Human Trafficking
A Strategic Framework Could Help Enhance the Interagency Collaboration Needed to Effectively Combat Trafficking Crimes Gao ID: GAO-07-915 July 26, 2007Human trafficking is a transnational crime whose victims include men, women, and children and may involve violations of labor, immigration, antislavery, and other criminal laws. To ensure punishment of traffickers and protection of victims, Congress passed the Trafficking Victims Protection Act of 2000 (TVPA), which is subject to reauthorization in 2007. The Departments of Justice (DOJ) and Homeland Security (DHS) lead federal investigations and prosecutions of trafficking crimes. As requested, this report discusses (1) key activities federal agencies have undertaken to combat human trafficking crimes, (2) federal efforts to coordinate investigations and prosecutions of these crimes, and (3) how the Bureau of Justice Assistance (BJA) supported federally funded state and local human trafficking task forces. GAO reviewed strategies, reports, and other agency documents; analyzed trafficking data; and interviewed agency officials and task force members.
Since the enactment of the TVPA in 2000, federal agencies have (1) investigated allegations of trafficking crimes, leading to 139 prosecutions;(2) provided training and implemented state and local initiatives to support investigations and prosecutions; and (3) established organizational structures, agency-level goals, plans, or strategies. For example, agencies have trained new and current personnel on investigating and prosecuting trafficking in persons crimes through their agency training academies and centers, provided Web-based training, and developed and disseminated guidance on case pursuance. Agencies have also sponsored outreach and training to state and local law enforcement, nongovernmental organizations, and the general public through a toll-free complaint line, newsletters, national conferences, and model legislation. Finally, some agencies have established special units or plans for carrying out their antitrafficking duties. Federal agencies have coordinated across agencies on investigations and prosecutions of trafficking crimes on a case-by-case basis, determined by individual case needs, and established relationships among law enforcement officials across agencies. For example, several federal agencies worked together to resolve a landmark trafficking case involving over 250 victims. However, DOJ and DHS officials have identified the need to advance and expand U.S. efforts to combat trafficking through more collaborative and proactive strategies to identify trafficking victims. Prior GAO work on interagency collaboration has shown that a strategic framework that includes, among other things, a common outcome, mutually reinforcing strategies, and compatible polices and procedures to operate across agency boundaries can help enhance and sustain collaboration among federal agencies dealing with issues that are national in scope and cross agency jurisdictions. To support U.S. efforts to investigate trafficking in persons, BJA has awarded grants of up to $450,000 to establish 42 state and local human trafficking law enforcement task forces. BJA has funded the development of a train-the-trainer curriculum and a national conference on human trafficking and taken further steps to respond to task force technical assistance needs. Nevertheless, task force members from the seven task forces we contacted and DOJ officials identified continued and additional assistance needs. BJA does not have a technical assistance plan for its human trafficking task force grant program. Prior GAO work has shown the need for agencies that administer grants or funding to state and local entities to implement a plan to focus technical assistance on areas of greatest need. BJA officials said they were preparing a plan to provide additional and proactive technical assistance to the task forces, but as of June 2007 had not received the necessary approvals.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-07-915, Human Trafficking: A Strategic Framework Could Help Enhance the Interagency Collaboration Needed to Effectively Combat Trafficking Crimes
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Report to Congressional Requesters:
United States Government Accountability Office:
GAO:
July 2007:
Human Trafficking:
A Strategic Framework Could Help Enhance the Interagency Collaboration
Needed to Effectively Combat Trafficking Crimes:
GAO-07-915:
GAO Highlights:
Highlights of GAO-07-915, a report to congressional requesters
Why GAO Did This Study:
Human trafficking is a transnational crime whose victims include men,
women, and children and may involve violations of labor, immigration,
antislavery, and other criminal laws. To ensure punishment of
traffickers and protection of victims, Congress passed the Trafficking
Victims Protection Act of 2000 (TVPA), which is subject to
reauthorization in 2007. The Departments of Justice (DOJ) and Homeland
Security (DHS) lead federal investigations and prosecutions of
trafficking crimes. As requested, this report discusses (1) key
activities federal agencies have undertaken to combat human trafficking
crimes, (2) federal efforts to coordinate investigations and
prosecutions of these crimes, and (3) how the Bureau of Justice
Assistance (BJA) supported federally funded state and local human
trafficking task forces. GAO reviewed strategies, reports, and other
agency documents; analyzed trafficking data; and interviewed agency
officials and task force members.
What GAO Found:
Since the enactment of the TVPA in 2000, federal agencies have (1)
investigated allegations of trafficking crimes, leading to 139
prosecutions; (2) provided training and implemented state and local
initiatives to support investigations and prosecutions; and (3)
established organizational structures, agency-level goals, plans, or
strategies. For example, agencies have trained new and current
personnel on investigating and prosecuting trafficking in persons
crimes through their agency training academies and centers, provided
Web-based training, and developed and disseminated guidance on case
pursuance. Agencies have also sponsored outreach and training to state
and local law enforcement, nongovernmental organizations, and the
general public through a toll-free complaint line, newsletters,
national conferences, and model legislation. Finally, some agencies
have established special units or plans for carrying out their
antitrafficking duties.
Federal agencies have coordinated across agencies on investigations and
prosecutions of trafficking crimes on a case-by-case basis, determined
by individual case needs, and established relationships among law
enforcement officials across agencies. For example, several federal
agencies worked together to resolve a landmark trafficking case
involving over 250 victims. However, DOJ and DHS officials have
identified the need to advance and expand U.S. efforts to combat
trafficking through more collaborative and proactive strategies to
identify trafficking victims. Prior GAO work on interagency
collaboration has shown that a strategic framework that includes, among
other things, a common outcome, mutually reinforcing strategies, and
compatible polices and procedures to operate across agency boundaries
can help enhance and sustain collaboration among federal agencies
dealing with issues that are national in scope and cross agency
jurisdictions.
To support U.S. efforts to investigate trafficking in persons, BJA has
awarded grants of up to $450,000 to establish 42 state and local human
trafficking law enforcement task forces. BJA has funded the development
of a train-the-trainer curriculum and a national conference on human
trafficking and taken further steps to respond to task force technical
assistance needs. Nevertheless, task force members from the seven task
forces we contacted and DOJ officials identified continued and
additional assistance needs. BJA does not have a technical assistance
plan for its human trafficking task force grant program. Prior GAO work
has shown the need for agencies that administer grants or funding to
state and local entities to implement a plan to focus technical
assistance on areas of greatest need. BJA officials said they were
preparing a plan to provide additional and proactive technical
assistance to the task forces, but as of June 2007 had not received the
necessary approvals.
What GAO Recommends:
GAO recommends that the Attorney General and Secretary of DHS develop
and implement a strategic framework to enhance collaboration and the
Attorney General direct BJA to develop and implement a plan to help
focus technical assistance to the task forces. DOJ and DHS generally
agreed with the need for enhanced collaboration, and DOJ identified
steps to assist the task forces.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-915].
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Robert Goldenkoff at
(202) 512-2757 or GoldenkoffR@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
Federal Agencies Have Undertaken Key Activities to Combat Trafficking
in Persons Crimes:
Federal Agencies Have Coordinated on Individual Trafficking Cases, but
a Strategic Framework Could Help Further and Sustain Interagency
Collaboration:
BJA Has Helped Support Federally Funded State and Local Human
Trafficking Law Enforcement Task Forces, but Lacks a Plan to Identify
and Focus Technical Assistance Needs:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Objectives, Scope, and Methodology:
Appendix II: Statutory Provisions Used to Investigate and Prosecute
Trafficking Crimes:
Appendix III: Federal Efforts to Investigate and Prosecute Trafficking
in Persons and Data on Resources:
Appendix IV: Summary Case Studies:
Appendix V: Comments from the Department of Justice:
Appendix VI: Comments from the Department of Homeland Security:
Appendix VII: GAO Contact and Staff Acknowledgments:
Related GAO Products:
Tables:
Table 1: Primary Statutory Provisions Used for Trafficking in Persons
Prosecutions:
Table 2: Other Related Statutory Provisions Used in Trafficking in
Persons Prosecutions:
Table 3: Trafficking in Persons Prosecutorial Statistics for Civil
Rights Division/Criminal Section and U.S. Attorneys' Offices, Fiscal
Year 1995 through June 14, 2007:
Table 4: Trafficking in Persons Cases Investigated by the FBI's Civil
Rights Unit, Fiscal Year 2001 through April 5, 2007:
Table 5: Trafficking in Persons Cases Investigated by Immigration and
Customs Enforcement, Fiscal Year 2005 through May 31, 2007:
Table 6: Innocence Lost Statistics, Fiscal Year 2004 through June 5,
2007:
Table 7: DOJ Estimates of CRT/CS Trafficking in Persons Resources,
Fiscal Years 2000-2007:
Figures:
Figure 1: Federal Agencies with Primary Responsibilities for
Investigating and Prosecuting Trafficking in Persons Crimes:
Figure 2: BJA-Funded Human Trafficking Law Enforcement Task Forces:
Abbreviations:
AUSA: Assistant U.S. Attorney:
BJA: Bureau of Justice Assistance:
CEOS: Criminal Division/Child Exploitation and Obscenity Section:
CRT/CS: Civil Rights Division/Criminal Section:
DHS: Department of Homeland Security:
DOJ: Department of Justice:
DOL: Department of Labor:
DOS: Department of State:
FBI: Federal Bureau of Investigation:
FLSA: Fair Labor Standards Act:
HSTC: Human Smuggling and Trafficking Center:
HTP: Human Trafficking Prosecution:
ICE: Immigration and Customs Enforcement:
ICE TIPS: ICE Trafficking in Persons Strategy:
JTN: Justice Television Network:
OVC: Office for Victims of Crime:
SAC: Special Agent in Charge:
TVPA: Trafficking Victims Protection Act of 2000:
WHD: Wage and Hour Division:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
July 26, 2007:
The Honorable Ileana Ros-Lehtinen:
Ranking Member:
Committee on Foreign Affairs:
House of Representatives:
The Honorable F. James Sensenbrenner:
House of Representatives:
Human trafficking is a transnational crime whose victims include men,
women, and children and may involve violations of labor, immigration,
antislavery, and other criminal laws. Victims of trafficking are
bought, sold, sometimes transported across national boundaries, and
forced to work in legal or illegal situations, including the sex
industry, sweatshops, domestic service, and agriculture, among
others.[Footnote 1] What usually distinguishes trafficking from crimes
such as alien smuggling or other labor law violations is the
trafficker's use of force, fraud, or coercion to compel these victims
into, or hold them in, the employment situation. Despite international
acknowledgment of the trafficking problem as a human rights violation,
estimates of the number of victims remain questionable because of
methodological weaknesses, gaps in data, and numerical
discrepancies.[Footnote 2] Since the mid-1990s, the United States has
played a leading role in putting trafficking in persons on the
international community's agenda and pursued trafficking crimes within
the United States. By 2000, various U.S. policymakers had determined
that existing U.S. statutes scattered enforcement authority across the
government and did not adequately protect trafficking victims, deter
trafficking, and bring traffickers to justice.
As a result, in October 2000, Congress passed the Trafficking Victims
Protection Act of 2000 (TVPA) to ensure just and effective punishment
of traffickers and protection of victims.[Footnote 3] Among other
things, the TVPA made it illegal to obtain or maintain persons for
commercial sexual activity, using force, fraud, or coercion for those
18 or over (but proof of force, fraud, or coercion is not required for
those under 18), and to use certain kinds of force or coercion to
provide or obtain persons for any labor or services (e.g., work in
farms, factories, and households). The act also updated and
supplemented existing involuntary servitude statutes used to prosecute
trafficking crimes, enhanced the penalties for trafficking crimes, and
provided a range of new protections and assistance for victims of
trafficking. Congress reauthorized the act in 2003 and 2005, and it is
subject to reauthorization in 2007.[Footnote 4]
Nevertheless, pursuing trafficking in persons crimes continues to
present special challenges to federal investigators and prosecutors.
Since the primary eyewitness to and evidence of the crime is typically
the trafficking victim, the first step in pursuing these crimes is
usually to identify victims. Yet these victims are often hidden from
view, employed in legal or illegal enterprises, do not view themselves
as victims, or are considered to be criminals or accessories to crimes
(e.g., prostitutes or smuggled aliens) subject to incarceration or
deportation. A nongovernmental organization, average citizens, or even
state and local law enforcement working in the community may be the
first point of contact for a trafficking victim, rather than federal
law enforcement.
Moreover, trafficking in persons cases are difficult to pursue because
they are multifaceted, complex, and resource intensive. Federal
agencies have to determine whether those identified as potential
victims have in fact been trafficked and then secure their cooperation
in order to pursue the investigation and prosecution of the
traffickers. Victims may be reluctant to testify because of trauma,
fear, loyalty to the trafficker, or distrust of law enforcement.
Moreover, a single case may involve one or hundreds of victims,
requiring housing, food, and other services from federal agencies;
diverse offenses, such as violent crime, labor exploitation, sex
crimes, alien smuggling, organized crime, and financial crimes; and
collection of significant evidence from overseas.
Accordingly, investigating and prosecuting trafficking crimes requires
collaboration[Footnote 5] among multiple components of the Departments
of Justice (DOJ) and Homeland Security (DHS) with responsibilities for
investigating and prosecuting trafficking crimes. Identifying
trafficking and victims can also involve collaboration between DOJ and
DHS agencies and components of the Departments of Labor (DOL) and State
(DOS) that may uncover information relevant to the pursuit of
trafficking crimes in the course of carrying out their missions.
Collaboration is also needed between federal agencies and state and
local law enforcement and nongovernmental organizations. Recognizing
the need to leverage these resources to identify victims and support
federal efforts to pursue traffickers, DOJ's Bureau of Justice
Assistance (BJA), working with the Office for Victims of Crime (OVC),
implemented a competitive grant program in 2004 to fund human
trafficking law enforcement task forces composed of state and local law
enforcement agencies, field offices of federal agencies, and victim and
social service organizations with the support of the local U.S.
Attorney. As of fiscal year 2006, BJA had funded 42 task forces across
the country.
As requested, to ascertain the status of U.S. efforts to investigate
and prosecute trafficking crimes, this report discusses (1) key
activities federal agencies have undertaken to combat trafficking in
persons crimes, (2) federal efforts to coordinate investigations and
prosecutions of trafficking in persons crimes and whether these efforts
might be enhanced, and (3) how BJA supported federally funded state and
local human trafficking task forces and whether these efforts might be
improved. This review is part of a larger body of work we have
conducted on U.S. efforts to combat trafficking in persons, here and
abroad. A companion report that examines U.S. and multilateral efforts
to combat human trafficking overseas was also issued today.[Footnote 6]
To determine key activities federal agencies have undertaken to combat
trafficking in persons crimes, we reviewed agency reports describing
these activities and strategies and memorandums applicable to federal
efforts to address these crimes. We interviewed officials from DOJ,
including the Federal Bureau of Investigation (FBI), Civil Rights
Division/Criminal Section (CRT/CS), Criminal Division/Child
Exploitation and Obscenity Section (CEOS), and the Executive Office for
U.S. Attorneys; DHS U.S. Immigration and Customs Enforcement (ICE) and
U.S. Citizenship and Immigration Services (CIS); DOL's Wage and Hour
Division; DOS's Bureau of Diplomatic Security and Office to Monitor and
Combat Trafficking in Persons; and the Human Smuggling and Trafficking
Center (HSTC).[Footnote 7] From the FBI, ICE, CRT/CS, and CEOS, we
obtained and analyzed relevant data on the cases investigated and
prosecuted, including numbers of cases, defendants charged, and
convictions, as well as, where possible, estimates of the resources
used to do so. We discussed the sources of these data with federal
agency officials to determine that these data were sufficiently
reliable to show trends in agencies' activities undertaken to
investigate and prosecute trafficking crimes.
To determine what efforts federal agencies have undertaken to
coordinate investigations and prosecutions of trafficking in persons
crimes and whether these efforts might be enhanced, we reviewed
pertinent documents, such as agency reports, strategies, and
memorandums to field offices, which described or directed agency and
interagency coordination on trafficking activities. We interviewed
officials from DOJ headquarters, including FBI, CRT/CS, CEOS, and the
Executive Office for U.S. Attorneys; ICE and CIS; DOL's Wage and Hour
Division; DOS's Bureau of Diplomatic Security and Office to Monitor and
Combat Trafficking in Persons; and HSTC. We also interviewed field
personnel from FBI, ICE, DOL, and selected U.S. Attorney's Offices. In
addition, we used relevant GAO reports on enhancing interagency
collaboration as criteria.
To assess how BJA has supported federally funded state and local human
trafficking task forces and whether these efforts might be improved, we
analyzed relevant documents and grant reports from BJA, including grant
solicitations, performance reports, and Web site information; met with
BJA, OVC, and CRT/CS officials to discuss the documents and technical
assistance to the task forces; made site visits to three task forces;
and conducted telephone interviews with key participants from four
other task forces. The task forces contacted were judgmentally selected
based on the length of time funded (fiscal year 2004); different levels
of success, based on BJA performance measures (e.g., number of
identified potential trafficking victims); and focus (e.g., trafficking
for labor, sex, or both). We interviewed key task force participants
(e.g., Assistant U.S. Attorneys, local and federal law enforcement, and
representatives of nongovernmental organizations) from the seven task
forces. Although this approach does not allow for generalizing, it
provided additional information on steps federal agencies took to
support state and local human trafficking task forces. In addition, we
reviewed relevant GAO reports on federal agencies' administration of
grants or funding to state and local entities.
We conducted our work from June 2006 through June 2007 in accordance
with generally accepted government auditing standards. Appendix I
presents more details about the scope and methodology of our work.
Results in Brief:
Since the enactment of the TVPA in 2000, federal investigative and
prosecutorial agencies have undertaken several key activities to combat
trafficking in persons crimes, such as (1) investigating allegations of
trafficking leading to 139 prosecutions;[Footnote 8] (2) providing
training, outreach, and state and local initiatives to support
investigations and prosecutions; and (3) addressing agency
responsibilities by establishing special units and developing agency-
level goals, plans, and strategies. For example, federal agencies have
provided training on trafficking in persons to their new and current
personnel using a variety of techniques, including integrating
information on trafficking into the curriculum at the respective
training academies and centers, providing Web-based training through
internal agency Web sites, and developing and disseminating guidance on
how to pursue these cases. Agencies have also sponsored outreach and
training to state and local law enforcement, nongovernmental
organizations, and the general public, for example, through a toll-free
complaint line, newsletters, and national conferences. Finally, ICE and
CRT/CS have established special units focused on trafficking, and ICE,
FBI, CRT/CS, and DOL have developed goals, strategies, or plans for
carrying out their antitrafficking responsibilities.
Federal agencies have coordinated investigations and prosecutions of
trafficking crimes across agencies on a case-by-case basis, but their
approaches to expand the scope of efforts to combat trafficking could
benefit from an overall strategic framework to help enhance and sustain
interagency collaboration on trafficking in persons. Agencies have
described their coordination as reactive, and coordination has occurred
as determined by the needs of individual cases and the established
relationships among law enforcement officials across agencies. For
example, federal agencies worked together to successfully resolve a
landmark trafficking case involving over 250 victims. Federal agencies
identified additional activities needed to expand U.S. efforts to
identify trafficking victims and institutionalize collaborative
relationships among federal agencies and between federal agencies and
state and local law enforcement and nongovernmental organizations.
These included developing coordinated proactive approaches to identify
trafficking victims; intelligence gathering; analysis of trafficking
patterns; and expanding outreach to non-law-enforcement agencies,
nongovernmental organizations, and other law enforcement agencies.
However, the current coordinating mechanisms do not address the
interagency collaboration needed for this level of expanded effort, and
individual agency plans only address individual agency goals linked to
agency missions--none of which is linked to a common governmentwide
outcome for investigations and prosecutions of trafficking crimes.
Additionally, while no single agency can bring traffickers to justice,
agencies have differing views on leadership of U.S. efforts to
investigate and prosecute trafficking and information sharing policies.
Our previous work has shown that a strategic framework that, at a
minimum, includes agencies working together toward a common outcome
with mutually reinforcing strategies; agreed-on roles and
responsibilities; and compatible polices, procedures, and other means
to operate across agency boundaries can help enhance and sustain
collaboration among federal agencies dealing with issues, such as
trafficking in persons, that are national in scope and cross agency
jurisdictions.[Footnote 9] Establishing such a strategic framework to
investigate and prosecute trafficking in persons crimes, as developed
by federal agencies to address the unique challenges posed by these
crimes, could help federal agencies enhance and sustain the
collaboration needed to expand their efforts to combat trafficking
crimes.
To support U.S. efforts to identify trafficking victims and investigate
and prosecute trafficking in persons crimes, BJA established a
competitive grant program to fund state and local law enforcement human
trafficking task forces, but lacks a plan to identify and focus the
task forces' technical assistance needs. Since 2004, BJA has awarded 42
task force grants (22 in fiscal year 2004 and 10 each in fiscal years
2005 and 2006) of up to $450,000 each, for a 3-year period for a total
of a total of $17,324,182. According to BJA, it has used $1,433,000 of
its general funds to provide technical assistance to the task forces,
including financing the development of a train-the-trainer curriculum
on human trafficking, delivering training sessions using the
curriculum, and funding the national conference on human trafficking
held in New Orleans in October 2006. In addition BJA reported that it
had taken steps to help it respond to human trafficking task force
technical assistance needs, including using task force performance
measures to help resolve task force performance issues; providing task
forces with information to help them submit better performance data;
and conducting site visits, in conjunction with other DOJ components,
to some task forces. Nevertheless, DOJ officials and task force members
also pointed to continued and additional technical assistance and
training needs, including advanced training on techniques to facilitate
law enforcement and nongovernmental organizations working together to
interview trafficking victims, standardized protocols, or a Web site to
facilitate information sharing among the task forces. At the time of
our review, BJA did not have a technical assistance plan for its human
trafficking task force initiative. Our previous work on federal grant
programs has shown the need for agencies that administer grants or
funding to state and local entities to implement a plan to focus
technical assistance efforts on areas of greatest need.[Footnote 10]
BJA told us that it was developing a plan to provide additional and
proactive technical assistance to the task forces, but as of June 2007
had not received the necessary approvals.
To help ensure that the U.S. government maximizes its ability to
enforce laws governing trafficking in persons, we recommend that the
Attorney General and the Secretary of Homeland Security, with other
agencies that support these enforcement efforts, develop and implement
a strategic framework for investigating and prosecuting trafficking
crimes that, at a minimum, defines and articulates a common outcome;
establishes mutually reinforcing or joint strategies; agrees on roles
and responsibilities; and establishes compatible policies, procedures,
and other means to operate across agency boundaries. In addition, to
enable BJA to better support the federally funded state and local human
trafficking task forces, we recommend that the Attorney General direct
the Director of the Bureau of Justice Assistance to develop and
implement a plan to help focus technical assistance to the task forces.
DOJ and DHS generally agreed with the content of our report and the
need for enhanced collaboration to expand U.S. efforts to investigate
and prosecute trafficking crimes. Regarding our recommendation to the
Attorney General and the Secretary of Homeland Security to develop a
strategic framework to coordinate U.S. efforts to investigate and
prosecute trafficking crimes, DOJ proposed that the report identify the
need for continued collaboration, but not mandate one particular
collaborative model. We acknowledged that it was not our intent to
prescribe a particular collaborative model and that specific elements
of and structures for developing and implementing the strategic
framework would be developed by the agencies involved. We added
language to our report that reinforces this point. Commenting on this
recommendation, DHS said that ICE would support such a framework if
certain considerations were taken into account, such as recognizing
that agencies' roles in a particular case would vary by available
resources, local priorities, and the nature of the case and
investigation. GAO would expect that the agencies involved in
developing and implementing this framework would determine how to
address these considerations. DOJ identified the efforts it would be
undertaking by October 1, 2007, to address our recommendation that the
Attorney General call on the Director of BJA to develop a plan for
providing technical assistance to the human trafficking law enforcement
task forces.
Background:
Congress passed the Trafficking Victims Protection Act of 2000 to
combat trafficking in persons. As the centerpiece for U.S.
antitrafficking efforts, the TVPA advanced a three-pronged victim-
centered approach--prevention of trafficking, protection and assistance
for victims of trafficking, and prosecution and punishment of
traffickers. Among its provisions, the TVPA addressed identified gaps
in existing law and enhanced the tools available to pursue these
crimes. Specifically, the act criminalized the obtaining or maintaining
of persons for commercial sexual activity, using force, fraud, or
coercion for those 18 or over (but not for those under 18), and to use
certain kinds of force or coercion to provide or obtain persons for any
labor or services (e.g., work in farms, factories, and households). It
also included nonviolent coercion and threats of harm to third persons
in federal involuntary servitude laws; made attempted trafficking
crimes punishable; criminalized the holding of actual or purported
identity documents in the course of committing, or with the intent to
commit, any trafficking crime; and increased the maximum penalty for
slavery and involuntary servitude offenses from 10 to 20 years or to a
life sentence if the offense involved factors like death, kidnapping,
or aggravated sexual abuse. In addition, the TVPA required restitution
for victims of trafficking and forfeiture of traffickers' assets and
provided legal status and special benefits to aliens certified as
trafficking victims in the United States who are willing to assist law
enforcement efforts against traffickers.[Footnote 11] (App. II
identifies specific statutory provisions relevant to investigating and
prosecuting trafficking in persons crimes.)
Responsibilities for pursuing trafficking crimes fall to multiple
federal agencies, including the FBI and ICE, which investigate these
crimes; CRT/CS, CEOS, and U.S. Attorney's Offices, which prosecute
traffickers; and other agencies within DHS and DOJ and components of
DOL and DOS that support U.S. efforts to investigate and prosecute
trafficking in persons. Figure 1 depicts these key agencies and their
respective responsibilities related to the investigation and
prosecution of trafficking in persons crimes.
Figure 1: Federal Agencies with Primary Responsibilities for
Investigating and Prosecuting Trafficking in Persons Crimes:
[See PDF for image]
Source: GAO analysis of agency documents.
[A] T visas grant eligible alien victims of trafficking nonimmigrant
status for up to 4 years, with the possibility of an extension.
[End of figure]
In addition, to coordinate the implementation of the TVPA, the act
directed the President to establish an Interagency Task Force to
Monitor and Combat Trafficking in Persons and authorized the Secretary
of State to create the Office to Monitor and Combat Trafficking in
Persons to provide assistance to the task force. In February 2002, the
President issued an executive order creating this cabinet-level task
force and then in December issued National Security Presidential
Directive 22, which identified trafficking in persons as an important
national security issue and directed federal agencies to strengthen
their collective efforts, capabilities, and coordination to support the
goal of abolishing human trafficking.[Footnote 12] Subsequently, the
2003 TVPA reauthorization statutorily established the Senior Policy
Operating Group (SPOG) to address interagency policy, program, and
planning issues regarding the TVPA's implementation.[Footnote 13] In
addition, HSTC, which is staffed by detailees from DHS, DOJ, DOS, and
the intelligence community, among other places, collects and
disseminates intelligence information to build a comprehensive picture
of human trafficking.[Footnote 14]
Pursuing trafficking investigations and prosecutions also needs the
support of state and local law enforcement, who may be in the best
position to find trafficking victims because of their familiarity with
their respective jurisdictions, and nongovernmental organizations, from
whom victims may more readily seek assistance. To leverage these
resources to support federal efforts to investigate and prosecute
trafficking in persons, DOJ designed, developed, and instituted a task
force approach that it presented during the first National Training
Conference on Human Trafficking: Rescuing Women and Children from
Slavery, held in Tampa, Florida, in July 2004. DOJ invited 21 teams of
20 federal, state, and local law enforcement and nongovernmental
service providers from communities that it believed to have potential
trafficking problems to attend the conference. After the conference,
the teams were expected to work together on human trafficking in their
respective communities. To implement the approach, BJA, the DOJ
component responsible for supporting local, state, and tribal efforts
to achieve safer communities, developed and implemented a human
trafficking law enforcement task force competitive grant program. These
grants were to be awarded to state or local police agencies that work
with the local U.S. Attorney's Office, federal law enforcement
entities, and nongovernmental organizations that may come into contact
with victims of trafficking. In addition, in spring 2003, the FBI's
Crimes Against Children Unit, DOJ's Child Exploitation and Obscenity
Section, and the National Center for Missing and Exploited Children
launched the Innocence Lost National Initiative in 14 U.S. cities where
the FBI field offices had identified a high incidence of trafficking of
U.S. children for commercial sex.
As trafficking in persons is a transnational crime, federal agencies
may need to obtain information and assistance directly from individual
foreign governments and through international law enforcement
organizations in order to investigate and prosecute trafficking in
persons cases in the United States. Multilateral and extradition
treaties provide the authority for U.S. investigative and prosecutorial
agencies to request information and assistance on criminal cases,
including trafficking in persons, from approximately 175 individual
foreign governments.[Footnote 15] Working through ICE and FBI personnel
stationed at U.S. embassies, U.S. investigative and prosecutorial
agencies have obtained a broad spectrum of assistance from individual
foreign governments and with such assistance have successfully
prosecuted traffickers. This assistance has included obtaining
documentary evidence and corroborating witness testimony, protecting
U.S. trafficking victims' family members in a foreign country,
apprehending fugitive traffickers, and extraditing defendants. In
addition, U.S. agencies may obtain information through the
International Criminal Police Organization, Interpol, which serves as a
conduit for a cooperative exchange of information on criminal
activities from its 186 member countries.[Footnote 16]
Federal Agencies Have Undertaken Key Activities to Combat Trafficking
in Persons Crimes:
Subsequent to the enactment of the TVPA, federal agencies reported 139
prosecutions[Footnote 17] and hundreds of investigations of trafficking
for commercial sex or labor as of June 2007. To support federal efforts
to identify victims and investigate and prosecute these crimes,
agencies (1) provided training to agency personnel to raise awareness
and increase the skills needed to identify victims and pursue
trafficking investigations and prosecutions, (2) carried out outreach
and training to raise public awareness of and skills in identifying
trafficking victims, and (3) engaged state and local knowledge and
resources by funding state and local trafficking in persons task forces
and developing and disseminating a model state law. In addition, to
address their responsibilities related to trafficking in persons
crimes, some agencies have established special units, agency-level
goals, or plans or strategies. Federal investigative and prosecutorial
agencies have generally drawn from existing resources to carry out
these efforts (app. III provides information on resources).
Federal Agencies Reported a General Increase in Investigations and
Prosecutions of Trafficking in Persons Beginning in Fiscal Year 2001:
With the enhanced tools available to federal investigators and
prosecutors as a result of the enactment of the TVPA, federal agencies
reported a general increase in the number of prosecutions and
investigations of trafficking in persons crimes. These data are an
indicator of the level of agency effort in pursuit of these crimes,
since fiscal year 2001, although they are limited by a number of
factors. Trafficking crimes and their victims are hidden and not
readily identifiable. Traffickers may be charged or convicted of other
than trafficking crimes (e.g., kidnapping, immigration violations, or
money laundering) for strategic or technical reasons. Also, limitations
of agency data systems, which are primarily case management systems,
may not allow for the extraction of trafficking data per se. In
addition, availability of individual agencies' data may be limited by
factors pertinent to that agency; for example, ICE was only established
in 2003. Moreover, agency data are not comparable across agencies nor
can data on investigations be linked to data on prosecutions. As a
result of these limitations, however, the actual number of
investigations and prosecutions that have led to the incapacitation of
traffickers may be greater than the numbers that have been reported by
federal agencies.
CRT/CS reported 139 prosecutions from fiscal year 2001 to June 14,
2007,[Footnote 18] as compared with 19 cases for fiscal years 1995 to
2000. These cases included 39 defined by CRT/CS as labor trafficking
and 100 as trafficking for commercial sexual activity. According to
CRT/CS officials, the number of prosecutions varies in any given year,
because of differences in the complexity of the cases. (See app. IV for
illustrations of the complexity of cases.) FBI and ICE provided data on
numbers of trafficking cases opened. The FBI's Civil Rights Unit
reported opening a total of 751 trafficking in persons cases between
fiscal year 2001 and April 5, 2007. However, these data do not include
investigations involving trafficking that are classified as other types
of crime, for example, alien smuggling cases that also involve
trafficking in persons. ICE reported opening a total of 899 trafficking
in persons cases, for fiscal year 2005 through May 31, 2007.[Footnote
19] Both FBI and ICE data may include cases involving investigations
handled jointly by the two agencies. In addition, as part of the
Innocence Lost National Initiative, the FBI's Crimes Against Children
Unit reported 327 cases opened on trafficking of U.S. children for
commercial sex between fiscal year 2004 and June 5, 2007. Appendix III
presents additional data related to trafficking in persons
investigations and prosecutions; including arrests; indictments;
convictions; and restitution to the victims, as required under the
TVPA, where appropriate.
Federal Agencies Have Undertaken Training, Outreach, and State and
Local Initiatives to Support Federal Efforts to Investigate and
Prosecute Trafficking Crimes:
National Security Presidential Directive 22 directed federal
departments and agencies to ensure that all appropriate offices within
their jurisdiction were fully trained to carry out their specific
responsibilities to combat trafficking, including interagency
cooperation and coordination on the investigation and prosecution of
trafficking. FBI, ICE, CRT/CS, CEOS, and DOL all reported taking steps
to ensure that their personnel received appropriate training, using a
variety of means to do so, including the following:
* training for new agents through the ICE and FBI training academies;
* a Web-based training module, which is available to ICE agents through
ICE's intranet;[Footnote 20]
* guidance to ICE domestic and international field offices about
conducting outreach, training, and coalition building;
* training conference sessions by the FBI Civil Rights Unit and
information on trafficking in the FBI's civil rights reference guide
for FBI agents;
* training of U.S. Attorneys and other prosecutors on trafficking in
persons and trafficking of U.S. children for commercial sex, at the
National Advocacy Center;[Footnote 21]
* guidance to all U.S. Attorneys' Offices about prosecuting under the
TVPA, a tool kit for prosecutors, and a law guide, developed by CRT/CS;
* training for victim-witness coordinators, who are the federal
government's liaisons to victims of federal crimes, and updating the
Attorney General's victim/witness guidelines to include trafficking in
persons;
* a nationwide televised human trafficking training initiative on the
Justice Television Network (JTN), initiated by CRT/CS in 2006 and
continuing in 2007, transmitted from the National Advocacy Center to
all 94 U.S. Attorneys' Offices. These offices and BJA-funded state and
local human trafficking task forces hosted members of the law
enforcement and nongovernmental organization communities to view these
programs; and:
* a week-long seminar on investigating and prosecuting cases involving
child sex trafficking, developed by CEOS, FBI, and the National Center
for Missing and Exploited Children for the joint training of state and
federal law enforcement agencies, prosecutors, and social service
providers in targeted cities. This seminar is given multiple times each
year.
In addition, to help identify victims of trafficking and support
federal efforts to pursue trafficking investigations, agencies have
used a variety of means to extend outreach and training to state and
local law enforcement, nongovernmental organizations, and the general
public. ICE developed laminated wallet-size cards, in five languages,
identifying the differences between human smuggling and human
trafficking as well as red flag indicators for human trafficking and
also developed a police roll call/muster DVD describing human
trafficking. CRT/CS publishes a newsletter on trafficking, available on
the DOJ Web site, and in collaboration with other federal agencies and
DOJ components, prepared and published the Report on Activities to
Combat Trafficking: Fiscal Years 2001-2005. DOJ's Office of Legal
Policy prepares the Attorney General's annual report to Congress on
U.S. efforts to combat trafficking, as required by the TVPA of 2003,
and the annual assessment of those efforts. DOJ also established, and
subsequently permanently funded, a toll-free Trafficking in Persons and
Worker Exploitation Complaint Line in February 2000 to provide a means
for victims, witnesses, and others to report potential trafficking
matters to law enforcement, get information, and obtain referrals to
services in their area.[Footnote 22] In 2004 and 2006, federal agencies
sponsored and participated in national conferences on human trafficking
in Tampa, Florida, and New Orleans, Louisiana, respectively.[Footnote
23] In 2006, CRT/CS, with the Attorney General, produced the film Give
Us Freedom: Liberty and Justice for Victims of Modern Day Slavery.
To further U.S. investigations and prosecutions of trafficking in
persons crimes, federal agencies have also fostered antitrafficking
efforts at the state and local levels. For example, federal agencies
have sought to engage state and local law enforcement and
nongovernmental organizations by funding the establishment of state and
local trafficking in persons task forces that bring together local law
enforcement, federal law enforcement, a U.S. Attorney, and
nongovernmental victim service providers. In addition, to expand
antitrafficking law enforcement authority and promote a uniform
national legal strategy to combat human trafficking, DOJ developed a
model state law, available on the DOJ Web site. According to DOJ, at
the time of its initial dissemination in 2004, 4 states--Texas,
Florida, Missouri, and Washington--had laws against trafficking in
persons. As of June 2007, 31 states had enacted antitrafficking in
persons legislation.[Footnote 24]
Individual Federal Agencies Have Established Special Units, Agency-
level Goals, or Plans or Strategies to Address Trafficking in Persons
Responsibilities:
National Security Presidential Directive 22 directed all federal
agencies to develop and promulgate plans to implement the directive by
March 2003. Plans for DOJ, DHS,[Footnote 25] DOL, and DOS enumerate
activities relevant to the investigation and prosecution of trafficking
in persons. Additionally, some agencies have undertaken various steps
to address their respective responsibilities related to the
investigation and prosecution of trafficking in persons, including
establishing special units that focus on trafficking in persons, agency-
level goals, or plans or strategies. In doing so, each of these
agencies has defined its responsibilities for pursuing trafficking
crimes in accordance with its broader agency mission.
Both ICE and CRT/CS have established specialized units focused on
trafficking in persons. The ICE Office of Investigations' Human
Smuggling and Trafficking Unit, consisting of a unit chief, with a
staff consisting of program managers who oversee programmatic and
operational issues globally, and victim witness coordinators, oversees
ICE's efforts to identify criminal smuggling and trafficking
organizations, prioritizes investigations based on risk factors,
coordinates field office investigations into those targeted
organizations, and coordinates victim assistance through approximately
300 of ICE's collateral-duty victim witness coordinators.[Footnote 26]
On January 31, 2007, the Attorney General and the Assistant Attorney
General for the Civil Rights Division announced the formation of a
special Human Trafficking Prosecution (HTP) Unit within CRT/CS.
According to CRT/CS officials, the unit is to continue to play a role
in coordinating intra-DOJ and interagency trafficking efforts (e.g.,
with ICE); develop new strategies to increase human trafficking
investigations and prosecutions throughout the nation; enhance DOJ's
investigations and prosecutions of trafficking crimes by pursuing cases
that are multijurisdictional or involve financial crimes; and also
continue to engage in training, technical assistance, and outreach
initiatives to federal, state, and local law enforcement and
nongovernmental organizations.
The primary investigative agencies for trafficking in persons have laid
out goals and activities for combating this crime. The top goal of
ICE's trafficking in persons efforts--to disrupt and dismantle criminal
organizations involved in trafficking, including intelligence gathering
on these organizations--is aligned with DHS strategic goals of
assessing vulnerabilities and mitigating threats to the homeland. In
addition, ICE's trafficking goals of seizing assets of criminal
organizations and rescuing and protecting victims of trafficking follow
ICE's top goal. The FBI's Strategic Plan 2004-2009 identifies
investigations of trafficking in persons crimes as a rising priority
under its responsibility to enforce civil rights protections. In
addition, the FBI Civil Rights Unit specifies the strengthening of its
intelligence base on trafficking activity as a top priority among its
programmatic goals and emphasizes coordination with other law
enforcement entities and partnerships with nongovernmental
organizations in pursuing trafficking investigations.
Furthermore, both ICE and FBI have disseminated guidance on handling
trafficking cases to their agents in the field. In December 2006, the
ICE Director of Investigations disseminated to Special Agents in Charge
(SACs) and ICE personnel assigned to U.S. embassies the ICE Office of
Investigations' new strategy document for combating trafficking in
persons, entitled ICE Trafficking In Persons Strategy, or ICE TIPS. ICE
TIPS emphasizes outreach and education on ICE's role in trafficking
investigations and ability to issue Continued Presence, a mechanism for
authorizing victims without legal immigration status to remain in the
United States; collaborations with other law enforcement entities and
nongovernmental service providers, including task force participation;
and performance evaluation to focus and refine ICE's efforts. In May
2007, additional guidance from the ICE Office of Investigations and the
ICE Office of International Affairs was sent to SACs and ICE personnel
assigned to U.S. embassies overseas. The guidance provided direction on
outreach, training, coordination, and coalition building and mandated
periodic reporting of efforts to ICE headquarters. The FBI's guidance
is contained in its Civil Rights Program Reference Guide, the fiscal
year Civil Rights Program Plan, and memorandums to the field. The
fiscal year 2007 Civil Rights Program Plan provides information similar
to that contained in ICE TIPS and encourages working partnerships with
other law enforcement entities and nongovernmental service providers,
including providing training to these groups.
As the lead prosecutorial agency for trafficking in persons, CRT/CS
identified three levels of strategic planning for its trafficking
efforts. DOJ's Strategic Plan (Fiscal Years 2003-2008) lays out broad
goals and performance measures. Specifically, CRT/CS's efforts on
trafficking in persons fall under goal two--enforce federal laws and
represent the rights and interests of the American people, strategic
objective 2.4--to uphold the civil and constitutional rights of all
Americans and protect vulnerable members of society. According to the
strategy, the Civil Rights Division intends to protect new immigrants
to America by, among other things, vigorously prosecuting those who
exploit their vulnerability through trafficking in persons, including
increasing efforts to combat the criminal trafficking of children and
other vulnerable victims, through more intensified efforts and
interagency coordination. To achieve DOJ's strategic goals and
objectives, CRT/CS's fiscal year 2007 internal priorities document lays
out activities to be undertaken in three areas--investigation and
prosecution; outreach and training; and policy development, including
intergovernmental coordination. In addition, DOJ communicates direction
and guidance on handling trafficking in persons cases through internal
DOJ memorandums between CRT/CS and U.S. Attorneys, including guidance
to U.S. Attorneys on how to prosecute trafficking cases, memorandums
between CRT/CS and the FBI, and memorandums between DOJ and other
federal agencies.[Footnote 27]
In addition, DOL's Wage and Hour Division has an internal plan that
addresses its role in federal interagency trafficking efforts. The plan
presents current goals and measures for the division's involvement with
human trafficking task forces in investigations, as appropriate with
its mission, and in assisting trafficking victims in securing
restitution, as well as long-term goals and measures for increasing
these efforts.
Federal Agencies Have Coordinated on Individual Trafficking Cases, but
a Strategic Framework Could Help Further and Sustain Interagency
Collaboration:
Recognizing that investigating and prosecuting trafficking cases can be
complex and multifaceted activities, federal agencies have taken steps
to coordinate their efforts to leverage the expertise and resources
required to resolve these crimes. Coordination of investigations and
prosecutions has usually occurred as determined by the needs of the
individual cases and personal relationships established between law
enforcement officials across agencies. However, DOJ and DHS officials
acknowledged the need to expand the scope of their efforts to
investigate and prosecute trafficking crimes by, for example,
undertaking proactive measures to identify trafficking victims and
multijurisdictional and international trafficking in persons
investigations and prosecutions. Pursuing such efforts requires more
strategic collaboration among agencies, since no one agency can carry
out these efforts alone. Our prior work has shown that a strategic
framework that would include, at a minimum, a common outcome and
mutually reinforcing strategies; agreed-on roles and responsibilities;
and compatible polices, procedures, and other means to operate across
agency boundaries can help agencies enhance and expand collaboration on
issues that are national in scope and cross agency
jurisdictions.[Footnote 28] However, the mechanisms that are currently
in place to facilitate interagency cooperation on human trafficking do
not address the greater collaboration needed for the expanded level of
effort to investigate and prosecute trafficking crimes. Establishing
such a strategic framework to investigate and prosecute trafficking in
persons crimes, as developed by federal agencies to address the unique
challenges posed by these crimes, could help federal agencies enhance
and sustain the collaboration needed to expand their efforts to combat
trafficking crimes.
Federal Agencies Have Coordinated Trafficking Efforts on a Case-by-Case
Basis:
According to DOJ and DHS officials, in practice, agency coordination of
investigations and prosecutions of trafficking in persons has occurred
on a case-by-case basis. CRT/CS, CEOS, ICE, and FBI officials
acknowledged that investigating and prosecuting trafficking in persons
crimes made it necessary for federal agencies to work with one another
and with state and local law enforcement, who were often the first ones
to discover possible evidence of trafficking, and with nongovernmental
organizations that provided assistance to the victims. Federal
officials emphasized that they knew whom to call; for example, the
victim-witness coordinators in ICE and CRT/CS know each other; ICE and
FBI investigators knew the names of prosecutors in CRT/CS.
ICE and FBI officials explained that they sometimes worked joint
investigations or investigated different aspects of a case. For
example, in one case, while ICE agents rescued the victims in one
location, the FBI was investigating related brothel operations in other
cities. Through their detailees to the HSTC, ICE and FBI may determine
whether the two agencies may be working on a related case. Agents in
the field may also contact their counterparts at other agencies to
ascertain whether they are working on a similar case. DOL Wage and Hour
Division officials told us that if they identified a potential
trafficking situation, they would notify the FBI and the respective
U.S. Attorney and the FBI might take over responsibility for the case,
as DOL's Wage and Hour Division does not carry out criminal
investigations related to trafficking in persons. In addition, victim
witness coordinators across DOJ and DHS are in regular contact with
each other to ensure victim care and services from the point of victim
identification through investigation and prosecution.
Investigative and prosecutorial agencies also work with nongovernmental
agencies. For example, ICE officials said that they shared information
with nongovernmental organization interviewers who helped the
investigators determine which potential trafficking victims were actual
victims and which were "victim enforcers" who were swept up in the raid
but worked for the traffickers. CRT/CS and U.S. Attorney's Offices
prosecute the cases developed by the investigative agencies. In
addition, under the auspices of the Innocence Lost National Initiative,
FBI investigators from its Crimes Against Children Unit, the National
Center for Missing and Exploited Children, and CEOS prosecutors have
joined forces with state and local law enforcement through the
establishment of formal or ad hoc task forces in 23 cities across the
country, as a grassroots operation to work on cases of trafficking of
U.S. children for commercial sex.
Two noteworthy trafficking cases illustrate the breadth and diversity
of coordination and cooperation that occurs in pursuit of these crimes.
For example, the prosecution of Kil Soo Lee brought together FBI
investigators, DOL investigators from the Wage and Hour Division and
the Occupational and Safety and Health Administration, CRT/CS
prosecutors, and some nongovernmental organizations and resulted in the
largest trafficking case brought to date. In a separate case, Gerardo
Flores Carreto and Josue Flores Carreto were each sentenced to 50 years
in prison in a case involving coordination among ICE, DOJ,
international nongovernmental organizations, as well as the Mexican
government. (See app. IV.)
In addition to interacting as needs emerge, officials told us that
various law enforcement procedures and protocols are in place to foster
coordination. Upon initiating a trafficking in persons investigation,
ICE and the FBI notify the local U.S. Attorney to determine if enough
evidence exists to pursue a federal trafficking in persons prosecution.
Moreover, U.S. Attorneys are required to report civil rights cases,
including trafficking in persons cases, to CRT/CS, which then
determines whether to accept the U.S. Attorney's staffing
recommendation. In addition, DHS, DOJ, and the Department of Health and
Human Services signed a memorandum of understanding that lays out the
basic responsibilities and functions of the departments as they relate
to the certification of victims' eligibility for certain federal
benefits.
Federal agencies have also developed tools to facilitate interagency
coordination and even coordination with state and local law enforcement
and nongovernmental organizations in trafficking cases, usually on a
case-by-case basis. According to DOJ and DHS officials, training is
provided to these stakeholders prior to raids; operations manuals are
prepared both for law enforcement and victim-witness coordinators.
A Strategic Framework Could Be Important to Implementing Expanded
Approaches to Combating Trafficking:
Although federal agencies have successfully coordinated on a case-by-
case basis to investigate and prosecute trafficking crimes, officials
described their approach to trafficking investigations and prosecutions
as usually being reactive and acknowledged the need for additional
proactive approaches to enhance interagency efforts to investigate and
prosecute trafficking crimes. DOJ and DHS senior officials identified
the need to expand the scope of efforts, including taking proactive
measures to identify trafficking victims (e.g., expanding outreach to
additional law enforcement agencies and nongovernmental organizations)
and pursuing multijurisdictional and international trafficking in
persons investigations and prosecutions. These efforts require more
strategic collaboration among agencies, since no one agency has the
authority to carry out these efforts alone. However, the current
coordinating mechanisms and National Security Presidential Directive 22
do not address the greater collaboration needed for this level of
expanded effort, and individual agency plans only address individual
agency efforts--none of which is linked to a common governmentwide
outcome to address the investigation and prosecution of trafficking
crimes. Additionally, differing perceptions among agencies exist on
leadership and roles and responsibilities surrounding some of these
expanded efforts.
As our previous work has shown, a strategic framework that includes
agencies working together toward a common outcome with mutually
reinforcing strategies, agreed-on roles and responsibilities, and
compatible policies and procedures can help enhance and sustain
collaboration among federal agencies dealing with issues, such as
trafficking in persons, that are national in scope and cross agency
jurisdictions.[Footnote 29] In light of the unique challenges posed by
trafficking in persons investigations and prosecutions, we acknowledge
that a framework to address the investigation and prosecution of
trafficking crimes needs to be flexible and incorporate different types
of collaborative mechanisms. The agencies involved would determine the
specifics of the elements enumerated above, any additional elements to
be included in the framework, and the structures for developing and
implementing such a framework.
Federal Agencies Identified Need for Expanded Approaches:
DOJ and DHS officials acknowledged the need to expand the scope of U.S.
efforts to combat trafficking crimes by developing proactive approaches
to identify trafficking victims (e.g., expanding outreach to non-law
enforcement agencies, nongovernmental organizations, and other law
enforcement agencies), pursuing multijurisdictional and even
international trafficking in persons investigations and prosecutions,
and establishing mechanisms for consistent communications and
information sharing among agencies.
Because trafficking victims are hidden and difficult to find, but are
also the primary source of evidence of trafficking crimes, agency
officials underscored the need to develop proactive approaches to
identify trafficking victims in order to increase investigations and
prosecutions. While current efforts to pursue trafficking crimes have
drawn on the support of other federal agencies that do not have
specific law enforcement functions or have benefited from the
collaboration between law enforcement and nongovernmental
organizations, officials expressed the desire to expand these efforts.
For example, CRT/CS officials told us that they would like to prosecute
more labor trafficking cases, but these situations were difficult to
identify. While CRT/CS has worked with DOL's Wage and Hour Division on
trafficking cases, such as the Kil Soo Lee prosecution, they hoped to
work with DOL to proactively identify potential trafficking situations,
possibly during Wage and Hour's self-initiated investigations of low-
wage work sites. However, DOL officials said that to do so, the
agencies would need to develop an approach that included regional
planning and further training of DOL's program managers. This level of
collaboration and planning could benefit from mutually reinforcing
strategies or a joint strategy to identify additional victims of labor
trafficking.
In addition, the main goal of ICE's outreach efforts to state and local
law enforcement, nongovernmental organizations, and foreign partners is
identifying victims. While there are several jurisdictions across the
country that are currently combating trafficking crimes in their
communities, DOJ and DHS officials recognized the need to expand their
outreach and training efforts to other law enforcement and non-law
enforcement entities to identify victims and increase the number of
investigations and prosecutions. Currently, coordination among agencies
on training and outreach is largely episodic. However, developing
collaborative outreach and training strategies to incorporate state and
local law enforcement, nongovernmental organizations, and foreign
partners, among others, could allow agencies to expand their efforts
while making the best use of agencies' resources.
DOJ officials also told us that they hoped to expand federal
antitrafficking efforts by pursuing multijurisdictional and
international investigations and prosecutions. For example, CRT/CS
officials told us that they were striving to enhance investigations and
prosecutions of significant trafficking in persons and slavery cases,
such as multijurisdictional cases and those involving financial crimes.
To do so, CRT/CS has engaged in training activities for federal
prosecutors across the country to institutionalize ways to combat
trafficking and allow CRT/CS attorneys to focus on multijurisdictional
cases. However, CRT/CS has also been actively involved in the training
of investigators, task forces, and foreign officials, as well as
carrying out their responsibilities to prosecute trafficking cases.
Folding CRT/CS's training and outreach efforts into a broader and more
collaborative training and outreach strategy could disperse
responsibility for training to other federal partners who are also
engaging in training and outreach efforts.
The DOJ officials identified the need to establish mechanisms for
consistent communication and information sharing. While FBI officials
said that case-by-case coordination between some field offices on
individual trafficking cases was good, they said that there was also a
lack of consistency in information sharing and communication among
field offices. DOJ officials also cited the need to maintain
information in a central repository to enhance tracking of the
movements of traffickers and victims. For example, CEOS identified the
lack of such a repository of information on trafficking and an
institutionalized policy on information sharing as factors that can
inhibit trafficking investigations. Working collaboratively with
counterparts in the field and across agencies at the national level to
establish mechanisms for consistent communication and information
sharing could be incorporated into a strategic framework. Additionally,
FBI and ICE officials pointed to the need to pursue information about
trafficking organizations back to their country of origin and identify
trafficking patterns in order to enhance efforts to dismantle
trafficking organizations. However, HSTC officials told us that the
intelligence community is not collecting as much information on
trafficking as it is on other issues, such as human smuggling. HSTC
officials also said that if HSTC could increase its analytical
capability, it would be able to expand its current collection and
dissemination of intelligence information on trafficking to develop
more products and in so doing provide a more valuable resource to law
enforcement and the intelligence community, among others. CRT/CS
officials told us they are working with the FBI to obtain information
that would help identify trafficking networks. With intelligence
information from traditional intelligence sources being limited,
agencies could work toward achieving their goal of tracking trafficking
patterns and dismantling trafficking organizations by establishing
collaborative practices to obtain needed information to support
proactive investigations of trafficking crimes.
Expanded Approaches Can Be Linked to a Common Outcome with Mutually
Reinforcing Strategies:
A strategic framework could promote a collaborative effort to define
and articulate a common federal outcome for investigations and
prosecutions of trafficking crimes. Agencies have identified agency-
level goals and proactive approaches to expand their current efforts to
combat trafficking crimes, but none of these approaches is linked to a
governmentwide outcome defined by the key federal agencies that
investigate and prosecute trafficking crimes. Our previous work on
effective interagency collaboration has demonstrated that having a
clearly defined governmentwide outcome could help align specific goals
across agencies.
While National Security Presidential Directive 22 instructed federal
agencies to develop and promulgate plans to implement the directive,
agencies primarily developed lists of activities that indicated
individual agency efforts, and the plans, taken together, did not cut
across agency boundaries and lead toward a common governmentwide
outcome. As we have illustrated in our work related to national
strategies to combat terrorism, a governmentwide outcome could hinge on
an ideal "end-state" followed by a logical hierarchy of major goals,
subordinate objectives, and specific activities to achieve
results.[Footnote 30] Gathering intelligence on traffickers,
dismantling trafficking rings, increasing prosecutions, and rescuing
victims can be activities linked to broader objectives to achieve a
common outcome for investigations and prosecutions of trafficking
crimes, but at this time, agencies have not collectively articulated
what that outcome might be. The scope of U.S. governmentwide efforts to
investigate and prosecute trafficking crimes can be linked to a common
outcome to provide an accountability framework.
Our prior work has shown that without a clearly defined outcome, it may
be difficult to overcome significant differences in agency missions,
cultures, and established ways of doing business. For example, pursuing
trafficking investigations and prosecutions involves collaboration
between law enforcement and nongovernmental organizations that
typically do not work together. Identifying a unified federal outcome
for investigations and prosecutions of trafficking crimes could help
align the goals and sustain the support of these agencies and
organizations, thereby enhancing investigations and prosecutions.
Our work has shown that after identifying a common outcome,
collaborating agencies need to establish strategies that work in
concert with those of their partners or are joint in nature. Such
strategies help in aligning the partner agencies' activities, core
processes, and resources to accomplish the common outcome. Some
individual agencies have developed their own strategies to combat
trafficking and implement the proactive approaches to expand current
activities, but strategies have not been linked to a common
governmentwide outcome for investigations and prosecutions of
trafficking crimes. Since no single agency is undertaking these
initiatives alone, mutually reinforcing strategies could help agencies
better align their activities and resources to accomplish a common
outcome.
Roles and Responsibilities Can Be Clearly Defined through a Strategic
Framework:
As federal agencies expand their approaches to investigating and
prosecuting trafficking crimes, a strategic framework could assist in
clarifying respective roles and responsibilities. Such a framework
could be important to ensure that agencies understand who will do what
and help to reconcile differing perceptions of leadership that exist
among the agencies on combating trafficking crimes.
Our prior work has shown that generally agencies can enhance their
collaboration by working together to define and agree on their
respective roles and responsibilities, including how the collaborative
effort will be led. Nonetheless, existing interagency collaborative
mechanisms are not positioned to support the greater collaboration
needed to coordinate expanded U.S. efforts to investigate and prosecute
trafficking in persons. The Interagency Task Force to Monitor and
Combat Trafficking, the SPOG, and SPOG working groups facilitate
governmentwide policy on human trafficking. However, operational
coordination on investigations and prosecutions of trafficking in
persons rests with criminal justice personnel and currently occurs on a
case-by-case basis. HSTC is an information clearinghouse and
facilitates information sharing among investigative and prosecutorial
agencies working on trafficking. HSTC is also available to assist
agencies to avoid duplication of efforts by querying an array of
participating agency databases to determine if more than one agency has
an ongoing interest or open investigation on a specific target. The
Trafficking in Persons and Worker Exploitation Task Force was involved
in both policy and operations, but at the time of our review, DOL told
us it understood that the task force was no longer functioning, and
CRT/CS officials said they were in the process of reinvigorating DOJ's
relationship with DOL on this issue.
Furthermore, developing a strategic framework could help reconcile
differing perceptions of who is in charge in coordinating
antitrafficking investigations and prosecutions. Specifically, CRT/CS
and investigative agencies perceived the interagency leadership role in
pursuing trafficking crimes differently. CRT/CS officials told us that
its newly formed Human Trafficking Prosecution Unit was positioned to
take the leadership role in coordinating trafficking efforts across the
federal agencies because investigative agencies historically work with
CRT/CS prosecutors to complete cases. While FBI officials acknowledged
CRT/CS as the leader on trafficking in persons, they also said that
leadership needs to cut across agencies, since no one agency carries
out trafficking cases alone. ICE officials said that agencies are all
equal partners in the effort to combat trafficking and that while CRT/
CS may take the lead on prosecutions, the investigative agencies each
take the lead on their own investigations, or work jointly on joint
investigations, until they are handed to prosecutors. ICE officials
also did not perceive the need for leadership beyond the SPOG for U.S.
policy on trafficking, but acknowledged that the SPOG did not have
oversight for investigations and prosecutions because of law
enforcement sensitive matters. ICE officials suggested that should a
problem with investigations and prosecutions arise, the SPOG could
create a subcommittee to deal with these issues. However, according to
DOJ officials, because investigative and prosecutorial agencies are
governed at the operational level by confidentiality rules (e.g., grand
jury secrecy) and limitations on sharing law enforcement sensitive
information, the SPOG or its working groups were not appropriate
vehicles for leading collaborative operational efforts to investigate
and prosecute trafficking in persons. Since no one agency will be able
to accomplish the steps identified to further U.S. efforts to combat
trafficking on its own, collaboration among agencies will need to go
beyond the current case-by-case coordination and views on leadership.
Establishing Compatible Policies, Procedures, and Other Means to
Operate across Agency Boundaries:
Our prior work has shown that a strategic framework could also foster
efforts to devise compatible standards, policies, procedures, and
information systems that will be used in collaborative efforts for a
range of topics across federal agencies. As agencies move forward in
their efforts to expand current activities to investigate and prosecute
trafficking crimes, such as tracking trafficking cases or addressing
the limitations posed on current coordinating mechanisms, agencies
could work jointly and consult with other stakeholders to determine
what information on trafficking could be collected and shared as
policies and procedures for developing information systems are being
planned and created. Additionally, agencies working together to
establish policies and procedures to provide guidance on how to achieve
maximum coordination and cooperation across agencies to investigate and
prosecute trafficking crimes, including the exchange of information,
would address current inconsistencies that exist among the field
offices of federal investigators.
BJA Has Helped Support Federally Funded State and Local Human
Trafficking Law Enforcement Task Forces, but Lacks a Plan to Identify
and Focus Technical Assistance Needs:
To help coordinate U.S. efforts to identify trafficking victims, get
needed services to victims of trafficking, and investigate and
prosecute trafficking in persons crimes in communities across the
country, BJA established a program to fund state and local law
enforcement human trafficking task forces. Each task force was to
develop a strategy to raise public awareness, identify more victims,
and establish protocols among government agencies and service providers
and to meet related performance measures. Since 2004, BJA has awarded
grants of up to $450,000 for a 3-year period to each of 42 task forces.
BJA reported using its general funds to support some technical
assistance to the task forces (e.g., sponsoring the development of a
train-the-trainer curriculum on human trafficking and funding a
national conference) and taking further steps to help respond to task
force technical assistance needs. However, task force members we
contacted and DOJ officials pointed to continued and additional
technical assistance needs. BJA does not have a technical assistance
plan for its human trafficking grant program. Our previous work has
shown the need for agencies that administer grants or funding to state
and local entities to implement a plan that focuses technical
assistance and training efforts on areas of greatest need. BJA
officials told us that they recognized the need for a technical
assistance plan for its human trafficking initiative and had begun to
prepare a plan to provide additional and proactive technical assistance
to the task forces.
BJA Funds State and Local Law Enforcement Human Trafficking Task Forces
to Support Investigations and Prosecutions of Trafficking Crimes:
In 2004, BJA established a program to fund state and local law
enforcement human trafficking task forces to help support U.S. efforts
to identify trafficking victims and investigate and prosecute
trafficking in persons crimes in communities across the country.
Working with OVC, which was already providing assistance to victim
service providers serving trafficking victims, BJA solicited
applications from state and local law enforcement for fiscal year 2004,
and then again for fiscal years 2005 and 2006. Each task force was to
develop a strategy that included the following: (1) a memorandum of
agreement outlining the respective roles and responsibilities of the
participating agencies and ensuring coordination and involvement of the
local U.S. Attorney; (2) training materials for first responding
officers and investigators, including written protocols and resource
manuals to enhance coordination and information/resource sharing among
law enforcement and victim service providers to identify and assist
human trafficking victims; (3) distinct protocols for resource referral
and service provisions for U.S. versus alien victims of human
trafficking; and (4) definition of the role of law enforcement and
service provider partners in training others in the community. The task
forces were to meet specific program goals and performance measures
focused on identification of and assistance to victims, training of law
enforcement in the identification of victims, public awareness and
outreach, and identification and collaboration with community
stakeholders. Grantees were required to collect and report data on
performance measures, including the number of potential and assisted
trafficking victims; DHS applications made to obtain trafficking
victims' benefits; law enforcement personnel and others trained;
presentations given to law enforcement and the general public; service
providers, community support groups, and community education groups
identified; and memorandums of agreement signed.
Under its human trafficking task force initiative, BJA has funded a
total of 42 law enforcement task forces on human trafficking--22 in
fiscal year 2004 and 10 in each of fiscal years 2005 and 2006.[Footnote
31] Each task force grant award was for up to $450,000 for a period of
3 years. BJA reported awarding a total of $17,324,182 to the 42 task
forces. The core membership of each task force includes federal, state,
and local law enforcement; the U.S. Attorney's Office; and
nongovernmental organizations. However, the task forces vary, as
evidenced by those we contacted, with respect to which federal agencies
participate--FBI, ICE, DOL, or others; the number of state or local law
enforcement agencies involved--a single or multiple police departments
and sheriff's offices; and the number of nongovernmental groups. As
shown in figure 3, the 42 task forces are located in 25 states, two
territories, and the District of Columbia.[Footnote 32]
Figure 2: BJA-Funded Human Trafficking Law Enforcement Task Forces:
[See PDF for image]
Source: GAO analysis of agency documents.
[End of figure]
BJA Has Provided Some Technical Assistance to the Task Forces:
To support its grant programs, BJA can provide technical assistance to
any justice-related state, tribal, or local agency or organization
through on-site and off-site technical assistance; peer-to-peer
information exchange and mentoring; publication drafting and
dissemination; information sharing; aid with developing conferences,
workshops, and training events; and curriculum development. According
to BJA officials, technical assistance is available to human
trafficking task forces, but BJA did not receive any specific funds to
support its technical assistance to the human trafficking law
enforcement task forces.[Footnote 33] BJA reported using $1,433,000 of
its general funds to finance the development of a train-the-trainer
curriculum on human trafficking, deliver training sessions using the
curriculum, and fund the national conference on human trafficking held
in New Orleans in October 2006.[Footnote 34]
The train-the-trainer curriculum, prepared by the Institute for
Intergovernmental Research to promote law enforcement awareness of
human trafficking in the United States, was completed in October 2004.
The curriculum included CD-ROMs with PowerPoint slides, instructor
notes, and lists of additional resources. It addressed the following
topics: introduction to human trafficking; legal overview;
investigative considerations, including investigative techniques for
trafficking cases; the roles of victim service providers in trafficking
cases; immigration issues; interagency cooperation; and engaging the
community. The curriculum was used to train trainers, including task
force members, at BJA-sponsored train-the-trainer sessions held in
California, Florida, and Illinois between November and April 2005, and
a Human Trafficking Conference in Houston, Texas, in February 2005.
According to BJA, some task force members attended the sessions and all
22 task forces funded at that time were represented at the Houston
conference. The trainers were to use the curriculum to train law
enforcement in their respective communities.
BJA worked with other DOJ components, DHS, and DOL, among others, to
put on the national trafficking conference in New Orleans. The plenary
and breakout sessions provided information on various aspects to
trafficking--investigative strategies, victims services, and
interviewing witnesses, among others. According to DOJ officials,
sessions were specifically held for the task forces in addition to the
public conference program. During these sessions, task force
participants discussed such issues as collaboration and reporting
progress using BJA's performance measures.
In addition, BJA reported further steps taken to respond to the
technical assistance needs of the task forces. According to BJA
officials, task force grantees could request technical assistance by
submitting the form found on the BJA Web site. BJA also reported if the
data submitted by a task force in its semiannual report indicated the
existence of performance problems, BJA would make routine calls to the
particular task force to help resolve the issues or obtain additional
information so that BJA could work with CRT/CS, OVC, or the appropriate
U.S. Attorney's Office on these matters. Also, having recognized that
some task forces were experiencing difficulties in collecting and
reporting data on its performance measures (e.g., identifying the
number of trafficking victims), BJA sponsored a special session on this
topic during the New Orleans conference. According to BJA officials,
after the conference it distributed to the task forces the materials
used during the session. Furthermore, between 2006 and 2007, BJA,
sometimes working in conjunction with OVC, conducted site visits to 8
of the 42 task forces. The site visits provided the opportunity for BJA
to identify challenges task forces were having, such as developing or
implementing training for law enforcement, that might be addressed
through training or technical assistance. In addition, CRT/CS reported
that, in coordination with BJA, its attorneys had provided technical
assistance and training to all but 8 of the task forces.
Continuing and Additional Task Force Technical Assistance Needs Were
Identified:
DOJ officials and task force members we interviewed identified
continuing and additional task force technical assistance and training
needs. BJA said that it was aware of this need from weekly phone
conversations with task force members; site visits to task force
jurisdictions; and conversations with U.S. Attorneys, CRT/CS, and OVC.
Continuing and additional technical assistance needs identified by DOJ
officials and task forces we contacted included (1) substantive
training about trafficking crimes and trafficking victims and (2)
technical assistance and training to help task forces develop the
components in their strategies required under their grants.
DOJ officials and members of task forces we contacted suggested a range
of training on substantive topics related to human trafficking. They
acknowledged that there would always be a need for basic training on
trafficking issues, as new task forces were formed, existing task
forces reached out to new participants, and individuals participating
in the task forces changed over time. In addition, to enhance the
capacity of the task forces to support investigations and prosecutions
of trafficking crimes, they identified the need for advanced training
on such topics as seizing and forfeiting traffickers' assets,
techniques to facilitate law enforcement and nongovernmental
organizations working together to interview trafficking victims, and
techniques for interviewing child victims of sex trafficking. To expand
their ability to identify more trafficking victims, DOJ officials and
some task forces we contacted pointed to the need for training of other
agency personnel, such as other law enforcement, hospital workers, and
social services personnel, who in the course of their jobs might come
into contact with trafficking victims. They also indicated that it was
sometimes necessary to tailor training and technical assistance to
specific populations. For example, training could be focused on
potentially vulnerable populations within the community where a task
force was located (e.g., farm labor, restaurant workers, domestic
service workers, alien victims, and U.S. children trafficked for
commercial sex) or trafficking populations that have typically been
more difficult to find, specifically victims of labor trafficking.
By requiring each task force grantee to lay out a strategy to raise
public awareness of trafficking, identify more victims, and establish
protocols among government agencies and service providers, BJA
demonstrated its awareness of the need for the task forces to have a
mechanism to coordinate activities and operations in order to achieve
program goals. Task force members we interviewed provided examples of
the challenges they had confronted in addressing the various elements
of their task force strategy. For example, some task force members said
that after 2 years of BJA funding they were still trying to iron out
protocols covering roles and responsibilities; experiencing tensions
among key players on the task force, including nongovernmental
organizations; or relying on informal contacts based on who knew whom
or pre-established relationships among task force members (e.g., local
law enforcement and FBI) rather than on positions or protocols. Members
from one task force we interviewed even held different opinions
regarding its protocols. The task force leader attributed the task
force's success to its informal protocols. By contrast, another task
force member told us that the protocols, which had not been developed
in consultation with task force members, were merely guidelines and led
to victims falling through the cracks because of the lack of standard
services. Examples of types of possible technical assistance needs
suggested by the task forces we contacted included (1) ways to improve
communication and sharing information/intelligence between and among
entities, including e-mail lists, a secure Web site, and training
bulletins; (2) standardized protocols that outline roles and
responsibilities of each member agency, which the task forces can adapt
for their own jurisdictions; (3) help in strategizing; (4) regional and
national meetings that bring smaller groups of task forces together;
(5) interpreters/cultural assistance; and (6) safe and secure housing
for victims.
Technical Assistance Plan Could Enhance BJA's Support to Human
Trafficking Task Forces:
BJA does not have a technical assistance plan for its human trafficking
grant program. Our previous work on federal agencies' administration of
grants or funding to state and local entities has shown the need for
agencies that administer grants or funding to state and local entities
to implement a plan that focuses technical assistance efforts on areas
of greatest need.[Footnote 35] BJA told us that it was developing a
plan to provide additional and proactive technical assistance to the
task forces. It said the plan would address developing BJA's capability
to provide technical assistance as needed, identifying model task force
leaders who could provide some technical assistance to other task
forces, and establishing a means to ensure communication among the task
forces. Officials said that they were working with OVC to develop an
approach that would meet the needs of BJA and OVC human trafficking
grantees. However, BJA reported that the development and review of the
plan had been delayed pending final decisions on DOJ's funding for
fiscal year 2007.
As part of its plan, BJA might address outreach needs to ensure that
task forces are aware of BJA's capacity to provide or facilitate the
obtaining of technical assistance and training. DOJ and DHS officials
emphasized the importance of the task forces to the overall U.S. effort
to investigate and prosecute trafficking in persons. Working within
communities, task force members are usually best situated to identify
trafficking victims and crimes. Representatives of some of the task
forces we contacted were not aware of BJA's capacity to respond to
technical assistance needs. Accordingly, identifying steps needed to
disseminate information on the types of assistance and training
available is a necessary component of a technical assistance plan for
these task forces.
Also, BJA might incorporate into its plan a systematic assessment of
its performance measures for the task forces. BJA reported that it
collated and analyzed the performance data it received, would make
routine calls to the particular task force to help resolve the
performance issues, or obtain additional information to assist a task
force in addressing a problem. However, systematically assessing task
force reports on BJA performance measures could help BJA to identify
common problem areas in collecting and reporting performance data. It
could also provide BJA with the means to determine which measures might
need to be modified or how BJA might enhance its measures to enable it
to assess the impact of task force efforts. Such an approach should
help BJA to facilitate the task forces' meeting the program's overall
goals and objectives of identifying victims and supporting
investigations and prosecutions.
In addition, through its technical assistance plan, BJA might identify
steps to obtain information from the task forces on areas for
continuous improvement. This information could be used to determine
common and emerging technical assistance or training needs, approaches
for meeting those needs, and how best to provide that assistance. As
part of its plan, BJA could also develop other means and mechanisms for
providing technical assistance to the task forces effectively and
efficiently. For example, as suggested by some of the task force
members we contacted, a secure Web site could provide a means for task
forces to share best practices, readily obtain samples of protocols or
other documents, or ask for peer-to-peer assistance from other task
forces. BJA could also use the Web site to disseminate information to
the task forces.
BJA's plan might also include a component for assessing the quality of
its technical assistance. To ensure that the technical assistance and
training provided to the task forces meet their needs, BJA might
request information from the task forces on technical assistance and
training provided to them, including evaluations of that assistance.
Such information could help BJA demonstrate what it has done to support
the task forces and the effectiveness of those efforts in meeting task
force needs. This information could also be used to ascertain necessary
modifications of or changes to technical assistance to better meet task
force needs.
To facilitate BJA's technical assistance to the task forces, the plan
might identify available technical assistance and training resources
from a variety of sources. BJA could then match a particular task
force's needs with technical assistance and training that might be
provided by other federal agencies, such as CRT/CS, or other task
forces. While such training and technical assistance are currently
provided on a case-by-case basis, within the context of a plan, BJA
could more systematically galvanize these resources, incorporate them
into its overall approach to meeting the task forces' needs, and assess
their impact on task force efforts. Information on task force training
needs could also be used to help BJA, working with other federal
agencies, to plan the content and format of the legislatively mandated
2007 and 2008 national trafficking conferences so that it meets the
range of training and technical assistance needs for experienced task
forces as well as new task forces.
Conclusions:
Federal agencies have made strides in several areas to combat
trafficking crimes and to coordinate their efforts on a case-by-case
basis. This approach has generally led to an increase in the number of
investigations and prosecutions since the passage of the TVPA in 2000.
However, as agencies look ahead to broadening their efforts while still
maintaining coordination on individual cases, strategic planning will
be necessary to ensure agency resources are being expended with the
greatest return on investment. Defining a common governmentwide outcome
for investigations and prosecutions of trafficking crimes, reconciling
roles and responsibilities, and ensuring consistent communication and
information sharing are vital to the investigation and prosecution of
trafficking crimes. Yet no such outcome has been collaboratively
defined by the agencies, perceptions of leadership differ among
agencies, and policies are not in place to ensure consistent
communication and information sharing. Furthermore, to sustain a
coordinated victim-centered approach to combating trafficking, agencies
must continue to educate and engage their own personnel, as well as
supporting partners in the effort to combat this crime, such as state
and local law enforcement, nongovernmental organizations, non-law
enforcement agencies, and citizens. As our prior work on multi-agency
collaboration has shown, a strategic framework that includes elements
such as defining a common outcome, establishing mutually reinforcing or
joint strategies, and agreeing on roles and responsibilities, among
others, is particularly useful in addressing problems that are national
in scope and involve multiple agencies with varying jurisdictions. Such
an approach allows for the necessary flexibility and incorporation of
different types of collaborative mechanisms to address the complexities
of and unique challenges posed by such problems. Working in a more
strategic fashion, agencies could build on their current cooperative
relationships to establish a strategic focal point, ensure consistency
of communication and partnerships, and sustain and expand a coordinated
effort to investigate and prosecute trafficking in persons crimes.
BJA's competitive grant program has funded state and local law
enforcement human trafficking task forces to support U.S. efforts to
identify trafficking victims and investigate and prosecute trafficking
crimes. Given its mission to support state and local law enforcement,
BJA has provided some training and technical assistance to the human
trafficking task forces, sometimes through coordinated efforts with
other agencies. However, the task forces we interviewed identified
challenges they faced in implementing BJA's strategic planning
requirements and carrying out their responsibilities, especially in
identifying potential victims and establishing partnerships with key
players. Our previous work on federal agencies' administration of
grants or funding to state and local entities shows the importance of
implementing a technical assistance plan that focuses the training and
technical assistance efforts by agencies that administer grant funding.
In the absence of such a plan, BJA may find it difficult to target
technical assistance to the task forces most in need and ensure that
task forces receive the technical assistance needed to meet the
strategic planning requirements and performance measures outlined in
the human trafficking task force grant solicitation. Implementing such
a plan will help BJA focus its efforts, enabling BJA to better ensure
that its efforts meet the needs of the task forces, achieve the
objectives of the program, enhance collaboration across levels of
government and between government and nongovernmental entities, and
ultimately support U.S. efforts to investigate and prosecute
trafficking in persons.
Recommendations for Executive Action:
To help ensure that the U.S. government maximizes its ability to
enforce laws governing trafficking in persons, we recommend that the
Attorney General and the Secretary of Homeland Security, in conjunction
with the Secretaries of Labor, State, and other agency heads deemed
appropriate, develop and implement a strategic framework to coordinate
U.S. efforts to investigate and prosecute trafficking in persons. At a
minimum this framework should:
a. define and articulate a common outcome;
b. establish mutually reinforcing or joint strategies;
c. agree on roles and responsibilities; and:
d. establish compatible policies, procedures, and other means to
operate across agency boundaries.
To better support the federally funded state and local human
trafficking task forces, we recommend that the Attorney General direct
the Director of the Bureau of Justice Assistance to develop and
implement a plan to help focus technical assistance on areas of
greatest need.
Agency Comments and Our Evaluation:
We requested comments on a draft of this report from the Attorney
General, the Secretary of Homeland Security, the Secretary of State,
and the Secretary of Labor. DOJ and DHS provided written comments,
which are summarized below and included in their entirety in appendixes
V and VI, respectively. In addition, these agencies and DOS and DOL
provided technical comments, which we incorporated as appropriate.
DOJ agreed with the contents of the report. Regarding our
recommendation to the Attorney General and the Secretary of Homeland
Security to develop a strategic framework to coordinate U.S. efforts to
investigate and prosecute trafficking crimes, DOJ acknowledged that
continued and increased collaboration could further efforts to
investigate and prosecute trafficking in persons crimes. DOJ further
noted that it is already pursuing a variety of such methods, including
establishing the Human Trafficking Prosecution Unit and holding
collaborative meetings and training sessions with its partners. As a
result, DOJ proposed that the report identify the need for continued
collaboration but not mandate one particular collaborative model.
It was not our intent to prescribe a particular structure or
collaborative model. We recognize that because of the unique challenges
posed by trafficking in persons investigations and prosecutions, the
proposed framework needs to be flexible. Our previous work has shown
that the four elements outlined in our recommendation--a common
outcome; mutually reinforcing or joint strategies; agreed-on roles and
responsibilities; and compatible polices, procedures, and other means
to operate across agency boundaries--are key to an effective strategic
framework. However, the specifics of each of these elements, additional
elements to be included in a strategic framework for the investigation
and prosecution of trafficking crimes, and the structures for
developing and implementing this framework would be determined by the
agencies involved. In response to DOJ's comments, we have included
language in our report that reinforces the need for flexibility in
developing and implementing a strategic framework for investigations
and prosecutions of trafficking in persons.
Commenting on our recommendation that the Attorney General call on the
Director of BJA to develop and implement a plan to help focus technical
assistance to the human trafficking task forces, DOJ stated that to
address the areas of task force technical assistance needs raised in
our report, BJA and OVC planned to collaboratively develop and lead a
facilitated working group, including representatives from these
agencies, ICE, HSTC, DOL, and other DOJ components, by October 1, 2007.
The working group is to provide input into BJA's collaborative outreach
and improve training and technical assistance strategies to address
issues raised in the report. DOJ enumerated the elements that its
training and technical assistance plan was expected to include, such as
a strategy for informing task force members, on a continuous basis, of
the availability of training and technical assistance resources; a
systematic assessment of performance measures; and methods to assess
the quality of training and technical assistance.
DHS generally agreed with the contents of the report. Specifically, DHS
said that the report reflected an overall understanding of the
complexities of the antitrafficking response; ICE's efforts in leading
investigations, conducting outreach, and responding to trafficking
victims; and properly characterized ICE's compliance with National
Security Presidential Directive 22. In response to the report's
discussion of interagency coordination and strategizing, DHS noted that
ICE regularly conducted strategic planning with its partners,
particularly in the field; worked with federally funded state and local
trafficking task forces; and contributed to annual trafficking reports
prepared by DOJ. Moreover, DHS maintained that interagency coordination
through the SPOG ensured that trafficking policies and guidelines were
carried out, and therefore ICE believed that a governmentwide framework
or strategy was not needed.
Our report acknowledged that the SPOG and its working groups help to
facilitate coordination of governmentwide policy on human trafficking.
However, the focus of our work was U.S. efforts to investigate and
prosecute trafficking in persons crimes, the coordination of which
rests with criminal justice personnel, primarily DHS and DOJ. Given DOJ
and DHS senior officials' acknowledgment of the need to expand the
scope of U.S. efforts to investigate and prosecute trafficking in
persons and our finding that existing mechanisms and individual agency
plans did not address the interagency collaboration needed to support
this expanded level of effort, we recommended the development of a
strategic framework for coordinating U.S. efforts to investigate and
prosecute trafficking cases.
Commenting on this recommendation, DHS said that ICE would support such
a framework if certain considerations were taken into account. For
example, DHS noted that mutual goal setting might be possible so long
as the goals contained objectives that specifically addressed unique
agency capabilities in combating trafficking. DHS also noted that any
framework would also need to recognize that agencies' roles in a
particular case would vary by available resources, local priorities,
and the nature of the case and investigation. Agency resources for
policy efforts and initiating any recommendations that arose from the
framework would also be critical. GAO would expect that in developing
and implementing such a framework for investigations and prosecutions
of trafficking crimes, the agencies involved would determine how to
address varying authorities, respective resources, and other relevant
factors.
We will send copies of this report to the Attorney General, the
Secretary of Homeland Security, the Secretary of State, and the
Secretary of Labor, and interested congressional committees. We will
also make copies available to others upon request. In addition, the
report will be available at no charge on GAO's Web Site at
http://www.gao.gov.
If you or your staff have any questions concerning this report, please
contact me on (202) 512-2757 or goldenkoffr@gao.gov. Contact points for
our Offices of Congressional Relations and Public Affairs may be found
on the last page of this report. Major contributors to this report are
listed in appendix VII.
Signed by:
Robert N. Goldenkoff:
Acting Director, Homeland Security and Justice:
[End of section]
Appendix I: Objectives, Scope, and Methodology:
To ascertain the status of U.S. efforts to investigate and prosecute
trafficking crimes, this report discusses (1) key activities federal
agencies have undertaken to combat trafficking in persons crimes, (2)
federal efforts to coordinate on investigations and prosecutions of
trafficking in persons crimes and whether these efforts might be
enhanced, and (3) how the Bureau of Justice Assistance (BJA) supported
federally funded state and local human trafficking task forces and
whether these efforts might be improved. This review is part of a
larger body of work that you requested on U.S. efforts to combat
trafficking in persons, here and abroad.[Footnote 36]
To determine key activities federal agencies have undertaken to combat
trafficking in persons crimes, we reviewed pertinent documents and
interviewed officials from the Department of Justice (DOJ), including
the Federal Bureau of Investigation (FBI), Civil Rights Division/
Criminal Section (CRT/CS), Criminal Division/Child Exploitation and
Obscenity Section (CEOS), and the Executive Office for U.S. Attorneys;
the Department of Homeland Security's (DHS) U.S. Immigration and
Customs Enforcement (ICE) and U.S. Citizenship and Immigration
Services; the Department of Labor's (DOL) Wage and Hour Division; the
Department of State's (DOS) Bureau of Diplomatic Security and Office to
Monitor and Combat Trafficking in Persons; and the Human Smuggling and
Trafficking Center (HSTC). We obtained and analyzed written responses
to questions we provided, departmentwide strategic planning documents,
agency plans, strategies, and memorandums and guidance on efforts to
combat human trafficking. We obtained examples of training materials
used to train investigative agents and to conduct outreach and attended
the national human trafficking conference in New Orleans in October
2006. From the FBI, ICE, CRT/CS, and CEOS, we obtained and analyzed
relevant data on the cases investigated and prosecuted, including
numbers of cases, defendants charged, and convictions, as well as,
where possible, estimates of the resources used to do so. We discussed
the sources of these data with federal agency officials to determine
that these data were sufficiently reliable to show trends in agencies'
activities undertaken to investigate and prosecute trafficking crimes.
We did not seek data prior to the passage of the Trafficking Victims
Protection Act in 2000 for investigative agencies since the
establishment of the Department of Homeland Security transferred some
human trafficking investigative duties from DOJ's legacy Immigration
and Naturalization Service to DHS's Immigration and Customs
Enforcement.
To determine what efforts federal agencies have undertaken to
coordinate investigations and prosecutions of trafficking in persons
crimes and whether these efforts might be enhanced, we reviewed
pertinent documents, such as agency reports, strategies, and
memorandums to field offices. We interviewed officials from DOJ
headquarters, including FBI, CRT/CS, CEOS, and the Executive Office for
U.S. Attorneys; DHS's ICE and U.S. Citizenship and Immigration
Services; DOL's Wage and Hour Division; DOS's Bureau of Diplomatic
Security and Office to Monitor and Combat Trafficking in Persons; and
the HSTC. We gathered and analyzed information from selected field
personnel representing the FBI, ICE, and local U.S. Attorney's Offices.
To ascertain how efforts to combat trafficking might be enhanced and
identify applicable criteria to be used in our analysis, we consulted
our prior work on agency collaboration, international crime, terrorism,
organized crime, and the illegal importation of prescription and
illegal drugs.[Footnote 37] We also interviewed agency officials to
identify challenges they face in the investigating and prosecuting of
trafficking crimes and to identify what elements may enhance their
efforts.
To assess how BJA has supported federally funded state and local human
trafficking task forces and whether these efforts might be enhanced, we
obtained and analyzed relevant documents from BJA, including task force
grant proposals, grant reports written by program managers, performance
measurement data, and information from its Web site.[Footnote 38] We
interviewed BJA, Office for Victims of Crime (OVC), and CRT/CS
officials on the origin of the task forces, when task forces were
funded, and the types of assistance provided to the task forces. We
also interviewed field personnel from the FBI, ICE, and DOL to
determine what federal supports had been given to the task forces we
selected for either site visits or telephone interviews. We developed
case studies of seven task forces to provide us with in-depth knowledge
about how the task forces are functioning, how they are working
together, and what supports and technical assistance they have been
provided. Gathering information for the case studies included site
visits to task forces in Collier County, Florida; Los Angeles,
California; and Washington, D.C; and telephone interviews with key
participants from task forces in Houston, Texas; Hawaii; and Nassau and
Suffolk Counties in New York.
In selecting the 7 task forces we contacted, we limited our selection
to the longest-running task forces (i.e., the 22 founded in fiscal year
2004)--those that had had an opportunity to be established. From this
group, we tried to include task forces located in various U.S.
geographic regions, and with a primary focus on either sex trafficking,
labor trafficking, or both sex and labor. To ensure that we included
task forces of varying performance levels, we asked officials from BJA
and CRT/CS for recommendations on task forces that were performing
well. In addition to these recommendations, we also used BJA
performance measures such as number of victims found and the number of
continued presence visas provided to make our selections. As a part of
our site visits or through telephone interviews, we interviewed the
task force leader, the Assistant U.S. Attorney (who may or may not the
leader), the primary local law enforcement contact, the dominant
nongovernmental organization participant, and FBI and ICE
representatives on the task force. BJA was not able to provide us with
a list of task force participants, but a nongovernmental organization,
Polaris Project, affiliated with the Washington, D.C., human
trafficking task force, had networked with all the BJA-funded task
forces at the federally sponsored human trafficking conference in New
Orleans in October 2006, and provided us with a list identifying the
"key players." From this list, we developed our list of interviewees
based on our inclusion criteria. The FBI and ICE participant names were
provided to us through the liaisons in each agency. Overall, through
site visits and telephone interviews we interviewed a total of 50 task
force members. We interviewed 13 Assistant U.S. Attorneys, 7 local law
enforcement, 6 FBI participants, 5 ICE agents, 1 DOL participant, 13
nongovernmental organization participants, and 3 task force leaders
from an Attorney General's office. In addition, we interviewed a U.S.
Attorney, who had recently set up a human trafficking task force, to
obtain his perspective on challenges faced in putting a task force into
operation. This approach does not allow for generalizing. In addition,
we reviewed relevant GAO reports on federal agencies' administration of
grants or funding to state and local entities.[Footnote 39]
We conducted our work from June 2006 through June 2007 in accordance
with generally accepted government auditing standards.
[End of section]
Appendix II: Statutory Provisions Used to Investigate and Prosecute
Trafficking Crimes:
During the 1990s, the United States began to take steps to address
trafficking in persons at home and abroad. DOJ prosecuted trafficking
cases under several federal criminal statutes, including the
involuntary servitude statutes,[Footnote 40] the Mann Act,[Footnote 41]
and labor laws on workplace conditions and compensation.[Footnote 42]
However, various U.S. policymakers determined that existing U.S.
statutes did not take into account some characteristics of contemporary
trafficking in persons and, therefore, did not adequately protect
trafficking victims, deter trafficking, and bring traffickers to
justice. These statutes did not always treat trafficked persons as
victims. Involuntary servitude was restricted to cases of physical
abuse--force, threats of force, or threats of legal coercion, as
opposed to the psychological coercion often used by today's
traffickers.[Footnote 43] While the modern concept of trafficking in
persons focused on compelled service, under the Mann Act trafficking
was perceived as interstate transportation for prostitution. Moreover,
these statutes scattered enforcement authority across the government
and resulted in different case outcomes, depending on the charges
brought or which agency learned of the allegations of abuse.
The TVPA addressed limitations in existing law that made it difficult
to prosecute traffickers, as well as adding new crimes and enhancing
the penalties. Federal agencies continue to rely on a number of
statutes to prosecute traffickers and halt their operations. Table 1
lays out the primary statutes that support the investigation and
prosecution of trafficking in persons crimes.
Table 1: Primary Statutory Provisions Used for Trafficking in Persons
Prosecutions:
U.S. Code: 18 U.S.C. § 241;
Provision: Conspiracy against rights.
U.S. Code: 18 U.S.C. § 371;
Provision: Conspiracy to commit federal offenses.
U.S. Code: 18 U.S.C. § 1581;
Provision: Peonage.
U.S. Code: 18 U.S.C. § 1584;
Provision: Involuntary servitude.
U.S. Code: 18 U.S.C. § 1589;
Provision: Forced labor.
U.S. Code: 18 U.S.C. § 1590;
Provision: Trafficking with respect to peonage, slavery, involuntary
servitude, or forced labor.
U.S. Code: 18 U.S.C. § 1591;
Provision: Sex trafficking of a minor or by fraud, force, or coercion.
U.S. Code: 18 U.S.C. § 1592;
Provision: Holding or confiscation of passport or immigration
documents.
U.S. Code: 18 U.S.C. § 1593;
Provision: Mandatory restitution.
U.S. Code: 18 U.S.C. § 1594(a);
Provision: Attempt to commit peonage, slavery, involuntary servitude,
forced labor, trafficking, or sex trafficking.
U.S. Code: 18 U.S.C. § 1594(b);
Provision: Asset forfeiture.
U.S. Code: 18 U.S.C. §§ 2421-2424;
Provision: Mann Act (transportation for illegal sexual activity and
related crimes).
U.S. Code: 8 U.S.C. § 1324;
Provision: Bringing in and harboring certain aliens.
U.S. Code: 8 U.S.C. § 1328;
Provision: Importation of an alien for immoral purposes.
Source: GAO analysis.
[End of table]
Traffickers may also be charged with other offenses. Examples of these
statutes are shown in table 2.
Table 2: Other Related Statutory Provisions Used in Trafficking in
Persons Prosecutions:
U.S. Code: 18 U.S.C. § 1546;
Provision: Arranging a false visa for the victim.
U.S. Code: 18 U.S.C. § 1622;
Provision: Witness tampering.
U.S. Code: 18 U.S.C. § 875;
Provision: Interstate transmission of threats.
U.S. Code: 18 U.S.C. § 1001;
Provision: False statements in any matter within the jurisdiction of
the executive, legislative, or judicial branch of the U.S. government.
U.S. Code: 18 U.S.C. § 982;
Provision: Asset forfeiture.
U.S. Code: 18 U.S.C. § 2;
Provision: Aiding and abetting a federal offense (e.g., employment of
unauthorized aliens).
U.S. Code: 31 U.S.C. § 5332;
Provision: Bulk cash smuggling.
U.S. Code: 18 U.S.C. § 1956;
Provision: Money laundering.
Source: GAO analysis.
[End of table]
[End of section]
Appendix III: Federal Efforts to Investigate and Prosecute Trafficking
in Persons and Data on Resources:
This appendix provides additional data on federal agencies' efforts to
investigate and prosecute trafficking in persons crimes. It also
presents available information on federal agency resources used to
support these efforts.
Federal Agencies Report Prosecutions and Investigations of Trafficking
in Persons since fiscal year 2001:
The FBI, ICE, and CRT/CS reported data on the investigations,
prosecutions, indictments, and arrests related to trafficking crimes
since the passing of the TVPA. These data are a general indicator of
the level of agency effort on trafficking in persons, although they are
limited by a number of factors. Because trafficking in persons is a
hidden crime and victims are hesitant to come forward, it is difficult
to estimate the extent of trafficking in persons crimes. Moreover,
because prosecutors may charge traffickers with other crimes (e.g.,
kidnapping, the Mann Act, immigration violations, or money laundering)
for strategic or tactical reasons, data on the number of trafficking in
persons investigations and prosecutions do not provide a complete
picture of the number of traffickers who have been thwarted. The data
systems agencies use are primarily case management systems, which may
not be able to extract trafficking data if trafficking was not listed
as a charge. Additionally, if an investigation on smuggling later
reveals a trafficking violation, some data systems will continue to
store investigative data under the smuggling classification.
The complexity of the investigations and the limitations of data
systems make providing data on human trafficking a labor-intensive
effort for agencies. Therefore, these data are not comparable across
the agencies and it is not possible to associate arrest and indictment
data with a particular case because of differences in agency data
systems. Moreover, agency officials noted that investigations do not
always lead to prosecutions, because situations that appear to be
trafficking may prove to be alien smuggling or prostitution accompanied
by abuse and, therefore, do not meet the criteria to be prosecuted as
trafficking cases. In addition, ICE officials said that in situations
involving children, the agency's priority was to rescue the victim
whether or not the investigation led to the prosecution of the
trafficker.
Since fiscal year 2001, CRT/CS has reported an overall increase in the
number of prosecutions for cases involving sex and labor trafficking,
as defined by CRT/CS, based on the facts of the case. Table 3 shows the
increase in number of prosecutions after the implementation of the TVPA
in 2001, compared to those in the years leading up to the law's
passage. CRT/CS officials noted that the number of defendants in each
case varied, as well as the number of victims, and the complexity of
the case (app. IV provides summaries of several cases to illustrate
this variation.)[Footnote 44]
Table 3: Trafficking in Persons Prosecutorial Statistics for Civil
Rights Division/Criminal Section and U.S. Attorneys' Offices, Fiscal
Year 1995 through June 14, 2007:
Cases prosecuted[B].
Sex trafficking;
Fiscal year: 1995-2000: 7;
Fiscal year: 2001: 4;
Fiscal year: 2002: 7;
Fiscal year: 2003: 8;
Fiscal year: 2004: 23;
Fiscal year: 2005: 26;
Fiscal year: 2006: 22;
Fiscal year: 2007[A]: 10.
Labor trafficking;
Fiscal year: 1995-2000: 12;
Fiscal year: 2001: 6;
Fiscal year: 2002: 3;
Fiscal year: 2003: 3;
Fiscal year: 2004: 3;
Fiscal year: 2005: 9;
Fiscal year: 2006: 10;
Fiscal year: 2007[A]: 5.
Defendants charged[C].
Sex trafficking;
Fiscal year: 1995-2000: 34;
Fiscal year: 2001: 26;
Fiscal year: 2002: 27;
Fiscal year: 2003: 21;
Fiscal year: 2004: 40;
Fiscal year: 2005: 75;
Fiscal year: 2006: 85;
Fiscal year: 2007[A]: 35.
Labor trafficking;
Fiscal year: 1995-2000: 55;
Fiscal year: 2001: 12;
Fiscal year: 2002: 14;
Fiscal year: 2003: 7;
Fiscal year: 2004: 7;
Fiscal year: 2005: 21;
Fiscal year: 2006: 26;
Fiscal year: 2007[A]: 15.
Defendants convicted[C,D].
Sex trafficking;
Fiscal year: 1995-2000: 20;
Fiscal year: 2001: 15;
Fiscal year: 2002: 23;
Fiscal year: 2003: 16;
Fiscal year: 2004: 30;
Fiscal year: 2005: 25;
Fiscal year: 2006: 60;
Fiscal year: 2007[A]: 59.
Labor trafficking;
Fiscal year: 1995-2000: 47;
Fiscal year: 2001: 8;
Fiscal year: 2002: 5;
Fiscal year: 2003: 5;
Fiscal year: 2004: 3;
Fiscal year: 2005: 10;
Fiscal year: 2006: 38;
Fiscal year: 2007[A]: 5.
Source: GAO analysis of Civil Rights Division/Criminal Section data.
[A] Data as of June 14, 2007.
[B] CRT/CS classified cases as sex or labor trafficking according to
the facts of the case; the categories are mutually exclusive.
[C] Data on defendants charged and convicted are not associated with
the data for cases opened in the same fiscal year.
[D] Comparisons cannot be made between persons charged and convictions,
since actions on some defendants may still be pending.
[End of table]
The data since fiscal year 2001 related to investigations of
trafficking in persons provided by the FBI and ICE is shown in tables 4
and 5, and also shows a general increase.[Footnote 45] As with the
prosecutions of human trafficking cases, variation in numbers from year
to year may be due to the complexity of a case. For example, factors
such as a case with many victims, multiple defendants, a long period of
victimization, and multiple jurisdictions from which to collect
evidence may affect how many cases are able to be investigated from
year to year.
Table 4: Trafficking in Persons Cases Investigated by the FBI's Civil
Rights Unit, Fiscal Year 2001 through April 5, 2007:
Cases opened;
Fiscal year: 2001: 54;
Fiscal year: 2002: 58;
Fiscal year: 2003: 65;
Fiscal year: 2004: 86;
Fiscal year: 2005: 146;
Fiscal year: 2006: 126;
Fiscal year: 2007[A]: 216.
Indictments/information;
Fiscal year: 2001: 29;
Fiscal year: 2002: 26;
Fiscal year: 2003: 40;
Fiscal year: 2004: 32;
Fiscal year: 2005: 45;
Fiscal year: 2006: 97;
Fiscal year: 2007[A]: 39.
Arrests;
Fiscal year: 2001: 67;
Fiscal year: 2002: 65;
Fiscal year: 2003: 32;
Fiscal year: 2004: 16;
Fiscal year: 2005: 51;
Fiscal year: 2006: 142;
Fiscal year: 2007[A]: 79.
Convictions;
Fiscal year: 2001: 15;
Fiscal year: 2002: 15;
Fiscal year: 2003: 18;
Fiscal year: 2004: 22;
Fiscal year: 2005: 14;
Fiscal year: 2006: 70;
Fiscal year: 2007[A]: 31.
Source: FBI Civil Rights Unit.
Note: These cases may include joint investigations with ICE. The number
of cases includes both sex and labor trafficking.
[A] Data as of April 5, 2007.
[End of table]
Table 5: Trafficking in Persons Cases Investigated by Immigration and
Customs Enforcement, Fiscal Year 2005 through May 31, 2007:
Cases opened.
Sexual exploitation;
Fiscal year: 2005: 183;
Fiscal year: 2006: 213;
Fiscal year: 2007[A]: 161.
Forced labor;
Fiscal year: 2005: 84;
Fiscal year: 2006: 85;
Fiscal year: 2007[A]: 88.
Other[B];
Fiscal year: 2005: 55;
Fiscal year: 2006: 26;
Fiscal year: 2007[A]: 4.
Total;
Fiscal year: 2005: 322;
Fiscal year: 2006: 324;
Fiscal year: 2007[A]: 253.
Indictments.
Sexual exploitation;
Fiscal year: 2005: 54;
Fiscal year: 2006: 93;
Fiscal year: 2007[A]: 60.
Forced labor;
Fiscal year: 2005: 11;
Fiscal year: 2006: 10;
Fiscal year: 2007[A]: 1.
Other;
Fiscal year: 2005: 46;
Fiscal year: 2006: 27;
Fiscal year: 2007[A]: 11.
Total;
Fiscal year: 2005: 111;
Fiscal year: 2006: 130;
Fiscal year: 2007[A]: 72.
Arrests.
Sexual exploitation;
Fiscal year: 2005: 85;
Fiscal year: 2006: 135;
Fiscal year: 2007[A]: 93.
Forced labor;
Fiscal year: 2005: 15;
Fiscal year: 2006: 6;
Fiscal year: 2007[A]: 28.
Other;
Fiscal year: 2005: 86;
Fiscal year: 2006: 43;
Fiscal year: 2007[A]: 2.
Total;
Fiscal year: 2005: 186;
Fiscal year: 2006: 184;
Fiscal year: 2007[A]: 123.
Convictions.
Sexual exploitation;
Fiscal year: 2005: 6;
Fiscal year: 2006: 69;
Fiscal year: 2007[A]: 54.
Forced labor;
Fiscal year: 2005: 5;
Fiscal year: 2006: 7;
Fiscal year: 2007[A]: 5.
Other;
Fiscal year: 2005: 80;
Fiscal year: 2006: 26;
Fiscal year: 2007[A]: 12.
Total;
Fiscal year: 2005: 91;
Fiscal year: 2006: 102;
Fiscal year: 2007[A]: 71.
Source: Immigration and Customs Enforcement.
Note: These cases may include joint investigations with the FBI.
[A] Data as of May 31, 2007.
[B] Human trafficking cases classified other than sex or labor
trafficking.
[End of table]
Additionally, FBI's Crimes Against Children Unit reported data on cases
of trafficking of U.S. children for commercial sex from its Innocence
Lost National Initiative, as shown in table 6.
Table 6: Innocence Lost Statistics, Fiscal Year 2004 through June 5,
2007:
Cases opened;
Fiscal year: 2004: 67;
Fiscal year: 2005: 71;
Fiscal year: 2006: 103;
Fiscal year: 2007[A]: 86.
Indictments/Information;
Fiscal year: 2004: 27;
Fiscal year: 2005: 48;
Fiscal year: 2006: 76;
Fiscal year: 2007[A]: 36.
Arrests;
Fiscal year: 2004: 118;
Fiscal year: 2005: 387;
Fiscal year: 2006: 157;
Fiscal year: 2007[A]: 137.
Convictions;
Fiscal year: 2004: 22;
Fiscal year: 2005: 45;
Fiscal year: 2006: 43;
Fiscal year: 2007[A]: 72.
Source: FBI's Crimes Against Children Unit.
[A] Data as of June 5, 2007.
[End of table]
DOL's Wage and Hour Division reported participating in four cases
involving criminal or potentially criminal allegations of trafficking
in persons, which were concluded in fiscal year 2007. The division
reported seven cases currently under investigation; seven cases at some
stage of litigation or case development by the FBI, Assistant U.S.
Attorney, or others; and one additional case in which it will be
providing technical assistance following direct law enforcement action.
According to the division, its involvement may have been as a result of
a referral from another agency (e.g., FBI, Assistant U.S. Attorney, or
local law enforcement), a referral from an advocacy organization, or a
situation in which the division was the initial investigating agency.
In addition to participation in cases involving violations of the
trafficking statutes, the division has also assisted other law
enforcement agencies in developing investigations or prosecutions of
criminal violations of other statutes and may pursue criminal penalties
under its own statutes. For example, according to CRT/CS, DOL has been
involved in the calculation of back wages and overtime pay for victims,
as in United States v. Calimlim. According to DOL, it provided
technical advisory assistance to the prosecuting U.S. Attorney,
furnishing sample back wage computations that would have been due had
the victim fallen under the provisions of the Fair Labor Standards Act
(FLSA), and had the case events occurred within the FLSA statute of
limitations. In the subsequent prosecution, CRT/CS successfully secured
a $940,000 restitution order.
Resource Commitments of Federal Investigative and Prosecutorial
Agencies to Meet Their Responsibilities for Pursuing Trafficking in
Persons Crimes:
To implement their respective plans and carry out activities related to
the investigation and prosecution of trafficking in persons, agencies
have generally drawn from existing resources. Therefore, according to
DHS and DOJ officials, resource information may not be distinguishable
from other activities and is generally an estimate. Information is also
not consistent across agencies.
Although the 2005 TVPA amendments authorized appropriations of
$18,000,000 in fiscal years 2006 and 2007 to ICE and $15,000,000 in
fiscal year 2006 to the FBI for trafficking investigations, these
amendments were enacted after fiscal year 2006 had already begun and
the amounts were not appropriated. ICE reported 53 full-time
equivalents for fiscal year 2005, 68 in fiscal year 2006, and 32
through the first half of fiscal year 2007 for trafficking activities.
In midyear 2003, ICE received $3.7 million in supplemental funding,
which mostly funded law enforcement operations to enforce the TVPA and
domestic and overseas training activities. FBI officials told us they
had not received a separate appropriation specifically for trafficking
in persons. The FBI Civil Rights Unit reported as of April 2007, 141
Special Agents are allocated to its Civil Rights Program throughout 56
field offices. One Unit Chief, six Supervisory Special Agents, and
eight support staff are assigned to headquarters. For fiscal year 2006,
approximately 24 percent of these resources were directed toward human
trafficking matters.
In fiscal year 2006, the FBI's Crimes Against Children Unit received
$500,000 from the Assets Forfeiture fund to support task forces and
working groups investigating trafficking of U.S. children for
commercial sex. The funds were used for overtime pay for state and
local officers, equipment, and training. Additionally, to support the
Innocence Lost National Initiative, the FBI received 16 positions (10
agents and 6 analysts) in fiscal year 2005, and 10 agent positions in
fiscal year 2006. The FBI said it requested 30 investigative, clerical,
and analytical personnel to support the Crimes Against Children program
initiatives for fiscal year 2008, including combating trafficking of
U.S. children for commercial sex.
In addition, the conference agreement for the fiscal year 2007 DHS
appropriation designated $1 million to ICE for its contribution to the
Human Smuggling and Trafficking Center (HSTC). HSTC officials said
although these funds were not designated specifically for trafficking
in persons, they would assist HSTC's trafficking efforts. Furthermore,
because ICE was the only agency with funds specifically designated for
HSTC, it would henceforth take on the responsibility for up-front
administrative expenses at HSTC, for which other agencies, including
DOS and DOJ, would then reimburse ICE.
CRT/CS also reported that it had not received funds specifically
designated for human trafficking prosecutions, but provided us with
estimates of the numbers of positions, attorneys, and full-time
equivalents for trafficking in persons. CRT/CS further noted that the
actual number of positions is very difficult to track, because, as is
true for all enforcement areas within the Criminal Section, most
attorneys do not work exclusively on trafficking in persons, but carry
other criminal enforcement cases as well. CRT/CS training, outreach,
and technical assistance on trafficking in persons have also been
provided from its operating funds. However, CRT/CS developed and
provided us with estimates of various types of resources it used to
address trafficking in persons, as presented in table 7.
Table 7: DOJ Estimates of CRT/CS Trafficking in Persons Resources,
Fiscal Years 2000-2007:
Fiscal year: 2000;
Positions: 6;
Attorneys: [Empty];
Full-time equivalents: 3;
Dollars in thousands: $401.
Fiscal year: 2001;
Positions: 9;
Attorneys: [Empty];
Full-time equivalents: 9;
Dollars in thousands: 980.
Fiscal year: 2002;
Positions: 21;
Attorneys: 14;
Full-time equivalents: 15;
Dollars in thousands: 1,748.
Fiscal year: 2003;
Positions: 21;
Attorneys: 14;
Full-time equivalents: 21;
Dollars in thousands: 2,527.
Fiscal year: 2004;
Positions: 21;
Attorneys: 14;
Full-time equivalents: 21;
Dollars in thousands: 2,638.
Fiscal year: 2005;
Positions: 21;
Attorneys: 14;
Full-time equivalents: 21;
Dollars in thousands: 2,687.
Fiscal year: 2006[A];
Positions: 21;
Attorneys: 14;
Full-time equivalents: 21;
Dollars in thousands: 2,900.
Fiscal year: 2007[B];
Positions: 21;
Attorneys: 14;
Full-time equivalents: 21;
Dollars in thousands: $3,100.
Source: GAO analysis of DOJ-provided data and data found in fiscal year
2008 congressional budget submission.
[A] Reflects estimated costs for fiscal year 2006.
[B] Reflects the fiscal year 2007 budget submission.
[End of table]
DOJ's fiscal year 2008 budget submission included a request for a CRT/
CS program increase of $1,713,000, 13 agent/attorney positions, and 7
full-time equivalents for its trafficking efforts.
According to CEOS, prosecuting sex trafficking and sex tourism cases
can be enormously resource intensive, especially if foreign victims or
investigators will be needed to testify at trial. As trafficking crimes
were not a line item in the appropriation legislation, CEOS could not
provide actual data on the resources used to prosecute these crimes.
However, CEOS estimated that it has devoted approximately 15 to 25
percent of its attorney time to trafficking crimes since 2003. FBI and
CEOS officials noted the lack of facilities for these victims, who need
special treatment.
The TVPA authorized the Attorney General to make grants to develop,
expand, or strengthen victim service programs for victims of
trafficking. DOJ received approximately $10 million per year in fiscal
years 2002 through 2006 for victim services programs for victims of
trafficking, as authorized by section 107(b)(2) of the TVPA. In fiscal
year 2002, OVC awarded these funds to nonprofit, nongovernmental victim
services providers to develop, expand, or strengthen services for
victims of trafficking. According to DOJ officials, in fiscal year
2003, DOJ decided to use a portion of these funds to award BJA task
forces grants on trafficking with the goal of expanding services for
victims by identifying more victims and connecting them with needed
services. In subsequent fiscal years, both OVC and BJA awarded grants
with these funds.
In addition, FBI, ICE, the Executive Office for U.S. Attorneys, and
CRT/CS have emergency funds that may be used to provide immediate
services to victims when services cannot be provided through other
programs that support trafficking victims. According to OVC, the
agencies coordinate these efforts through it to ensure that any use of
emergency funds is appropriate, maximizes the use of trafficking
appropriation dollars when they are available, and occurs when no other
funds are available.
[End of section]
Appendix IV: Summary Case Studies:
The following case studies illustrate several of the characteristics of
human trafficking described in this report, including (1) the diverse
purposes for which people are trafficked and the circumstances in which
they work, both legally and illegally; (2) the variation in the number
of victims; (3) case complexity; and (4) coordination among law
enforcement and nongovernmental organizations in caring for the victims
and prosecuting the perpetrators.[Footnote 46]
United States v. Kil Soo Lee:
United States v. Kil Soo Lee--the largest trafficking prosecution
before a federal court--resulted from an investigation involving five
languages, several countries and states, and numerous federal agencies
and nongovernmental organizations. Between September 1998 and December
2000, Lee recruited 250 skilled garment workers--mostly young women who
had paid $5,000 and $8,000 recruitment fees--from China and Vietnam,
locating his garment factory, named Daewoosa Samoa, in American Samoa
to use the "Made in America" label and avoid drawing attention to his
operation. The workers believed the fees to be legitimate payment in
exchange for new jobs possibly leading to a better life. Instead, they
lived, ate, and slept in barracks on the factory compound, surrounded
by fences that remained locked and guarded during working hours. Lee
and his associates seized passports--threatening the workers with
deportation, bankruptcy, severe financial hardship to family members
back home, and false arrest--and withheld food and pay.
In March 1999, workers asked to be paid for several months' labor. Kil
Soo Lee refused to pay them, and when the workers protested, he locked
them inside of the Daewoosa compound and refused to provide them with
food. Several workers climbed over the fence at night and contacted
local residents to complain and seek food. Upon finding out that
workers had left the compound, Kil Soo Lee notified the American Samoan
police that the workers were causing a disturbance and had the police
arrest three of the female workers who tried to leave the company
grounds. The workers were unable to speak English or Samoan, and thus
were unable to communicate the true version of events to the police.
Attempting to communicate with the outside world, another worker threw
a handwritten note from the window of the company car after visiting
jailed coworkers. This note was found and passed on to the U.S.
Department of Labor, which investigated allegations that Kil Soo Lee
had withheld the workers' pay. Because of the investigation, DOL
required Lee to make restitution to the affected employees. Following
additional complaints and allegations that Lee was requiring workers to
kick back the back wage payments, DOL again investigated. The garment
manufacturers for which Lee was producing goods provided the back wage
restitution for the underpaid employees in this second investigation.
In November 2000, workers protested again by slowing production. On
Lee's direction, guards entered the factory and conducted a mass
beating of the Vietnamese, inflicting severe injuries on several. Local
police investigated the uprising but dismissed the case, believing the
guards' accounts that the Vietnamese workers had attacked the Samoans.
The Occupational Safety and Health Administration of DOL then arrived
to conduct inspections of the Daewoosa facility from November to
February 2001, citing violations of workplace safety noted from earlier
investigations concluded in June 1999. In March 2001, FBI agents and
CRT/CS prosecutors traveled to American Samoa to investigate. They
conducted interviews, surveyed the factory, and seized records,
computers, and other evidence. Kil Soo Lee was then arrested on March
23, 2001. He and four other defendants were indicted in August of that
year on 22 charges of subjecting workers to involuntary servitude. The
trial began in October 2002 and lasted 4 months.
During prosecution, the nature of the crime and the cultural and
linguistic backgrounds of the workers posed challenges for the Civil
Rights Division. Attorneys had to prove that the workers--now witnesses
in the trial--were victims rather than simply violators of labor and
immigration laws. Lee had already had some of them deported, while
others scattered to 20 states around the country after being given
temporary immigration status to testify. During the pretrial
preparations and the trial, more than 200 victims had to be housed and
fed, while the sick and injured required medical care. Because the
victims had limited or no English facility (languages spoken included
Chinese, Vietnamese, Korean, and Samoan), interpreters had to be
provided. Agents and attorneys also had to gain the victims' trust,
overcoming their fears of law enforcement and authority, which Kil Soo
Lee and the other defendants had earlier exploited. Finally, the
victims needed to be assured that no harm would come from the
proceedings either to them or their families back home and that they
had done nothing to draw shame or fear of exposure upon themselves.
In August 2001, two of the American Samoan guards entered guilty pleas
to participating in the conspiracy to violate the civil rights of the
garment workers and were later sentenced to 70 and 51 months in prison.
Two codefendants were acquitted on all charges. In February 2002, Kil
Soo Lee was convicted of conspiracy to violate the civil rights of the
workers, 11 counts of involuntary servitude, 1 count of extortion, and
1 count of money laundering. Lee, who was in his mid-50s, was sentenced
in June 2005 to 40 years in prison, which at that time was the highest
sentence handed down in a trafficking/slavery case that did not result
in death, and ordered to pay restitution of $1,826,087.94.
On April 16, 2002, the High Court of American Samoa in a separate
consolidated civil case also ordered Daewoosa Samoa, Ltd. to pay $3.5
million in back wages to the workers.
United States v. Carreto:
The Carreto case came to the U.S. government's attention on a tip from
Mexican authorities that a victim was believed to have been held and
forced into prostitution. An investigation led agents to locations
where a number of young women and their traffickers were arrested. The
defendants were members or associates of an extended family whose
principal business was reaping the profits from compelling young
Mexican women into prostitution through force, fraud, and coercion. The
defendants, who often lured the women into romantic relationships, used
deception, psychological manipulation, and false promises, along with
physical beatings and rapes, to overcome the will of the victims,
compel them into prostitution, and force them to turn over virtually
all the proceeds to the defendants.
During the investigation of this case, ICE and DOJ coordinated with
international nongovernmental organizations, the Mexican government,
and Mexican attorneys to remove the victims' children from the custody
of the Carreto family, thereby removing one of the last means of
control the Carreto family had exerted over the victims. The
investigation revealed extensive sex trafficking activity between
Mexico and the United States, prompting initiatives to coordinate
multijurisdictional, multi-agency investigations.
On November 16, 2004, a federal grand jury returned a 27-count
superseding indictment charging Josue Flores Carreto, Gerardo Flores
Carreto, Daniel Perez Alonso, Eliu Carreto Fernandez, Consuelo Carreto
Valencia, and Maria de los Angeles Velasquez Reyes with victimizing
nine young Mexican women. The indictment charged the six defendants
with counts of conspiracy to commit sex trafficking, sex trafficking,
attempted sex trafficking, forced labor, violation of the Mann Act,
conspiracy to import aliens for immoral purpose, and alien
smuggling.[Footnote 47] Two additional defendants, Edith Mosquera de
Flores and Eloy Carreto Reyes were charged separately by complaint.
On April 5, 2005, on the morning trial in this case was to begin,
Gerardo Flores Carreto, Josue Flores Carreto, and Daniel Perez Alonso
pled guilty to all charges in the 27-count indictment. On April 27,
2006, Gerardo Flores Carreto and Josue Flores Carreto were each
sentenced to 50 years in prison. Daniel Perez Alonso was sentenced to
25 years in prison. Edith Flores had previously been sentenced to 16
months. On June 1, 2006, Eliu Carreto Fernandez was sentenced to 80
months in prison. Eloy Carreto Reyes is still pending sentencing.
On January 19, 2007, the Mexican government extradited defendant
Consuelo Carreto Valencia to the United States, along with 14 other
criminal defendants, in an extradition that Attorney General Gonzales
lauded as unprecedented in its scope and importance. Consuelo Carreto
Valencia, the mother of two of the lead defendants, is charged with
conspiring with the other defendants to compel the victims into forced
prostitution. An additional defendant, Maria de los Angeles Reyes,
remains in Mexico, where she has previously been arrested on related
charges. CRT/CS is seeking her extradition.
[End of section]
Appendix V: Comments from the Department of Justice:
U.S. Department of Justice:
Washington, D.C. 20530:
July 20, 2007:
Mr. Robert N. Goldenkoff:
Acting Director, Homeland Security and Justice:
Government Accountability Office:
Washington, D.C. 20548:
Dear Mr. Goldenkoff:
Thank you for the opportunity to review the final draft of the
Government Accountability Office (GAO) report entitled "Human
Trafficking: A Strategic Framework Could Help Enhance the Interagency
Collaboration Needed to Effectively Combat Trafficking Crimes, GAO-07-
915. " This draft report was reviewed by the Department of Justice (DOJ
or Department) components that participated in the review. This letter
constitutes the Department's formal comments. I request that the GAO
include this letter in the final report. The Department's technical
comments were provided under separate cover.
Human trafficking programs are very complex, technical programs that
require a large amount of training to both identify and explain the
subject matter and to coordinate the response, which often includes
representatives from law enforcement, the judicial system, victim
service providers, and community leaders. As noted in this report,
these programs are looking for victims who are deliberately hidden and
are unfamiliar with our legal system or the rights and services
available to them. Because both the crime of human trafficking and the
needs of the victims are challenging to address, a significant
investment in training and technical assistance is required for
effective implementation of any human trafficking program. However,
compared to technical assistance funding for other complex Department
initiatives, two percent of the appropriation is a very small
percentage of funding to be dedicated to technical assistance.
Additionally, this two percent of appropriated funds must also be split
between the Bureau of Justice Assistance (BJA) and the Office for
Victims of Crime (OVC) to provide training and technical assistance to
its nongovernmental victims service providers.
As the GAO reports, since 2001, the Department has significantly
increased the number of human trafficking prosecutions and
investigations. The Department prosecuted six times more human
trafficking cases from 2001 to 2006 than in the previous six years.
Likewise, the Federal Bureau of Investigation (FBI) and, since 2003,
the Department of Homeland Security (DHS) have investigated record
numbers of human trafficking matters. These high numbers of
prosecutions and investigations are the result of regular collaboration
between the Departments of Justice, Homeland Security and Labor (DOL),
the 42 BJA funded Human Trafficking Task Forces, and our other law
enforcement partners. Also, DOJ and DHS have engaged in extensive
outreach, and provided training and technical assistance to other
federal and state law enforcement entities, to Non-Governmental
Organizations (NGO), and foreign governments. As discussed more fully
below, we agree with GAO that routine collaboration among the various
partners is a key factor in the continued success of this program.
However, we recommend that the GAO allow for more flexibility in
determining the appropriate collaborative model.
Despite the significant increase in the trafficking caseload since
2001, using existing resources, it is important to reiterate that
additional resources are needed if we are to continue our successful
investigation and prosecution of human trafficking crimes and to
further our collaborative efforts.
Our comments about the proposed recommendations follow.
Recommendation that the Attorney General and the Secretary of Homeland
Security in conjunction with the Secretaries of Labor State and other
agency heads deemed appropriate develop and implement a strategic
framework to coordinate U.S. efforts to investigate and prosecute
trafficking in persons.
The GAO report states that interagency coordination on trafficking
occurs primarily on a reactive, case-by-case basis and that "individual
agency goals on trafficking are linked to individual agency missions,
rather than to a common government-wide outcome for combating
trafficking crimes." However, DOJ, DHS, Department of State (DOS), and
the other agencies identified by GAO engage in regular strategic and
proactive collaboration, in addition to what GAO calls "case-by-case"
or "reactive" collaboration. Senior government officials regularly meet
at the Senior Policy Operating Group (SPOG) to identify broad
government-wide common outcomes or "end goals." Senior officials at the
DOJ, DHS, and the other law enforcement agencies have met and developed
subordinate goals. For example, DOJ and DHS senior officials met and
created Memoranda of Understandings that identify "Joint strategies"
and "agreed on roles." In addition, DOJ, working with our other
partners, designed and implemented a proactive task force model that
includes regular collaboration among task force representatives,
including DOJ, FBI, DHS, DOS, DOL, the Internal Revenue Service (IRS),
state law enforcement, and NGOs. Likewise, DOJ, DHS, DOS, the Central
Intelligence Agency and other agencies proactively collaborated to form
the Human Smuggling and Trafficking Center (HSTC). The Department
regularly convenes conferences and other programs designed to bring
together representatives from DOJ, FBI, DHS, DOL, and our other
partners to proactively collaborate on enforcement objectives.
Moreover, the Department's law enforcement activities in this regard
are designed to achieve end goals and operational results determined as
part of the collaborations with our partners at DHS, DOL, DOS, and
elsewhere. For example, DOJ and its partners proactively established
the victim-centered task force model for investigating and prosecuting
human trafficking crimes. In each specific investigation and
prosecution, FBI agents and DOJ attorneys implement and utilize this
model, as GAO describes in the draft report. As GAO recognizes, this
system has been successful and resulted in record numbers of
investigations and prosecutions.
We acknowledge that continued and increased collaboration could further
our efforts to investigate and prosecute human trafficking crimes. We
also agree that this heightened collaboration should be led by and be
held primarily among law enforcement due to the sensitive and
confidential nature of law enforcement activities and decisions.
However, the "unique challenges" in these matters, identified by GAO in
its report, counsel for more flexibility in determining the methods of
collaboration among our law enforcement partners. We are pursuing a
variety of methods already. For one, we established the Human
Trafficking Prosecution Unit. Its members held collaborative meetings
and training sessions with our partners.
Therefore, DOJ proposes that the report identify the need for continued
collaboration, but not mandate one particular collaborative model.
Recommendation that the Attorney General direct the Director of the
Bureau of Justice Assistance (BJA) to develop and implement a plan to
help focus technical assistance on areas of greatest need.
By October 1, 2007, BJA and OVC plan to collaboratively develop and
lead a facilitated working group with representatives of their agencies
and representatives from the Immigration and Customs Enforcement; the
HSTC; the DOL; and from the following DOJ components: the CRT, National
Institute of Justice, Bureau of Justice Statistics, Executive Office of
U.S. Attorneys, and the FBI. The working group will address the
following training and technical assistance needs which were raised by
the GAO report:
1. Substantive training about trafficking crimes and victims for the
task forces;
2. Technical assistance and training to help task forces develop the
components in their strategies required under their BJA grants;
3. Continuation of basic training on trafficking issues;
4. Advanced training on such topics as: seizing and forfeiting
traffickers' assets, techniques to facilitate law enforcement and NGOs
working together to interview trafficking victims, and techniques for
interviewing child victims of sex trafficking,
5. Training of other agency personnel (other law enforcement, hospital
workers, code enforcement personnel, and social services personnel);
6. Tailored training and technical assistance to specific populations;
7. Protocols covering roles and responsibilities, methods of
communication, and establishing and maintaining relationships;
8. Technical assistance on ways to improve communication and
information sharing, assistance with strategizing, translator/cultural
assistance, and issues around securing safe housings for victims;
9. Identifying ways to enhancing communication among all parties, such
as email lists, a secure website, and training bulletins; and:
10. Regional and national meetings that bring smaller groups of task
forces together.
The working group will provide input to BJA regarding the development
of collaborative outreach. Further, it will allow BJA to improve
training and technical assistance strategies to address issues raised
by GAO in its report The Training and Technical Assistance plan is
expccted to include, at least:
1. A strategy for informing task force members, on a continuous basis,
of the availability of training and technical assistance and the wide
variety of related resources. BJA will review its outreach strategies
and develop a comprehensive strategy to disseminate training and
technical assistance options and resources available to task force
members and other key individuals;
2. A systematic assessment of performance measures;
3. Steps to obtain information from the task forces on areas for
continuous improvement;
4. An exploration of options for communication such as a secure
website(s) to share best practices, obtain samples of protocols or
other documents, and provide peer-to-peer assistance from other task
forces. Additionally, BJA could use the website(s) to share information
with task forces;
5. Methods to assess the quality of training and technical assistance
provided to recipients; and:
6. A strategy for identifying training, technical assistance and
related resources from all working group members, NGOs, task forces and
foreign partners and matching particular task force's needs with such
training and technical assistance.
BJA believes that the creation of a facilitated working group composed
of agencies actively involved in addressing human trafficking will lead
to a strong training and technical assistance program which will
enhance the ability of task forces to achieve their primary goal of
identifying and rescuing trafficking victims.
The extensive effort that your staff has put into this report and the
opportunity to work with them on this important issue are appreciated.
Sincerely,
Signed by:
Leo J. Lofthus:
Assistant Attorney General for Administration:
[End of section]
Appendix VI: Comments from the Department of Homeland Security:
U.S. Department of Homeland Security:
Washington, DC 20528:
July 18, 2007:
Mr. Robert N. Goldenkoff:
Acting Director, Homeland Security and Justice:
U.S. Government Accountability Office:
Washington, D. C. 20548:
Dear Mr. Goldenkoff:
Thank you for the opportunity to review and comment on this most
important report, Human Trafficking: A Strategic Framework Could Help
Enhance the Interagency Collaboration Needed to Effectively Combat
Trafficking Crimes, GAO-07-915. The Department of Homeland Security
(DHS) aggressively takes action against human trafficking through its
Immigration and Customs Enforcement (ICE) component.
DHS and ICE believe the audit report reflects an overall understanding
of the complexities of the antitrafficking response as well as ICE's
efforts in leading investigations, conducting outreach, and responding
to victims of trafficking crimes. The GAO's assessment properly
characterizes ICE's compliance with National Security Presidential
Directive (NSPD)-22, which directs federal agencies to ensure that
employees are fully trained to carry out investigative and
prosecutorial responsibilities as well as to effectively coordinate
efforts across agencies and disciplines.
The report notes that coordination and strategizing among agencies is
reactive and on a case-by-case basis, however interagency coordination
does occur through the Senior Policy Operating Group (SPOG). The SPOG
ensures that the U.S. Government anti-trafficking policies and
guidelines are carried out; therefore ICE does not believe there is a
need for a government-wide framework or strategy.
Additionally, recommendations from various agencies that foster the
development of frameworks are included in the annual "Attorney General
Report to Congress" and the "U.S. Government Assessment of Efforts to
Combat Trafficking in Persons." These annual reports also include plans
of action to be applied in the upcoming fiscal years.
Furthermore, ICE regularly conducts direct strategic planning with
partner agencies. Most of the strategic planning with partner agencies
occurs in the field. There are 42 Human Trafficking Task Forces, also
referred to as the Human Trafficking Rescue Alliances around the
country. Federal agencies, including ICE, the Federal Bureau of
Investigations, U.S. Attorney Offices, local law enforcement agencies,
and Non-Governmental Organizations.
(NGOs) participate in these task forces. Each task force agrees to
operational trafficking strategies or protocols. Protocols include
which agency is the lead for the investigation, which NGOs are notified
when a trafficking victim is discovered, which agency handles media
inquiries, etc. The task force members also agree on outreach
strategies, such as when and where training will be held, who will be
the target audience, frequency of training classes, trafficking
awareness campaigns, etc. The Human Trafficking Task Forces usually
meet once per quarter, during which ongoing analysis and strategic
planning is conducted.
Recommendation 1 impacts ICE's roles and responsibilities in planning
and orchestrating investigations related to human trafficking.
Specifically, the GAO report indicates that interagency coordination on
trafficking occurs primarily on a reactive, case-by-case basis and that
federal investigative and prosecutorial agencies would "benefit from an
overall strategic framework to help enhance and sustain interagency
collaboration on trafficking in persons. individual agency goals on
trafficking are linked to individual agency missions, rather than to a
common government-wide outcome for combating trafficking crimes."
The strategic framework suggested by the GAO would be developed and
implemented by the Attorney General and the Secretary of Homeland
Security, in conjunction with the Secretaries of Labor, State, and
other agency heads deemed appropriate. The following are the items GAO
would like to see addressed in the framework:
-A commonly identified outcome,
-Mutually reinforcing or joint strategies,
- Roles and responsibilities, and:
-The establishment of compatible policies, procedures, and other means
to operate across agency boundaries (See page 36, Recommendations for
Executive Action).
ICE would support an interagency strategic framework if the
considerations herein were taken into account. Mutual goal-setting may
be possible as long as the goals contain several objectives that will
specifically address unique agency capabilities in combating
trafficking. Note that the agencies identified by GAO to develop and
implement this common framework include agencies with both domestic and
international responsibilities. On cases in which ICE and the FBI are
involved in a joint investigation, it might be feasible to develop
joint strategies for investigation and response. However, while ICE
does not object to the creation of roles and responsibilities that
would effectuate enhanced communication and collaboration among federal
and local agencies, it is critical to note that such protocols must
take into account that agencies' roles in a particular case will vary
by available resources, local priorities, and --to a certain extent--
the nature of the case and investigation. ICE remains amenable and
responsive to conducting human trafficking investigations where victims
and offenders are not U.S. citizens.
ICE notes that the 2003 Reauthorization of the trafficking Victims
Protection Act established that the Attorney General prepare and submit
an annual report to Congress on efforts to combat trafficking
domestically. The report to Congress, though submitted by the
Department of Justice, is prepared with input from all federal agencies
involved in investigating and prosecuting trafficking crimes or funding
programs to respond to victim coordination. While the report is
primarily an update summarizing each agency's contributions in the
areas of service provision to victims, investigations and prosecutions,
international efforts, and training and outreach, it also includes
language that identifies goals for each agency in improving their
response to human trafficking issues. Although the Attorney General
Report to Congress does not amount to a government-wide strategic plan
or trafficking, it is a call for individual agencies to create a
strategy for improved response within the context of existing
resources.
ICE was authorized appropriations amounting to $18 million for
investigations involving trafficking in persons under the provisions of
the Trafficking in Persons Reauthorization Act of 2005 (H.R. 972) in
Fiscal Years 2006 and 2007. Congress has not yet provided funding to
carry out the provisions of the Act, which would include conducting
trafficking investigations, victim/witness support, outreach, and
domestic and international training. ICE continues to conduct this
important mission using baseline funding. Relying upon base
appropriations is particularly challenging with respect to the victims
and witnesses of this criminal activity. Presently, the funding vacuum
precludes placement of full-time victim/witness coordinators in the
field in the same way that our partner agencies do. In order to be
fully responsive to the GAO's desire for ICE to develop and
operationalize a common trafficking framework with our federal
partners, it is critical to ensure that the necessary resources are
allocated for policy efforts and for the initiating of recommendations
that arise from the development of any common framework.
We thank you for the opportunity to review this most important draft
report and to provide comments.
Sincerely,
Signed by:
Steven J. Pecinovsky:
Director:
Departmental GAO/OIG Liaison Office:
[End of section]
Appendix VII: GAO Contact and Staff Acknowledgments:
GAO Contact:
Robert N. Goldenkoff (202) 512-2757.
Staff Acknowledgments:
In addition to the individual named above, Glenn G. Davis, Barbara A.
Stolz, Susanna R. Kuebler, Richard Ascarate, Kelly Bradley, Erin
Claussen, Frances Cook, Stuart Kaufman, and Elizabeth Curda made
significant contributions to the report.
[End of section]
Related GAO Products:
Human Trafficking: Better Data, Strategy, and Reporting Needed to
Enhance U.S. Anti-Trafficking Efforts Abroad, GAO-06-825 (Washington,
D.C.: July 18, 2006):
Human Trafficking: Monitoring and Evaluation of International Projects
Are Limited, but Experts Suggest Improvements, GAO-07-1034 (Washington,
D.C.: July 26, 2007):
Results-oriented Government: Practices That Can Help Enhance and
Sustain Collaboration among Federal Agencies, GAO-06-15 (Washington,
D.C.: Oct. 21, 2005):
International Crime Control: Sustained Executive-Level Coordination of
Federal Response Needed, GAO-01-629 (Washington, D.C.: August 13,
2001):
Combating Terrorism: Evaluation of Selected Characteristics in National
Strategies Related to Terrorism, GAO-04-408T (Washington, D.C.:
February 3, 2004):
Organized Crime: Issues Concerning Strike Forces, GAO/GGD-89-67
(Washington, D.C.: April 11, 1989):
Prescription Drugs: Strategic Framework Would Promote Accountability
and Enhance Efforts to Enforce the Prohibitions on Personal
Importation, GAO-05-372 (Washington, D.C.: September 8, 2005):
Community Services Block Grant Program: HHS Should Improve Oversight by
Focusing Monitoring and Assistance Efforts on Areas of High Risk, GAO-
06-627 (Washington, D.C.: June 29, 2006):
FOOTNOTES
[1] The terms "human trafficking" and "trafficking in persons" are
often used interchangeably. In this report, we use the term
"trafficking in persons," as referred to in U.S. law, except where
source documents use the term "human trafficking."
[2] See GAO, Human Trafficking: Better Data, Strategy, and Reporting
Needed to Enhance U.S. Anti-Trafficking Efforts Abroad, GAO-06-825
(Washington, D.C.: July 18, 2006).
[3] Pub. L. No. 106-386, div. A, 114 Stat. 1464, 1466-91 (2000).
[4] Pub. L. No. 108-193, 117 Stat. 2875 (2003); Pub. L. No. 109-164,
119 Stat. 3558 (2006).
[5] As defined in previous GAO work, for the purpose of this report we
define "collaboration" as any joint activity by two or more
organizations that is intended to produce more public value than could
be produced when the organizations act alone. We use the term
"collaboration" broadly to include interagency activities that others
have variously defined as "cooperation," "coordination," "integration,"
or "networking." See GAO, Results-oriented Government: Practices That
Can Help Enhance and Sustain Collaboration among Federal Agencies, GAO-
06-15 (Washington, D.C.: Oct. 21, 2005).
[6] See GAO, Human Trafficking: Monitoring and Evaluation of
International Antitrafficking Projects Are Limited, but Experts Suggest
Improvements, GAO-07-1034 (Washington, D.C.: July 26, 2007). We
previously issued Human Trafficking: Better Data, Strategy, and
Reporting Needed to Enhance U.S. Anti-Trafficking Efforts Abroad, GAO-
06-825 (Washington, D.C.: July 18, 2006).
[7] The Intelligence Reform and Terrorism Prevention Act of 2004
established the Human Smuggling and Trafficking Center, to be jointly
run by the Departments of State, Justice, and Homeland Security, in
order to collect and disseminate information to help prevent
clandestine terrorist travel and facilitation of migrant smuggling and
trafficking in persons. 8 U.S.C. § 1777.
[8] This number does not include any CEOS/Innocence Lost National
Initiative prosecutions for trafficking of U.S. children for commercial
sex or trafficking prosecutions brought by U.S. Attorney's offices and
not reported to CRT/CS.
[9] See GAO-06-15.
[10] See GAO, Community Services Block Grant Program: HHS Should
Improve Oversight by Focusing Monitoring and Assistance Efforts on
Areas of High Risk, GAO-06-627 (Washington, D.C.: June 29, 2006).
[11] Under the TVPA, certification that a victim is willing to assist
law enforcement is made by the Secretary of Health and Human Services
after consultation with the Attorney General. Certification is a
prerequisite for benefits only for victims 18 and older.
[12] National Security Presidential Directive 22 (NSPD 22), signed on
December 16, 2002.
[13] The SPOG had previously functioned under the name Senior Policy
Advisory Group.
[14] In December 2006, the HSTC Steering Group approved amendments to
the HSTC Charter. DHS/ICE now nominates the Director. The nomination is
still subject to the approval of the Steering Group.
[15] Mutual Legal Assistance Treaties (MLAT) are intended to enable law
enforcement to efficiently and effectively obtain evidence,
information, and testimony from abroad in a form admissible in courts
of the requesting state. Extradition treaties govern the preconditions
for, and exceptions to, the surrender of a fugitive from justice found
in one country to another country claiming criminal jurisdiction over
the fugitive.
[16] Located in Lyon, France, Interpol does not maintain a force of
international police officers or agents. The United States has
participated in Interpol since 1938, with the authority for that
participation resting with the Attorney General (22 U.S.C. § 263a).
Established in 1969, the Interpol-U.S. National Central Bureau, headed
since 2003 alternatively by officials from DOJ and DHS, is the central
point of contact for Interpol business in the United States (Memorandum
of Understanding between the U.S. Department of Homeland Security and
the U.S. Department of Justice Pertaining to U.S. Membership in the
International Criminal Police Organization [INTERPOL] and related
matters, May 2003).
[17] This number does not include any CEOS/Innocence Lost National
Initiative prosecutions for trafficking of U.S. children for commercial
sex or trafficking prosecutions brought by U.S. Attorney's offices and
not reported to CRT/CS.
[18] This number does not include any CEOS/Innocence Lost National
Initiative prosecutions for trafficking of U.S. children for commercial
sex or trafficking prosecutions brought by U.S. Attorney's offices and
not reported to CRT/CS.
[19] ICE data were for a more limited time period, because the agency,
which was established in 2003, had initial problems in capturing
trafficking in persons data.
[20] ICE agents had to take a test to show that they had completed this
training. On the basis of this test information, ICE headquarters
officials told us that they believed that all agents have completed the
training.
[21] The National Advocacy Center is operated by the Department of
Justice and Executive Office for United States Attorneys.
[22] The toll-free number of the Trafficking in Persons and Worker
Exploitation Complaint Line is 1-888-428-7581. It is operational
between 9 a.m. and 5 p.m. Eastern Standard Time. Operators have access
to interpreters and can talk with callers in their own language.
[23] The 2006 conference was mandated by the 2005 TVPA reauthorization
act.
[24] The states are Alaska, Arizona, Arkansas, California, Colorado,
Connecticut, Florida, Georgia, Idaho, Illinois, Indiana, Iowa, Kansas,
Kentucky, Louisiana, Maryland, Michigan, Minnesota, Mississippi,
Missouri, Montana, Nebraska, Nevada, New Hampshire, New Jersey, New
York, North Carolina, Pennsylvania, South Carolina, Texas, and
Washington.
[25] DHS was established in March 2003.
[26] ICE defines collateral duty as an additional part-time duty
assigned outside the agent's or officer's regular duties, as the need
arises.
[27] For example, DOJ, DHS, and the Department of Health and Human
Services have a memorandum of understanding on the basic functions and
interrelationships of the departments as they relate to certification
of persons as victims of a severe form of trafficking under the TVPA.
[28] See GAO-06-15.
[29] See GAO-06-15.
[30] See GAO, Combating Terrorism: Evaluation of Selected
Characteristics in National Strategies Related to Terrorism, GAO-04-
408T (Washington, D.C.: Feb. 3, 2004).
[31] According to BJA and OVC officials, the task force grants are
funded with a portion of the funds appropriated under the TVPA to
develop, expand, or strengthen victim service programs for victims of
trafficking. The agency's goal in using a portion of the funds in this
way is to make services available to more victims by identifying more
victims and then connecting them with needed services.
[32] The BJA task forces are not the universe of human trafficking task
forces directed toward law enforcement. For example, Philadelphia and
Pittsburgh also have task forces. In addition, in 23 cities formal or
informal task forces have been established as part of the Innocence
Lost National Initiative on the trafficking of U.S. children for
commercial sex. However the 42 BJA-funded task forces are considered to
be part of the overall federal effort to investigate and prosecute
trafficking in persons.
[33] The TVPA allows 2 percent of the funds appropriated for the grants
for victim service programs for trafficking victims to be set aside for
training and technical assistance each fiscal year. For fiscal years
2002 through 2006, DOJ received approximately $10 million for the TVPA
grants, which means that approximately $200,000 (less rescissions and
other allocations) were available for each fiscal year for training and
technical assistance. OVC awarded Safe Horizon, a nongovernmental
organization, a grant to provide technical assistance to victim service
providers funded under the program. According to OVC, Safe Horizon was
given a total of $596,595 for fiscal years 2002, 2003, and 2004. OVC
officials also told us that OVC and BJA expect to award remaining
technical assistance funds from subsequent fiscal years to provide
technical assistance to both OVC and BJA human trafficking grantees. In
the interim, Safe Horizon does provide some technical assistance to
task force grantees, according to OVC officials.
[34] BJA reported that it relied on funding from deobligated accounts
at one time made available by the Office of the Assistant Attorney
General.
[35] See GAO-06-627.
[36] See GAO-07-1034 and GAO-06-825.
[37] See GAO-06-15; International Crime Control: Sustained Executive-
Level Coordination of Federal Response Needed, GAO-01-629 (Washington,
D.C.: Aug. 13, 2001); GAO-04-408T; Organized Crime: Issues Concerning
Strike Forces, GAO/GGD-89-67 (Washington, D.C.: Apr. 11, 1989);
Prescription Drugs: Strategic Framework Would Promote Accountability
and Enhance Efforts to Enforce the Prohibitions on Personal
Importation, GAO-05-372 (Washington, D.C.: Sept. 8, 2005).
[38] The BJA task forces are not the universe of human trafficking task
forces directed toward law enforcement. However, they were clearly
defined as task forces focused on human trafficking, readily
identifiable by federal agencies, considered by federal agencies to be
part of the overall federal effort to investigate and prosecute
trafficking in persons, and had a definite source of federal funding.
For these reasons, we focused our work on the BJA-funded task forces
that existed at the time of our review.
[39] See GAO-06-627.
[40] 18 U.S.C. §§ 1581-1588.
[41] 18 U.S.C. §§ 2421-2424.
[42] For example, 29 U.S.C. §1851 (criminal sanctions for violations of
the Migrant and Seasonal Agricultural Worker Protection Act and related
regulations).
[43] See United States v. Kozminski, 487 U.S. 931 (1988).
[44] According to CRT/CS officials, as a result of successful
prosecutions, defendants have been ordered to pay restitution in 34
cases since October 2000. The restitution amounts ranged between
$257.55 to more than $1.8 million. The amounts can vary based on the
length of time the victim was exploited, the wages associated with the
labor or service performed, and the number of victims involved.
However, when setting the amount of the restitution, a court may not
consider the defendant's ability to pay.
[45] Only limited data were available from ICE, because the agency was
established in 2003 as part of the Department of Homeland Security and
initially had difficulties capturing trafficking in persons data.
[46] CRT/CS and DOL's Wage and Hour Division reviewed the summary of
the Kil Soo Lee prosecution, and CRT/CS provided the summary of the
Carreto prosecution.
[47] 18 U.S.C. § 371 conspiracy to commit 18 U.S.C. § 1591 sex
trafficking; 18 U.S.C. § 1591 sex trafficking; 18 U.S.C. § 1594
attempted sex trafficking; 18 U.S.C. § 1589 forced labor; 18 U.S.C. §
2421 Mann Act; 18 U.S.C. § 371 conspiracy to import for immoral purpose
under 8 U.S.C. § 1328; and 8 U.S.C. § 1324 alien smuggling.
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