U.S. Bank Stadium in downtown Minneapolis, the site of Super Bowl LII.
By Evan Sparks
Well over 100 million Americans are expected to tune into the gridiron action and funny ads during Super Bowl LIII on Sunday night, but amid the fun is a dark side that often accompanies major live sporting events: a local surge in sex trafficking.While estimates are uncertain—and advocacy organizations note that events like the Super Bowl don’t correlate with increases in the number of victims of trafficking—there is evidence that traffickers move victims into the Super Bowl locale to take advantage of the influx of partying visitors. Studies have shown a 40 percent increase in out-of-market area codes appearing in ads on adult services websites. The same phone numbers have often been identified in prior ads appearing in other cities, suggesting that the big game is associated with coordinated movement of victims.
For U.S. Bank, having 2018’s Super Bowl LII at the U.S. Bank Stadium—just a few blocks away from its downtown Minneapolis headquarters—represented an opportunity to put its financial intelligence and anti-money laundering capabilities to work in helping law enforcement tackle the sex trafficking surge.
Developing the playbook
The work began in earnest 10 months before the Super Bowl itself, says Phillip DeLuca, an SVP in U.S. Bank’s enterprise financial crimes compliance unit who directs work on solutions and emerging risks. The team at U.S. Bank began diving into its transaction data—credit and debit card use, ATM withdrawals, branch visits—to identify “areas where we would be most successful in identifying information that would point to human trafficking,” DeLuca says in an ABA Banking Journal Podcast interview.
Starting in the summer before, U.S. Bank team members began meeting with the U.S. attorney’s office in Minneapolis. They also worked with a vendor, which provided a list of out-of-market phone numbers scraped from ads on adult services websites “that may have moved into the area around the time of the Super Bowl.” The bank could cross-reference these with its own data.
Ensnaring an estimated 40 million people worldwide in forced labor and sexual slavery, human trafficking shares many money laundering patterns with other criminal enterprises. But human trafficking does have distinct red flags, notes Jim Dinkins, an SVP and financial crimes compliance operations executive at U.S. Bank who previously led investigations at the Department of Homeland Security. Perhaps the most obvious is a link to adult services advertising, “a very common indicator for sex trafficking,” Dinkins explains. If an analyst recognizes one of these red flags, it may take something that “may look like a traditional structuring case and make it that much more important—because it’s linked to human trafficking and needs to be escalated forthwith to law enforcement,” he adds.
Running drills
Training to recognize these red flags is key. “As part of our initiative at U.S. Bank, we believe in training, training and training,” says Dinkins. “We train throughout every business line so that everyone has an idea of what human trafficking is, the state of the problem and sensitivity to the situation so that you can detect and report something.”
For example, a teller or branch employee might notice that a customer is “accompanied by someone who appears to be influencing or controlling them,” Dinkins explains. “That dominance and control is something that’s often seen.”
Other risk factors: “Individuals have multiple accounts in their own name,” says DeLuca. Heavy use of cash is another red flag. Transactions associated with sex trafficking include multiple simultaneous charges on ride-hailing services like Uber and Lyft (which Dinkins says are often favored over taxis because the traffickers can track their victims’ rides in real-time via the app), and multiple hotel rooms, far more than any single individual would be reasonably expected to have on a single night.
Meanwhile, “sometimes it’s not what you see in the account but what you don’t see in the account,” adds DeLuca. In a typical account associated with sex trafficking, you won’t see utility payments, purchases related to hobbies or mortgage payments.
In the end zone
As the Super Bowl approached, U.S. Bank drew on its research and data to develop “typologies,” in the parlance of the financial crimes world, to identify possible human trafficking cases. The team solicited real-time feedback from law enforcement to ensure the bank was looking for red flags that would support criminal investigations—but it also brought their own frameworks to law enforcement via suspicious activity reports filed in the months leading up to the Super Bowl. “We explained where we were going,” DeLuca says. “We explained how we were able to determine based in the transaction patterns and activities that this looked like human trafficking. That process really got them engaged.” U.S. Bank also partnered with seven different local banks on the initiative, sharing trend and pattern information as appropriate.
The 10 day-period leading up to the 2018 Super Bowl was the most intense time of the initiative. At the ABA/ABA Financial Crimes Enforcement Conference in December, DeLuca described one of the first cases they reported: a trafficker who was on law enforcement’s radar for bad checks. He was identified through transactions on six ATM cards used around Minneapolis, and the team pulled ATM security footage. “This guy had four to five girls lined up behind him handing him money that he was putting into the ATM machine,” DeLuca said.
Ultimately, law enforcement arrested 94 individuals for sex trafficking in the days around Super Bowl LII, according to the St. Paul Pioneer Press. “Many of the reports we made to law enforcement were a part of those arrests,” says DeLuca. “This effort was probably the most successful effort that I’ve been involved in . . . at times you don’t get that feedback, but with the program that we set up with law enforcement along the way, we got that feedback right away.”
And now it’s on to Super Bowl LIII. While U.S. Bank doesn’t have a retail presence in the Atlanta area, “we were asked early on to talk about what we did on LII, and we’re a part of the effort on LIII as well,” DeLuca says.
