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Launch of the Polaris Financial Intelligence Unit

Human trafficking is a diverse crime, often perpetrated through complex psychological manipulations, the exploitation of economic desperation, or of emotional need. But behind all the complexity, the major motivation of traffickers is in fact quite simple: Greed. Human trafficking is a business. It exists because someone is making money off of it. Make trafficking more risky, and less lucrative, and you shut the business down – and keep new ones from popping up. 

That’s the fundamental premise behind the launch of Polaris’s Financial Intelligence Unit, a partnership with PayPal. The Financial Intelligence Unit will equip the one industry all traffickers try to misuse – financial services – with the tools to better understand how traffickers use banks, credit cards, payment processors and the like. This knowledge, shared throughout the industry, will help anti-money laundering professionals better spot likely trafficking activity, and generate more actionable leads for law enforcement. 

There are a number of victim-centered reasons why taking a financial crime approach to trafficking investigations is vital. One of the most significant difficulties in prosecuting trafficking cases has traditionally been their dependence on survivor testimony – an experience that can be terrifying and retraumatizing for many. Financial crime prosecutions do not require the same level of victim participation, relieving the intense pressure placed on survivor witnesses, and in some cases, eliminating it entirely. 

Financial investigations also differentiate in nuanced ways between traffickers and their victims, helping to ensure that the right people are prosecuted.  Even when money laundering or other financial crimes charges are not pursued, financial evidence helps identify assets for forfeiture and restitution to support the individuals harmed.

The anti-money laundering community has sophisticated systems and methods to monitor for various kinds of criminal activity in financial records – and is legally obligated to do so. But just because it is possible to detect trafficking through these transactions, doesn’t mean it is easy. The use of overly broad “red flags” can yield too many false positives, overwhelming investigators and negatively impacting vulnerable communities.  A nuanced understanding of the crime and how the associated financial patterns manifest is needed to ensure that anti-money laundering efforts are both effective and responsible. 

One of the keys is research. This is done in collaboration with the financial services industry and with key stakeholders – including survivor experts. We use data from the U.S. National Human Trafficking Hotline and other sources to study how traffickers operate on a number of fronts – from how new technologies are being misused by traffickers and professional money launderers to how sex and labor traffickers use their victims’ credit and bank accounts to hide their own profits and activities. 

Part of that collaborative effort will be documented and spread through STAT – the acronym for Stand Together Against Trafficking. This online platform will allow the anti-money laundering community to learn from one another, spot trends and understand how trafficking works – and changes – over time. 

This innovative work serves as a model for the ways corporate partners can step up to help fight trafficking in meaningful ways that go far beyond writing checks. PayPal is a true program partner in this effort, as are countless banks and other financial services institutions. 

The potential for impact is enormous. Financial services are used in virtually every trafficking operation. Working with the financial services industry to make trafficking a high-risk, low-profit business venture is the very definition of scalable, long-term change. 

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