For Texas native Mallory Harrington, she knows that uncovering the nuanced, buried red flags of financial transactions tied to human trafficking is a challenge – because the criminals running these networks are doing their best to stay hidden and continue to target and harm new victims.
But as an anti-money laundering/Bank Secrecy Act (AML/BSA) officer for TFNB Your Bank for Life and being a member of the Heart of Texas Human Trafficking Coalition, she has a unique perspective.
She is privy to view the interweaving of credit and debit card transactions and view the interplay between individuals and businesses and be able to view those crisscrossing data points through the lens of a shrewd investigator sensitized to the full spectrum of financial crimes.
Harrington has been working in financial institutions for more than 10 years, with her curiosity, tenacity and quest for knowledge in this space helping her jump from roles in accounts payable to ever more complex positions tied to uncovering and investigating financial crimes.
She has worked in dedicated counter-crime roles for nearly four years, with a hyper-focus on human trafficking (HT).
“In my day to day role, I follow the money!” she told ACFCS. “Money and remaining unidentified is the motivation of a trafficker. I look for reg flags that may be indicative of trafficking. Cash is not the only red flag, there are other indicators as well.”
Some of these can include, “multiple hotel charges in a day, and excessive use of transportation networks throughout various accounts,” she said. “I focus on cash intensive industries that are more vulnerable to trafficking like spas, and nightclubs.”
Part and parcel of this drive to learn about the financial tells of human traffickers, terror groups, sanctions evaders, fraudsters, identity thieves and money launderers is that she has always had a soft spot for the victims.
She knows intimately that when they win – for instance in the case of identity theft – a bank customer, friend or relative can lose, in some cases, everything.
“I find it rewarding to share my knowledge and bring awareness to family and friends,” she said. “I also find it very rewarding to speak to law enforcement officials on the basics of money laundering and financial red flags for human trafficking.”
As part of that broader mission, she also shares what she has learned with the Heart of Texas Human Trafficking Coalition and the related financial red flags with area law enforcement.
By arming law enforcement with a better understanding of what can be small, diffused transactions for seemingly lower-risk businesses, investigators can both cripple trafficking networks and free individuals trapped in a cycle of human slavery.
“After all, traffickers must launder the money in effort to remain undetected,” Harrington said. “It feels great to share my knowledge with an audience that actually has the authority to pursue the criminal [tied to] the trafficking [network] and potentially save hundreds of victims in the process.”
In recent years, one of Harrington’s key focus areas has been on improving awareness, with a call to action to operations outside of banking.
“One area I think we could improve is awareness and training, and not just training for the financial industry, but all industries,” Harrington said. “The general public needs tools for more awareness on detecting and how to report it.”
It was for those and many other reasons ACFCS chose Harrington as one of the recipients of the association’s inaugural 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.
Those chosen for the scholarship 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.
Harrington was kind enough to share some of her thoughts, insight and experiences in this ACFCS Scholarship Spotlight.
Mallory Harrington, AML/BSA Officer at TFNB Your Bank for Life
How do you work to detect, prevent and/or raise awareness of human trafficking, in your job role or outside of it?
In my day to day role, I follow the money! Money and remaining unidentified is the motivation of a trafficker.
I look for red flags that may be indicative of trafficking. Cash is not the only red flag, there are other indicators as well.
Some of these include, multiple hotel charges in a day, and excessive use of transportation networks throughout various accounts. I focus on cash-intensive industries that are more vulnerable to trafficking like spas, and nightclubs.
Outside of my job role, I am a member of the Heart of Texas Human Trafficking Coalition. As a coalition, our mission is to increase awareness for prevention and detection and to provide services to the individualized needs of human trafficking victims.
In an effort to aid in investigations, I also present on money laundering basics and financial human trafficking red flags for area law enforcement.
What is the most rewarding part of your job?
I find it rewarding to share my knowledge and bring awareness to family and friends. I also find it very rewarding to speak to law enforcement officials on the basics of money laundering and financial red flags for human trafficking.
After all, traffickers must launder the money in effort to remain undetected. It feels great to share my knowledge with an audience that actually has the authority to pursue the criminal [tied to] the trafficking [network] and potentially save hundreds of victims in the process.
When it comes to human trafficking detection/prevention, what do you think is going well, and where could we get better?
One aspect I believe is going well is the advances in technology when it comes to detecting potential trafficking on the financial side.
Utilizing data and analytics has proven a huge tool for me in detecting. Without technology, it would be hard to do my job.
One area I think we could improve is awareness and training, and not just training for the financial industry, but all industries. The general public needs tools for more awareness on detecting and how to report it.
I know that there are a lot of misconceptions on what trafficking really is. There are so many stigmas associated with massage parlors.
Although very common, this is not the only business industry this is happening in. Trafficking does not discriminate or target race, gender or age specifically. Trafficking is not isolated to third world [countries] or the disadvantaged, inner-city kid.
Why did you apply for the CFCS certification scholarship?
I applied for the CFCS certification scholarship because I felt the credential will provide me with extensive knowledge and a variant skill set to assist in detecting various financial crimes.
As a financial crime professional, I am passionate about my work and I look for ways to utilize all the tools and resources available to me.
How do you think the CFCS credential will impact your career, especially your work to combat human trafficking?
This certification will impact my career by giving me a wide range of knowledge across the financial crime spectrum. The threats I face are always changing and this certification will help me recognize and respond to those threats.
The CFCS credential will also assist me in providing extensive training to law enforcement across Texas, in hopes to ultimately combat human trafficking and related crimes while helping to protect members of my local community.