Towards operational cooperation on local administrative financial investigations in the fight against human trafficking

Local city government is confronted with indications of human trafficking:

• in the hotel and catering industry (cafés, bars, private clubs), massage salons, establishments for sexual activities, buildings for (window) prostitution, , - (= sexual exploitation)
• in hand-carwashes, night-shops, betting centers, housing foreign workers (= economic exploitation)
• in the public domain (= begging)

These indications are apparent in reports concerning the disturbance of public peace (bothersome and irritant behaviour, overpopulation, rent of mattrasses, illegal employees and (possible covert) forms of prostitution). These indications are reported by neighbourhood workers, police forces, civilians and city administrations.

Some of these establishments are subjected to an obligatory permit by local aministration, as a result of which several checks are performed (compliance with building regulations, integrity of the applicant, financial situation of the business, ... ) However, the financial screening is limited and often fails to identify criminal activities which could lead to a refusal of the permit. As a result, human traffickers are able to use legal economy to facilitate and sustain their criminal activities, sometimes even supported by government subsidies.

A thorough financial screening could provide clues of human trafficking, both during the screening process of the requested permit, as during the business operation. This also includes a thorough scrutiny of the legal forms of company, assets and deposit money flows. Reports of bothersome and irritant behaviour or slumlords might not be related to human trafficking on first sight, but broader screening could reveal clear links.

This project proposal aims to organise a financial screening of the different sectors mentionend above. Said screening would focus on financial criteria that seem to point to human trafficking. As such, human traffickers are denied the opportunity to develop their illegal practices. At the very least human trafficking could be detected and stopped in very early stages. In Belgium, the mayor has the authorization to close down an establishment when there are serious indications of human trafficking, provided he has deliberated with the public prosecution.

A financial screening as described above would require:

• An investigation into the financial criteria that could point to human trafficking
• A systematic screening of open data sources, such as the Registry of Commerce, cadastral data, official publications of enterprises (locally, nationally, internationally)
• A structural collaboration with tax administrations, Carin , Belgian Fiancial Intelligence Processing Unit (CTIF-CFI), fiscal investigation units, the public prosecutor’s office, police forces and other national and international financial serviceproviders
• Scientific research into the possibilities local administration has to obtain financial information regarding the concerned businesses;
• Develop systems to exchange financial information with different stakeholders, within legal boundaries and legal framework

The project will result in a clear methodology to develop operational cooperation in administrative financial screening. Immediate beneficiaries will be the local administrations fighting trafficking in human beings (THB), as well as their (judicial and financial) partners fighting organized crime in general. European decision makers will profit from the scientific advisory report.

The project aims to organize 2 operational workshops, an intermediate seminar, a dissemination conference, and training of municipal staff. This will result in a manual, a scientific advisory report, and training syllabus that can be used in any other European municipality.