Human Trafficking, Compliance and a 1980s-Inspired Sci-Fi Series: Fighting the Upside Down

When I left my position as a prosecutor in the Manhattan District Attorney’s Office, I thought I was walking away from a position that allowed me to make a difference in the community. After all, if you are not directly involved in law enforcement and seeing the criminal justice system at work from a front row seat, how much of an impact can you really make? Well, the answer is a lot. After spending the last decade in the private sector (first in a financial institution and now in a data and technology company), I realized just how wrong I was. The potential to reach a much broader community was quite high, especially as I saw all of my worlds evolve and converge as part of the powerful, unexpected army that is the anti-money laundering (AML) community. I simply have a new role to play. It turns out I was in the best position possible to empower others to join me in combating the bad acts perpetrated through our financial systems—among them, “the upside down” world of human trafficking.

In Stranger Things, a recent Netflix sci-fi series set in the 1980s, four boys meet an odd young girl. They are forced to face the dark, ugly, scary, flesh-eating, soul-sucking evils from “the upside down.” It is a parallel world, opposite (or upside down) from the world most of us know and live in. The buildings, roads, trees, structures and landscape of the upside down are a mirror image of the real world. The difference is that in the upside down, it is always dark, the air is toxic and there are monsters that prey on any living animal. Humans will not survive unless they literally have superpowers. It is a real place that no one wants to see or think about—a place the “people in the white van” try to hide from society.

For approximately 24.9 million people around the world, this is what reality must feel like. Basic survival is the only thing they think about because they simply do not have access to essentials (without giving away parts of their souls). They live in this alternate universe with very little hope of finding their way out. The more people who tell their stories and demand accountability, the more likely it is for those trapped in the upside down to find their way to freedom. In addition, it is more likely that we can find our way to a world where the portal to the upside down is closed for good.

Given that human trafficking is a $150 billion per year business (at least 7.5 percent of the total estimated amount of money laundered worldwide), the financial industry is ideally situated to play a major role in demanding visibility and accountability. Backed by strong regulations, staffed by the right people and granted access to the data, financial institutions have a strong playing field to make a big impact in the collective effort to eradicate modern-day slavery.

First, tell their stories—the more detail, the better. And for the sake of effective monitoring, it is important that we get it right. Most are familiar with human trafficking for sexual exploitation or for the drug rings. These stories ring loud and clear, and they are deep, dark and dirty. These are the stories that are splashed across the front page or are the main plot lines in mainstream movies. But the work cannot stop there as there are many other stories that need to be told. Labor trafficking, or forced labor, is the most widespread and involves the largest percentage of victims (approximately 64 percent of the total number of victims worldwide). By comparison, commercial sex trafficking accounts for about 19 percent of the total estimate and state-sponsored slavery accounts for about 16 percent. There are a vast number of industries involved, many of them striking very close to home from nail salons, restaurants, construction, manufacturing, fishing boats, agriculture, and in the latest news, 7-Eleven convenience stores.

While a recent NBC article headline screamed of a crackdown on immigration,1 the story found between the lines was one of modern-day slavery. In fact, it was practically a play-by-play of news articles from five years ago. The difference in the message is stark: the headlines from 2013 actually pointed to human smuggling (e.g., 7-Eleven Shops Raided By Homeland Security in Human Smuggling Probe).2 Though not the focal point of the media coverage, the recent 2018 immigration investigation exposes the stories of the workers who were underpaid, under-informed and forced to live in conditions only those with no other choice would. It resurfaces the stories told throughout the past years of labor trafficking and reminds people that behind the immigration issue, there is a human rights issue.

Victims travel thousands of miles away from their homeland based on a promise of work to provide for their families, only to be faced with the harsh reality that once they get to their destination, they are at the complete mercy of their employers. They enter into a cycle of debt bondage and are oppressed by an inability to communicate or understand a complex system. They are forced to depend on their oppressors for the basics necessary for survival—food, water and shelter. In the instance of slaves on fishing boats, they are held out at sea for long periods of time and forced to rely on whatever food and water is delivered by supply boats. Medical attention is used as a weapon of coercion and it is often ultimately denied even if it is caused by a lack of proper tools and protection needed for the work.

The workers fall victim to an alternate reality—the upside down.

Exposing this world has become more and more prevalent as different organizations and industries come together to tell these stories. In addition to the Polaris Project, there are several nonprofit organizations (NPOs) that have identified a specific need in the financial industry in this important movement and prioritized efforts to assist financial institutions in detecting activities that could be indicative of slavery. These organizations are the important storytellers:

  • The Mekong Club3 identified an important need early on to involve the private sector to join forces with NPOs and governments and has focused much of its efforts on conducting and contributing to extensive training specific for financial institutions, as well as participating in multiple collaborative working groups to ensure that banks have useful information for their monitoring programs
  • Liberty Asia4 has dedicated resources to leverage data and technology to identify typologies of slavery impacting southeast Asian countries
  • The Thomson Reuters Foundation5 has launched events such as the Trust Conference and Stop Slavery Awards to recognize companies who have taken proactive and impactful steps to eliminate and detect forced labor in supply chains
  • Established and acclaimed media companies (e.g., Oceans8Films has spent many years filming “Ghost Fleet,” a documentary feature focused on telling the story of fishing boat slaves6)
  • ACAMS7 has prioritized numerous initiatives to bring all of the right parties together for thought leadership to identify and create solutions that financial institutions can proactively and effectively deploy

Today, there are the added possibilities that data, science and technology solutions can bring change to the movement. Enriching the hard work of these various organizations through collective analytics and public government data can, and will, be a game changer. The ability to collect, contextualize and visualize these typologies will allow financial institutions, NPOs and law enforcement to better understand and utilize data at their fingertips. Similar technology efforts have already been deployed through the Enigma Labs Sanctions Tracker8 and suspicious activity report trending analysis.9 The role data and technology companies play is a pivotal one that adds a whole new dimension to finding solutions.

What comes from all of this is that every single person is necessary if we are to make progress toward eliminating modern-day slavery. It is with this collective brain trust that we can create the literal superpowers necessary to survive and eliminate the upside down from a financial industry perspective.

This can be summed up in the words of Joyce Byers, whose son was lost in the upside down, “This is not yours to fix alone. You act like you’re all alone out there in the world, but you’re not. You’re not alone.”10 As an industry, working professionals in the field of AML and compliance, and as humans, we all have a role to play.

Angel Nguyen Swift, CAMS, vice president of compliance and financial crimes solutions, Enigma, former vice president of the Global Financial Crimes Compliance—FIU, American Express, New York, NY, USA,

  1. Corky Siemaszko, “Immigration Agents Raid 7-Eleven Stores Nationwide, Arrest 21 People in Biggest Crackdown of Trump Era,” NBC News, January 10, 2018,
  2. “7-Eleven Shops Raided By Homeland Security In Human Smuggling Probe,” The Huffington Post, June 18, 2013,
  3. Mekong Club,
  4. Liberty Asia,
  5. Thomson Reuters Foundation,
  6. Oceans 8 Films, The Ghost Fleet,
  7. “Human Trafficking,” ACAMS,
  8. Enigma,
  9. Rashida Kamal, “Trend Watching Across FinCEN’s Suspicious Activity Data,” Enigma, November 17, 2017,
  10. Stranger Things, 21 Laps Entertainment/Monkey Massacre, 2016.

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