He is passionate about building capacity in any region and any agency in the U.S. and beyond related to the transactional trails and nuanced permutations of human trafficking investigations.
He has also led and trained 215 law enforcement agencies throughout 26 states, extending investigative thought leadership in the human trafficking arena to 3,000 people, including a powerful cross-section of professionals from law enforcement, attorneys, and non-government organizations.
On the federal end of the spectrum, Scaramucci has also trained nine agencies, including the U.S. Army and Air Force and the Mongolian Federal Police and Prosecutor’s Offices on how to conduct counter-trafficking operations, along with stings targeting illicit massage parlors – a common front for monetizing trafficked victims.
As part of taking a broader, more criminal-focused approach, Scaramucci is also championing a change in law enforcement pressure, which can sometimes snare victims and paint them with the same brush as those who took advantage of them.
“I have been approaching human trafficking using non-traditional investigative practices for years,” he told ACFCS. “Most entities will detain or arrest victims with the hope of the victim then testifying against their trafficker.”
But there is much better financial crime fulcrum: funding.
“We have proven for many years that this works on an extremely limited basis, so we are forced to look to other laws and methods to attack trafficking,” Scaramucci said. “One thing all traffickers seek to gain, is money. Most traffickers cannot escape money laundering and RICO cases, because they have to enter illicit funds into their daily lives through various ways.”
RICO refers to the federal Racketeer Influenced and Corrupt Organizations law, a powerful piece of legislation passed in 1970 aimed at taking down organized criminal groups with a collection of nearly three dozen predicate offenses, including murder, kidnapping, bribery and others.
He is further employed as a consultant for the Polaris Project, training agencies throughout the country, along with providing technical support for their Human Trafficking Operations and Investigations.
While expanding knowledge to bolster investigations around the globe is fulfilling, saving victims is equally important.
“The most rewarding part of the job would be removing a victim from their situation and assisting with whatever way I can to ensure that they have the tools necessary to no longer be vulnerable to the tactics used by traffickers to recruit them back into the networks,” Scaramucci said.
A worthy goal he believes attaining the CFCS designation will reinforce and embolden.
“I wanted to further my knowledge of anti-money laundering (AML) to have a much deeper understanding of how financial crimes are conducted and obtain a deeper knowledge of how all types are carried out.”
It was for Scaramucci’s drive, dedication and passion to share that ACFCS chose him 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 from April through June of this year.
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.
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.
ACFCS in the current quarter has a focus on cryptocurrencies. To read more about the crypto initiative and find a list of useful resources, click here.
Those chosen for these 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.
Scaramucci was kind enough to share some of his thoughts, expertise and experiences in this 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?
My role is as a Human Trafficking Investigator for my Sheriff’s Office. I investigate human trafficking either through incoming tips, or from the initial undercover work through the duration of the investigation.
I investigate all aspects of human trafficking, from all forms of sex trafficking, to all forms of labor trafficking. I train law enforcement both nationally and internationally on how to conduct human trafficking operations, as well as the following investigations.
2. What do you see as key challenges related to human trafficking detection/prevention in your role or in the sector overall?
I believe the biggest challenge from a law enforcement perspective is building cases that are offender focused, in order to take the center of the investigation off of the backs of the victims.
As a training provider, this is often the most difficult part, because most law enforcement entities see human trafficking as a “prostitution” based offense, rather than organized crime and money laundering. Shifting that focus within law enforcement is definitely a challenge.
3. What is the most rewarding part of your job?
The most rewarding part of the job would be removing a victim from their situation and assisting with whatever way I can to ensure that they have the tools necessary to no longer be vulnerable to the tactics used by traffickers to recruit them back into the networks.
4. When it comes to human trafficking detection/prevention, what do you think is going well, and where could we get better?
I think education is key to detection and prevention. For law enforcement and the justice system, to our citizens. Until people learn to be angry about the exploitation of other human beings, it makes it difficult for them to consider someone could be a victim of trafficking.
5. Why did you apply for the CFCS certification scholarship?
I have been approaching human trafficking using non-traditional investigative practices for years. Most entities will detain or arrest victims with the hope of the victim then testifying against their trafficker.
We have proven for many years that this works on an extremely limited basis, so we are forced to look to other laws and methods to attack trafficking. One thing all traffickers seek to gain, is money.
Most traffickers cannot escape money laundering and RICO cases, because they have to enter illicit funds into their daily lives through various ways.
I wanted to further my knowledge of anti-money laundering (AML) to have a much deeper understanding of how financial crimes are conducted, and obtain a deeper knowledge of how all types are carried out.
6. How do you think the CFCS credential will impact your career, especially your work to combat human trafficking?
I feel like the certification will lend much more credibility in very different ways. A basic understanding of crimes is often not enough to aggressively investigate them.
As a certified expert witness in criminal courts of law, it provides another deep form of credibility to assist courts in determining whether or not human trafficking is occurring.
See What Certified Financial Crime Specialists Are Saying
"The CFCS tests the skills necessary to fight financial crime. It's comprehensive. Passing it should be considered a mark of high achievement, distinguishing qualified experts in this growing specialty area."
KENNETH E. BARDEN
"It's a vigorous exam. Anyone passing it should have a great sense of achievement."
(CFCS, Official Superior
de Cumplimiento Cidel
Bank & Trust Inc. Nueva York)
"The exam tests one's ability to apply concepts in practical scenarios. Passing it can be a great asset for professionals in the converging disciplines of financial crime."
(CFCS, Royal Band of
"The Exam is far-reaching. I love that the questions are scenario based. I recommend it to anyone in the financial crime detection and prevention profession."
(CFCS, CAMS Lead Compliance
Trainer, FINRA, Member Regulation
Training, Washington, DC)
"This certification comes at a very ripe time. Professionals can no longer get away with having siloed knowledge. Compliance is all-encompassing and enterprise-driven."
CFCS, CAMS, CFE, CSAR
Director, Global Risk
& Investigation Practice
FTI Consulting, Los Angeles