Festus Aisagbonhi knows that one of the greatest allies for criminals is when people – whether they are compliance professionals, investigators and even potential victims – don’t even understand the crime, or know the underlying human and financial red flags.

That’s why as Head of Conduct and Compliance at Access Bank Rwanda Plc, he uses his passion and position to understand all there is to know about human trafficking and share those best practices within his bank and with nearby allies to form a regional counter-crime compliance bulwark in the Central and East African country, one of the smallest in Africa.

With nearly 20 years of banking experience, and recent years in top anti-money laundering (AML) compliance positions, Aisagbonhi realizes criminals will look to launder their ill-gotten funds in regions with weak AML laws or little understanding of trafficking red flags. He is making sure his bank isn’t one of them.

“In many of these countries, laws criminalizing trafficking are relatively new and investigators simply lack the expertise and experience to effectively investigate this class of crime,” he told ACFCS. “In many countries trafficking is still a new crime.”

Aisagbonhi knows the critical importance of sharing knowledge related to the transactional trails indicative of human trafficking both near and far as many large syndicates cross borders in hopes individual investigative agencies won’t be able to put all the pieces together.

“The transnational nature of many trafficking cases presents particular challenges to law enforcement, who must collect evidence from foreign jurisdictions, some of which may be unwilling or unable to cooperate,” he said, citing academic research.

Even though countering this crime comes with a host of challenges, Aisagbonhi stated being part of the fight is its own reward.  

“The most rewarding part of my effort is in the aspect of standing as voice and a catalyst at the forefront of efforts towards addressing the ugly trend of human trafficking,” he said. “With a clear mission of ensuring the three P’s: prevent trafficking, protect victims and prosecute traffickers. [That] slogan is now becoming a norm in the environment.”

Part of the issue is also spreading awareness so vulnerable individuals are not victimized in the first place, Aisagbonhi said.  

“From improving female education in source countries so that girls are less vulnerable to trafficking to increasing the incentives and motivation of law enforcement agents in destination countries so that officers are less susceptible to bribery” are vital goals, he said.

In 2000, the United Nations launched the Protocol to Prevent, Suppress and Punish Trafficking in Persons, which established a victim-centered approach to trafficking, with nearly 180 countries already signed on.

As well, in 2005, the Council of Europe Convention on Action against Trafficking in Human Beings came into force, marking a “step towards greater cooperation and dedication within Europe,” Aisagbonhi noted.

“But more needs to be done,” he said. “Many people still do not know what trafficking is or do not care. We need to work to change that, at every level of society through the creation of proper awareness and full criminalization of human trafficking under any guise.”

It was for those and many other reasons ACFCS chose Aisagbonhi 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 compliance controls and financial crime inclinations involving 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.

Aisagbonhi was kind enough to share some of his thoughts, expertise and experiences in this ACFCS Scholarship Spotlight.

I am earnestly passionate about the measures towards preventing the age-long problem [of human trafficking] with the attendant risk of terrorist financing, as a compliance manager and through the Committee of Chief Compliance Officer forum in my seconded country, Rwanda.

We have to embark upon actions that will expose the hideous act of trafficking through supporting community awareness via online communications to various stakeholders in [uncovering] the contemporary act of the traffickers within the border with [Democratic Republic of Congo].

The campaign platform is available in several languages and encourages users to upload their own videos with anti-trafficking messages and to get involved with NGOs in their communities.

We also explore various mediums to get to the intended audience, which helps them to evaluate their potential risks for human trafficking and point out actions that can be taken to address them.

Below are some suggested measures for corporate entities to take up [to champion] Corporate Social Responsibility (CSR) in preventing human trafficking in our society by the forum:

• Technology companies can coordinate to create an industry code of conduct to combat trafficking online.
• Media and technology companies can use their distribution channels and services to increase the awareness of [red flags tied to] trafficking online.
• Companies interested in implementing a CSR policy of preventing human trafficking can attempt to limit illegal activity through their terms of use (or terms of service). The terms of use for each website and service are an important resource for learning the policies and priorities of the various popular online platforms.
• Private-sector cooperation with law enforcement is one way to bring successful prosecutions of trafficking.
• Criminal justice and law enforcement organizations should not only enforce existing anti-trafficking laws but refine their methods to fight modern slavery in order to keep up with an evolving understanding of the crime.
• In order to keep pace with the rapidly changing methods of online communications [that could be linked to human trafficking networks], law enforcement needs the support of the private sector.
• Companies can provide efficient mechanisms for public authorities to access actionable information related to trafficking in persons.

Law enforcement agencies in many countries lack the training, experience, and resources to investigate complex, transnational organized crime.

In many of these countries, laws criminalizing trafficking are relatively new and investigators simply lack the expertise and experience to effectively investigate this class of crime. Indeed, as Gallagher and Holmes (2008, p. 320) observe, in many countries trafficking is still a new crime, involving “new and untested laws” (see also Farrell, Owens and McDevitt, 2014).

The transnational nature of many trafficking cases presents particular challenges to law enforcement, who must collect evidence from foreign jurisdictions, some of which may be unwilling or unable to cooperate.

This challenge was recognized in the United States case of Cruz v. Toliver, (W. D. Ky. March 30, 2007). The court held ” Claims of forced labour and trafficking (…) required more time, effort and research to address (…) The Plaintiff’s counsel not only had to conduct discovery here in the United States, but also had to go abroad to take discovery in order to submit the claim under these statutes.”

Challenges include:

• Logistical difficulties in investigating cross-border criminal activity.
• Lack of cooperation, resources, training, skills and adequate laws.
• Shortcomings and conflicts between the laws of the various countries in which a particular group of traffickers are operating, creating difficulties in investigating, arresting, extraditing and prosecuting offenders.
• The ability of traffickers to evade arrest by absconding from the jurisdiction attempting to hold them to account.
• The ease with which traffickers can launder the proceeds of their criminal activities in countries with underdeveloped financial transaction tracking systems.
• The logistical difficulties in providing protection to victims, witnesses and their families living outside the prosecuting jurisdiction.
• Victims reluctant to testify – Many victims are reluctant to take part in criminal trials (see Davy, 2017). Numerous factors feed into this reluctance, including, inter alia, fear of reprisals by traffickers and their associates, irregular status and fear of deportation, mistrust of authorities, shame, and a perception that their traffickers’ actions are not criminal or wrong.
• Others may simply want to go home and restart their lives, rather than stay for potentially lengthy periods in a country where they experienced exploitation and abuse. As Davy (2017, p.123) observes, “[t]here is little doubt that the experience of providing evidence as a witness can be a traumatic event, and one that may lead to ‘secondary victimization.'”
• Victim testimony – many challenges are linked to victims’ testimonies in trafficking cases. Some victim testimonies do not appear to be candid, straightforward and unwavering, but rather seem to be inconsistent, irrational, unpersuasive or clearly untruthful. In some cases, there is no other credible evidence to corroborate testimony.

The most rewarding part of my effort is in the aspect of standing as voice and a catalyst at the forefront of efforts towards addressing the ugly trend of human trafficking.

With a clear mission of ensuring the three P’s: prevent trafficking, protect victims and prosecute traffickers. [That] slogan is now becoming a norm in the environment.

The first step to preventing human trafficking and prosecuting the traffickers is therefore to recognize the complexity of the crime which cannot be tackled in a vacuum.

Anti-trafficking strategies have to be embedded in every policy area: 

• From improving female education in source countries so that girls are less vulnerable to trafficking.
• To increasing the incentives and motivation of law enforcement agents in destination countries so that officers are less susceptible to bribery.
• We cannot allow ourselves to marginalize the issue of trafficking, viewing it as something that can be ended with a few extra task forces or dedicated units.
• We need everyone to be aware of how it affects them, and what they can do to stop it.
• Laudable efforts in this direction have already been made. In 2000, the United Nations launched the Protocol to Prevent, Suppress and Punish Trafficking in Persons, which established a victim-centered approach to trafficking.
• It has since been signed by 177 countries. In 2005, the Council of Europe Convention on Action against Trafficking in Human Beings marked a step towards greater cooperation and dedication within Europe.
• But more needs to be done. Many people still do not know what trafficking is or do not care. We need to work to change that, at every level of society through the creation of proper awareness and full criminalization of human trafficking under any guise.

In addition, [the CFCS Certification will add] to my growing passion in expanding my knowledge in the area of financial crime after my certification as an Anti-Money Laundering Specialist (CAMS).

I see [the CFCS Certification] as a golden opportunity to actually present my view in fighting human trafficking. [That crime is a] monster that is contending with the dignity of humanity.

[CFCS will] also contribute in a little measure on what I feel will be more effective [human trafficking investigations] through innovative approaches that have the potential to be used by various actors in anti-trafficking efforts.

I believe technological interventions in anti-trafficking may fall into one or more of the following categories which can be extensively explored in mitigating the growing trend of human trafficking:

• Technology that disrupts behaviors that underpin the trafficking trade
• Technology that helps anti-trafficking groups to cooperate, and
• Technology used to create public awareness and/or provide support for victims and survivors of trafficking.

My CFCS experience has impacted my career tremendously, having unhindered access to several current and correct articles on financial crime and a solid long list of webinar sessions which I always look forward to has aided me on the job and also contributed immensely in presenting my views on the topic I am extremely passionate about – Human Trafficking Detection and Prevention.

I definitely know passing the certification examination will open a new door to a greater impact in my professional calling.