1. Preventing human trafficking: Global issue, calling Canada
Understanding, identifying and ending trade in human lives
2. PROJECTPROTECT
In an effort to support our collective on-going education and
awareness, our team at Grant Thornton has worked to
further understand and identify relevant indicators of Human
Trafficking activity. This document provides information
organized by both industry and by participant role.
This document is meant to be a contribution, we know there
is more to learn and much to do. Please review, share and
contribute; please act and support Project Protect.
Have you seen and read:
FINTRAC's operational alert:
http://www.fintrac.gc.ca/publications/operation/oai-hts-eng.asp
Grant Thornton's backgrounder:
http://www.grantthornton.ca/resources/insights/reports/Human_
Trafficking_10-11-16_WEB.pdf
Human Trafficking: How to recognize and report suspicious activity 2
3. Red flag indicators
by industry
3
Hospitality & Accommodation
Property Management
Automotive
Financial Services
Transportation & Travel
4. Hospitality&
Accommodation
4
Indicators to assist with the detection of Human Trafficking activity:
• Individuals who are making multiple hotel/ motel bookings in
unreasonable patterns such as 2 /3 times a day, 4/5 times per week,
or 15/20 times a month
• Individuals with minimal or no personal items when checking in
• Clients who have excessive visitors during their stay
• Clients who appear to be in a very young age group accompanied by
other individuals
• Individuals who pay in cash or pre paid credit cards and repeatedly
request same suite or floor
• Individuals who have no control over possession of money or
identification
• Patrons that are apprehensive about providing their full names,
home address or vehicle information when registering
• Refusal of cleaning services for multiple days
• Several individuals loitering in hallways or in the vicinity of the
rooms
• Individuals who enter/exit through the side or rear entrances
• Rooms are stocked with excessive amounts of computers, cell
phones, pagers and point of sale machines
• Clients who exhibit signs of fear, anxiety, tension, submission,
and/or nervousness
Hotel/motel staff, housekeeping,
maintenance and room service staff
often are in a position to see
potential signs of Human Trafficking
as they have direct or indirect
interaction with both Traffickers and
Victims/Survivors.
5. Property
Management
5
Property Management / Rental Properties
While the list below is not exhaustive, these are several
indicators to watch out for:
• Multiple units rented by same individuals or numbered companies
• High traffic at all times of the day
• Large cash payments for rental fees, either upfront or on monthly
basis
• Young individuals renting multiple units or rental units that appear to
be beyond their expected source of funds, just does not make sense
For some time now, the hospitality
industry has increased its
awareness in educating staff and
owners on what to watch for if they
observe signs that someone is being
trafficked. Discussions with law
enforcement have identified that
Traffickers are changing tactics and
shifting to using rental properties to
conduct the criminal activity.
6. Automotive
6
Automotive / Car Dealerships
Through discussions with law enforcement, it was learned that Traffickers
will have Victims/Survivors lease vehicles on their behalf to obscure their
identity and association with the vehicle or have a credit check
performed.
The following are indicators to assist with the detection Human Trafficking
activity:
• Individuals who appear to be young applying for leases on
high end luxury vehicles
• Large cash payments for luxury vehicles
• Applicants who have no income or proper credit history
applying for a lease with considerable upfront funds (cash)
• Trade in of vehicles for higher end-models
• Individuals who throughout the lease application process
appear to be unable to answer questions regarding personal
finances, identification, income and personal details (i.e.
address)
• Individuals accompanied by other individuals who do not
appear to be related or co-signers, who respond to all
questions being asked
7. 7
FinancialServices
The following are indicators to assist with the detection of Human Trafficking activity:
• Transactional review of client accounts looking for the booking of hotels, motels, and rental
condos (e.g. Airbnb) to identify if client is making bookings in the same geographic location
or area of residence stated in their client profile/account
• Repeated transactions which appear excessive for the period (daily / weekly / monthly)
• Multiple purchases for VISA and MasterCard pre-paid cards
• Review of client profile with multiple rental properties (whose stated net worth does not
seem appropriate for multiple rentals) with high volume of cash payments, or payments to
real estate agents
• Transactions of property management companies who are regularly depositing cash
• Account reviews reveal multiple payments to virtual advertising companies or sites such as:
Backpage EMP Media Vibe Media
Darkside Productions Madom Fox seekingarrangement .com
whatyourprice.com
Many Financial Institutions have been focusing efforts to combat Human Trafficking by
making use of rigorous transaction monitoring and partnerships with IT and software
companies to create reliable alerts and rules to detect potentially criminal activity.
8. 8
When reviewing the profiles of clients in the age group of (approx.) 17-23, and
analyzing the flow of funds and transactions, focus on:
• How many accounts does the client have?
• More than one or two accounts? Does this make sense considering the
client's age?
• Is there a high velocity of transactions, money moving in and out of the
account?
• Are there multiple ATM cash deposits? At different times a day?
Occurring at odd times throughout the day and at night?
• Is there depletion/disbursement of funds? Usually done via email money
transfer.
• Does a client in a younger age group have an account showing multiple
payments or transactions for leasing and purchasing high end vehicles?
Sometimes used to obscure the true user and owner of the vehicle.
• Client accounts show high multiples of transactions with food delivery
companies such: Ubereats, Doordash, Justeats and others.
FinancialServices
9. TransportationandTravel
9
• Individuals that lack control or possession of
identification and travel documents
• Traveler appears to be coached on what to say to law enforcement
and immigration officials
• Individuals that are unable to answer seemingly basic questions about
travel plans (i.e. itinerary, individuals they are visiting, address where
they are staying during their trip)
• Individuals unable to provide details of their departure location,
destination, or flight information
• Traveler who can't move freely in an airport or on a plane, or they are
being closely watched or followed
• Individuals wearing clothing and/or overall appearance that does not
align with route of travel, weather
The number of individuals trafficked across international
borders each year keeps growing as global criminal
infrastructures engaged in human trafficking continue to
benefit from the illicit activity.
Airports, train and bus stations are hubs for human
trafficking where some of the following indicators can be
observed:
10. 10
Discussions with law enforcement officers have identified
the following indicators particular to the behaviors of
Traffickers:
• Traffickers generally answer questions for victims/survivors
and/or provide evasive answers
• They observe the victim/survivor persistently
• When forced to interact with others, the trafficker will often
pose as a relative
• Individuals usually buy food with cash & pre-paid cards. The
pre paid cards are used as payment for hotel rooms at hotels
as cash is typically not accepted
• Traffickers advertise the victims/survivors through online
advertising sites
• Traffickers will use a currency exchange provider, or various
different ones, to take cash and convert it into digital currency.
If the currency exchanger provider accepts cash or email
money transfers, the individual sets up a digital wallet to
receive the digital currency.
Participant Role
in the Criminal
Activity:
Trafficker
11. 11
Discussions with law enforcement officers have identified
the following indicators particular to the behaviors of
Victims/Survivors:
• While the age groups of victims fluctuate, these are potential indicators:
o 14 – 17 age – funds are deposited and then quickly or repeatedly
dispersed/depleted to other individuals; not used as
savings/accumulation accounts.
o 18 – 23 age –account activity is atypical; money comes in and goes
out right away, no evidence that the account is being used for
expected living, day to day expenses
• Individual makes multiple cash deposits via ATM into their own account
or the accounts of others
• Money moves (often repeatedly) from the individual's account to
another party (e.g. the Trafficker), often via email money transfer, or
money is pulled out from the account directly by the Trafficker
Participant Role
in the Criminal
Activity:
Victim/Survivor
12. 12
Discussions with law enforcement officers have identified the
following indicators particular to the behaviors of
Buyers:
Potential indicators or pattern of activity for the buyers of human trafficked activity:
• Hotel/Motel bookings in repetitive patterns, same day of the week or same
hotel, and occurs within the same city/geographic location of where they reside
• Cash withdrawals (payments) and email money transfer to individuals where no
apparent relationship seems to exist
• Transactions on internet sites where Traffickers advertise; e.g.:
Whatyourprice.com
Madom Fox
Backpage.com
Participant Role
in the Criminal
Activity:
Buyer
13. HowtoHelp
13
We can all make a difference and speak out when unusual behavior and
risk factors of human trafficking are observed in our daily lives. The Royal
Canadian Mounted Police recommends that any instances where suspicion
of human trafficking, individuals should do one of the following:
4
• If you or someone you know is being exploited, contact your local
police.
• If you or someone you know needs help, speak to a trusted adult
(family member, teacher or school counselor), or contact a counselor
anonymously at the Kids Help Phone at 1-800-668-6868 or online at
www.kidshelpphone.ca
• If you wish to report a crime anonymously,
call Crime Stoppers at 1-800-222-TIPS (8477)
4http://www.rcmp-grc.gc.ca/ht-tp/q-a-trafficking-traite-eng.htm#q13
Note: A single indicator is not necessarily indicative of
human trafficking. Indicators and other facts surrounding a
financial transaction or activity should be considered as a
whole.
