Following the Money, Shutting Down Exploitation

With the support of HHS’s Office on Trafficking In Persons, Polaris operated a trusted national lifeline for trafficking victims for almost two decades — a program built from a survivor’s vision and expanded through deep listening and action. That experience made one thing clear: stopping trafficking means going beyond crisis response. 

Survivors asked us to help disrupt exploitation at its source. The Financial Intelligence Unit (FIU) is one part of our answer. It’s a survivor-informed program that helps financial institutions detect trafficking, follow the money, and pursue justice without causing further harm.

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To stop human trafficking, we have to think like traffickers. We have to understand how they operate and, importantly, how they hide. That means looking at systems and asking who profits, who’s protected, and who’s being exploited. Polaris’s Financial Intelligence Unit (FIU) was built for exactly that.

With survivor-informed strategies and partnerships across the financial sector, the FIU is disrupting trafficking at its roots: by following the money.

Making the Invisible Visible

Human trafficking doesn’t always announce itself through obvious financial patterns. In many cases, there’s no single red flag — just a series of subtle gaps, inconsistencies, or warning signs that only make sense when viewed together.

That’s where Polaris comes in. With deep expertise in fighting human trafficking across typologies, Polaris’s FIU serves as a trusted partner to financial institutions, provides technical expertise, helps partners refine risk indicators, and convenes conversations across the sector to share emerging best practices.

“Sometimes, what matters most isn’t what you see — it’s what’s missing,” said one FIU team member.

Traditional transaction monitoring — like flagging suspicious activity based on thresholds or patterns — remains a vital tool. It has helped identify countless trafficking cases and should absolutely remain part of any institution’s approach. But it’s often not enough on its own.

That’s why Polaris encourages institutions to take a broader view that includes things like due diligence during customer onboarding, periodic reviews, and risk assessments based on sector, geography, and labor practices.

A business might appear legitimate on paper, but something in the staffing, payroll, or transaction history doesn’t add up. The number of employees seems low for the size of operations. Insurance claims don’t reflect known risks. Loan activity doesn’t align with reported revenue.

By connecting the dots across these different touchpoints, institutions are better equipped to identify potential trafficking and intervene earlier. It’s not about casting suspicion broadly. It’s about asking smarter questions and recognizing that exploitation can hide behind even the most routine financial activity.

Powerful Partnerships & Best Practices

In 2024, Polaris welcomed its first credit card company to the FIU’s network of partners. It’s a meaningful expansion of the collaborative ecosystem working together to disrupt human trafficking. As money moves in increasingly complex ways, it’s critical that all corners of the financial system — from banks to payment platforms to card issuers — are engaged and sharing insights.

Through Polaris’s bimonthly FIU convenings, these partners exchange best practices, surface new trends, and learn from one another’s approaches. Presentations from financial institutions doing this work have helped foster a deeper understanding of how financial products are used — and misused — across different platforms.

“These gatherings create space for innovation,” said one FIU team member. “Partners can compare notes, share what’s working, and strengthen their ability to identify and disrupt trafficking.”

Justice Redefined

Financial intelligence doesn’t just help stop trafficking; it helps ensure accountability.

FIU analysts contribute research to support broader enforcement tools like trade protections and labor investigations. By mapping financial relationships and documenting patterns, they equip policymakers and regulators with the evidence they need to act.

In one case, Polaris helped surface financial evidence related to a company suspected of trafficking workers through a pattern of dissolving, reorganizing, and relaunching under new names to avoid detection. Financial intelligence made it possible to follow that trail and help put an end to the cycle of abuse.

But for the FIU, justice isn’t just about convictions. It’s about disruption, restitution, and repair.

Under the Trafficking Victims Protection Act, convicted traffickers are required to pay restitution to those they exploited. But that restitution is rarely ordered — and even more rarely paid. Polaris’s FIU works to change that by identifying assets early and providing courts with the tools to seize them.

Financial investigations make it harder for traffickers to hide their wealth and easier for survivors to receive what they are owed. They help courts move beyond punishment and toward meaningful accountability: not just jail time, but financial disempowerment. As one Polaris leader shared, “When you take away traffickers’ assets, you also take away their ability to earn more money by exploiting other people.”

What Comes Next

Polaris’s FIU has already proven what’s possible, but there’s more to do. 

The team is pushing to follow money across borders to help dismantle transnational trafficking rings. With expanded resources, they could trace international remittances, investigate crypto-based transactions, and partner more deeply with global financial institutions.

And as always, they’re grounded in survivor insight.

“We wouldn’t be here if survivors hadn’t trusted us with their stories — and their statements,” said one leader. “Our job is to make that trust count.”

In a world where traffickers move fast, Polaris is working to move faster. With the FIU, we’re changing the rules of the game — and delivering justice in a form that truly serves survivors.

Want to help stop trafficking at its source? Join us.

Polaris partners with financial institutions to disrupt trafficking before it spreads. Whether you’re in finance, tech, or policy — your insight and support can make a difference.

– Invest in our work now to bring traffickers to justice and protect survivors.
– If you’re a financial institution interested in exploring partnership with Polaris’s FIU, contact us today.
– Read up on the origins of the FIU — a program developed in direct response to survivors’ call for new ways to seek justice.

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