By Brian Monroe
September 10, 2019
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.
1. How do you work to detect, prevent and/or raise awareness of human trafficking, in your job role or outside of it?
My primary job function is as a Senior AML Investigator, working in my financial institution’s Special Investigations Unit.
My previous manager was incredibly talented and worked with data analytics to build an initial set of transaction-based alert rules, that will “trigger” a relationship-wide review.
Using the groundwork that she set, as well as information we’ve learned since, I get to work with management and the data magicians to try and start to build predictive behavioral rules.
We take “if this, then that” scenarios that we make up on the fly, outlying transaction patterns we’ve observed, or red flags we’ve since identified in the ever-changing landscape, and test if the scenarios we are running are indicative of human trafficking.
Using the information we glean from our testing, and as we learn more about what Human Trafficking (HT) looks like, we’re able to train out investigators on what to look for.
I of course can’t go into specific details as to what scenarios we are running or the investigation process, but we are hoping in the future to be able to take the data patterns we learn to be indicative of HT, and to use that knowledge as a blueprint to share in the future, with non-governmental organization (NGO) partners and other financial institutions.
Another thing that I’m interested in 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?
With legal services funding for trafficking victims having been removed or restricted by the current administration, what part can financial institutions play in helping victims rebuild their financial lives and assimilate back into society?
Currently this is not something that is commonly looked at [from] the investigative perspective, but Polaris points out that without access to the financial system, victims obviously have a hard time rebuilding their lives.
It’s far off on the horizon, and obviously as a financial institution (FI) we can’t solve for perfect, but I’d love to see banks taking a proactive approach in offering victims a second chance in one arena that we do have control.
2. What do you see as key challenges related to human trafficking detection/prevention in your role or in the sector overall?
Human Trafficking is so pervasive in our culture, and most people don’t even realize it – the National Human Trafficking Hotline receives about 150 calls a day, and this is only the people that are reaching out for help!
But it’s also relatively new in the public conscious – it wasn’t even technically made illegal here in the U.S. until 2000.
One challenge is the fact that Human Trafficking has so many facets – you hear HT, and automatically think of sex trafficking, in particular having to do with children, because that’s what’s out there and on the mind of the public.
But the true face of HT is not just sex trafficking, but also cantinas or residential brothels, it’s the operation of Illicit Massage Businesses, it’s labor trafficking as well.
It can be someone who is forced to prostitute themselves, but it can also be the person who is working in the factory of goods you purchase, someone growing the food you eat, someone cleaning your house, someone doing your nails, or it can be the kid that is part of a sales crew that knocks on your door to try and sell you products under the guise of earning money for college.
Navigating the ever-changing landscape of what Human Trafficking looks like is going to always be an uphill battle, from a detection standpoint.
One of the largest challenges we face on the investigation side, is the fact that the methodologies are always changing.
For example, you used to be able to look and see purchase activity for Backpage or other websites that cater to the salacious advertising purchases, when looking for potential sex trafficking.
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.
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.
These challenges beg a host of questions in a quest for a solution:
• How can we build scoring models without being overly broad and grabbing a bunch of false positives?
• What is the best way to train out investigators in charge of monitoring without running the risk of having an inundation of false alarms or flooding [the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN)] with a bunch of Human Trafficking SAR filings?
• What are best practices we can learn from other financial institutions or law enforcement?
• How can FI’s work together to share information, using the channels available to us (ie [Patriot Act Section] 314 (b) sharing requests) when we identify an immediate risk?
• How can we build a platform for banks to be able to share trends they’re observing?
By bringing more focus to the subjects, including the way ACFCS has made a huge focus this last quarter, hopefully it will help us all to solve for these issues.
3. What is the most rewarding part of your job?
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.
Knowing that I’ve presented a thorough case that compelled LE to dig in deeper is immensely satisfying.
Of course, by time we as a bank can detect the activity, it’s already happening – but knowing that we have the possibility to intervene and prevent further damage from being done – that’s reward in and of itself.
I can’t say enough how rewarding it is, and how grateful I am to work for an organization that invests so much time, energy, and resources in doing our part to fight against this global epidemic.
4. When it comes to human trafficking detection/prevention, what do you think is going well, and where could we get better?
I think continuing to get knowledge out there is going to be paramount. In just a few short years, public knowledge has increased on the subject, and it’s much more visible in the public eye.
It was just around 2016 that airlines started training staff to look for signs of HT, and these days you can’t walk 100 feet in an airport without seeing signs with resources to report suspicious activity.
California passed a law that requires manufacturing and retail firms disclose what they’re doing to prevent HT – and while compliance numbers are abysmal, it’s a step in the right direction.
Human Trafficking hides in plain sight, and even when it’s not doing a whole lot to hide, like advertising, we’re blind to it, because it’s not something we’re looking for.
The National Center for Missing and Exploited Children states that more than 70 percent of the child sex trafficking reports it has had have involved salacious advertising, from websites like Backpage. [Think about that figure for a minute: 70 PERCENT.]
They also estimate that 60 percent of recovered child victims were in the foster care system at some point.
As a bank, we’ve got to get better at detecting this kind of activity in real time, and submitting solid, quality SARs for Law Enforcement to follow up on.
We’ve got to get better as a whole at protecting the men, women, and children that are getting trafficked, and while we don’t get to make the laws or make the arrests, banks have a huge part to play in this, because we see some of the most intimate aspects of a person’s life: how they spend their money.
If we can use channels open to us for information sharing with other financial institutions, we can get a clearer picture of everything that’s happening financially and present a strong case to Law Enforcement.
If we can get strong filings to Law Enforcement, they can follow up and make arrests.
One thing that I think we’re doing great here at my bank is taking a proactive approach to looking for new ways to detect Human Trafficking, in all of its forms.
We’ve established a relationship with Polaris, which is an invaluable resource when we’re looking at what steps we can take moving forward.
The resources and knowledge that organizations like Polaris have are invaluable to Financial Institutions, because they have real world interaction with victims, and can help us do our jobs better.
Their publications are great training tools, and they know well before we do what the face of human trafficking is and what the activity patterns are going to look like.
We can look at facts and data all day long, but having that real-time knowledge is incredibly helpful. [So much so in fact, that] I’d urge other FI’s to establish relationships like these where they can.
There are also many great publications out there – from Polaris, FATF, The UNODC, FinCEN, etc- there are open-source learning resources out there, which is more than can be said for 10 years ago.
[FATF stands for the Paris-based Financial Action Task Force, which sets global AML and counter-crime compliance standards. UNODC standards for the United Nations Office on Drugs and Crime.]
5. Why did you apply for the CFCS certification scholarship?
I’ve been interested in joining the ACFCS family for some time now.
The webinar content is always top notch, and the certification is a great compliment to others, since it’s the only one that I know of that is all encompassing, versus just being geared toward fraud or AML concerns.
The resources that ACFCS is dedicating to their quarterly focuses are pretty incredible. There are a ton of great resources on the HT Dashboard, and even though it’s phasing from HT to Crypto for this quarter, even that information can help us do our jobs better because many facets of HT are digital.
The knowledge and real-world experience that is being brought in by the other scholarship recipients is pretty incredible. Being a part of the ACFCS community is going to be an invaluable resource, and I’m grateful to have been included last quarter.
6. How do you think the CFCS credential will impact your career, especially your work to combat human trafficking?
Knowledge, knowledge, knowledge! The more I know, the more I can teach other people.
Having the CFCS certification shows that not only is the investigation of financial crimes something I do for a living, but that I’ve dedicated myself to continued learning, and bringing real-time knowledge into my investigations.