Trafficking in human beings (THB) often emerges as a corollary of war. It is well-established that human traffickers perceive opportunity in the midst of turmoil, and actively seek to capitalise on the vulnerabilities of those fleeing conflict zones.[i] The Russian invasion of Ukraine earlier this year has proven no exception: the rapid displacement of millions of people since 24 February 2022 has provided fertile ground for nefarious actors seeking to exploit refugees, the vast majority of whom are women and children.[ii] Although it is too early to quantify the scale of THB arising from the war, there are clear indicators of increased demand. There have been major spikes in online searches – across multiple languages and jurisdictions – for explicit content and sexual services in relation to Ukrainian women and girls. Data from Thomson Reuters indicates that, just two months following Russia’s invasion, global search traffic for “Ukrainian porn” had increased by 600 per cent, while searches for “Ukrainian escorts” had tripled. That surge in demand is anticipated to incentivise traffickers in recruiting and exploiting Ukrainian women and girls at scale.[iii]
“LARGE-SCALE AND COMPLEX MOVEMENTS OF REFUGEES, AND THE RESULTING DISRUPTION OF FAMILY NETWORKS AND FINANCIAL SECURITY, CORRELATE WITH HEIGHTENED RISKS OF EXPLOITATION.”
The international community, including agencies such as the UNHCR[iv], UNICEF[v], International Labour Organization[vi] and International Organization for Migration,[vii] have consistently warned that large-scale and complex movements of refugees, and the resulting disruption of family networks and financial security, correlate with heightened risks of exploitation. Approximately half of those fleeing Ukraine are women, while 40 per cent are children. It is estimated that thousands of children are travelling unaccompanied by their parents or guardians.[viii] Europol issued an Early Warning Notification in March alerting Member States that women and children arriving from Ukraine, including unaccompanied minors, are most at risk of sexual and labour exploitation, as well as forced criminality and begging.[ix] Evidence has already been documented of an increase in THB activity.[x] As the war persists, the risks continue to escalate, and were recently described by one UN expert as “a crisis within a crisis”.[xi]
Gatekeepers’ role fundamental in identifying risk indicators of THB
The need for a comprehensive anti-trafficking response is high on the agenda in Europe and beyond. In May, the European Commission issued a new Anti-Trafficking Plan designed to address the risks of THB and support potential victims. Emphasised within the Plan is the need to raise awareness amongst the private sector, particularly in high-risk industries such as agriculture, construction, hospitality, cleaning, care and domestic work.[xii]
“THB IS INVARIABLY PROFIT-ORIENTED, AND TRAFFICKING NETWORKS WILL SEEK TO LAUNDER ILLICIT PROCEEDS THROUGH BOTH UNDERGROUND AND LEGITIMATE CHANNELS.”
While not explicitly stated in the Plan, the need for vigilance necessarily extends to the financial sector. THB is invariably profit-oriented, and trafficking networks will seek to launder illicit proceeds through both underground and legitimate channels. From that perspective, the critical inquiry thus becomes: What risk indicators are relevant to financial institutions in detecting THB activity arising from the situation in Ukraine?
Emerging concerns
There is insufficient evidence, at present, to conclusively establish THB risk indicators specific to Ukrainian refugee flows, and any attempt to do so at this stage would be premature. Publicly available information relating to instances of exploitation has largely been disseminated via media reporting, rather than by law enforcement; however, several issues of concern can be gleaned from such reports.
Geographical aspects
Refugees coming from Ukraine are exposed to trafficking risks for the duration of their journey – risks which may not abate even after arrival at their ultimate destination. Suspected human traffickers have been detected at reception centres and border crossings in Poland, Hungary and Moldova.[xiii] Though Poland continues to be the main country of arrival, UNHCR estimates that some 2.9 million refugees have moved beyond Ukraine’s immediate neighbours,[xiv] and there has been anecdotal evidence of recruitment attempts at major travel hubs such as Munich and Berlin Central train stations.[xv] Once arrived in recipient countries, refugees face an acute need to generate income, which thereby increases their susceptibility to trafficking.[xvi] For example, in April, Swedish police arrested 38 men as part of an anti-prostitution operation, where the majority of women exploited were Ukrainian refugees.[xvii] Similarly, Norway’s serious crime agency assessed in April that it is “very probable” that refugees from Ukraine could be exposed to sexual abuse in Norway.[xviii] In the UK, concerns have arisen with respect to the “Homes for Ukraine” sponsorship scheme.[xix] Indeed, NGOs expect all EU countries to be touched by THB arising from the war.[xx]
Vulnerabilities in virtual spaces
The business model for THB – particularly for recruitment and advertisement of victims for sexual exploitation – has largely shifted online. Sites oriented to sexual services; employment/classified websites; and accommodation/transport ‘matching’ websites (among others) have been identified as particularly relevant.[xxi] Moreover, many Ukrainians are utilising social media platforms to find accommodation and/or transport, and are thereby exposed to traffickers who may seek to contact them under the false pretence of offering assistance.[xxii] Telegram, Whatsapp and Instagram offer quick and convenient communication but are closely attended by a sense of urgency, as refugees feel they must act quickly in accepting offers for transport and housing via these channels.[xxiii]
“THERE IS INSUFFICIENT EVIDENCE, AT PRESENT, TO CONCLUSIVELY ESTABLISH THB RISK INDICATORS SPECIFIC TO UKRAINIAN REFUGEE FLOWS, AND ANY ATTEMPT TO DO SO AT THIS STAGE WOULD BE PREMATURE.”
Exposed industries
Reporting remains nascent; however, several stories of labour exploitation have emerged, demonstrating the need for increased vigilance in vulnerable sectors. In France, for example, Ukrainian women have been found illegally employed in childcare and cleaning sectors, working under abusive conditions.[xxiv] In the UK, concerns have been raised regarding the Seasonal Worker Visa and corollary Ukraine Extension schemes. The Seasonal Worker Visa places workers on farms and other such workplaces, often in isolated rural locations. The Ukraine-specific Extension Scheme introduced in May allows existing visa-holders to remain in the UK for up to three years. Ukrainians’ exposure to potential trafficking and labour exploitation under the visa scheme has repeatedly been identified even prior to the war – and experts say those risks are now exacerbated.[xxv]
Commentators have also referred to potential exploitation of Ukrainian refugees via fraudulent employment agencies, and forced participation in drug trafficking and other forms of crime. In Italy, for example, Ukrainian refugees have allegedly been exploited in a counterfeit cigarette factory, reportedly shut down by police in April.[xxvi]
Established THB Indicators
While the situation in Ukraine continues to evolve, risk indicators for THB-associated transactions remain relevant in the current context and merit heightened scrutiny. Even prior to the war, the trafficking of Ukrainians was “a well-established, illegal industry”.[xxvii] In 2020, Ukrainians were among the top five nationalities represented amongst trafficking victims identified in the EU.[xxviii] Data collected by the United Nations Office on Drugs and Crime reveals that, from 2017 to 2020, Ukrainian victims were identified as having been trafficked to 29 countries, with criminal networks operating between Ukraine and countries in Europe and Central Asia. Key destination countries and regions are set out below:[xxix]
Current refugee flows traverse well-known trafficking routes out of Ukraine, exposing people on the move to potential exploitation.
While many previously identified victims were exploited within Ukraine by domestic traffickers with lower levels of organisation, others were trafficked by complex, transnational networks with significant victim counts.[xxx] Established organised crime networks can thus be expected to rely on, and further exploit, existing trafficking pathways, and to rapidly mobilise in response to the enormously high levels of women and children fleeing the war.[xxxi]As experts have emphasised, the trafficking crisis is in its infancy, and will continue to evolve as traffickers become more organised and effective in their operations.[xxxii]
Risk indicators of THB for sexual exploitation include:
- frequent ATM deposits, sometimes followed by ATM withdrawals in a different location;
- regular transactions outside of normal business hours (such as card payments at a beauty parlour late at night);
- multiple accounts making repeated transfers to the same third-party; or
- multiple individuals providing the same personal information (such as address, telephone number, employment reference etc.) without obvious reason.
Risk indicators of THB for labour exploitation include:
- customer connections to vulnerable sectors as highlighted above, as well as the manufacturing and lumber industries (where Ukrainian trafficking victims have previously been identified [xxxiii]);
- payments for accommodation which deviate from the customer’s personal use or stated business activity (indicating housing of workers);
- a private customer being accompanied by a third party at account opening or when conducting transactions (indicative of the customer being an exploited individual); or
- customer association with negative news or adverse media reports relating to allegations such as cheap labour or unfair business practices.
“THIS WORLD REFUGEE DAY, WE WISH TO HIGHLIGHT THE CRITICAL ROLE THAT THE FINANCIAL SECTOR CAN (AND, INDEED, MUST) PLAY IN DETECTING AND DISRUPTING ILLICIT FINANCIAL FLOWS ARISING FROM THE EXPLOITATION OF REFUGEES.”
Conclusion
The war in Ukraine has now led to the displacement of over 8 million people internally, and approximately 6.5 million have fled across international borders.[xxxiv] This World Refugee Day, we wish to highlight the critical role that the financial sector can (and, indeed, must) play in detecting and disrupting illicit financial flows arising from the exploitation of refugees. THB actors are motivated by profit, and there are already signs that traffickers are seeking to capitalise on the mass refugee flows coming from Ukraine. It is thus incumbent on the financial sector to be cognizant of the risks of THB, and to be vigilant in recognising, and responding to, both traditional and emerging risk indicators when they arise.
Mara Wesseling and Stephanie Ygoa – Intelligence and Regulations at Acuminor
Sources:
[i] See, e.g., United Nations Office on Drugs and Crime. (2022, March 24). Targeted by Traffickers – Ukrainian Refugees at High Risk of Exploitation [Press release]. https://www.unodc.org/unodc/frontpage/2022/March/targeted-by-traffickers---ukrainian-refugees-at-high-risk-of-exploitation.html ; and Jensen, Donald. (Moderator). (2021, June 6–present). The Ukraine Conflict and the Crisis of Sexual Violence: A Conversation with The Honourable Pramila Patten, U.N. Special Representative on Sexual Violence in Conflict [Online Event]. United States Institute of Peace. https://www.usip.org/events/ukraine-conflict-and-crisis-sexual-violence
[ii] UN Special Rapporteur on trafficking in persons, especially women and children; UN Special Rapporteur on violence against women, its causes and consequences; UN Under-Secretary-General and Special Representative of the Secretary-General on Sexual Violence in Conflict. (2022, March 16). Ukraine: Armed conflict and displacement heightens risks of all forms of sexual violence including trafficking in persons, say UN experts [Press Release]. United Nations Human Rights Office of the High Commissioner. https://www.ohchr.org/en/press-releases/2022/03/ukraine-armed-conflict-and-displacement-heightens-risks-all-forms-sexual
[iii] Office of the OSCE Special Representative and Coordinator. (2022, April 22). Recommendations on enhancing efforts to identify and mitigate risks of trafficking in human beings online as a result of the humanitarian crisis in Ukraine. Organization for Security and Co-operation in Europe. https://www.osce.org/cthb/516423
[iv] Triggs, G. (2022, April 12). Statement on risks of trafficking and exploitation facing refugees from Ukraine attributed to UNHCR’s Assistant High Commissioner for Protection [Statement]. United Nations High Commissioner for Refugees. https://www.unhcr.org/en-in/news/press/2022/4/6255a6964/statement-risks-trafficking-exploitation-facing-refugees-ukraine-attributed.html
[v] United Nations Children’s Fund (UNICEF). (2022, March 19). Children fleeing war in Ukraine at heightened risk of trafficking and exploitation [Press release]. https://www.unicef.org/press-releases/children-fleeing-war-ukraine-heightened-risk-trafficking-and-exploitation
[vi] International Labour Organization. (2022, April 12). Prevention through information: ILO campaign on Ukrainian railways to prevent labour exploitation among refugees [Press release]. https://www.ilo.org/budapest/whats-new/WCMS_842255/lang--en/index.htm
[vii] International Organization for Migration. (2022, March 16). IOM Warns of Increased Risk of Trafficking in Persons for People Fleeing Ukraine (IOM Statement). https://www.iom.int/news/iom-warns-increased-risk-trafficking-persons-people-fleeing-ukraine https://www.iom.int/news/iom-warns-increased-risk-trafficking-persons-people-fleeing-ukraine .
[viii] United Nations Children’s Fund (UNICEF). (2022, March 19). Children fleeing war in Ukraine at heightened risk of trafficking and exploitation [Press release]. https://www.unicef.org/press-releases/children-fleeing-war-ukraine-heightened-risk-trafficking-and-exploitation ; and UNODC Research. (2022, March). Conflict in Ukraine: Key Evidence on Risks of Trafficking in Persons and Smuggling of Migrants. United Nations Office on Drugs and Crime. https://www.unodc.org/documents/data-and-analysis/tip/Conflict_Ukraine_TIP_2022.pdf
[ix] Europol. (2022, March 30). Early Warning Notification – War in Ukraine: refugees arriving to the EU from Ukraine at risk of exploitation as part of THB [Europol Public Information] https://www.europol.europa.eu/publications-events/publications/early-warning-notification-war-in-ukraine-refugees-arriving-to-eu-ukraine-risk-of-exploitation-part-of-thb
[x] Hoff, S. & de Volder, E. (2022, May 10). Preventing human trafficking of refugees from Ukraine: A rapid assessment of risks and gaps in the anti-trafficking response. La Strada International & The Freedom Fund. https://www.lastradainternational.org/news/new-report-sounds-alarm-on-ukraine-trafficking-risks/
[xi] Jensen, Donald. (Moderator). (2021, June 6–present). The Ukraine Conflict and the Crisis of Sexual Violence: A Conversation with The Honourable Pramila Patten, U.N. Special Representative on Sexual Violence in Conflict [Online Event]. United States Institute of Peace. https://www.usip.org/events/ukraine-conflict-and-crisis-sexual-violence
[xii] Directorate-General for Migration and Home Affairs. (2022, May 11). Common Anti-Trafficking Plan. https://ec.europa.eu/home-affairs/news/new-anti-trafficking-plan-protect-people-fleeing-war-ukraine-2022-05-11_en
[xiii] See, e.g., Human Rights Watch. (2022, April 29). Poland: Trafficking, Exploitation Risks for Refugees: Security Measures, Systems to Address Gender-Based Violence Urgently Needed [News report]. https://www.hrw.org/news/2022/04/29/poland-trafficking-exploitation-risks-refugees ; Jensen, Donald. (Moderator). (2021, June 6–present). The Ukraine Conflict and the Crisis of Sexual Violence: A Conversation with The Honourable Pramila Patten, U.N. Special Representative on Sexual Violence in Conflict [Online Event]. United States Institute of Peace. https://www.usip.org/events/ukraine-conflict-and-crisis-sexual-violence ; https://www.usip.org/events/ukraine-conflict-and-crisis-sexual-violence Hoff, S. & de Volder, E. (2022, May 10). Preventing human trafficking of refugees from Ukraine: A rapid assessment of risks and gaps in the anti-trafficking response. La Strada International & The Freedom Fund. https://www.lastradainternational.org/news/new-report-sounds-alarm-on-ukraine-trafficking-risks/ ; and media reports such as, e.g., Shoaib, A. (2022, March 26). ‘Pimps‘ are stalking Poland‘s railway stations and border crossings targeting vulnerable women and children refugees fleeing Ukraine, charity groups warn. Insider. https://www.businessinsider.com/ukraine-women-and-children-refugees-targeted-by-predatory-traffickers-2022-3?r=US&IR=T ; and Sleigh, S. (2022, March 22). Inside the Human Trafficking Tragedy Unfolding on Ukraine’s Border. HuffPost UK. https://www.huffingtonpost.co.uk/entry/human-trafficking-ukraine-refugees-war_uk_622b15a1e4b0d1329e8332de
[xiv] UNHCR. (2022, June 3). Ukraine Situation: Flash Update #15 [Situation Report]. https://data.unhcr.org/en/documents/details/93271
[xv] See, e.g. Newsweek. (2022 March 10). German Police Warn Ukrainian Refugees of Possible Human Trafficking Traps https://www.newsweek.com/german-police-warn-ukrainian-refugees-possible-human-trafficking-traps
[xvi] UNODC Research. (2022, March). Conflict in Ukraine: Key Evidence on Risks of Trafficking in Persons and Smuggling of Migrants. United Nations Office on Drugs and Crime. https://www.unodc.org/documents/data-and-analysis/tip/Conflict_Ukraine_TIP_2022.pdf
[xvii] SVT Nyheter. (2022, April 11). 30 av 38 män köpte sex av kvinnor från Ukraina. https://www.svt.se/nyheter/inrikes/30-av-38-man-kopte-sex-av-kvinnor-fran-ukraina
[xviii] Asvall, H. (2022, April 22). Kripols: «Meget sannsynlig» at ukrainske flyktninger kan utsettes for overgrep. NRK Nyheter. https://www.nrk.no/norge/ny-kripos-vurdering_-_meget-sannsynlig_-at-ukrainske-flyktninger-kan-utsettes-for-overgrep-1.15939054
[xix] Dr Cockbain, E. & Dr Sidebottom, A. (2022, April 29). The war in Ukraine and associated risks of human trafficking and exploitation: Insights from an evidence-gathering roundtable. Office of the Independent Anti-Slavery Commissioner. https://www.antislaverycommissioner.co.uk/media/1801/ucl-iasc-2022-roundtable-report-the-war-in-ukraine-human-trafficking-and-exploitation.pdf ; and UNHCR. (2022, April 13). UNHCR Statement on the UK’s Homes for Ukraine scheme [Press release]. https://www.unhcr.org/uk/news/press/2022/4/6256b5144/unhcr-statement-on-the-uks-homes-for-ukraine-scheme.html
[xx] Pasquesoone, V. (2022, May 2). Guerre en Ukraine: sur la route de l’exil, les réfugiés sous la menace du trafic d’êtres humains.France Télévisions. https://www.francetvinfo.fr/monde/europe/manifestations-en-ukraine/enquete-franceinfo-guerre-en-ukraine-sur-la-route-de-l-exil-les-refugies-sous-la-menace-du-trafic-d-etres-humains_5094085.html
[xxi] Office of the OSCE Special Representative and Coordinator. (2022, April 22). Recommendations on enhancing efforts to identify and mitigate risks of trafficking in human beings online as a result of the humanitarian crisis in Ukraine. Organization for Security and Co-operation in Europe. https://www.osce.org/cthb/516423
[xxii] Office of the OSCE Special Representative and Coordinator. (2022, April 22). Recommendations on enhancing efforts to identify and mitigate risks of trafficking in human beings online as a result of the humanitarian crisis in Ukraine. Organization for Security and Co-operation in Europe. https://www.osce.org/cthb/516423
[xxiii] RTL Nieuws(2022, March 10). Mensenhandel Oekraïense vluchtelingen ligt op de loer: ‘Zijn heel kwetsbaar’. https://www.rtlnieuws.nl/nieuws/buitenland/artikel/5293994/mensenhandel-oorlog-oekraine-unhcr-oorlogsslachtoffers
[xxiv] Pasquesoone, V. (2022, May 2). “Nous avons dû voler pour manger”: après avoir fui l’Ukraine, Anna et Natalia ont été victimes d’une tentative d’exploitation. France Télévisions. https://www.francetvinfo.fr/monde/europe/manifestations-en-ukraine/temoignages-nous-avons-du-voler-pour-manger-apres-avoir-fui-lukraine-anna-et-natalia-ont-ete-victimes-dune-tentative-exploitation_5103559.html
[xxv] Dr Cockbain, E. & Dr Sidebottom, A. (2022, April 29). The war in Ukraine and associated risks of human trafficking and exploitation: Insights from an evidence-gathering roundtable. Office of the Independent Anti-Slavery Commissioner. https://www.antislaverycommissioner.co.uk/media/1801/ucl-iasc-2022-roundtable-report-the-war-in-ukraine-human-trafficking-and-exploitation.pdf
[xxvi] Tomlinson, C. (2022, April 20). Ukrainian Refugees Allegedly Exploited in Counterfeit Cigarette Factory. Breitbart News Network. https://www.breitbart.com/europe/2022/04/20/ukrainian-refugees-allegedly-exploited-in-counterfeit-cigarette-factory/amp/
[xxvii] United Nations Office on Drugs and Crime. (2022, March 24). Targeted by Traffickers – Ukrainian Refugees at High Risk of Exploitation [Press release]. https://www.unodc.org/unodc/frontpage/2022/March/targeted-by-traffickers---ukrainian-refugees-at-high-risk-of-exploitation.html
[xxviii] European Commission. (2020, October 20). Report from the Commission to the European Parliament and the Council: Third report on eh progress made in the fight against trafficking in human beings (2020) as required under Article 20 of Directive 2011/36/EU on preventing and combating trafficking in human beings and protecting its victims. https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52020DC0661
[xxix] UNODC Research. (2022, March). Conflict in Ukraine: Key Evidence on Risks of Trafficking in Persons and Smuggling of Migrants. United Nations Office on Drugs and Crime. https://www.unodc.org/documents/data-and-analysis/tip/Conflict_Ukraine_TIP_2022.pdf
[xxx] UNODC Research. (2022, March). Conflict in Ukraine: Key Evidence on Risks of Trafficking in Persons and Smuggling of Migrants. United Nations Office on Drugs and Crime. https://www.unodc.org/documents/data-and-analysis/tip/Conflict_Ukraine_TIP_2022.pdf
[xxxi] Fischer, H. (Host). (2022, May 24–present). Human rights crimes spiking with war in the Ukraine [Audio podcast]. Thomson Reuters Institute Market Insights. https://legalexecutiveinstitute.libsyn.com/podcast-human-rights-crimes-spiking-with-war-in-the-ukraine
[xxxii] Dr. Johnstone, Principal Deputy Director of the Office to Monitor and Combat Trafficking in Persons. (2022, April 7). Protecting Ukrainian Refugees from Human Trafficking [Hearing unofficial transcript]. Commission on Security & Cooperation in Europe: U.S. Helsinki Commission, Washington, DC, United States. https://www.csce.gov/sites/helsinkicommission.house.gov/files/unofficial-transcript/0407%20Protecting%20Ukrainian%20Refugees%20From%20Human%20Trafficking%20Unofficial%20Final.pdf
[xxxiii] Office to Monitor and Combat Trafficking in Persons. (2020). Trafficking in Persons Report, 20th ed. U.S. Department of State. https://www.state.gov/wp-content/uploads/2020/06/2020- TIP-Report-Complete-062420-FINAL.pdf
[xxxiv] International Organization for Migration. (2022, May 24). IOM Scales Up Regional Displacement Tracking in Response to the War in Ukraine. https://www.iom.int/news/iom-scales-regional-displacement-tracking-response-war-ukraine
