Trying to counter a crime as complex and nuanced as human trafficking – with criminal networks in recent years more aggressively weaving transactions in crypto coins and dispersing them through seemingly unconnected credit and prepaid cards and bank accounts – is a team effort, says Rosie McWhorter.
As a senior anti-money laundering (AML) investigator, the Dallas resident has dedicated herself to learning the latest transactional red flags of trafficking operations, and the expanding array of businesses they can hide behind, to better teach her own team at the financial services company and share those best practices with other institutions and law enforcement.
McWhorter is cognizant that financial institutions in many cases are on the front lines when it comes to detecting, preventing and reporting on suspected activities indicative of human trafficking – and such an awareness should be expanded to all areas of an operation, from tellers to business lines, the c-suite and even the board.
Moreover, she believes it’s also vital banks, credit card companies and other financial institutions compare notes with each other to better understand the latest human trafficking tactics and connect the dots when larger networks are working across multiple institutions.
That spirit of camaraderie in pursuit of a common goal also must be broadened related to public-private partnerships between banks, law enforcement and even non-government organizations and domestic and international watchdog groups.
The more quickly and completely these groups can identify the latest human trafficking typologies – what sites traffickers are using, which regions they are co-opting and moving victims and funds and even what new businesses are being used as front companies – can empower investigative agencies to act, freezing funds and potentially even saving lives.
For McWhorter, her focus on human trafficking under the ambit of the over-arching AML program is the culmination of more than 15 years working in financial services, mostly in investigations roles, where she has been voraciously gathering expertise on a broad array of financial crimes, including fraud, identity theft, sanctions, terror financing and others.
After starting out in a call center in 2003, her bosses “quickly realized my overall nosiness could come as a benefit, and I moved pretty quickly to an investigation role,” she told ACFCS. “I’ve felt myself to be an advocate in my work, be it fighting for ID theft victims, keeping people from getting ripped off in fraud schemes, and now, fighting in the arena of HT detection and prevention.”
The calling to deepen her understanding of fincrime investigations comes both from a desire to stop criminals, but also to protect victims.
“I’ve found myself drawn investigation roles because it puts me in a position to help protect people in vulnerable situations, which is why I am grateful to be able to dedicate the time to helping solve for what is a global epidemic,” McWhorter said.
Recently, her primary focus has been on a “Human Trafficking detection initiative, in an effort to help build future detection methods, which in future scope can hopefully help other financial institutions bulk up their programs in this space.”
Another lesser talked about arena around human trafficking McWhorter is analyzing is trying to figure out how banks can help confirmed victims rebuild their financial lives.
“Activity may be conducted on an account owned by a victim, but do we want to treat processing on these cases the same for a victim as we do the perpetrator?” she said.
In this latest phase of her career, McWhorter is realizing that whatever banks do to better detect a given crime, criminals also respond, adapt, and create new avenues to obfuscate their formal interactions with the international financial system.
“Nowadays however, those purchase methods have shifted to using digital currency, or even gift cards for the purchases, so you’re constantly having to shift what you’re looking for in your detection methods,” she said.
“It’s so easy to open up accounts and credit cards at financial institutions, or to use peer-to-peer networks to move money, that traffickers can obscure the money trail so each financial institution is only seeing a snippet of the overall activity patterns.”
Even so, while the challenges to uncover and cripple human trafficking networks may be herculean, working as an ally of law enforcement and getting validation her institution is helping in the fight is a powerful incentive.
The most rewarding part of her job is “being in the realm of financial investigations, writing a [suspicious activity report (SAR)] and later having Law Enforcement (LE) follow up for additional documentation is a pretty great feeling,” McWhorter said. “Knowing that I’ve presented a thorough case that compelled LE to dig in deeper is immensely satisfying.”
It was for those and many other reasons ACFCS chose McWhorter 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 crime and compliance around 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.
McWhorter was kind enough to share some of her thoughts, expertise and experiences in this ACFCS Scholarship Spotlight.