Hello and welcome to another episode of The know your

compliance podcast. I am extremely excited about today's

conversation. I'm normally excited about my conversations,

but this one I'm particularly excited about. It's something

that internally, I've felt some pressure from our team that we

really should be talking about this more, and I know that in my

own journey as a as a CEO of an anti money laundering company,

I've had a lot to learn, and so to be able to have jenisha Join

me today is terrific. So let me start with a bit of an

introduction our top by the way, I should say our topic primarily

is going to be human trafficking and the impacts in Canada. So

with that, Jinish thank you for joining me, and I will give you

a bit of introduction as to who you are in a second.

I'm so thrilled, Greg, thank you. Thank you for

having me.

So just to set the scene as to why Jinisha, Jinisha Bhatt is an

anti financial crime consultant, human trafficking investigator.

Does a lot of work in fraud detection, both in Canada,

United States, around the world. At this point in time, Jinisha

has worked in banks doing money laundering, human trafficking

investigation, and about six years ago, decided to kind of

join the the fight against human trafficking in a more serious

way, by joining forces with survivors and leaders. She

teamed up with group of organizations and law

enforcement to identify human trafficking victims using open

source intelligence, and is now a the leader of a collective

known as the Canadian anti human trafficking consortium, CA HTC.

And so ca HTC is a not for profit that Jinisha leads, and

its goal is to foster widespread collaboration among private

sector entities across Canada in the fight against human

trafficking. So I truly cannot think of a better person to come

talk with us about human trafficking, and I, again, I

want to thank you for for spending the time with us today.

So Jinisha, let's jump right in. what let's, let's start with,

for our audience, a really broad what is human trafficking, and

is this really something that's happening in Canada, of all

places?

Yeah, great question. Let's start here. What is human

trafficking? You know, the universal definition that

everybody talks about, right, is human trafficking is the

unlawful act of transporting or coercing people in order to

benefit from their work or service, typically in the form

of forced labor and sexual exploitation. I do like to

challenge things, and so I'm going to challenge the

definition, and many people do. It's not the unlawful act of

transporting. I think that's where we get conflated does not

require transport. So let's just say three words that are truly

important for to understand human trafficking, force, fraud

and coercion. And the world unanimously agrees on this, it's

compelling a person, a victim, to use their bodies in ways they

do not consent to, whether it be for sex or labor or marriage or

organ donations and so on.

That's a pretty like scary list, pretty quickly, in

fact, like and, and I think a lot of indeed, yeah. For the

audience, we're taping this on November 1. So fully appropriate

for kind of a more of a more of a topic from, from when you

start to talk through these, like organ harvesting, I hadn't

even considered, but Yeah, certainly sex trafficking is the

one that gets a lot of the the nastiest of the press, I

suppose. But, and we've talked about this a little bit, but

it's not just that, so I think maybe, maybe delve a little

deeper on, if you could, on some of these other facets of human

trafficking that I don't think people necessarily associate

with human trafficking.

Yeah, well, let's, let's talk about what the

United Nations says about Canada. And you asked me whether

trafficking happens here, we'll get into that. But United

Nations has said Canada is a breeding ground, our temporary

worker permit program, our temporary, sorry foreign worker

program, is a breeding ground for contemporary slavery. And

they're asking us. They have been asking us what we're doing

about it. So we are systematically exploiting

temporary foreign workers for labor, and this is, may or may

not even be trafficking, because here is a government that says

to businesses, hey, we are going to allow people to come here

without. Any labor rights, without any human rights, and

you can exploit them. No one will find out, because they have

no mechanisms to complain. But if you look at other forms of

human trafficking, yes, sex trafficking gets a lot of PR and

definitely we should be concerned about that, because an

average victim's age is about 12 to 17 years, right? And many,

many young people are exploited in this act. Go on,

My oldest daughter is 12, so this is a terrifying

statement you've just made. Tell me more. Oh, my goodness.

And that's why I challenged the very definition.

See, the idea is someone is forcefully brought somewhere to

be trafficked. The way many young people are exploited these

days is online. They are lured into sharing content or forced

to sell their content when someone else is profiting,

right? They are extorted or sextorted,

right? That Okay, well, that's that really

broadens the scope of of what we're talking about all of a

sudden. Because you do take that, that transport definition,

that transport piece out of the definition, and suddenly we're,

I can see how this becomes very real and and is something that's

happening in Canada. There's, there's no question about it,

how often it happens?

Yeah, let's, let's go to prevalence. What's the what's

the numbers? What do you know?

Yeah, so last time we met, I told you about

prevalence, but turns out I looked at the study again. This

is a global database. They do a global slavery index. And you

know, they've studied all these countries, including Canada. If

you go to Canadian sources like stat scan, you would see numbers

like there have been, I think it's under 1500 cases in the

last 10 years. So since we started measuring between 2003

and, sorry, between 2013 and 2023 there have been under 1500

cases. So that kind of sounds terrific, right? Yeah, which,

which only places about 1.1 individuals per 100,000 people

at risk or or at risk of having been trafficked. However, if you

look like the global, global slavery index, and this is an

index that studied comprehensive factors like poverty and

people's living conditions and debt, and even things like

corruption index and services available. They are saying that

at least 69,000 people in Canada are actually living in modern

day slavery. They're not, this is not a prevalence study.

They're, they're claiming they're living in modern

slavery, like currently, as we speak. That's a that's a lot

more than the stats can number that's, that's downright

depressing all of a sudden, yeah, and that should tell you,

that should give you an idea of what kind of systemic issues we

face. The number one issue is enforcement. And the number one

issue, actually, I'd say the number one issue is

identification. We haven't even identified more than 1% more

than half a percent of victims worldwide and Canadians stats,

if anything, are more abysmal, and we haven't really done a

good job of prosecuting. The prosecution rate global is also

1%

that's a lot to digest. So you're saying that

the stats can numbers are pretty low, but by all reasonable

metrics are way too low, way lower than the actual. And the

actual might actually be vastly still under representing the

truth of the situation, if we could actually get to the core

of it. If I'm hearing you correctly,

exactly, and I know your listeners are going to

challenge that. How does you know this lady know? Well, I

know because it is my job to look at the data and to get the

data, and we could get into that in a bit, if you like, Yeah,

well, let's, let's do a little bit of that, because I

don't want people to, you know, one of the, one of the risks of

talking about something like this is that you don't people

just wash their hands say, Oh, this is so uncomfortable. I

don't want to consider this possibility. So tell me why I

should believe you. Let's, let's go very core like, what? What

data do you bring that that allows you to make that

statement and gives you the confidence that you're on the to

doing something worth doing, which, by the way, I'm on board

with. I just want to, I just want to, want to make sure that

our listeners kind of follow through with it.

So okay, so I think the gloomy stuff has to

end now. So let's talk about what is being done. This is

really a more sanguine picture of where Canada could go in the

future. I found it the Canada anti human trafficking

consortium after I learned from many survivor leaders, you know,

who desperate to find victims how to actually use data. So,

you know, we have to realize we have people have vulnerabilities

that are exploited by traffickers, but so do

traffickers, and their main vulnerability is that they have

to market their product. The product is a the human being.

Is, yeah. And so you look at the way these people are marketed,

of course, there are independent sex workers also marketing

themselves, but they are not describing their bodies as a

product, as an object. There are many indicators that would tell

us what kind of ad you're looking at, the type of emojis

used, or the number of times a phone number shows up, or even

their area codes. And you know, trafficking is a transient

crime, so we're looking at all of these factors. And it said

that every 30 or actually every minute. So every minute you can

see multiple ads being posted online in canada, okay? And this

is also very aligned with with global stats. Wherever human

trafficking is prevalent, every minute you have multiple new ads

posted. And, yeah, and these are human trafficking ads, is what

you're saying. So there are sex ads, but then in this pile, you

know, you can look at indicators that show you how exploitation

happens, like, who are the people behind these ads? Why is

the same person showing up over and over again on multiple forms

in multiple cities, for example, and what kind of language is

being used? And then you look at the metadata. There's so many

indicators, like the tattoos or tattoos that traffickers put on

their on their victims. These are like ownership,

like a brand.

Essentially, yes, victims are branded in the sex

trafficking game here and in the US. And so we look at all of

that. We also look at particular keywords. Like someone would say

no law enforcement or no, if you really want to get into it, some

of them would say no, no African American man or no on black

Canadians. And this is not to say that I discriminate against,

you know, certain types of clients. This is the trafficker

or the advertiser suggesting telling other pimps. Hey, this

is a pimp control person, so don't try to come here and steal

my pimp. Because, wow, yes, or sorry, steal my victim. So this

is also signal. So we're looking at all of these types of

indicators, and then we're trying to process the data,

figure out where these people can be found, and then

ultimately Hand over that data to nonprofits, to survivor

leaders who are in the business of doing outreach. That's how we

actually get the victims out, and that's why we know these ads

are working, because when the victims come out, they're

corroborating all this information, right? They're

telling us how they were trafficked.

And that's insane to me. And so your team of

volunteers are actually doing this open source work of reading

through and sifting through these ads and looking for some

of these indicators on these ads, and are then passing that

on to people who can affect change in the like, who can

actually get these, these victims out of their situations.

Is that what I'm hearing you tell me that your organization

does, that's so cool, by the way, but

yeah, we're all about making a tangible impact.

And by impact, I mean how many people we've saved so or not

saved is definitely not the right word extracted, I would

say. But remember, I told you, there are two very troubling

stats here, victim identification and prosecution.

So handing over that data to nonprofits is just one piece of

the puzzle. You cannot solve this problem simply by placing

victims in safe shelter, there will be more victims, and

typically, an average victim will be revictimized about five

to 13 times in her lifetime. And so yes, and that's because of

very complex issues, challenges like, say, trauma bonding or

debt or lack of services, or having children with a person

who is a trafficker, all of those zones.

So it occurs to me that, and this is true of so

many different ways of fighting crime, that the actual solution

would be to go after the traffickers somehow. And it

sounds to me like that's even more challenging is that, is

that what I'm hearing you kind of because if people are being

re victimized by the same traffickers, that tells me that

there's some sort of systemic problem that continues to exist

here. Would that be fair?

Yeah, I think traffickers seem to have an

impunity up until now, up until very recently, since we changed

our legislation a bit in 2014 we also had been really good at

punishing victims, right? Because victims are easy to

find. They are prostituting themselves. So you're going

after the lowest hanging fruit as law enforcement or. Used to

at least, and wow, you're quite right. When you change your

legislation, we say we decriminalize sex work for

victims. We only want to go after the traffickers. Now,

people are even more confused, because now we need a different

set of skills to actually uncover the complex like layer

of a trafficking network. And that's why the second piece that

we really care about is prosecution. And that's also

where our data is really very useful to a law enforcement, but

B, to anybody who is in the business of doing anti financial

crime and anti money laundering, like myself,

well, and this is where there's an intersection

that's that becomes interesting, and really Why, certainly,

we've, as a company, have become interested in this conversation

is, where is that intersect? What does that look like? What

Why Should those of us working in anti money laundering "A" I

mean, I think you've made, I think you've elegantly made the

case of why we should care. So I think we've probably covered

that. But then, what should we be doing? And what could we be

doing differently, and what, what are the indicators we

should be kind of thinking about as we go about our businesses?

Okay, that's a whole bunch of questions nested in one. So

unpack them as you want, and we can come back to some of them

for sure.

No, you're quite right. We don't always have to

appeal to your humanity to do something. Yes, everybody should

care. But what I find fascinating about our industry

is we are the best equipped to care because we have access to

data that I don't have as an open source investigator, I

don't have access to someone's PII, someone's transactions, and

so suppose I give you a whole bunch of data.

We are working on an API, right? So one day, say your firm comes

across an suspicious character who's trying to get buy a

property, and you use our API to look up the phone number, for

example. Now I can only give you the data that I see online that

is not privately personally identifiable information, but

you are equipped to then take that data, match it with your

consumer database and say there were some suspicions here and

now maybe we'll flag this person as a high risk or a person of

interest, and do our due diligence, do our enhanced due

diligence. So I think we are very well equipped to actually

make a difference and what we're missing, and maybe we will talk

more about that. What we're missing at the moment is

collaboration. We can all do this already, like a lot of

firms, private companies, have these transaction monitoring

tools that might very well be catching the data we do, but

ours is a bit more sophisticated in that we're looking at layers

upon layers of data that traditional adverse media

companies may not be looking at, and then we are also doing our

own manual investigations to supplement that. So I think we

can actually make a big difference by talking to each

other, talking to law enforcement and talking to

FINTRAC,

yeah. I mean, I think this is this has gone from being

a perfect Halloween episode to being kind of really kind of

positive, and giving me some hope, because I think we, and I

think a lot of our definition around human trafficking there,

our conversation around focused a little bit on sex trafficking

primarily, but I think there's just no question, and I guess

maybe that's one thing we should have delved into, and maybe

shouldn't, wouldn't mind going back to for a second, is what

other offenses are involved, are associated with human

trafficking, and what's the like? What's the harm to

society? We talked about the harm to the to the victims,

certainly. But what else has what is, what else happens as a

result of this, and what, what else is involved there? What are

the other predicate offenses?

I love that question. I think I should have

defined earlier, human trafficking is the second most

profitable crime after drug trafficking. So currently, you

know, we're talking about a two, $50 billion industry for all we

know now, that means this is one of the biggest predicate

offenses to money laundering, right? Or, if you like, the US

term, this is a specified unlawful act. Sua, it's one of

the big ones. Now, it's not just the exploitation of human beings

for sex and labor. There is a slew of other sorts of crimes.

Just like any other criminal enterprise, there is an

intersection, usually, of fraud, of identity fraud, of what we

call forced criminality. So now the victims, if they don't meet

their quota or to enhance their revenue, the victims will who

are serving all these clientele at night, they might be forced

to go and steal merchandise during the day. A and then their

accounts are used, and I've seen this in many Canadian cases.

Their accounts are used to conduct check fraud and all

sorts of wire fraud and all of that, and they're the ones who

have charges on their rap sheet. So there is this

intersectionality between I find, between drug trafficking,

especially on the west coast, where you are, and human

trafficking and fraud, and even narcotics trafficking and like

any kind of gang related activity, because here you have

a surplus of revenue which you can now use in any way you like,

well, and then you have a free pool of labor to if

that, and a free pool of labor that shields you from potential

criminal or that gives you some layer of protection from

protection from potential criminal charges, as it were,

it's funny, I, as we're talking through this, I remember a case

out of Ontario a handful of years ago where there was a home

listed by Somebody fraudulently, and it turned out that that

person was a human was being trafficked. There was no

question that that person was forced into that activity. They

had nothing to do with the actual fraudulent selling of the

house, made none of the proceeds of it, and their idea they were

just being used as the as the pawn in the whole kind of

scheme. So it definitely, I, I I have seen this case in in the

media, so it definitely is happening in Canada. And I

wanted to kind of step back to that, because I don't think we'd

fully tied that not together. So

about what it looks like, I think, yeah,

that's, that's where I think the next place, what

if I'm conducting my business? I'm I'm a mortgage

broker. I'm a real estate broker. My day to day practice

doing whatever it looks like. What? What is it going to look

like for me? And how might I be helpful in this whole thing?

Let's talk about some behavioral red flags first,

and then we'll talk about money laundering indicators. Too. So

behaviorally, suppose you're a realtor. You go to a place, and

if you're aware of the general signs of vulnerability, let's

forget that you're looking at different types of trafficking,

because here you could be exposed to sex trafficking or

minor trafficking, you know, child abuse material production

of that, which usually happens in a person's home, because it's

usually the family, right, that's conducting this activity.

Now, what are the signs of vulnerability? These are things

that are good to know. So you have a very average looking

people in a home, but then one person stands out. One person

looks vulnerable, malnourished, afraid, they don't seem to

really belong there. Or you may see multiple people. If you're

looking at a pimp controlled place, you may see that this one

is really interesting. You may see that there are internal

locks in a big house.

This one really stuck with me, and I was thinking

about this because I've, I've shown many homes over the years

that I thought were just student housing, and there's locks on

all of the internal bedrooms door, internal bedroom doors,

excuse me, but this is stuck with me because I'm I have seen

these houses, and I thought, that's probably student housing.

It never even would have occurred to me until our

conversation that this is something that might be an

indicator that should at least cause me to think a little bit

more about it. But I don't want to interrupt completely. So

please carry on, because these are super useful, but I really

wanted to highlight that. So

no, thank you for that interjection. And that

reminds me, it's just like a list of indicators when you get

them from FINtrack, a single indicator alone wouldn't tell

you what you're looking at, so you very comprehensive

understanding, and that's why looking at people and their

behavior, if something sticks out to you and somebody you know

that look of vulnerability when you see a person, a troubled

child, a bullied child, you know that you're looking at somebody

who needs help, but may not quiet, believe that he's a

victim or She's a victim herself, then there are some

tattoos. Like I said, teams or traffickers would have typical

tattoos. We know at least what some of them look like. Maybe we

can add them to show notes later. But you have these crown

tattoos. They are very or were very popular at least a couple

years ago, and still might be. You have usually, like,

someone's initials followed by the money, the dollar sign, or,

like, I've even seen something like property of this person and

tattoos in strange places too, like here, close closer to their

chest area or their shoulders. And then there is this question

about injuries, like, if there is force involved, for. Uh, in

typical cases, you know, no trafficker wants to damage their

products. And pardon me for sounding so coarse. I think,

because I speak to a lot of survivors, like this is the

language I pick up on, but no trafficker wants, yeah, so when

the beatings happen, when the disciplining happens, same with

children. It's usually going to happen in unusual places, like

but buttocks, or like the back, that people are not exposed to

their their thighs, or sometimes, if there are signs of

being dragged, then you see the knees can be scraped, but that

can happen to an average person. And then, if you're dealing

looking at a victim, who's dealing with a lot of buyers.

Buyers seem to exert force on their on their victims, I want

to say, and that's when you might see some typical injuries,

like you have the wrist injuries when people are restrained,

so that one could be visible to somebody just, you

know, I'm thinking through some of these indicators, and I don't

often see the buttocks of my clients, but probably better

that way, but certainly the risks that risks that's easy to

observe. And you know, if I were thinking through a situation

where, you know, you go into that house, and maybe somebody

does look like they're out of place, and then you observe the

locks on the doors. Maybe then I would start to pay attention to

the wrists. And hey, if there's some bruising on the wrists or

some chafing on the wrists, that would be another like I'm

starting to paint a puzzle here that starts to look compelling

and scary,

black burns like a lot of buyers, have this

paraphilia. You know, it's a very popular paraphilia. But you

know what really has stood out to me in my experiences, the

victim, who's truly a victim, doesn't have a lot of personal

possessions, so you might see someone has her all her clothes

in a garbage bag, and that means she's a transient person, and

now she's using a room, and all you see is a garbage bag or

someone who's wearing PJs in a very casual setting, but then

she doesn't have regular comfortable shoes, so PJs and a

pair of heels while she's limping Like all of these signs,

wow. Okay, now we've mostly talked about sex trafficking,

but what about labor trafficking? I think I was

asking you if you ever run into, like, say, new properties or new

new buildings, if you ever look at labor workers there? So

that's one place where you could find people who are scared or

malnourished again, people who look extremely exhausted. And

I'll give you an example. If you go to a really nice resort in

the Bahamas, you may not notice this, but say you go to a

relatively like average, below average resort in the Dominican

Republic, you will see a lot of migrant Haitian workers. They're

extremely exploited for labor. They have 15 hour shifts. See if

you can have a conversation with them in French Creole, and

you'll come to to see the signs of labor trafficking. So that's

what a construction worker looks like when they're fourth. ut

then they're also living in residential properties, right?

Like, seen one in Hamilton, Ontario, about, I think 10 years

ago, actually, yeah, one of the survivors, I know very well, he

was extracted from that ring. This was a family in Hamilton,

and they were in the construction business. They had

about 15 to 20 Hungarian men in their basement right sleeping on

these mattresses, and all of them had interacted with a major

Canadian bank, because they'd all open these debit accounts

where they were collecting some sort of benefit. I don't, I

don't remember which one it was, and the traffickers had access

to their debit cards in their bedroom. So like you might see

some of these signs, like, why are there so many mattresses in

the basement?

I was gonna say that's a really good one that

you could easily as a as a realtor, you go through a house

for whatever reason, thinking, listing it, working with a

buyer, whatever it is that would that wouldn't necessarily have

stood out without this background of how that actually

plays out in real life, in our Canadian society, already,

that's a that's a fascinating indicator for sure.You would

talk to we talked a little bit about behavioral stuff, and I

think that's probably where I think it is. Realtors and

mortgage brokers have the most opportunity to learn, because

Realtors do actually physically get into homes. And there is

some some stuff there. We've talked a little bit about that,

but the behavioral stuff was interesting, too. And I think

one of the things you'd mentioned when we first talked

was around this idea of like somebody clearly puppet

mastering a transaction from and maybe not ever being present.

During showings, walk me through why that might be important to

as an indicator.

Okay, so you're looking at an organized crime

here, and let's talk about the most successful of human

traffickers. We'll get into, like, particular types of human

trafficking in a bit sex trafficking in a bit, but let's

just say, an average trafficker can make one to $2 million a

year per victim, and if they're multiple victims, that's a lot

of money. So that's a lot of money they have to move. But

that also means to manage all of these victims and this business

enterprise, they also have a lot of conspirators or a lot of

brokers, nominees, all of that.