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Treliant Takeaway:

Human trafficking involves the use of force, fraud, or coercion to obtain some type of labor or commercial sex act. The UN TIP Protocol mandates the criminalization of money laundering when proceeds are derived from human trafficking. Financial institutions should continue to be vigilant in implementing and enhancing detection methods such as appropriate customer due diligence and “red flag” indicators that identify potential human trafficking activity.

Treliant’s team of compliance professionals has deep experience in the design, implementation, and independent assessment of AML programs of financial institutions that seek to detect and prevent introduction of the proceeds of human trafficking into the U.S. financial system through risk-based customer due diligence and automated transaction monitoring tools and models and assist law enforcement in identification and prosecution of bad actors.

Report Highlights:  

On February 2, 2022, U.S. Attorney General Merrick B. Garland released the Justice Department’s new National Strategy to Combat Human Trafficking pursuant to the Justice for Victims of Trafficking Act. The strategy aims to enhance the Department’s capacity to prevent human trafficking; to prosecute human trafficking cases; and to support and protect human trafficking victims and survivors.  The multi-year strategy will: strengthen engagement, coordination and joint efforts to combat human trafficking by prosecutors in all 94 U.S. Attorneys’ Offices and by federal law enforcement agents nationwide; establish federally-funded, locally-led anti-human trafficking task forces that support sustained state law enforcement leadership and comprehensive victim assistance; step up departmental efforts to end forced labor by increasing attention, resources and coordination in labor trafficking investigations and prosecutions; enhance initiatives to reduce vulnerability of American Indians and Alaska Natives to violent crime, including human trafficking, and to locate missing children; develop and implement new victim screening protocols to identify potential human trafficking victims during law enforcement operations and encourage victims to share important information; increase capacity to provide victim-centered assistance to trafficking survivors, including by supporting efforts to deliver financial restoration to victims; and expand dissemination of federal human trafficking training, guidance and expertise; and advance innovative demand-reduction strategies.


Efren Marquez Alba

Efren Marquez Alba is an Engagement Director with Treliant. His financial crime experience includes Anti-Money Laundering/Counter-Terrorist Financing (AML/CFT), sanctions, anti-bribery and -corruption, and fraud. With Treliant, Efren has led independent assessments of compliance programs for adherence to the Bank Secrecy Act and Anti-Money Laundering rules (BSA/AML) and to the Office…