This webinar will take place on July 30 at 10:00 AM CT, bringing together experts across sectors to explore the evolving landscape of human trafficking and the critical role collaboration plays in addressing it.

Hosted by Heather Panton, 成人VR视频 Senior Advisor of Social Impact and Human Rights, the session will feature Andrew Workman (TRSS), who will share insights from his forthcoming research on Missing and Murdered Indigenous Women and Girls (MMIWG)鈥攈ighlighting the intersection of trafficking, vulnerability, and systemic risk. Additional panelists from federal law enforcement and investigative agencies are expected to join the discussion, offering perspectives from the front lines of prevention and enforcement.

Together, panelists will examine the complexities of trafficking today, including emerging trends, the impact on vulnerable communities, and the importance of coordinated efforts across the public, private, and nonprofit sectors.

We invite professionals, partners, and advocates committed to advancing justice and protecting communities to join this important conversation as we work toward a world free from exploitation.

Register today and play a role in raising awareness and driving action.

Key highlights:

• • • Plans without funding are political theater, not strategy 鈥� Across the G20 and beyond, governments spend about $1 per vulnerable person per year, making the most comprehensive national action plans functionally undeliverable.

    • Corporate forced labor is a crime with no perpetrators 鈥� Despite an estimated tens of millions of victims in global supply chains, there has been only one forced labor investigation ever brought against a Fortune 500 company, exposing a near-total absence of criminal accountability in non-financial industries.

    • Real-time data accountability can work on a shoestring budgets 鈥� Uganda’s TipMap platform, built on a budget of just hundreds of thousands of dollars with NGO and US government support, demonstrates that transparent, publicly accessible prosecution tracking is achievable even for low-income countries 鈥� yet most wealthy nations have yet to replicate this model.

Every year, governments around the world publish sweeping national action plans to combat modern slavery, covering everything from vulnerable children, forced labor, and gender-based violence to prosecution targets and victim support. These action plans are, in many cases, genuinely comprehensive documents, and also in many cases, they are almost entirely unfunded.

That is the central finding of the (MSPI), a new tool developed by Duncan Jepson, Director of Strategy and Operations at . After decades working across supply chains, corporate law, and financial crime compliance in Asia, Jepson grew frustrated with a sector that was generating more conferences and consultants than criminal prosecutions. The MSPI takes a step back from that ground-level work and asks how governments are investing in this problem at a scale that matches their stated ambitions.

The answer, unsurprisingly, is that there is a big gap between plans and funding the execution of those plans. Across the G20 plus additional countries, total government spending on modern slavery prevention amounts to roughly $1.6 billion annually, Jepson notes. When measured against the estimated population of up to 2 billion people living in conditions of poverty and precarity that make them vulnerable to exploitation, the 鈥渋nvestment鈥� by governments works out to approximately $1 per person per year.

Grand plans & empty coffers

The MSPI evaluates governments across four dimensions, which include the context of exploitation within their borders, the comprehensiveness of their national action plan, the funding allocated to that plan, and the measurable outcomes produced. The gap between the second and third dimensions is the point at which the analysis reveals the most confounding gap.

Most national action plans, Jepson notes, look remarkably similar regardless of whether they come from wealthy nations or some of the poorest countries in the world. They include all the right elements; however, the problem is that the ambition of the plan rarely maps onto available resources. “If you see a similar kind of plan in a country which is not providing anywhere near the same investment, maybe only providing $10 million to $20 million,” then they’re clearly not going to be able to build the kind of institutional mechanisms and have them operational to achieve their stated ends, Jepson explains.

When measured against the estimated population of up to 2 billion people living in conditions of poverty, the 鈥渋nvestment鈥� by governments works out to approximately $1 per person per year.

This gap is partly a result of how these plans get written. Policy teams include every desirable outcome, every population group, and every intervention type because comprehensiveness signals seriousness. The result is what Jepson describes as a political product rather than a strategic one because it is detached from realities of resource constraints.

The three Ps framework 鈥� set out in the , which organizes anti-trafficking efforts around prevention, protection, and prosecution 鈥� has drifted from being a planning tool into being a target in itself. Governments check the boxes, publish the plan, and treat that as a win. The actual investment required to deliver outcomes becomes secondary.

Many perpetrators face no accountability

Perhaps the most sobering element of Jepson’s analysis concerns corporate accountability which, outside of healthcare and financial services, is extremely limited for criminal matters such as forced labor. Modern slavery in global supply chains, particularly forced labor in agriculture, manufacturing, fishing, and extractive industries, generates enormous profits. Prosecutions against the corporations involved are nearly nonexistent.

The , which Jepson brought to the U.S. Department of Homeland Security鈥檚 investigations unit a few years ago, remains a rare landmark. When he received a World Customs Organization award for the work, the citation described it as recognition for “the first investigation into a Fortune 500 company.鈥� Indeed, the fact that there is only one successful investigation in the entire history of Fortune 500 enforcement on forced labor is stunning in itself.

The structural reason for this, Jepson argues, is that non-financial industries operate without a criminal legal framework wrapped around their regulatory obligations. Banks are required to identify suspicious transactions, file reports, and de-risk clients connected to illicit activity, all under threat of serious legal regulatory consequence.

Modern slavery in global supply chains, particularly forced labor in agriculture, manufacturing, fishing, and extractive industries, generates enormous profits, while prosecutions against the corporations involved are nearly nonexistent.

Manufacturers, food producers, and commodity traders face no equivalent pressure. Their obligations tend to be framed in the language of sustainability and ethical sourcing, which are voluntary, subjective, and entirely company controlled.

When violations are discovered, the response is typically managed internally through grievance mechanisms, remediation programs, and consultant-led audits. Workers rarely have access to independent legal recourse and access to justice.

What good funding and enforcement should look like

Jepson is careful to point out that meaningful progress exists, even on limited budgets. , developed with support from the Human Trafficking Institute and US funding, provides a real-time, publicly accessible database of trafficking prosecutions and arrests. For a country investing only hundreds of thousands of dollars in this space, the platform demonstrates how transparency and institutional accountability can be achieved without enormous resources.

Italy and Germany both earn recognition for aligning their plans with their investment levels and for building on contextual knowledge. Yet neither country has solved corporate supply chain accountability, even though both demonstrate that coherent strategy tied to realistic resourcing produces better outcomes than aspirational planning without funding.

The US import ban mechanism, developed through U.S. Customs and Border Protection, remains the most significant enforcement tool in the world, although it鈥檚 still largely unique to one country.

The case for realistic investment

What Jepson would like to see instead is relatively straightforward. Governments need to develop a deeper, intentional recognition that their current spending levels are insufficient, he says, adding that investment in prevention also makes economic sense.

Every dollar not spent stopping exploitation upstream generates far greater costs in law enforcement response, victim and social services, and lost economic productivity downstream. Clearly, $1 per vulnerable person per year will not build the necessary infrastructure to protect anyone.

You can find out more about the challenges in combatting force labor in supply chains here

Key highlights:听

• • • The scale of risk demands urgent attention 鈥� The World Cup’s five-week span across three nations creates a human trafficking risk profile far beyond any previous North American sporting event.

    • Geographic exposure extends far beyond host cities 鈥� Unlike the Super Bowl, where risk is concentrated in one metro area, the World Cup’s national identity-driven fan engagement means every city in the US, Canada, and Mexico is effectively a participant city.

    • Cross-sector preparation is the most critical investment 鈥� Cutting down siloed operations among law enforcement, financial institutions, and NGOs is required, that means establishing financial institution task forces, training frontline bank branch employees to recognize trafficking indicators, sharing cross-sector information, and amplifying public awareness campaigns before the tournament begins is crucial.

The 2026 FIFA World Cup will be the largest sporting event ever hosted on North American soil, a tournament with 104 matches spanning more than five weeks across three nations and drawing an estimated 6.5 million visitors from around the world. While the United States hosts large sporting events like the Super Bowl each year, the World Cup brings with it the unique challenges of length of time, fan influx from around the globe, and geographic expansion.

Assessing the scale of human trafficking risk

To understand the magnitude of the human trafficking risk involved in events such as this, it is useful to apply a framework that accounts for three variables: i) the likelihood of a trafficking event; ii) the potential extent of damage; and iii) the duration of exposure. When that framework is applied to the 2026 World Cup, the human trafficking risk associated with the event registers high due to numerous factors.

For more on this, tune into the 成人VR视频 Institute’s latest “Clarity” podcast

The most significant differentiating factor of the World Cup is its time duration. The Super Bowl is a single-day event, and the Olympics run approximately two weeks. The 2026 World Cup spans more than five weeks across three nations, a duration that has no modern sporting equivalent. The last three World Cups, held in Brazil, Russia, and Qatar, offer limited comparative value given the substantial differences in legal frameworks, cultural contexts, and infrastructure. For purposes of risk assessment, this is why the Super Bowl represents the most relevant domestic benchmark, even though it falls considerably short as a true comparison.

Human trafficking evidence from the most recent Super Bowl

The most recent Super Bowl, held in the San Francisco Bay Area in February 2026, illustrates the scale of the human trafficking challenge. A coordinated anti-trafficking campaign conducted across 11 Bay Area counties resulted in the recovery of 73 sex trafficking victims, including 10 minors, and 29 arrests, all in connection with a single-day event.

Sex advertisement data from that period further substantiates the scale of human trafficking concern. In the months preceding the event, advertisement volume rose steadily before spiking dramatically during Super Bowl weekend and declining sharply in the days that followed. Analysis that was restricted to advertisements referencing the Super Bowl by name showed trend lines that remained essentially flat until the event itself, at which point volume surged significantly.

Likewise, examination of phone numbers associated with those advertisements revealed organized and purposeful movement. Nearly 500 unique numbers that had posted sex advertisements in other states in the preceding weeks appeared in San Francisco during the event.

The risk of human trafficking expanding beyond the host city is one additional insight uncovered during the anti-trafficking operation during the Super Bowl. Advertisements referencing the Super Bowl spiked simultaneously in Boston and Seattle, the home cities of the two competing teams. In the context of the World Cup, every city in the United States, Mexico, and Canada is effectively a participant city, and national identity rather than team affiliation drives fan engagement. The geographic distribution of risk is therefore exponentially greater than anything observed around the Super Bowl.

Hotspots of sex ads

What anti-trafficking partners should do now

Those organizations and institutions that take action in advance of the World Cup will be substantially better positioned to detect exploitation and protect vulnerable individuals. More specifically, these organizations should:

• Establish financial institution task forces in advance of the event 鈥� Convening local financial institutions to align on existing practices and identify gaps will aid in ensuring all parties are on the same page. It also establishes relationships and procedures that cannot be built effectively during a five-to-six-week surge in cross-border transactions. Activating established information-sharing mechanisms, such as the processes supporting the filing of and the , will be essential for detection and pattern recognition.
• Institute branch-level employee training at local financial institutions 鈥� Frontline employees possess local knowledge that no centralized system can replicate. A branch employee in a high-traffic urban location understands the patterns of their customer base and is often the first to recognize when something is amiss. What they frequently lack is the context in which to interpret that instinct and the guidance to act upon it. Addressing that training gap before the World Cup represents one of the highest-value preparedness investments available to financial institutions at this time.
• Dismantle institutional silos 鈥� Siloed operations, in which law enforcement, financial institutions, and non-governmental organizations (NGOs) each operate independently, represent the least effective organizational posture for an event of this scale. Institutions that establish cross-sector relationships and information-sharing commitments in advance will be meaningfully better equipped to respond.
• Develop and amplify public awareness campaigns 鈥� Research demonstrates that sustained public awareness campaigns and visible law enforcement presence reduce demand. Host cities, law enforcement agencies, and NGOs should treat this as actionable guidance in planning their response strategies.

The 2026 FIFA World Cup is not simply another major sporting event. The institutions, agencies, and organizations that approach it as such will find themselves unprepared for a scale of human trafficking risk that North America has never previously encountered.

You can find more about the resources, tools, and information that cities and organizations need to address听human trafficking around large-scale sporting events at听the 成人VR视频 Institute鈥檚 Large-Scale Public Events Toolkit here

Key insights:

• • • AI as a force multiplier 鈥� Advanced analytics now reveal financial and behavioral anomalies that traditional monitoring systems routinely miss, giving executives a clearer view of emerging risks.

    • Geospatial and digital intelligence converge 鈥� Intelligent networks like OSINT, ADINT, and location-based data expose hidden networks and movement patterns, improving the detection of money laundering, trafficking, and smuggling operations.

    • Enterprise risk strategies must evolve 鈥� Organizations that integrate AI-driven intelligence across compliance, security, and operations can respond faster, reduce blind spots, and operate with greater resilience during high-risk events.

Illicit financial activity has always evolved faster than the systems designed to stop it. And today, the speed and sophistication of criminal networks are accelerating in ways that traditional compliance processes can no longer match. Major international events, such as the 2026 FIFA World Cup, bring millions of visitors, heightened commercial activity, and a surge in cross鈥慴order movement, all creating fertile ground for exploitation.

AI as an intelligence multiplier

In this environment, financial institutions are on the front lines of detection and mitigation, and corporations must strengthen their ability to detect hidden risks. AI 鈥� particularly when combined with digital intelligence sources, behavioral analytics, and geo-referenced data 鈥� has emerged as the most powerful accelerator of that transformation.

Among all of this high-volume activity, AI is redefining how institutions detect early-stage indicators of illicit activity. Instead of relying solely on manual reviews or rule-based monitoring, organizations are increasingly deploying systems capable of analyzing vast volumes of structured and unstructured data at once. Three capabilities are shaping this new frontier:

Open-source intelligence (OSINT) 鈥� Criminal activity, even when intentionally concealed, tends to leave trace signals online. OSINT tools can examine social platforms, online marketplaces, media sources, forums, and digital discussion channels to uncover suspicious behavioral patterns, potential recruitment or exploitation signals, inconsistencies between official identification and online presence, or clusters of accounts linked by shared attributes. For many executives, OSINT has become an indispensable layer of enhanced due diligence, risk scoring, and early threat detection long before suspicious activity appears in financial records.

Advertising intelligence (ADINT) 鈥� ADINT focuses on metadata produced by mobile applications and digital advertising ecosystems. While it does not expose personal identifiers, it reveals mobility patterns, device behavior, and clustering anomalies. This type of intelligence becomes particularly powerful during large-scale events because of the ability to monitor the movement of devices across high-risk corridors, identify unusual concentrations of activity near event venues or border regions, or detect digital behavior consistent with organized criminal logistics. ADINT introduces a geographic and behavioral dimension to risk that enables institutions to understand not only who a customer appears to be, but where they go, how they behave, and whether those patterns align with legitimate economic activity.

AI-enhanced investigations 鈥� Modern platforms now merge financial data with OSINT and ADINT inputs and then apply descriptive and generative AI (GenAI) to draw connections that would be impossible to detect manually. These systems can classify digital communications by sentiment or intent, identify unusual financial behavior within seconds, convert large datasets into actionable intelligence summaries, translate and interpret foreign-language content, and map networks through recurring metadata or visual similarity. For decision-makers and organizational stakeholders, this shift represents a dramatic reduction in blind spots and a faster escalation pathway when emerging threats surface.

Why financial institutions and corporations must lead

Human trafficking, migrant smuggling, and money laundering cannot function at scale without the financial system. Even when exploitation occurs offline, profits eventually make their way into the formal economy through remittances, structured cash movements, shell companies, digital wallets, recruitment payments, or short-term rental arrangements.

AI enhanced investigations can help institutions identify subtle but meaningful indicators, such as coached or inconsistent customer responses, accounts linked through shared devices or addresses, rapid deposits followed by immediate withdrawals, purchases that do not correspond to a customer鈥檚 risk profile, payments directed to unverifiable recruiters, unusual patterns of short-term housing across multiple individuals, or transaction flows that follow established exploitation routes.

Illicit financial activity has always evolved faster than the systems designed to stop it. And today, the speed and sophistication of criminal networks are accelerating in ways that traditional compliance processes can no longer match.

All this information already exists inside institutional data today; AI simply makes it visible and usable much more easily and quickly.

While financial institutions are central in detecting illicit finance, companies across multiple sectors face heightened exposure during large events. Hospitality, logistics, transportation, construction, real estate, and digital services all see risk intensifying as demand surges and oversight becomes more complex.

Those senior leaders who responsible for operational continuity should integrate AI-powered monitoring into their internal controls. This can help detect unusual workforce recruitment patterns, unexpected badge or access activity, subcontractor behavior that conflicts with declared operations, repeated presence in high-risk zones, or digital communications that hint at coercive or exploitative conduct.

In the fight against illicit finance, technology is no longer optional. Indeed, it is our most powerful ally.

You can find out more about the fight against illicit finance and money laundering here

Key insights:

• • • Big sporting events create perfect cover for sex trafficking 鈥� The World Cup鈥檚 massive crowds, temporary workers, and stretched local infrastructure make it easier for traffickers to blend in and exploit vulnerable people while staying largely out of sight.

    • Money trails and online ads are where traffickers slip up 鈥� Trafficking often leaves patterns, such as payments tied to commercial sex ads, round鈥慸ollar peer鈥憈o鈥憄eer transactions, and repeat phone numbers or language across online ads. Banks and investigators can spot these red flags, if they know what to look for.

    • Early, cross鈥憇ector collaboration is what actually makes a difference 鈥� The strongest prevention efforts happen before kickoff, when law enforcement, financial institutions, and nonprofits share intelligence, use formal information鈥憇haring tools, and build trusted local networks to respond quickly and protect victims.

As millions of soccer fans descend upon stadiums across North America for the 2026 FIFA World Cup in June and July, perpetrators of human rights crimes also are getting ready to operate in the shadows of host cities. Criminal networks are preparing to exploit the crowds, traffic, and chaos during the event by trafficking vulnerable individuals for commercial sex.

Human traffickers and organized crime groups often exploit major sporting events as opportunities to make quick money because the massive influx of visitors, temporary workers, and strained infrastructure creates perfect conditions for traffickers to operate while being largely undetected. At the same time, the stakeholders involved in countering this illegal activity 鈥� including law enforcement, civil society organizations, and financial institutions 鈥� stand ready to detect it, disrupt it, and protect vulnerable individuals who are exploited by criminal actors.

Indeed, close coordination and collaboration among these entities in advance of the games is key. To that end, the Association of Certified Anti-Money Laundering Specialists (ACAMS) and 成人VR视频 are collaborating on a virtual and live event series to support these planning counter-trafficking efforts among stakeholders in several local cities this Spring.

Why major sporting events attract human trafficking activity

Not surprisingly, large crowds draw business opportunities whether they are legitimate or illicit. Collaboration between public and private entities underscore spikes in human trafficking activity. For example, during a recent large sporting event in 2025, 成人VR视频 Special Services partnered with federal law enforcement and other partners to identify nine adult encounters & services offered, which led to the recovery of two juveniles from sex trafficking and three state arrests

Common industries that involve the exploitation of vulnerable individuals include hospitality, construction, illicit massage businesses, escort services, and adult content production. The chaos of events and large influx of people mask the reality that exploitation is happening and makes detection significantly more challenging during these high-traffic periods.

Human traffickers and organized crime groups often exploit major sporting events as opportunities to make quick money because the massive influx of visitors, temporary workers, and strained infrastructure creates perfect conditions for traffickers to operate while being largely undetected.

Critically, understanding human trafficking as a business model depends on the recruitment of vulnerable people and access to money flows. These aspects of the business are also where detection can occur. Financial institutions and money service businesses can identify suspicious transactions related to human trafficking by understanding and recognizing specific transactional patterns, including payments to commercial sex advertisement websites, round-dollar peer-to-peer transactions, and merchant services linked to illicit massage businesses.

This online footprint left by traffickers proves invaluable for detection. Investigators track advertisements across adult services websites, identifying criminal networks through repeated phone numbers, distinctive emojis, and similar wording that may appear across multiple cities. However, smaller-scale operations present significant challenges as well. When the trafficker is an intimate partner or family member with limited transaction volumes, detection becomes exponentially more difficult without external intelligence.

Collaboration is key for prevention and detection

The most critical element for combating human trafficking at major sporting events is collaboration among anti-trafficking experts and employers of these professionals. Effective prevention requires building strong partnerships before these major events occur. Specific actions that can be taken include:

Establishing multi-sector task forces 鈥� The most successful anti-trafficking efforts involve joint task forces that combine federal, state, and local law enforcement with trusted private sector partners and supportive nonprofits or non-government organizations (NGOs) that offer victim services. This toolkit for large scale public events and other anti-trafficking toolkits are excellent resources for local host cities to use to execute these partnerships. These collaborative mechanisms allow different entities to share information in a timely manner.

Leveraging information sharing mechanisms 鈥� Financial institutions can use Section 314(b) authority for peer-to-peer information sharing between banks. This allows financial institutions to piece together fragments of suspicious activity that individually might seem insignificant but collectively reveal trafficking networks. Large federal agencies are consumed by multiple priorities and benefit from information sharing through Section 314(a) and assistance from financial sector partners during special operations to act as a force multiplier. Law enforcement also can benefit from detailed Suspicious Activity Reports (SARs) that contain specific dollar amounts, clear timelines, behavioral observations, and explicit keywords like human trafficking.

Preparing host cities by building networks and outreach in advance 鈥� Some World Cup host cities have already established human rights plans with robust collaborative systems within local task forces, government awareness campaigns, QR codes that link to support services, and multidisciplinary safety plans.

In addition, anti-trafficking professionals across all sectors are accessible and willing to help. Resources include national hotlines, such as the , referral directories on website, and the for cases involving minors. The most important step is simply reaching out to establish connections before crises occur.

Preparing for a safer event

The 2026 World Cup presents a pivotal moment to strengthen collaborative efforts against human trafficking across North America’s host cities. By establishing robust information-sharing networks between financial institutions, law enforcement, NGOs, and host communities before the tournament begins, stakeholders can transform heightened awareness into meaningful action that protects vulnerable individuals.

While traffickers will undoubtedly attempt to exploit the inevitable chaos surrounding a major event like the World Cup, a coordinated, multi-sector response grounded in shared intelligence, victim-centered approaches, and proactive preparation can disrupt their operations and ensure that the world’s celebration of soccer doesn’t come at the cost of human dignity and freedom.

You can find out more about听how organizations are trying to fight against human rights crimes here

Key takeaways:

• • • Human trafficking is a financial crime 鈥� Without the financial system, human trafficking networks cannot operate at scale. Banks, compliance officers, money transmitters, and casinos are uniquely positioned to detect suspicious patterns.

    • The 2026 World Cup amplifies existing risks 鈥� With 5.5 million additional visitors expected in Mexico City alone, criminal networks will exploit the surge in cash flows, new customers, and cross-border movement.

    • Red flags are observable in financial behavior 鈥� Human trafficking networks often leave detectable financial footprints, which is why financial institutions must update monitoring systems and stay alert to unusual transaction spikes during the tournament.

MEXICO CITY 鈥� As the 2026 FIFA World Cup get ready to hold its tournament in June and July across three North American countries, anti-human trafficking experts are meeting as well and attempting to address the challenges facing the three host countries of the largest World Cup in history.

To that end, the Association of Certified Anti-Money Laundering Specialists (ACAMS), in partnership with 成人VR视频, organized one such event, focused on the scourge of human trafficking that often surrounds large sporting events like the World Cup.

One speaker at the event noted an important clarification in the difference between human trafficking and human smuggling 鈥� two terms that are frequently confused yet carry vastly different legal and humanitarian implications. The key distinction lies in consent and the nature of the crime. In human smuggling, the individual being transported across borders consents to the movement, typically driven by socioeconomic necessity, and the offense is considered a crime against the state. Human trafficking, by contrast, is a crime committed directly against the victim, often involving exploitation through force, coercion, threats, or deception, and does not require the crossing of any international border.

The ACAMS event challenged the common belief is that human trafficking is exclusively sexual in nature. In fact, there are 10 additional forms of exploitation beyond sexual abuse, including slavery, forced labor or services, use of minors in criminal activities, forced marriage, servitude, labor exploitation, forced begging, illegal adoption of minors, organ trafficking, and illicit biomedical experimentation on human beings.

As the World Cup approaches, financial institutions鈥� compliance teams must recognize that the same operational conditions that make major sporting events exciting are precisely the conditions that money launderers and traffickers seek to exploit.

Still, sexual exploitation remains the dominant form of human trafficking. Indeed, it is the second most lucrative illicit business in the world after drug trafficking, with every 15 minutes of sexual abuse of a trafficking victim generating approximately $30.

Of course, without clients, there is no demand, said one speaker from the 脕GAPE Foundation, an organization that works to raise awareness against gender-based violence and human trafficking.

Financial sector as a key line of defense

When identifying human trafficking, it鈥檚 wisest to examine it from a financial perspective to find important indicators, according to several speakers. Indeed, the financial sector plays a critical role given its capacity to detect suspicious accounts and payments, shell companies, cash movements, digital platforms, and commercial operations.

For example, when a customer opens an account or conducts a transaction, certain red flags can be visible, including whether the customer needs to consult notes to answer basic questions such as their address or occupation, or that their responses are not spontaneous or natural. Also, another indicator is if the customer’s profile is inconsistent with the type or volume of transactions being conducted.

For financial institutions, there are other patterns that have triggered alerts in illicit activity in the past, including near-immediate deposits and withdrawals with no clear justification for the cash flow, or multiple individuals registered at the same address or linked to the same account.

Similarly, another red flag would be if there鈥檚 a high number of accounts opened from the same state or municipality with similar patterns, particularly in areas identified as origin points for trafficking networks; or, payment of multiple short-term rentals or payments abroad to unverifiable recruiters or employment agencies.

Financial institutions should be on the lookout for companies that file no tax returns or invoice simulated transactions, or that use of front men to open accounts or conduct operations.

Also, new businesses whose declared activity does not correspond to their financial operations should be flagged, as well as any frequent, large-volume purchases of condoms, lingerie, or women’s clothing inconsistent with the declared business activity.

Indicators at the 2026 World Cup

In the context of major sporting events such as the World Cup, existing risks are significantly amplified, several speakers pointed out. Sexual tourism, including the commercial sexual exploitation of children and adolescents, is a known and serious threat. Indicators that are relevant not only for the financial and banking sectors, but also for the real estate, tourism, transportation, hospitality, and restaurant industries including unusual accommodation requests, such as deactivating security cameras, delivering keys through third parties, or inquiring about the presence of neighboring guests.

When identifying human trafficking, it鈥檚 wisest to examine it from a financial perspective to find important indicators, and the financial sector plays a critical role given its capacity to detect suspicious accounts.

These industries should also be on the lookout for any adult or group of adults traveling with an unusually large number of minors, or individuals who travel in silence and are accompanied by someone who appears to exercise visible control over them.

As the World Cup approaches, financial institutions鈥� compliance teams must recognize that the same operational conditions that make major sporting events exciting 鈥� high transaction volumes, new customers, cross-border flows, and institutional attention diverted toward the event itself 鈥� are precisely the conditions that money launderers and traffickers seek to exploit.

For these compliance teams, monitoring systems must be updated, know-your-customer processes must go beyond documentation and reflect a genuine understanding of the client’s activity and context, and on-site verification visits must be conducted by personnel who know exactly what they are looking for.

The financial sector does not need to become an investigative body; however, it does need to remain alert, informed, and willing to report. Indeed, this is exactly what the compliance function exists for, and in the context of human trafficking, the cost of silence is measured not in fines or reputational damage, but in human lives.

You can find out more about the听challenges of hosting the 2026 FIFA World Cup here

Key highlights:

• • • Fragmented protection creates vulnerability 鈥擟urrent US privacy laws operate as a patchwork system without comprehensive national standards, leaving children and other users exposed to data exploitation across state lines and international borders.

    • Body data collection opens future manipulation potential 鈥擵irtual reality platforms collect granular biometric information through sensors that can reveal deeply sensitive information about users.

    • Use-based regulations outlast technology changes 鈥� Restricting harmful applications of data provides more durable protection than the current regulatory approach, which relies on categorizing rapidly evolving data types.

Virtual reality (VR), social media, and gaming companies have long avoided robust content moderation, largely out of concern over implementation costs and the risk of alienating users. This reluctance stems from platforms wanting to have the widest pool of users as possible. Yet, the shortsightedness of this decision has consequences, including insufficient protection of children and long-term cost to companies鈥� bottom-lines.

The child exploitation crisis in digital spaces requires better laws and a reimagining of how VR, gaming, and social medial companies balance privacy, safety, and accountability across diverse platform architectures, according to , an expert in child exploitation methods in digital spaces and Policy Advisor at the NYU Stern Center for Business and Human Rights.

Limitations of existing regulatory frameworks

The current regulatory landscape is insufficient to protect children online. The lack of a comprehensive national privacy law in the United States, the use of consent mechanisms, and the haphazard rollout of age verification all expose protection gaps and come with economic and psychological costs, according to Olaizola Rosenblat. For example, some of the dangers include:

Gaps in patchwork of regulations leave children vulnerable 鈥� Regulatory demands for child safety often collide with privacy protections, creating contradictory obligations that platforms cannot realistically satisfy. In the absence of unified standards, however, companies operate in a jurisdictional maze that leaves most users, including children, exposed to data exploitation across borders.

America鈥檚 regulatory landscape remains especially fragmented, with no comprehensive national privacy law to provide consistent protection. comes close to establishing meaningful safeguards, according to Olaizola Rosenblat, yet it still permits companies to collect data even after users opt out of the sale or sharing of their data.

Federal reform attempts, including the , collapsed amid conflicts between states demanding stronger protections and tech lobbyists aligned with conservative representatives seeking weaker standards. In addition, child-specific laws, such as the , provide protection only for those under 13, which leaves older minors and adults vulnerable.

鈥淥nce users turn 13, they fall off a regulatory cliff,鈥� says Olaizola Rosenblat. 鈥淭here is no federal child-specific data protection regime, and existing state-level safeguards are patchy and largely ineffective for teens.鈥�

Internationally, the European Union鈥檚 (GDPR), although considered the gold standard for regulation, suffers from a persistent gap between its ambitious text and its uneven enforcement.

Age verification tensions 鈥� These regulatory shortcomings also are evident in debates over age verification. Protecting children requires collecting data to determine user age, yet privacy advocates frequently oppose such measures. Without pragmatic guidance acknowledging these inherent trade-offs, platforms often face contradictory obligations they cannot simultaneously fulfill.

Current consent frameworks offer little protection 鈥� Current consent mechanisms offer users an illusory choice that fails to protect children from data exploitation. Even relatively robust frameworks like the GDPR rely on consent models in which refusal means exclusion from digital spaces essential to modern life. This approach proves particularly inadequate for younger users. Indeed, that about one-third of Gen Z respondents expressed indifference to online tracking.

VR data collections may allow future exploitation

VR platforms differ fundamentally from traditional gaming spaces and social media platforms. Users with VR headsets embody avatars that move through thousands of interconnected experiences. While no actual touching occurs, the experiences feel visceral. Indeed, the psychological and physiological responses can mirror aspects of real-world experiences, which include sexual exploitation, even though no physical contact occurs.

Olaizola Rosenblat explains that the data collected from the sensors can open up the potential for future exploitation. “The inferences that can be drawn from your body-based data collected by these sensors is granular and often intimate,鈥� she explains. 鈥淭he power that gives to companies is pretty remarkable in terms of knowing things about you that you might not even know yourself.鈥�

Recommended actions to address challenges

Addressing the child exploitation crisis in digital spaces requires coordinated action, according to Olaizola Rosenblat, and that needs to include:

Universal protection standards 鈥� Corporate action in partnership with legislators is necessary for effective reform that protect all users rather than fragmenting safeguards by age or vulnerability status. Current approaches that shield only younger children create dangerous gaps and leave adolescents and adults exposed once they age out of protected categories.

Enforce existing regulations 鈥� Even well-crafted legislation proves meaningless without robust enforcement mechanisms. Commitment by government agencies along with the appropriate levels of funding is the most meaningful approach to achieve desired outcomes.

Technology-agnostic use regulation 鈥� Rather than attempting to categorize rapidly evolving data types, companies in the VR, gaming, and social media sectors must work with legislators to restrict harmful uses of data such as manipulation, exploitation, and unauthorized surveillance, regardless of technical collection methods. Regulating data use 鈥� rather than the current method of regulation based on categories of data, which include personally identifiable information 鈥� is the right approach.

Public mobilization is essential 鈥� Citizens must understand that the stakes of data exploitation beyond corporate collection also include hacking vulnerabilities and manipulative deployment. Without consumer demand for better protection and the willingness for legislators to pass the laws, regulation will not happen.

The path forward

The digital exploitation of children demands immediate action that transcends partisan divides and corporate interests. Only through coordinated regulatory reform, meaningful enforcement, and sustained public pressure can we create digital spaces in which innovation thrives without sacrificing our privacy and safety. The cost of continued inaction grows steeper each day we delay.

You can find out more on how organizations and agencies are fighting child exploitation here

Key highlights:

• • • Principles need a repeatable process 鈥斕齊esponsible AI commitments become real only when companies systematize human rights due diligence to guide decisions from concept through deployment.

    • Policy and engineering teams should co-own safeguards 鈥� Ongoing collaboration between policy and technical teams can help translate ideals like fairness into concrete requirements, risk-based approaches, and other critical decisions.

    • Engage, anticipate, document, and improve continuously 鈥斕齀nvolving impacted communities, running regular foresight exercises (such as scenario workshops), and building strong documentation and feedback loops make human rights accountability durable, instead of a one-time check-the-box exercise.

More and more companies are adopting responsible AI principles that promise fairness, transparency, and respect for human rights, but these commitments are difficult to put into practice when it comes to writing code and making product decisions.

, a human rights and responsible AI advisor at Article One Advisors, works with companies to help turn human rights commitments into concrete steps that are followed across the AI product lifecycle. He says that the key to bridging the gap between principles and practice is embedding human rights due diligence into the framework that guides product development from concept to deployment.

Operationalizing human rights

Human rights due diligence involves a structured process that begins with immersion in the process of building the product and identifying its potential use cases, whether it is an early concept, prototype, or an existing product. This is followed by an exercise to map the stakeholders who could be impacted by the product, along with the salient human rights risks associated with its use.

From there, the internal teams collectively create a human rights impact assessment, which examines any unintended consequences and potential misuse. They then test existing safeguards in design, development, and how and to whom the product is sold. “Typically, a new product will have many positive use cases,鈥� explains Natour. 鈥淭he purpose of a is to find the ways in which the product can be used or misused to cause harm.” In Natour’s experience, the outcome is rarely a simple go or no-go decision. Instead, the range of decisions often includes options such as go with safeguards or go but be prepared to pull back.

The use of human rights due diligence in the AI product lifecycle is relatively new (less than a decade old) and as Natour explains, there are five essential actions that can work together as a system:

1. Encourage collaboration between policy and engineering teams

Inside most companies, responsible AI is split between policy teams, which may own the principles, and the engineering teams, which own the systems that bring those principles to life. Working with companies, Natour brings these two functions together through a series of workshops to create structured, ongoing collaboration between human rights and responsible AI experts and the technical teams to better co-develop responsible AI requirements.

In the early stages of the collective teams鈥� work, the challenges of turning principles into practice emerge quickly. For example, the scale of applications and use cases for an AI product can make it difficult to zero in on those uses that . Not all products or use cases need to be treated equally, says Natour, and companies should identify those that could potentially cause the most harm. Indeed, these most-harmful uses may involve a “consequential decision” such as in the legal, employment, or criminal justice fields, he says, adding that those products should be selected for deeper due diligence.

2. Consider the principles at each stage of the development process

Broad principles and values, such as fairness and human rights, should be considered at each stage of the lifecycle. For the principle of fairness, for example, teams may assess which communities will use this product and who will be impacted by those use cases. Then, teams should consider whether these communities are represented on the design and development teams working on the product, and if not, they need to develop a plan for ensuring their input.

3. Engage with impacted communities and rightsholders

Natour advocates for companies to actively engage with impacted communities and stakeholders, including those who are potential users or who may be affected by the product鈥檚 use. This could be the company鈥檚 own employees, for example, especially if the company is developing productivity tools to use internally in their workplace. Special consideration should be given to vulnerable and marginalized groups whose human rights might be at greatest risk.

External experts, such as Natour and his colleagues, hold focus groups with such stakeholders as . The feedback from focus groups can then be used to influence model design, product development, as well as risk mitigation and remediation measures. “In the end, knowing how users and others are impacted by your products usually helps you make a better product,” he states.

4. Establish responsible foresight mechanisms

To prevent responsible AI from becoming a one-time check-the-box exercise, Natour says he uses responsible foresight workshops and other mechanisms as a “way to create space for developers to pause, identify, and consider potential risks, and collaborate on risk mitigations.鈥�

The workshops use personas and hypothetical scenarios to help teams identify and prioritize risks, then design concrete mitigations with follow-on sessions to review progress. Another approach includes developing simple, structured question sets that push product teams to pause and think about harm. For example, Natour explains how one of his clients includes the question: What would a super villain do with this product? in order to help product teams identify and safeguard against potential misuse.

5. Create documentation and feedback loops for accountability

As expectations around assurance rise from regulators, customers, and civil society, strong documentation and meaningful, accessible transparency are essential, says Natour.听Clear, succinct, and accessible user-facing information about what a model does and does not do, about data privacy, and other key aspects can help users understand “what happens with their data, as well as the capabilities and the limitations of the tool they are using,” he adds.

Further, transparency should enable two-way communication, and companies should set up feedback loops to enable continuous improvement in the ways they seek to mitigate potential human rights risks.

The hardwired future

Effectively embedding human rights into the AI product lifecycle starts with a shared governance model between a company鈥檚 policy and engineering teams. Together they can collectively hardwire human rights into the way AI systems are imagined, built, and brought to market.

You can find more about human rights considerations around AI in our here

Key insights:

• • • Effective human rights due diligence 鈥� Human rights can be hardwired into procurement by setting standards that include clear documentation thresholds, a code of conduct that bans forced labor and trafficking, a supplier assessment questionnaire, a locally informed worker safeguards addendum, and a risk-based vendor-grading rubric.

    • Procurement should feature human rights enforceable obligations 鈥� Further, human rights can be hardwired into commitments, such as request for proposals, vendor evaluation, and contract clauses.

    • Engaging unions and community groups early can lead to strong execution 鈥� Effective implementation relies on early stakeholder structures (unions, community groups, etc.), robust worker grievance mechanisms, and independent interviewers, complemented by AI-driven monitoring and continuous, rapid risk response.

Mega sporting events can have a significant impact on local economies, but they also pose substantial human rights risks, including labor exploitation, forced displacement, and sex trafficking. With the Super Bowl and Winter Olympics coming up next month, and the World Cup in summer, it鈥檚 crucial that organizations, communities, and governments prepare now to mitigate any human rights problems with these events.

As an advisor to host cities on human rights with more than a decade of experience now as the chief executive of , I have seen firsthand how the right commitments and responsible contracting practices can help mitigate these risks. By prioritizing human rights and adopting robust contracting practices, the cities that host these mega sporting events can ensure a positive legacy that extends beyond the event itself.

This was a recent topic at an event hosted by 成人VR视频 and the International Labor Organization as part of its in which representatives from host cities, civil society organizations, and governments came together to discuss best practices to turn commitments around human rights into action during the FIFA World Cup games later this year. As a participant in this event, Henekom shared our approach in translating high鈥憀evel human rights commitments into context鈥憇pecific safeguards in order to create the social architecture that aligns organizational practice with community needs.

January is National Human Trafficking Prevention Month in the United States.听Check out our Human Rights Crimes resource center to learn how to听stop and prevent human trafficking

Centering human rights by using rigorous contracting standards starts with local jurisdictions working with multidisciplinary stakeholders to embed strong and comprehensive policies and protocols at all stages of event planning. In my experience, an all-inclusive approach typically shares five elements:

1. 1. 1. Clear thresholds in human rights documentation that are designed for speed of business.
      2. Code of conduct with essential ingredients, which include explicit bans on forced labor, trafficking, and other exploitation.
      3. Supplier assessment questionnaire (SAQ) that flags geographic and sector risk, such as temporary labor of food service employees.
      4. Worker safeguards addendum (WSA) that is built from local labor stakeholders who have lived concerns that help to translate the United Nations Guiding Principles on Business and Human Rights (UNGPs) into local realities.
      5. Risk-based grading rubric for vendors that weights SAQ and WSA responses and turns them into a contracting risk rating.

In my experience, implementing these policies and tools deeply within the organization means embedding requirements at three critical junctures: i) request for proposals (RFPs); ii) vendor evaluation as part of the selection process; and iii) contract clauses. First, when subject-matter experts draft RFPs, the workflow should force-check human rights and sustainability language (or auto-insert standard clauses). Second, during vendor evaluation, the human rights team grades each SAQ/WSA and assigns a risk-based score. Third, contracts must lock in enforceability with particular emphasis on audit rights, corrective action plans, termination for cause, access to remedy, and accountability mechanisms, such as payment withholding.

Vendor contract agreements between the host cities and primary contractors are the best vehicle to incorporate enforcement of these rights. Likewise, provisions for these rights should also be incorporated into contracts between primary contractors and any subcontractors.

Centering human rights by using rigorous contracting standards starts with local jurisdictions working with multidisciplinary stakeholders to embed strong and comprehensive policies and protocols at all stages of event planning.

Temporary labor at mega sporting events 鈥� which include individuals working in private security, souvenir sales, construction, janitorial, and food service 鈥� adds complexity but does not have to stifle efforts to honor decent work and other human rights. With a solid sourcing policy, vendors get practical tools and technical assistance to implement requirements quickly.

Common examples include building a checks-and-balances loop with worker centers to receive complaints, and data reporting to track hours, wages, recruitment fees, and grievance outcomes. The risk-based grading rubric for vendors ideally determines the monitoring intensity, frequency of site visits, and reporting cadence.

Effective approaches for implementation

Beyond contract language, the following three actions and tools to help instill accountability in human rights commitments are recommended:

Working with stakeholders from day one 鈥� To effectively safeguard human rights, it’s crucial to establish standing stakeholder structures, such as advisory councils and labor roundtables, in order to co-create standards and monitor progress with unions and community groups. By doing so, organizations can ensure workers’ voices are heard, issues are escalated, and commitments are translated into tangible results through collective action and remediation advice.

Centering workers and ensuring access to grievance mechanisms 鈥� Establishing on-site, back-of-house centers for workers with confidential and multilingual intake processes, along with clear resolution pathways, is an effective way to drive accountability and reinforce human rights commitments. Using trained, independent worker interviewers with unannounced access to ensure compliance across venues, shifts, and subcontractor tiers further adds to this accountability.

Together, these approaches provide a means for workers to report concerns, verify compliance with policy requirements, and ensure that human rights are respected throughout the supply chain.

Using AI to fortify accountability 鈥� AI offers powerful tools for detecting and preventing labor exploitation in supply chains through automated monitoring and pattern recognition. Likewise, natural language processing may be able to analyze hotline transcripts and grievance logs to identify trends.

Even with the best policies and accountability tools, however, risks still persist because operating and business conditions are dynamic. New suppliers are added late, or a hot day turns into potentially harmful working conditions. This makes human rights due diligence a continuous requirement with ongoing risk monitoring, fast incident response, and a humble posture to make it right quickly, transparently, and fairly.

If host cities want a legacy that lasts beyond the mega sporting events鈥� closing ceremony, it is critical to ensure that the people who made the spectacle possible were seen, protected, paid, and heard. Doing the right thing is strategy 鈥� contracts and worker-centered approaches are how it shows up on the ground.

You can find out more about how organizations are trying to fight against human rights crimes here

Key insights:

• • • Sextortion has evolved into a global industry 鈥� This crime is being fueled by organized crime networks and human trafficking.

    • Victims exist on both sides鈥� Often, vulnerable workers, who operate as forced labor in scam compounds abroad, are as much the victims as those people being scammed online and extorted for financial gain.

    • Digital literacy and cross-border cooperation are strong tools 鈥� Governments and law enforcement need to better educate the public about these scams and seek better collaboration to prevent exploitation and to dismantle organized crime networks.

A 17-year-old Michigan high school student after inadvertently sharing explicit photos with a Nigerian sextortion scammer after the scammer posed as a teenage girl on a fraudulent Instagram account. Also, a 16-year-old Kentucky high school student after he was blackmailed with an AI-generated nude image.

Sadly, these two families are victims of the more than 100,000 sextortion reports filed with the National Center for Missing and Exploited Children (NCMEC) since 2020, many now involving AI-generated imagery. These reports are part of the larger increase in , which typically targets males ages 14 to 17 and which has been on the rise since 2020. These tragic cases are part of a vast network of scams that stretches from the to criminal compounds in Asia and Africa.

Sextortion in the modern age

The FBI defines sextortion as a criminal act in which an offender blackmails a victim for payment under the threat of releasing sexually explicit material, such as a photo or video. The material may have been solicited through a romance scam or may be the product of generative AI (GenAI). Sextortion is the latest trend in a series of scams that generate billions of dollars for international criminal syndicates on the backs of forced labor in parts of the world with unstable governance and oversight. An average 800 CyberTipline reports submitted to NCMEC from 2022 to 2023 related to the sextortion of minors.

NCMEC notes that victims of sextortion scams to the CyberTipline and make use of the . Take It Down allows for anonymous requests to remove explicit images from participating platforms and social media companies. encourages changing passwords after scam activity and not responding to any requests for payment, even if threats are made.

Organized crime syndicates and cyber-scams

are the 鈥渄efinitive market leaders鈥� in cyber-enabled fraud and online scams, which have been rapidly expanding since the COVID-19 pandemic, according to the United Nations鈥� Office on Drugs and Crime. In areas of Asia with weak governance, scam centers and fraud gangs run sophisticated operations that often front as industrial parks or casinos and hotels. and coerced into defrauding other victims online. The trafficked individuals often are lured with false promises of high-paying jobs and the ability to maximize their language skills.

Broad enforcement efforts have been relatively ineffective as scamming operations simply move within the country or offshore.

Once there, victims are forced into labor to commit financial fraud usually by enticing smartphone users to invest in cryptocurrency scams or engaging in sextortion (which sometimes includes forced sex trafficking to produce sexual content). It is unclear if teenagers are being targeted explicitly or if they are inadvertently targeted through broader, population-wide cyber-scams.

The Myanmar town of Laukkaing (also spelled Laukkai), the capital city of the Kokang Self-Administered Zone is considered the engine-room of forced labor scamming. In Myanmar鈥檚 Kokang region, have turned from narcotics to online scamming, operating casinos, and scam compounds possibly because these crimes are more lucrative and easier to operate at scale.

In October 2023, a deadly crackdown at Myanmar鈥檚 Crouching Tiger Villa (referred to as the 1020 Incident) was the beginning of the crumbling of mafia-led control in Laukkaing. The Chinese government launched coordinated attacks, which resulted in . The leader of the Ming family (which operated Crouching Tiger Villa) took his own life after being captured, but of his extended family with ties to organized crime and illegal activities in Myanmar were sentenced in Chinese courts in September 2025, including 11 who were sentenced to death.

An estimated US $1.4 billion was generated by the Ming family over 10 years through telecommunications fraud, illegal casinos, drug trafficking, and prostitution.

Inside offshore scam compounds

Beyond Southeast Asia, forced-scam operations have grown rapidly across the Mekong region. The听, funded in part by 成人VR视频, notes their study of CyberTipline reports and IP addresses point to a strong presence of scam compounds in Myanmar and Cambodia.

The financial impact of scam compounds is no small factor 鈥� ruling elites in these countries have a financial motivation to look the other way because of its high profitability. The in Cambodia are more than US $12.5 billion annually, or about half of the country鈥檚 formal GDP. Across Mekong countries (China, Myanmar, Laos, Thailand, Cambodia, and Vietnam), cyber-scam returns generate an estimated US $43.8 billion annually.

The financial impact of scam compounds is no small factor 鈥� ruling elites in these countries have a financial motivation to look the other way because of its high profitability.

Broad enforcement efforts have been relatively ineffective as scamming operations simply move within the country or offshore, and there are reports that these complex money laundering operations help move funds into the formal economy of countries with weak governance.

Despite the challenges in enforcement, some high-profile enforcement cases have helped to generate international coordination against cyber-scams and sextortion. A California teen鈥檚 death by suicide resulting from sextortion led to three years later. Interpol鈥檚 (July and August 2025) resulted in 260 arrests and more than 1,200 electronic device seizures in 14 African countries. The Association of Southeast Asian Nations (ASEAN) announced that as the main regional security concern last month. Domestically, the U.S. Department of the Treasury鈥檚 Office of Foreign Assets Control (OFAC) has issued sanctions on nine targets involved in scam operations in , and against (who is also associated with online scam centers).

Digital literacy as a solution

To truly begin to crack scam networks that operate in parts of the world with weak governance, of their citizens and support stronger cross-border investigation strategies. Stronger anti-money laundering frameworks can disrupt scam compounds more effectively than sting operations that just force the scam operation to move elsewhere.

It is critical that digital literacy is emphasized for online users who fall prey to sextortion and among job seekers lured into forced labor in scam compounds by fraudulent job advertisements. Cross-border collaboration among authorities, along with stronger enforcement and shared digital literacy, are the best defenses against this evolving threat.

You can find out more about our coverage of human trafficking, child exploitation, and forced labor at our Human Rights Crimes Resource Center here