Guide on Following the Money in Trafficking in Persons Cases

Behind trafficking in persons lies a complex web of illicit financial flows

Trafficking in Persons (TIP) continues to be a harmful and pervasive crime across the Asia Pacific region. It exploits women, men and children, and diverts billions of US dollars in illicit proceeds from the legitimate economy into the operations of transnational organised crime.

Trafficking in persons is profit-driven

USD $236 billion

The economic impact of TIP is difficult to measure, however, the International Labour Organization (ILO) estimates that the profits from forced labour amount to USD $236 billion per year.

USD $9.9 billion

In addition, scams were one of the biggest drivers of cryptocurrency-based crime, accruing at least USD $9.9 billion in 2024. However, these estimates of illicit proceeds likely represent only a fraction of the total scale.

More than 70 countries affected

Hundreds of thousands of nationals from more than 70 countries have been reported to have been deceived and trafficked into cyber-scam compounds in Myanmar, Cambodia and Laos.

Take the profit out

Strategies that ‘take the profit out of crime’ have seen success at identifying, investigating and disrupting transnational crime. Over the past decade, ‘following the money’ has become a core part of the response to a range of transnational crimes including TIP.

Relationship between financial and trafficking investigations

Financial investigations and TIP investigations serve distinct but complementary purposes. While TIP investigations typically focus on identifying and prosecuting perpetrators, and protecting victims, financial investigations centre on identifying, tracing, seizing and confiscating proceeds of crime. It is strongly recommended that financial investigations run concurrently with TIP investigations to maximise impact, improve evidentiary outcomes, and identify broader criminal networks, assets and facilitators. This guide focuses on TIP investigations and the intersection with the laundering of illicit funds associated with these cases. While TIP comes in a number of forms, some of which overlap, this guide will focus on the following types of trafficking:

Trafficking in persons for the purpose of forced labour involves the recruitment, transportation, transfer, harbouring, or receipt of persons by traffickers, including transnational organised crime groups, through means such as coercion, deception, abuse of power or of a position of vulnerability, or debt bondage, for the purpose of exploitation.

Forced labour encompasses any work or service extracted from a person under the menace of penalty and without their free and voluntary consent, including the freedom to leave at any time.

The recruitment, transfer, harbouring or receipt of a child through deception, coercion, or abuse of a position of vulnerability, where digital tools and online platforms are used to facilitate any stage of that process, for the purpose of sexual exploitation.

The exploitation itself may take a range of forms, including the production, distribution, or possession of child sexual abuse material (CSAM); the live-streaming of child sexual abuse; the grooming of a child for sexual purposes; or the sexual extortion of a child. In some instances, the abuse is committed or directed entirely remotely, without any physical movement of the child.

Forced commercial sexual exploitation involves compelling a person, through force, coercion, abduction, fraud, deception, abuse of power or of a position of vulnerability, or debt bondage, to engage in commercial sex acts for the financial benefit of another.

Exploitation can include forced prostitution, sexual servitude, or the use of victims in the production of sexual abuse material. The consent of a victim is irrelevant where any of the above means have been used.

Trafficking for the purpose of forced criminality is a form of trafficking in persons in which victims are exploited through being compelled to commit criminal acts for the economic or other gain of traffickers or exploiters.

How illicit proceeds are laundered

The Financial Action Task Force (FATF) describes money laundering (ML) as the process of making the proceeds of crime appear legitimate, typically through converting, transferring or concealing illicit property to hide its criminal origin and prevent legal consequences. While the ML process can include various steps, it is usually separated into three broad stages:

Placement

Placement involves bringing the illegal funds or assets into the financial system. Methods employed may include depositing cash into bank accounts or purchasing assets with cash.

Layering

Layering involves concealing the illegal origin of the placed funds by moving or disguising them. At this stage, the objective is to obscure the illicit origin of the funds through a series of complex transactions.

Integration

Integration occurs once the funds are layered and distanced from their origins and can be made available for criminals to use and control as ostensibly legitimate funds through being reintroduced into the legitimate economy, making them available for use by criminals as seemingly clean money.

A gap in awareness

A significant challenge in harnessing financial investigations for effective counter-trafficking efforts remains a lack of comprehensive data and risk understanding across countries. For example, a 2018 FATF report on TIP-related financial flows examined 28 National Risk Assessments (NRA) from a range of jurisdictions. Only 14 of those identified TIP as a ML risk and only four classified such risks as high.

Money laundering threats in trafficking in persons

Rapid evolutions in technology, such as artificial intelligence (AI), digital identities and virtual assets (VAs), have led to drastic changes in the transnational crime landscape. Select a threat to explore more.

Virtual assets

Virtual Assets (VAs), encompassing non-fiat digital representations of value, such as cryptocurrencies, have become integral to the global financial landscape. While they offer innovative solutions to issues such as financial inclusion, their characteristics, such as anonymity, decentralisation, and rapid transaction capabilities, make them susceptible to misuse by criminal entities, including those involved in TIP.

The swift advancement of VAs and their supporting technologies often outpaces the development of regulatory frameworks, creating vulnerabilities and gaps that traffickers can exploit.

FATF found in April 2025 that 70 per cent of jurisdictions which had been assessed for compliance with the FATF Standards for VAs and Virtual Asset Service Providers (VASP) were found to be partially compliant or non-compliant.

Conducting financial investigations and spotting the red flags

Effective financial investigations involve looking beyond individual transactions to identify patterns, trace the movement of funds and detect indicators of trafficking-related activity. This requires understanding how money moves through different channels. Swipe through to explore the red flags.

1. Cash, accounts and financial institutions

🚩 Late-night cash activity

Cash deposits or withdrawals between 10 p.m. and 6 a.m.

🚩 Multiple small deposits

Small cash deposits across different bank branches, ATMs, cities or provinces.

🚩 Rapid cash movement

Large cash deposits followed by rapid withdrawals, bill payments or transfers to third parties.

🚩 Multiple hotel bookings

One individual booking multiple rooms for the same dates.

🚩 Pass-through accounts

Funds received from multiple third parties and quickly forwarded or withdrawn, leaving a consistently low balance.

🚩 Employer repayments

Payments deposited back into an employer’s account by a suspected victim.

🚩 Intermediary payments

Payments routed through intermediaries instead of directly to employees, suggesting wage withholding or forced labour.

🚩 Low-value transfers

Frequent low-value transfers associated with subscriptions or access to content in cyber-lockers.

2. Money value transfer services and virtual assets

💰 Informal financial networks

Underground banking, non-bank cross-border transfers, small-value payments, cryptocurrency, mule accounts and unlicensed brokers.

💰 Anonymous virtual asset transactions

Privacy coins or decentralised exchanges without know-your-customer (KYC) procedures.

💰 Rapid cross-platform transfers

Quick transfers across virtual asset accounts, platforms or jurisdictions, potentially indicating layering.

💰 Rapid deposits and withdrawals

Virtual assets promptly withdrawn in a different form or through another platform.

💰 High-risk IP addresses

Transactions linked to regions with weak AML regulations or known TIP activities.

Building an effective, holistic approach

Effective trafficking in persons responses require collaboration among government, civil society and the private sector. There are several foundational building blocks to support effective follow-the-money approaches for TIP, at all stages (prevention, identification, investigation, asset tracing/confiscation and prosecution).

Select an option below to explore the key building blocks of effective approaches:

Legal and regulatory frameworks

Legal and regulatory frameworks, including sufficient AML, international cooperation and asset confiscation regimes.

Some BPMS report lengthy delays and hefty administrative burdens in pursuing conviction-based confiscation (CBC) actions. As an acceptable alternative that complements traditional CBC regimes, non-conviction-based confiscation (NCBC) frameworks enable law enforcement to seek confiscation in the absence of a criminal conviction, but where the link to criminality can be demonstrated to the civil standard of proof.

Next steps

▶️ Enhancing information gathering

Improve information gathering and sharing, map financial flows, identify new trafficking routes and document evolving recruitment tactics.

▶️ Investigating enabling environments

Investigate enabling environments, key financial facilitators and institutional vulnerabilities to disrupt trafficking operations at their most vulnerable points.

▶️ Implementing holistic, multi-stakeholder approaches

Combine ‘following-the-money’ approaches with victim-centred approaches, involving financial intelligence units, law enforcement, civil society and the private sector.

▶️ Expanding beyond formal financial systems

Address the use of informal financial networks alongside formal financial systems, balancing AML regulations with targeted interventions in informal financial systems.

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