Ending Human Trafficking Podcast

346 – Leveraging Financial Tools To Disrupt Human Trafficking


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Derek Marsh joins Dr. Sandie Morgan as the two discuss leveraging financial tools and intelligence as core investigative strategies to disrupt human trafficking operations and improve survivor restitution outcomes.

Derek Marsh

Derek Marsh is the Associate Director of the Global Center for Women and Justice and a deputy chief with extensive law enforcement experience. He has been a frequent guest on the Ending Human Trafficking Podcast and led a recent roundtable discussion on following the money in human trafficking investigations. His background includes hands-on experience with trafficking investigations and a deep understanding of the collaborative approaches needed to combat these complex crimes.

Key Points
  • Financial intelligence serves as a core investigative tool that provides a clearer perspective of criminal organizations than traditional methods relying on confidential informants or victim testimony.
  • Sophisticated money laundering patterns include funnel accounts, structured cash deposits, and geographically patterned movements that help traffickers hide the origin and legitimacy of their funds.
  • Financial investigations can expose connections between what appear to be separate crimes, revealing larger criminal enterprises rather than isolated “mom and pop” operations.
  • Suspicious Activity Reports (SARs) generated by banks when they detect unusual deposit patterns provide valuable intelligence for law enforcement agencies investigating trafficking operations.
  • Advanced software tools like those from Valid8 Financial can visualize complex transaction flows and present financial data in comprehensible formats for courts, making cases stronger and easier to prosecute.
  • Geographic analysis of financial flows reveals high-risk corridors between certain countries that banks monitor for potential criminal activity, such as Nigeria to Italy or Philippines to Europe pathways.
  • Human trafficking investigations require multi-agency collaboration because finances cross jurisdictional boundaries as easily as phone calls or internet connections.
  • Public-private partnerships with banks, corporations, NGOs, and faith-based organizations create interlocking layers of expertise that strengthen investigations globally.
  • Financial tools enable law enforcement to seize assets and freeze accounts tied to trafficking operations, providing funds for survivor restitution that has historically been difficult to collect.
  • Using financial intelligence reduces the burden on survivors to testify in court by providing concrete evidence that doesn’t require victim testimony to prove criminal enterprise operations.
  • The approach transforms financial intelligence into justice by treating human trafficking fundamentally as a financial crime that exploits people for profit.
  • Training law enforcement on financial investigative techniques and providing AI-enhanced tools are essential since most officers lack accounting expertise needed for complex financial analysis.
  • Resources
    • Derek Marsh
    • Valid8 Financial
    • Roundable Notes (coming soon)
    • 341 – Following the Money
    • Transcript

      [00:00:00] Sandie Morgan: Welcome to the Ending Human Trafficking Podcast. This is episode number 346, leveraging financial tools to disrupt human trafficking. I am very happy to be joined here in the studio by Global Center for Women and Justice Associate Director, deputy Chief Derek Marsh.

      [00:00:28] We have been working together for a very long time and he’s been a frequent guest here on the podcast, so I’m not going to include a bio, but you can go back to the website and learn more from his perspective. By just searching our episodes with the name Derek Marsh. So we’re gonna dive right into the financial aspects.

      [00:00:53] We recently interviewed David Tyree on following the money and we talked to, um, district attorney Ryann Jorban along the same lines.

      [00:01:05] Today we’re going to look at this from a broader perspective, after having had a round table on following the money here at Vanguard University led by Derek Marsh, and let’s just get some understanding of what the key strategies and insights are.

      [00:01:26] That we were able to glean from that round table, and that will lead us into some action steps. So welcome Derek.

      [00:01:45] Derek Marsh: Thanks for having me again, Sandie.

      [00:01:47] Sandie Morgan: So, who else was at the table?

      [00:01:50] Derek Marsh: Well, besides you and myself, David Tyree, our expert from the, retired DEA agent, but also working with Valid8 Financial. Now, we also had Ryann Jorban, who’s an A DEA with Los Angeles, District Attorney’s Office, but we were also lucky enough to have a couple professors from here at Vanguard University.

      [00:02:09] Professor Julius Angbor, who is a marketing and business expert, specifically in international business issues, focusing mostly in Africa and that region of the world. We also had assistant professor, Dr. Thomas Ropel, who was a retired FBI agent, who was able to focus on the collaborative strategies used by the federal agencies to work on human trafficking and exploitation types of investigations.

      [00:02:35] We were also lucky to have assistant director of the US Department of Labor Wage in our division, Paul Chang, who was one of our favorites we’ve had on before. Uh, and he was able to discuss specifics about labor trafficking, where we’re finding a lot of labor trafficking occurring and how that process occurs.

      [00:02:53] And we were also able to have, members, from Valid8 Financial actually show up and discuss their software and give us a demonstration to show how all these. incredible amounts of data that would take a regular person, you know, hours if not weeks, to put together their software is able to put together in a matter of minutes.

      [00:03:12] It was amazing. So, we had a good group of people who we could discuss this with. And, and finally, I don’t wanna lose this out obviously, but we had, Linh Tran, who is our task force administrator, In charge of the Orange County Human Trafficking Task Force has been for years, ever since even I was there.

      [00:03:30] So that’s like dating myself or dating her, I’m not sure which, and finally we had, of course, John Cotton Richmond, who, was gracious enough to spend some time with us. He was our, previous human trafficking, czar, maybe that’s the wrong word to use, but that’s, you know, our previous human trafficking, director for the United States and the State Department.

      [00:03:52] And he was also, actively participating in, in the discussion helping us understand, uh, federal perspectives and where we’re moving forward with financial investigations and the financial tools that can be used.

      [00:04:05] Sandie Morgan: And, and I think this round table demonstrated how broad the element of following the money as across our movement.

      [00:04:18] We’re looking at law enforcement, we’re looking at prosecutors, but there’s also this sense that the element of restitution is more attainable for better victim outcomes, and that’s what drove me. You all know my background in pediatric nursing, so a lot of this was foreign language for me. So while Derek and I break down an executive summary of what happened at that round table, I’m the one whoDoesn’t understand even what a forensic accountant does.

      [00:04:54]  So I’m gonna help stop him when it sounds a little too complicated so that I can put it into my normal context. Is that okay with you, Derek?

      [00:05:11] Derek Marsh: Perfectly okay. Frankly, I don’t wanna pretend I’m an accountant at heart either, but I, I do love the numbers and I, I love the fact that, uh, numbers don’t lie. That the reality is that they can hide things, hide people, hide locations, hide phone numbers. But when you get ahold of the accounts and you’re able to track those accounts and where money’s moving, it really gives you a crystal clear perspective of the

      [00:05:33] criminal organization that is running any kind of a human trafficking operation.

      [00:05:39] Sandie Morgan: So our first. Key strategy is built around the aspect of financial intelligence as a core investigative tool. And when I first started hearing the group around the table talk about financial intelligence, I kind of reduced it to my understanding of, oh, we need financial literacy. And then I began to see there was a huge world I had never explored, and that is an area of data that, we need to understand.

      [00:06:18] Can you unpack that for us?

      [00:06:20] Derek Marsh: I will try. Again, Um, still getting to know, some specifics about this, but lemme go back to a time when I was actually wearing uniform and we were doing investigations where we would run into these sex trafficking operations, labor trafficking organizations, and

      [00:06:36] we would look for money. We really couldn’t find that much of it. And we’re trying to figure out why is that? We know money’s a major, major motivator for this, and saving money’s great, but we know that they were also producing money and we just couldn’t seem to get a hold of it. Understanding that financial intelligence as a core investigative tool kind of flipped the switch for me.

      [00:06:54] As far as perspective with the idea is instead of looking at any organization is basically a financial, Method to which finances are moved. You know, places are supported, people are supported, people are charged. All of that became kind of, it almost felt like saying “duh”, because it was just so intrinsically basic that we’ve been relying so much on.

      [00:07:19] confidential informants or going on the web and trying to solicit, people to in initiate an investigation or maybe relying on past, victim survivors who could share with us what they thought was going on. Whereas if we were to go into these, financial records of these different organizations, we would’ve had a much cleaner perspective and been much less reliant on our victim survivors to provide evidence to substantiate these criminal organizations.

      [00:07:48] Sandie Morgan: So some of the patterns that you’re looking for, use terminology. That is new to me. “Funnel accounts”, “structured cash deposits”, “geographically patterned movements”. Can you break that down a little bit?

      [00:08:06] Derek Marsh: I will try, but it’s still, it’s still a little bit of Greek to me as well. The idea here is that you have certain accounts that roll over and are pushed forward to different, different locations.

      [00:08:17] So you might start at this bank and then have it a certain amount rolled over to the next account, then a following bank account. So you have to, there’s actually a trail that’s left, but the more they move it, the more difficult it is. To identify where the money initially came from and it, and its legitimacy also, you find that they move locations as well.

      [00:08:36] So maybe you start with a bank here in the United States of America, but then you’re at the Grand Caymans and maybe you’re in Switzerland next and maybe you’re wherever. And it keeps making circles coming back to where people are able to access it. So by the time you see the money or those people are able to access the money, It’s so deep into this, electronic transferring that anybody just looking at normal accounts would see transfers in and out, but they wouldn’t be able to follow the money from the point of origin where the trafficking occurred or where the money’s being, taken to the point where it’s actually being used to facilitate organizational goals and missions, which in this case are criminal.

      [00:09:16] So. These types of operational dynamics are important for us to understand how this organization is structured and also understands how extensive that organization may be. We, you know, we talk about mom and pop organizations versus criminal enterprises. Will the financials really support? Whether it something is really just a mom and pop organization, maybe just does one or two jumps in a financial stream and it stops, versus having criminal enterprises where it may, it may have 15, 20, 30 different stops at.

      [00:09:49] Different bank accounts may not even seem to be cross related to the bank account before or after, but then in essence are the way that they’re hiding this money, they’re funneling this money, they’re laundering this money basically, to make it more, seem more legitimate, so that the organization can use it to further their criminal enterprise.

      [00:10:07] Sandie Morgan: So that kind of financial investigation can actually expose those kind crimes that are connected and that we’re looking at them as separate crimes, but they’re really part of

      [00:10:22] a network, an enterprise is the language that you’re using.

      [00:10:26] Derek Marsh: Right. I, I look back at some of the things we, we found when we were doing our investigation, some of what we considered mom and pop organizations for sex trafficking and for labor trafficking.

      [00:10:36] And now having, again, Paul Chans insight into how these are, are run. Also, seeing how these financial insights can be provided. It makes me wonder if we were just being naive and shortsighted and not realizing that they, they all worked the same way, but they didn’t seem connected. But if we’d take the time, had the resources to follow the money, that I think we would’ve found that there were a lot more connections and a lot larger criminal enterprise than we initially suspected.

      [00:11:01] Sandie Morgan: And from my side of the perspective on victim services, victim, restitution, one of the things that happens when you start using finance as a core investigative tool is.

      [00:11:20] We can prove things without making a survivor testify in court, publicly facing her abuser. So there’s some intangible rewards, not just financial.

      [00:11:37] So I, I was thinking about the structured cash deposits that are part of what they follow and I remember someone talking at their table about how they avoid being detected by some of the alerts we have in accounts by depositing just under the limit before it rises to the level of investigation.

      [00:12:05] And our group talked about how the SAR can be part of our strategies. What is that?

      [00:12:15] Derek Marsh: So SAR stands for “suspicious activity reports” that banks are required to share with different agencies. If they find a singular deposit or a pattern of deposits they, they believe might be. Generated through criminal enterprise.

      [00:12:33] Now, how they determine that I’m gonna defer to David Tyree every day of the week. ’cause I mean, he’s the man when it comes to understanding that and articulating better. However, what these reports are do is they’re, they’re, they’re sent to various federal agencies, which can either act upon them or not act upon them.

      [00:12:51] The challenge is if they’re able to take those reports and able to go through the various deposits and movement of money sufficiently to be able to establish any kind of pattern or practice behavior. And obviously I think most, most people who don’t understand accounting, and I’m gonna have to raise my hand here and say I’m not an accountant.

      [00:13:13] I don’t even pretend to be one. Are gonna have a hard time looking at some of those numbers. ’cause my extent, my sense of understanding is like looking at my paycheck, sorry, looking at my paycheck and following it into my bank account and realize it got deposited there. I’m pumped. So these are way more complicated and way more intricate.

      [00:13:29] And as a result they were, that’s when David and our, our, our friends from Valid8 Financial, were able to. Demonstrate how their software is able just to take these sheets and sheets of papers and make sense out of it and connect the dots, where just looking at a document would prove nothing other than, yeah, I’m looking at a document.

      [00:13:48] It looks like an Excel spreadsheet that has no intrinsic meaning to me, and no way of connecting the dots.

      [00:13:54] Sandie Morgan: So visualizing those transaction flows instead of just, engaging in actual accounting, adding up the numbers is a different way of using financial intelligence in the investigation process.

      [00:14:16] And if you wanna go back and listen to our interview with David Tyree, it’s episode number 341. And frankly, I had to listen to it three times, so you might wanna set aside a little extra time because there’s a lot of, content in his explanation. And I think it’s important for us as local advocates, even though this seems like it’s way beyond, what the average person is going to be able to apply

      [00:14:51] It does give us an edge in asking questions and finding ways to get the right people with that expertise at our table in our courts and our, investigations.

      [00:15:08] Derek Marsh: Sandie, you mentioned courts, and I think it’s important we remember that the, the beauty of some of this investigative tools and these methods and this software is that it presents this data in a comprehensible format. So instead of an investigator testifying, “Hey, you may not see it, but I’m telling you it’s really there”, and everyone’s saying, well, that’s not quite good enough to prove evidentiary value, they’re able to create re.

      [00:15:32] Ports showing link analysis and other types of pictures and images that represent flows of money back and forth, who it’s going to, what accounts it’s coming to and from the amount that it’s coming to and from making it. Very easy for both prosecutors, defense attorneys, suspects, and our judges to have a better understanding of what’s being presented in court so they can decide if this really does substantiate the claim that these persons or individual is part of a criminal enterprise.

      [00:16:07] Sandie Morgan: So, I know that. With the kind of data that’s out there. Now, my family knows where I am most of the time. I’m assuming that probably my financial institution can figure out where I am depositing money from or withdrawing if I’m withdrawing from an ATM in another country.

      [00:16:32] And this aspect of investigation that is location centered seems to be able to add to our ability to corroborate a victim’s story in other elements in, in our investigation. Can you expand on that?

      [00:16:54] Derek Marsh: Sure. So I mean, and what, like you were saying, if some credit cards are generous, some are not so generous. You know, you can leave the country if you don’t notify your credit card, they’ll shut down any transaction occurs internationally.

      [00:17:05] But I get notifications every once in a while saying, “Hey, is this particular activity relevant to you? Did you actually charge this to your account?” And I think we’ve all experienced that to some degree. Technology’s kind of a world where the, the, the bank has an algorithm. They have a way that you usually spend your money and if something falls outside those parameters, they’re checking in on you.

      [00:17:26] They don’t wanna inherit that debt, especially if you’re gonna deny it. Well, that same thing works on the international level as well. The idea that there are certain streams, location to location of financial flow that have a high chance of being suspect of criminal activity. For instance, there’s a Nigeria, Italy,

      [00:17:46] pathway of funds that it makes, banks quiver in their, in their, in their vaults, if you will, to, to realize that maybe something isn’t all, all right in Denmark there, or maybe the Philippines to Europe. I mean, all of these, and there are multiple, many, many more of those, but I’m just throwing a couple off.

      [00:18:04] The idea being that certain location, two locations can potentially raise red flags. That there is potential criminal activity gone. Even if it’s the transactions, it may seem legitimate. Even if it’s going from a church to a church or it’s going from a gov apparent government organization to apparent government organization or a government organization to an NGO, they are able to look, they’re able to see those risk-based locations, risk-based, transactions, and they’re able to generate either those suspicious activity reports.

      [00:18:37] or they’re able to pay more attention to those to see if they need to generate an SARI to let law enforcement know there may be illicit crimes occurring. And these particular corridors are funneling locations are being used to facilitate that criminal enterprise.

      [00:18:57] Sandie Morgan: So that geographical piece leads me then into thinking about how some of our old paradigms for investigation that, have to do with, this is my territory. this, my investigation ends at the county line.

      [00:19:17] How do we overcome that by creating some way to collaborate across that kind of geographical, restriction?

      [00:19:28] Derek Marsh: I think from day one, we just have to accept that human trafficking cannot be done on an island.

      [00:19:35] You just cannot have one agency that is responsible for an entire case. I think I’ve told the story before where on the first trafficking investigation, we tried to try to do it independently. I was kind of arrogant. I felt like, Hey, we’ve done other investigations without outside help. I should be able to handle this internally.

      [00:19:53] And found out very quickly the complications involving victim witness assistance. the complications involved with having international, suspects involved, having international connections involved where they were transported from a foreign country here to the us. All of those things were way outside my capabilities handling.

      [00:20:12] So you have to collaborate, you have to have multiple agencies getting together to work this out. And now we’re finding that, And not really a surprise, but I think just something that just doesn’t normally hit in most investigations from a local or even a, a county based investigative team is we need to look at finances as being ultimately the most mobile thing out there.

      [00:20:33] I mean, think about it, our phones, cross state and country barriers. Without a blink, we, you know, I can call and we’ve done it. Now, we’ve done our travels, we’ve called home. No, no. It sounds like we’re next door. It is. No big deal. So same thing with finances. They get moved as quick as you can. Your internet connections are bouncing all over the world, you know, as they validate and go across different countries and different states and different, areas.

      [00:20:55] So it’s not surprising to find that we have to think if human trafficking is being a much more sophisticated financial network than we originally suspected.

      [00:21:07] Sandie Morgan: So, you know me, I’m not an athlete and I, I resist all of those sports analogies, but for me, when I started beginning to understand the conversation around that table about all that bouncing

      [00:21:23] It’s like we have to have our teams where we’re passing the ball between the players, the players in the uk, the players in Africa, those kinds of global models, And how do we do that when, It can’t all fit through governments because often the governments don’t have those kinds of connections.

      [00:21:52] Derek Marsh: Well, and that’s where you come with your public private partnerships. That’s when you’re looking at connecting businesses together that might be able to support or help validate what’s going on.

      [00:22:01] A bank is a business, if you wanna think of it that way. Yeah. Corporations, right? So, you wanna think of NGOs. ’cause here’s the thing. Not all NGOs just stay in one spot and they’re singular. We have international NGOs all over the place that we can connect with and move forward. We have faith-based organizations that are internationally, located.

      [00:22:20] So if you need help identifying people or providing resources, or even being able to host, you know, investigators when they go to these different locations, then they’re out there as well too. I think that there are a, a group there, there’s a large number of opportunities here where your private groups, your, especially your business partners, your corporations, can really contribute significantly and positively to not only providing, helping provide the tools that make these investigations so much more coherent and understandable to judges and prosecutors and to investigators, but also the idea that these public-private partnerships help build multiple groups of interlocking layers so that they leverage everyone’s expertise to create a greater whole than they would ever have individually.

      [00:23:15] Sandie Morgan: Wow.

      [00:23:17] It’s still a bit complicated. I may have to listen to this episode three times, but, I wanna come down to the reason I was at the table, the idea of survivor centered restitution and financial empowerment. How is this going to be more than just about catching the bad guys another way to capture somebody?

      [00:23:43] Derek Marsh: Well, Sandie, I share your frustration.

      [00:23:45] I know in California and just about every state in the United States, including our federal government, restitution is mandatory. Our victim survivors need to get money to compensate them, for them to start standing up on their own and re recompense them for what’s occurred to them. You can’t unwind and exploitation.

      [00:24:01] I’m not pretending that, but at least you could put, put them in a better financial position moving forward, so they can be, have a better chance for success. So when you’re using financial software to identify the account and identify the amounts of money, who the players are, the locations that there are, how they’re spending or not spending the money, this allows you to be able to do what cops love to do is seize things right?

      [00:24:24] And obviously legally we’re not just out there just to robber bear in the world. But the idea here is that if we’re able to find this money that historically has been so difficult and so ephemeral and difficult hold of, now we can find these bank accounts that are. Obviously facilitating the criminal enterprise, lock those monies down and then start using that money to pay restitution to our victim survivors based on whatever the amounts are that are reasonable and are mandated by whatever statute you’re following.

      [00:24:56] In addition to that, besides just having your victim. Victims be compensated, or survivors being compensated. This can, all, this money can also be put together to help, fund further investigations and to fund further victim services. So it, it works for everybody. It’s a win-win across the board. The criminal enterprise loses the money upon which it’s, it’s based, it’s gonna be disrupted if not dismantled the,

      [00:25:22] Victims are getting restitution. And maybe even if we’re, if we have, we’re able to find sufficient funds, maybe even get a little compensation for the time of during the investigation and for the victim services that are going to have been provided and will need to be provided moving forward. ’cause you know, our victims just don’t get better the minute they’re released from the are liberated from these situations.

      [00:25:43] And finally, it’s also something that we can do as far as making it clear for the courts. So that we can make sure that these people are held accountable. Maybe not just criminally, but also civilly and administratively as well. Paying fines to those agencies that have been, circumvented those rules that have been ignored so that we can help support other agencies out there and other, public-private partnerships, if you will, to move forward and sustain the effort that we’re trying to maintain.

      [00:26:15] Sandie Morgan: So let’s think through, if we want to call our listeners to action, what are some areas that deserve our attention?

      [00:26:26] We don’t know all the answers, but we are going to be seeking out experts to provide this kind of knowledge base on

      [00:26:35] the ending Human Trafficking podcast. So let’s talk about that.

      [00:26:39] Derek Marsh: Well, I think number one, and it sounds like, I think this is the answer just about everything we started, it was like training, training, training.

      [00:26:45] We have to get people to articulate better that I’m articulating to you now, but to to not only articulate, but understand the importance and significance of using financial tools and financial investigative techniques to supplement human trafficking investigations and show positive results. I think that’s number one.

      [00:27:04] Number two, you’ve gotta find ai, you know, artificial intelligence enhanced tools to help us do that work. Because the reality is there are many, many officers out in the field over a hundred thousand, right? But guess what? Not all of ’em are accountants. In fact, I would guess most of ’em are not. And I think that.

      [00:27:20] That’s why you need these tools to supplement the efforts and make them work well. The other thing we need to understand is there is cross border legal and data sharing frameworks. We need to understand, respect, and follow to make sure our investigations aren’t. usurped by evidentiary problems or by misunderstandings across borders so we can make sure that we hold everyone accountable and liberate the people who need to liberate as well.

      [00:27:48] And finally, we have to maintain, like we always do, our survivor victim-centered, trauma-informed approach across the board, enhance those restitutions that we are unfortunately not capable of enforcing all the time. Even though they may be levied against a group, they may not be able to afford it and they’re not able to afford it ’cause we can’t identify the financial

      [00:28:11] pathways and the accounts and all of the intricacies involved with the whole finance of these operations. But if we have this software, we’re able to freeze those accounts, you know, use those SAR effectively, then we’ll be able to recoup much more money.

      [00:28:27] Provide those needed services and they that can be paid for through the restitutions and help these people start in a much better place than square one with dime zero and having to rely and  continue to rely on other people to move forward in their lives.

      [00:28:45] Sandie Morgan: I think my favorite quote at the end of the round table regarding survivors

      [00:28:55] is that this kind of investigative tool translates financial intelligence into justice.

      [00:29:03] Wow. Um. Ultimately, human trafficking is a financial crime. Ambassador Richmond wanted to be at the table because that has been his mantra from the time he was a DOJ attorney all the way through his, service at the State Department, and so many people in this movement. Are beginning to grasp that this is not just a horrific human rights issue.

      [00:29:39] It’s not just about sexual exploitation. Even when we use the word exploitation, it implies a financial crime. So we need to up our game in having tools. To investigate the financial side of things. So we wanna call you to start doing your own digging, find out what tools are there, and look up our friends at

      [00:30:07] Valid8 Financial. Go online and read the executive summary. It has citations for many of the things we’ve talked about here. See a list of the people who are around the table. Find somebody in your area. Begin to develop partnerships and together we will start making financial intelligence a part of our understanding and a part of our toolkit in this battle to combat human trafficking.

      [00:30:41] Derek, thanks for showing up again.

      [00:30:43] Derek Marsh: Thanks for having me show up. I appreciate it.

      [00:30:45] Sandie Morgan: And if you are new to the Ending Human Trafficking Podcast, please go on over to the ending human trafficking website, subscribe and you’ll be notified when a new episode drops every two weeks. Find out what we’re doing.

      [00:31:06] follow our survivor voices, check out our resources, and come back in two weeks for the next episode.

       

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