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Human Trafficking: Ukraine in Crisis

Terri Luttrell, CAMS-Audit
July 1, 2022
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Ukraine War Creates Human Trafficking Crisis

War, forced migration, and lack of governmental oversight lead to human traffickers seizing the opportunity to exercise their illicit activity.

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Human trafficking has long been a global concern and has officially become one of the eight national anti-money laundering and counter-terrorism priorities for the United States. As stated in the Financial Crimes Enforcement Network's (FinCEN) priorities, human trafficking networks use a variety of means to move illicit proceeds, ranging from cash smuggling by individual victims to sophisticated cash operations through professional money laundering networks and criminal organizations.

The U.S. Department of Homeland Security defines human trafficking as modern-day slavery involving the use of force, fraud, or coercion to obtain labor or commercial sex act. The United Nations reports that there are approximately 40.3 million people across the globe who are victims of human trafficking. This horrific crime enslaves men, women, and children of any age, race, or nationality.

At the border of Poland, millions of Ukrainians have fled Ukraine since the Russian invasion. Approximately 90% are women and children due to existing restrictions on males 18- 60. They have been forced to leave their homes, losing access to essential services and, in many cases, their incomes. These conditions attract the worst type of predators and sexual exploitation, forced labor, domestic slavery, and organ removal are serious concerns.  

Financial crime

Human Trafficking: Ukraine in Crisis

In times of humanitarian crisis, such as political instability, armed conflict, and natural disasters, the risk of human trafficking escalates as vulnerabilities increase exponentially. The Russian invasion of Ukraine is no different, creating the perfect storm for traffickers to take advantage of vulnerable people fleeing Ukraine to reach safety from the devastating effects of war.

These common factors increase the vulnerability of potential victims:

  • Lack of social safety nets
  • Poverty/economic hardship
  • Demand for cheap labor
  • Political instability/armed conflict
  • Natural disasters  
  • Criminal activity
  • Immigration status

It's easy to understand how the invasion of Ukraine has caused the current dangerous conditions. Millions of people are desperate to keep themselves and their loved ones safe from war and need necessities for survival, food and shelter. Refugees can easily fall victim to someone lending a helping hand, their exhaustion contributing to their eagerness to trust those who might help. After all, don't we all want to believe the best in others, especially in such a dire situation? Most of us cannot fathom what Ukrainian families are experiencing.

With the increased risk of trafficking among Ukrainian refugees, The United Nations Office on Drugs on Crime (UNODOC) is supporting countries affected by the crisis to identify potential victims and develop strategies to prevent this crime. Evidence from conflicts shows that criminals profit from the chaos and desperation of war. Crisis increases vulnerabilities and opportunities to exploit people in need, especially internally displaced people and refugees," says UNODC Executive Director Ghada Waly.

Learn more about FinCEN priorities on Human Trafficking.

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Getting Involved

Organizations Fighting Human Traffickers

The trafficking of Ukrainian victims is already a well-established, illegal industry with criminal networks operating between Ukraine and countries in Europe and Central Asia. Traffickers groom victims by providing them with a sense of "safety" and "belonging" by meeting their physiological needs, which are exponentially increased due to the conflict. UNODOC works with several non-governmental organizations (NGOs) to coordinate responses to the current risks. These efforts have stopped several attempts at abductions in border states.

How can we, as citizens of a nation halfway around the world, help reduce the risk of human trafficking among the millions of Ukrainian refugees? If you have the desire and the means to help, you can partner with the many reputable nonprofits working on getting humanitarian aid to Ukraine and its refugees. However, unscrupulous groups are rising as they do with any humanitarian crisis; NGOs that want to defraud the contributors and never allow the funds to go for the intended purposes.

You can vet a nonprofit before volunteering time or money to their cause in several ways. The Federal Trade Commission (FTC) strongly recommends checking with organizations such as the Better Business Bureau (BBB), Wise Giving Alliance, Charity Navigator, CharityWatch, or GuideStar. These organizations will help you better understand how much of the charity's donations go towards expenses and overhead.​ Texas Advocacy Project, a nonprofit that works with survivors of human trafficking, domestic violence, stalking, and sexual assault, suggests several vetting steps to help ensure that the NGO of your choice is a reputable one:

  • Identify the organization's mission
  • Review Internal Revenue form 990, which is used to share information with the public about their programs
  • Read the annual report and audit
  • Evaluate the results of vetting
  • Speak to a representative or volunteer for the organization

Unfortunately, it seems the Ukraine crisis will not end soon, and NGOs around the globe must assist in safeguarding this newly vulnerable population of millions. As citizens striving for a humane world, we can do a small part in battling this issue by partnering with vetted NGOs. Here at home, financial institutions have a unique position to see front-line activity and the flow of illicit funds and can detect and report human trafficking within our communities.

In addition to the issuance of the national priorities, FinCEN has issued advisories for financial institutions around red flags of human trafficking. The combined advisories are an excellent tool for financial institutions to use for training front-line staff and FinCrime professionals. FinCrime professionals can download an easy-to-use, free red flag checklist from Abrigo here. Enhancing your training and diligent suspicious activity investigations could save a life.

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About the Author

Terri Luttrell, CAMS-Audit

Compliance and Engagement Director
Terri Luttrell is a seasoned AML professional and former director and AML/OFAC officer with over 20 years in the banking industry, working both in medium and large community and commercial banks ranging from $2 billion to $330 billion in asset size.

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About Abrigo

Abrigo enables U.S. financial institutions to support their communities through technology that fights financial crime, grows loans and deposits, and optimizes risk. Abrigo's platform centralizes the institution's data, creates a digital user experience, ensures compliance, and delivers efficiency for scale and profitable growth.

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