ACAMS Today interviewed Dr. Kari Johnstone, special representative for the Organization for Security and Co-operation in Europe (OSCE) and coordinator for Combating Trafficking in Human Beings, and Tarana Baghirova, programme officer at the OSCE, the world's largest regional security organization with 57 participating states throughout the world. Dr. Johnstone and Baghirova shared their work and how they are bringing human trafficking (HT) awareness to the anti-financial crime (AFC) community and the world at large.

Dr. Johnstone represents the OSCE at the political level on trafficking issues, coordinating the organization’s efforts to combat HT in the OSCE region. Based in Vienna, Austria, Johnstone leads efforts to support OSCE participating states in strengthening their anti-trafficking strategies, operational frameworks and actions. Prior to joining the OSCE in October 2023, Johnstone served in several positions at the U.S. Department of State, including the roles of principal deputy director and acting director of the Office to Monitor and Combat Trafficking in Persons (TIP Office), and office director of the Office of International Religious Freedom. During her nine years at the TIP Office, she gained wide-ranging experience advising senior officials on policy and programming approaches to fight HT globally and protect victims, and she oversaw the production of the State Department’s annual “Trafficking in Persons Report.”

Baghirova, who is also based in Vienna, leads the OSCE’s portfolio on financial investigations into HT, where she supports public and private sector efforts to establish partnerships and develop guidance dedicated to HT. Baghirova also leads policy work on trafficking for the purpose of criminal exploitation with a key focus on its nexus with drugs and terrorism. Before Baghirova was named programme officer in 2023, she evaluated over 20 OSCE states’ anti-trafficking efforts for nearly five years as the associate country visit officer for the OSCE Office of the Special Representative and Coordinator for Combating Trafficking in Human Beings, after serving in several other roles at OSCE including associate officer on Countering Trafficking in Human Beings; national project officer, Politico-Military Activities; and National Anti-Trafficking officer.

ACAMS Today (AT): As your organization is based in Europe, could you discuss the differences in perspective of how HT is perceived in Europe versus how it is perceived in the U.S. or other regions of the world outside of Europe?

Kari Johnstone (KJ): The OSCE spans the U.S. and Canada, across all of Europe, the Caucasus, Central Asia and Mongolia—from Vancouver to Vladivostok. There are more commonalities in trafficking trends, perceptions and frameworks to combat it than there are regional differences. The primary international legal definition and anti-trafficking approach are outlined in a global United Nations (UN) protocol. All OSCE members (participating states) are party to this protocol, and OSCE commitments and activities are aligned with this global framework. Perceptions—and misconceptions—can vary in Europe and the U.S.; but many span across the ocean, such as stereotypes that poor migrants and young girls are most often targeted and lured through kidnapping or physical violence and taken across international borders. In fact, victims can come from a wide variety of backgrounds and victim demographics are evolving—men and boys are increasingly exploited, and no movement is required. With online exploitation growing, victims may be trafficked without leaving their house, much less crossing international borders. Most authorities in the U.S. realize trafficking can take many forms—for sexual or labor exploitation and increasingly for forced criminality. In some countries in Europe, there is still a greater focus on either sex trafficking or labor exploitation, while we always advocate for a comprehensive approach to combat all forms of trafficking.

AT: What specific efforts has the OSCE undertaken to combat HT throughout the world?

Tarana Baghirova (TB) and KJ: As a regional organization, our primary mandate is to assist OSCE participating states fulfill their commitment to protect victims, prevent trafficking and ensure criminal justice for traffickers. We do this through conducting research to help practitioners in the region and around the world understand persistent and evolving trafficking trends, as well as developing policy guidance to implement their commitments, and practical tools and capacity-building to help them do so in practice. In many ways, the OSCE has been working hard to help global anti-trafficking stakeholders stay abreast of the latest developments in HT. As a global thought leader, the OSCE also works to develop policy guidance and tools to keep up with current challenges and opportunities across the globe. For example, we have led many efforts to understand ways that traffickers abuse technology—including artificial intelligence—to find and exploit their victims, as well as to amplify positive tech tools to combat trafficking and identify and protect victims. We are the first multilateral organization to implement procedures to prevent HT in the supply chains of the goods and services we procure, and we are helping UN agencies to do the same through our role as the secretariat for the UN procurement task force. We are also the first multilateral organization with an advisory council of survivor leaders—a formal mechanism to inform OSCE anti-trafficking policies and programs with their lived experience expertise. Finally, we are one of the few international organizations that mobilize financial services action to prevent and tackle HT through engaging in partnerships and advocacy. This year we will present our new guidance that shall provide information on the use of virtual currencies in trafficking cases and further red flag indicators of trafficking in children and forced criminality.

AT: What documentation is your organization focusing on as it strives to eliminate and dismantle HT networks?

KJ: The OSCE views trafficking as a cross-dimensional problem, intersecting with all three dimensions of OSCE activity—at the politico-military, economic-environmental and human level. As special representative, my office has a substantial mandate to support the states in preventing trafficking, protecting victims and ensuring perpetrators are detected and brought to criminal justice. In the area of prevention, we focus on how to positively use technology to identify and prevent trafficking; support the development of practices to prevent HT in supply chains and reduce demand for the sexual services that fuel sex trafficking; and empower and equip labor inspectors to identify and prevent labor trafficking, which is on the rise across the OSCE.

In the area of protection, our focus is on supporting the development and effectiveness of identification mechanisms that include proactive, broad efforts to find victims—what we call a “social path.” This approach equips all governmental and nongovernmental actors that might encounter victims with the know-how and mandate to identify victims and refer them to comprehensive care, regardless of their cooperation with the authorities. In this area of work, we raise understanding of intersectional vulnerabilities that traffickers target—both inherent and created—that link to the age, gender, social and health conditions, migratory status and ethnicities to inform tailored prevention and protection efforts. In addition to addressing technology-facilitated trafficking where we promote the positive use of tech tools to tackle HT, we have developed policy guidance on the gender dimension of trafficking, social path to identification, and minorities and disabilities that are often targeted by traffickers for various exploitative purposes. Our work to support public and private sector partnership-based investigations into the financial flows of trafficking is well-established and continues to produce tangible results.

AT: Are there any recent trends that the OSCE has seen developing in the HT space? Are criminals changing their methods to adapt to advancements law enforcement (LE) is employing to identify and arrest HT criminals?

KJ: One of the emerging trafficking trends has been the trafficking of children and adults into criminal exploitation—in other words, forced criminality. OSCE’s 2022 survey showed a tenfold increase in this form of trafficking and a year later, the United Nations Office on Drugs and Crime’s global report revealed similar findings. This is the fastest-growing form of HT, both globally and in OSCE countries. Traffickers often target children and young adults for petty crimes, such as pickpocketing and theft, and force them to beg. However, new trafficking patterns have shown a shift in the type of crimes traffickers force their victims to commit. These are no longer just petty crimes, but more serious offenses such as fraud, forced scamming, the production and distribution of drugs, and violent crimes. Particularly concerning is an increase in the grooming of children as young as 11 to 12 years of age for these criminal activities, which often results in the incarceration and punishment of these children and contributes to a continuum of exploitation and abuse.

Other rapidly increasing forms of trafficking include forced scamming and fraud, in which individuals are targeted and exploited in so-called scam centers. While the vast majority of such centers are in Southeast Asia, several of them have also been found in Europe, while an increasing number of individuals from countries in the OSCE region have been trafficked into scam centers.

AT: What are some of the red flags financial institutions (FIs) should look for to identify HT activity at their institution?

TB: The OSCE compiled a comprehensive list of red flag indicators back in 2019,¹ which have been used by various financial services and informed the strategic analysis of financial intelligence units (FIUs) and regulators. Although already a few years old, this document continues to be a reference guide for the private sector in anti-trafficking initiatives. When it comes to red flag indicators, they should be contextually relevant to the HT profile of the country and should be based on a comprehensive analysis of risks and threats of HT, whether they are jurisdictional risks, sectoral risks or risks related to a specific financial product. The 2019 compendium of resources that we developed together with Scotiabank, and namely Joseph Mari, divided red flag indicators into know your customer (KYC), transactional and behavioral indicators, which guide various layers and sections of financial services. This was the foundation of our further engagement in this area—during our first pilot project with Cyprus’ FIU—where we supported the country’s first strategic analysis of financial flows derived from trafficking. A year later, we saw a 64% increase in the reporting of HT by financial services to the FIU. In our recent project with the Swiss FIU, Financial Intelligence Against Human Trafficking, we worked closely with Swiss partners to develop a guide for Swiss-based FIs. In this guide, we introduced the concept of “yellow flag” indicators, which was first initiated by Scotiabank. This concept is important as often FIs are challenged to apply red flag indicators in the financial system that often can be generic. Hence, yellow flag indicators provide an additional layer of suspicion to support financial services while doing this work. For example, one of the yellow flag indicators in the guide is “Missing expenses for living costs (e.g., food, petrol, utilities and rent), especially if the KYC shows that this is the customer’s main account.” This indicator alone will not be sufficient to indicate trafficking; however, the customer should be subject to more enhanced monitoring to gather a full picture of the customer’s activity, any adverse media linked to the customer’s name, or any address or addresses that are often used by the customer.

Red flag indicators, such as that incoming deposits “indicate that this person provides sexual services to an extremely high number of people on a daily basis (no breaks, days off) or receives money for services provided by others (indicates management of other people’s money),” already suggest a valid suspicion that the case we are dealing with is a sex trafficking scenario.

AT: How important are partnerships between organizations across the globe in successfully fighting human traffickers and protecting HT survivors and potential victims?

TB: HT is a multifaceted crime and intersects with a range of other crimes; it cannot be tackled in isolation—it requires a collaborative approach. It demands partnerships between and among FIUs, FIs, financial regulators, LE, social services, nongovernmental organizations, survivors and international organizations working together. The social path approach we advocate also should include the public health and education sectors, as well as labor inspectors and first responders. Working closely with and leveraging different disciplines, sectors and distinct mandates are essential to build a comprehensive understanding of trafficking networks and risks across jurisdictions and sectors. This inevitably enhances the ability to find and protect victims and dismantle this crime. Such partnerships between the public and private sectors have been increasing; however, with HT such partnerships are often short-lived or developed on an ad hoc basis. This is where we support states to develop long-term partnership mechanisms specifically dedicated to sharing information and exchanging data on HT. Needless to say, such partnerships are vital internationally, too. I was pleased to see the Financial Crimes Enforcement Network joining the Financial Transactions and Reports Analysis Centre of Canada’s landmark “Project Protect” that achieved fascinating results based on genuine collaboration and the proactive work of both the FIs and the intelligence unit.

Our aim is to reverberate such initiatives across the OSCE and beyond. In 2025, we will engage with several of our participating states directly to support the partnership goals and trafficking analysis.

AT: What specifically can AFC professionals do to best assist in the fight against HT?

TB: Awareness is a starting point of action for AFC professionals. This means AFC professionals should understand and approach trafficking as they do other predicate offenses that generate a massive amount of illicit funds. It is an evolving crime with traffickers employing new techniques and developing new methods regarding how and where they can exploit vulnerable adults and children. HT should be included in the risk assessment of FIs to help practitioners map their actions around the risks that are associated with this specific type of crime. These assessments should not be static documents but rather informed by ongoing analysis of persistent and emerging patterns of trafficking threats. Second, proactivity and a commitment to tackle the crime is critical because the object of HT is the exploitation of human beings. Robust KYC programs are important to ensure AFC practitioners can differentiate between trafficking perpetrators and trafficking victims. Civil society organizations, particularly those led by trafficking survivors, are great partners to engage with to both train AFC practitioners and inform due diligence processes. They are the holders of firsthand information on how illicit funds are generated from trafficking. Through such efforts, AFC professionals can help keep people around the world safe from HT and contribute to criminal accountability for traffickers committing heinous crimes and causing tremendous harm and trauma. Their role is important and has an enormous impact on human lives. This action is also fundamental to the mandate of AFC practitioners: Along with acting for social good, they fight a crime whose mere purpose is to make money.

Interviewed by Karla Monterrosa-Yancey, CAMS, ACAMS, editor-in-chief, editor@acams.org

Ben Bahner, CAMS, ACAMS, editor, bbahner@acams.org

1. “Following the Money: Compendium of Resources and Step-by-Step Guide to Financial Investigations Related to Trafficking in Human Beings,” Organization for Security and Co-operation in Europe, October 2019, https://www.osce.org/files/f/
   documents/f/5/438323_0.pdf