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entitled 'Human Trafficking: A Strategic Framework Could Help Enhance 
the Interagency Collaboration Needed to Effectively Combat Trafficking 
Crimes' which was released on July 26, 2007. 

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Report to Congressional Requesters: 

United States Government Accountability Office: 

GAO: 

July 2007: 

Human Trafficking: 

A Strategic Framework Could Help Enhance the Interagency Collaboration 
Needed to Effectively Combat Trafficking Crimes: 

GAO-07-915: 

GAO Highlights: 

Highlights of GAO-07-915, a report to congressional requesters 

Why GAO Did This Study: 

Human trafficking is a transnational crime whose victims include men, 
women, and children and may involve violations of labor, immigration, 
antislavery, and other criminal laws. To ensure punishment of 
traffickers and protection of victims, Congress passed the Trafficking 
Victims Protection Act of 2000 (TVPA), which is subject to 
reauthorization in 2007. The Departments of Justice (DOJ) and Homeland 
Security (DHS) lead federal investigations and prosecutions of 
trafficking crimes. As requested, this report discusses (1) key 
activities federal agencies have undertaken to combat human trafficking 
crimes, (2) federal efforts to coordinate investigations and 
prosecutions of these crimes, and (3) how the Bureau of Justice 
Assistance (BJA) supported federally funded state and local human 
trafficking task forces. GAO reviewed strategies, reports, and other 
agency documents; analyzed trafficking data; and interviewed agency 
officials and task force members. 

What GAO Found: 

Since the enactment of the TVPA in 2000, federal agencies have (1) 
investigated allegations of trafficking crimes, leading to 139 
prosecutions; (2) provided training and implemented state and local 
initiatives to support investigations and prosecutions; and (3) 
established organizational structures, agency-level goals, plans, or 
strategies. For example, agencies have trained new and current 
personnel on investigating and prosecuting trafficking in persons 
crimes through their agency training academies and centers, provided 
Web-based training, and developed and disseminated guidance on case 
pursuance. Agencies have also sponsored outreach and training to state 
and local law enforcement, nongovernmental organizations, and the 
general public through a toll-free complaint line, newsletters, 
national conferences, and model legislation. Finally, some agencies 
have established special units or plans for carrying out their 
antitrafficking duties. 

Federal agencies have coordinated across agencies on investigations and 
prosecutions of trafficking crimes on a case-by-case basis, determined 
by individual case needs, and established relationships among law 
enforcement officials across agencies. For example, several federal 
agencies worked together to resolve a landmark trafficking case 
involving over 250 victims. However, DOJ and DHS officials have 
identified the need to advance and expand U.S. efforts to combat 
trafficking through more collaborative and proactive strategies to 
identify trafficking victims. Prior GAO work on interagency 
collaboration has shown that a strategic framework that includes, among 
other things, a common outcome, mutually reinforcing strategies, and 
compatible polices and procedures to operate across agency boundaries 
can help enhance and sustain collaboration among federal agencies 
dealing with issues that are national in scope and cross agency 
jurisdictions. 

To support U.S. efforts to investigate trafficking in persons, BJA has 
awarded grants of up to $450,000 to establish 42 state and local human 
trafficking law enforcement task forces. BJA has funded the development 
of a train-the-trainer curriculum and a national conference on human 
trafficking and taken further steps to respond to task force technical 
assistance needs. Nevertheless, task force members from the seven task 
forces we contacted and DOJ officials identified continued and 
additional assistance needs. BJA does not have a technical assistance 
plan for its human trafficking task force grant program. Prior GAO work 
has shown the need for agencies that administer grants or funding to 
state and local entities to implement a plan to focus technical 
assistance on areas of greatest need. BJA officials said they were 
preparing a plan to provide additional and proactive technical 
assistance to the task forces, but as of June 2007 had not received the 
necessary approvals. 

What GAO Recommends: 

GAO recommends that the Attorney General and Secretary of DHS develop 
and implement a strategic framework to enhance collaboration and the 
Attorney General direct BJA to develop and implement a plan to help 
focus technical assistance to the task forces. DOJ and DHS generally 
agreed with the need for enhanced collaboration, and DOJ identified 
steps to assist the task forces. 

[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-915]. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Robert Goldenkoff at 
(202) 512-2757 or GoldenkoffR@gao.gov. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

Federal Agencies Have Undertaken Key Activities to Combat Trafficking 
in Persons Crimes: 

Federal Agencies Have Coordinated on Individual Trafficking Cases, but 
a Strategic Framework Could Help Further and Sustain Interagency 
Collaboration: 

BJA Has Helped Support Federally Funded State and Local Human 
Trafficking Law Enforcement Task Forces, but Lacks a Plan to Identify 
and Focus Technical Assistance Needs: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Statutory Provisions Used to Investigate and Prosecute 
Trafficking Crimes: 

Appendix III: Federal Efforts to Investigate and Prosecute Trafficking 
in Persons and Data on Resources: 

Appendix IV: Summary Case Studies: 

Appendix V: Comments from the Department of Justice: 

Appendix VI: Comments from the Department of Homeland Security: 

Appendix VII: GAO Contact and Staff Acknowledgments: 

Related GAO Products: 

Tables: 

Table 1: Primary Statutory Provisions Used for Trafficking in Persons 
Prosecutions: 

Table 2: Other Related Statutory Provisions Used in Trafficking in 
Persons Prosecutions: 

Table 3: Trafficking in Persons Prosecutorial Statistics for Civil 
Rights Division/Criminal Section and U.S. Attorneys' Offices, Fiscal 
Year 1995 through June 14, 2007: 

Table 4: Trafficking in Persons Cases Investigated by the FBI's Civil 
Rights Unit, Fiscal Year 2001 through April 5, 2007: 

Table 5: Trafficking in Persons Cases Investigated by Immigration and 
Customs Enforcement, Fiscal Year 2005 through May 31, 2007: 

Table 6: Innocence Lost Statistics, Fiscal Year 2004 through June 5, 
2007: 

Table 7: DOJ Estimates of CRT/CS Trafficking in Persons Resources, 
Fiscal Years 2000-2007: 

Figures: 

Figure 1: Federal Agencies with Primary Responsibilities for 
Investigating and Prosecuting Trafficking in Persons Crimes: 

Figure 2: BJA-Funded Human Trafficking Law Enforcement Task Forces: 

Abbreviations: 

AUSA: Assistant U.S. Attorney: 

BJA: Bureau of Justice Assistance: 

CEOS: Criminal Division/Child Exploitation and Obscenity Section: 

CRT/CS: Civil Rights Division/Criminal Section: 

DHS: Department of Homeland Security: 

DOJ: Department of Justice: 

DOL: Department of Labor: 

DOS: Department of State: 

FBI: Federal Bureau of Investigation: 

FLSA: Fair Labor Standards Act: 

HSTC: Human Smuggling and Trafficking Center: 

HTP: Human Trafficking Prosecution: 

ICE: Immigration and Customs Enforcement: 

ICE TIPS: ICE Trafficking in Persons Strategy: 

JTN: Justice Television Network: 

OVC: Office for Victims of Crime: 

SAC: Special Agent in Charge: 

TVPA: Trafficking Victims Protection Act of 2000: 

WHD: Wage and Hour Division: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

July 26, 2007: 

The Honorable Ileana Ros-Lehtinen: 
Ranking Member: 
Committee on Foreign Affairs: 
House of Representatives: 

The Honorable F. James Sensenbrenner: 
House of Representatives: 

Human trafficking is a transnational crime whose victims include men, 
women, and children and may involve violations of labor, immigration, 
antislavery, and other criminal laws. Victims of trafficking are 
bought, sold, sometimes transported across national boundaries, and 
forced to work in legal or illegal situations, including the sex 
industry, sweatshops, domestic service, and agriculture, among 
others.[Footnote 1] What usually distinguishes trafficking from crimes 
such as alien smuggling or other labor law violations is the 
trafficker's use of force, fraud, or coercion to compel these victims 
into, or hold them in, the employment situation. Despite international 
acknowledgment of the trafficking problem as a human rights violation, 
estimates of the number of victims remain questionable because of 
methodological weaknesses, gaps in data, and numerical 
discrepancies.[Footnote 2] Since the mid-1990s, the United States has 
played a leading role in putting trafficking in persons on the 
international community's agenda and pursued trafficking crimes within 
the United States. By 2000, various U.S. policymakers had determined 
that existing U.S. statutes scattered enforcement authority across the 
government and did not adequately protect trafficking victims, deter 
trafficking, and bring traffickers to justice. 

As a result, in October 2000, Congress passed the Trafficking Victims 
Protection Act of 2000 (TVPA) to ensure just and effective punishment 
of traffickers and protection of victims.[Footnote 3] Among other 
things, the TVPA made it illegal to obtain or maintain persons for 
commercial sexual activity, using force, fraud, or coercion for those 
18 or over (but proof of force, fraud, or coercion is not required for 
those under 18), and to use certain kinds of force or coercion to 
provide or obtain persons for any labor or services (e.g., work in 
farms, factories, and households). The act also updated and 
supplemented existing involuntary servitude statutes used to prosecute 
trafficking crimes, enhanced the penalties for trafficking crimes, and 
provided a range of new protections and assistance for victims of 
trafficking. Congress reauthorized the act in 2003 and 2005, and it is 
subject to reauthorization in 2007.[Footnote 4] 

Nevertheless, pursuing trafficking in persons crimes continues to 
present special challenges to federal investigators and prosecutors. 
Since the primary eyewitness to and evidence of the crime is typically 
the trafficking victim, the first step in pursuing these crimes is 
usually to identify victims. Yet these victims are often hidden from 
view, employed in legal or illegal enterprises, do not view themselves 
as victims, or are considered to be criminals or accessories to crimes 
(e.g., prostitutes or smuggled aliens) subject to incarceration or 
deportation. A nongovernmental organization, average citizens, or even 
state and local law enforcement working in the community may be the 
first point of contact for a trafficking victim, rather than federal 
law enforcement. 

Moreover, trafficking in persons cases are difficult to pursue because 
they are multifaceted, complex, and resource intensive. Federal 
agencies have to determine whether those identified as potential 
victims have in fact been trafficked and then secure their cooperation 
in order to pursue the investigation and prosecution of the 
traffickers. Victims may be reluctant to testify because of trauma, 
fear, loyalty to the trafficker, or distrust of law enforcement. 
Moreover, a single case may involve one or hundreds of victims, 
requiring housing, food, and other services from federal agencies; 
diverse offenses, such as violent crime, labor exploitation, sex 
crimes, alien smuggling, organized crime, and financial crimes; and 
collection of significant evidence from overseas. 

Accordingly, investigating and prosecuting trafficking crimes requires 
collaboration[Footnote 5] among multiple components of the Departments 
of Justice (DOJ) and Homeland Security (DHS) with responsibilities for 
investigating and prosecuting trafficking crimes. Identifying 
trafficking and victims can also involve collaboration between DOJ and 
DHS agencies and components of the Departments of Labor (DOL) and State 
(DOS) that may uncover information relevant to the pursuit of 
trafficking crimes in the course of carrying out their missions. 
Collaboration is also needed between federal agencies and state and 
local law enforcement and nongovernmental organizations. Recognizing 
the need to leverage these resources to identify victims and support 
federal efforts to pursue traffickers, DOJ's Bureau of Justice 
Assistance (BJA), working with the Office for Victims of Crime (OVC), 
implemented a competitive grant program in 2004 to fund human 
trafficking law enforcement task forces composed of state and local law 
enforcement agencies, field offices of federal agencies, and victim and 
social service organizations with the support of the local U.S. 
Attorney. As of fiscal year 2006, BJA had funded 42 task forces across 
the country. 

As requested, to ascertain the status of U.S. efforts to investigate 
and prosecute trafficking crimes, this report discusses (1) key 
activities federal agencies have undertaken to combat trafficking in 
persons crimes, (2) federal efforts to coordinate investigations and 
prosecutions of trafficking in persons crimes and whether these efforts 
might be enhanced, and (3) how BJA supported federally funded state and 
local human trafficking task forces and whether these efforts might be 
improved. This review is part of a larger body of work we have 
conducted on U.S. efforts to combat trafficking in persons, here and 
abroad. A companion report that examines U.S. and multilateral efforts 
to combat human trafficking overseas was also issued today.[Footnote 6] 

To determine key activities federal agencies have undertaken to combat 
trafficking in persons crimes, we reviewed agency reports describing 
these activities and strategies and memorandums applicable to federal 
efforts to address these crimes. We interviewed officials from DOJ, 
including the Federal Bureau of Investigation (FBI), Civil Rights 
Division/Criminal Section (CRT/CS), Criminal Division/Child 
Exploitation and Obscenity Section (CEOS), and the Executive Office for 
U.S. Attorneys; DHS U.S. Immigration and Customs Enforcement (ICE) and 
U.S. Citizenship and Immigration Services (CIS); DOL's Wage and Hour 
Division; DOS's Bureau of Diplomatic Security and Office to Monitor and 
Combat Trafficking in Persons; and the Human Smuggling and Trafficking 
Center (HSTC).[Footnote 7] From the FBI, ICE, CRT/CS, and CEOS, we 
obtained and analyzed relevant data on the cases investigated and 
prosecuted, including numbers of cases, defendants charged, and 
convictions, as well as, where possible, estimates of the resources 
used to do so. We discussed the sources of these data with federal 
agency officials to determine that these data were sufficiently 
reliable to show trends in agencies' activities undertaken to 
investigate and prosecute trafficking crimes. 

To determine what efforts federal agencies have undertaken to 
coordinate investigations and prosecutions of trafficking in persons 
crimes and whether these efforts might be enhanced, we reviewed 
pertinent documents, such as agency reports, strategies, and 
memorandums to field offices, which described or directed agency and 
interagency coordination on trafficking activities. We interviewed 
officials from DOJ headquarters, including FBI, CRT/CS, CEOS, and the 
Executive Office for U.S. Attorneys; ICE and CIS; DOL's Wage and Hour 
Division; DOS's Bureau of Diplomatic Security and Office to Monitor and 
Combat Trafficking in Persons; and HSTC. We also interviewed field 
personnel from FBI, ICE, DOL, and selected U.S. Attorney's Offices. In 
addition, we used relevant GAO reports on enhancing interagency 
collaboration as criteria. 

To assess how BJA has supported federally funded state and local human 
trafficking task forces and whether these efforts might be improved, we 
analyzed relevant documents and grant reports from BJA, including grant 
solicitations, performance reports, and Web site information; met with 
BJA, OVC, and CRT/CS officials to discuss the documents and technical 
assistance to the task forces; made site visits to three task forces; 
and conducted telephone interviews with key participants from four 
other task forces. The task forces contacted were judgmentally selected 
based on the length of time funded (fiscal year 2004); different levels 
of success, based on BJA performance measures (e.g., number of 
identified potential trafficking victims); and focus (e.g., trafficking 
for labor, sex, or both). We interviewed key task force participants 
(e.g., Assistant U.S. Attorneys, local and federal law enforcement, and 
representatives of nongovernmental organizations) from the seven task 
forces. Although this approach does not allow for generalizing, it 
provided additional information on steps federal agencies took to 
support state and local human trafficking task forces. In addition, we 
reviewed relevant GAO reports on federal agencies' administration of 
grants or funding to state and local entities. 

We conducted our work from June 2006 through June 2007 in accordance 
with generally accepted government auditing standards. Appendix I 
presents more details about the scope and methodology of our work. 

Results in Brief: 

Since the enactment of the TVPA in 2000, federal investigative and 
prosecutorial agencies have undertaken several key activities to combat 
trafficking in persons crimes, such as (1) investigating allegations of 
trafficking leading to 139 prosecutions;[Footnote 8] (2) providing 
training, outreach, and state and local initiatives to support 
investigations and prosecutions; and (3) addressing agency 
responsibilities by establishing special units and developing agency- 
level goals, plans, and strategies. For example, federal agencies have 
provided training on trafficking in persons to their new and current 
personnel using a variety of techniques, including integrating 
information on trafficking into the curriculum at the respective 
training academies and centers, providing Web-based training through 
internal agency Web sites, and developing and disseminating guidance on 
how to pursue these cases. Agencies have also sponsored outreach and 
training to state and local law enforcement, nongovernmental 
organizations, and the general public, for example, through a toll-free 
complaint line, newsletters, and national conferences. Finally, ICE and 
CRT/CS have established special units focused on trafficking, and ICE, 
FBI, CRT/CS, and DOL have developed goals, strategies, or plans for 
carrying out their antitrafficking responsibilities. 

Federal agencies have coordinated investigations and prosecutions of 
trafficking crimes across agencies on a case-by-case basis, but their 
approaches to expand the scope of efforts to combat trafficking could 
benefit from an overall strategic framework to help enhance and sustain 
interagency collaboration on trafficking in persons. Agencies have 
described their coordination as reactive, and coordination has occurred 
as determined by the needs of individual cases and the established 
relationships among law enforcement officials across agencies. For 
example, federal agencies worked together to successfully resolve a 
landmark trafficking case involving over 250 victims. Federal agencies 
identified additional activities needed to expand U.S. efforts to 
identify trafficking victims and institutionalize collaborative 
relationships among federal agencies and between federal agencies and 
state and local law enforcement and nongovernmental organizations. 
These included developing coordinated proactive approaches to identify 
trafficking victims; intelligence gathering; analysis of trafficking 
patterns; and expanding outreach to non-law-enforcement agencies, 
nongovernmental organizations, and other law enforcement agencies. 
However, the current coordinating mechanisms do not address the 
interagency collaboration needed for this level of expanded effort, and 
individual agency plans only address individual agency goals linked to 
agency missions--none of which is linked to a common governmentwide 
outcome for investigations and prosecutions of trafficking crimes. 
Additionally, while no single agency can bring traffickers to justice, 
agencies have differing views on leadership of U.S. efforts to 
investigate and prosecute trafficking and information sharing policies. 
Our previous work has shown that a strategic framework that, at a 
minimum, includes agencies working together toward a common outcome 
with mutually reinforcing strategies; agreed-on roles and 
responsibilities; and compatible polices, procedures, and other means 
to operate across agency boundaries can help enhance and sustain 
collaboration among federal agencies dealing with issues, such as 
trafficking in persons, that are national in scope and cross agency 
jurisdictions.[Footnote 9] Establishing such a strategic framework to 
investigate and prosecute trafficking in persons crimes, as developed 
by federal agencies to address the unique challenges posed by these 
crimes, could help federal agencies enhance and sustain the 
collaboration needed to expand their efforts to combat trafficking 
crimes. 

To support U.S. efforts to identify trafficking victims and investigate 
and prosecute trafficking in persons crimes, BJA established a 
competitive grant program to fund state and local law enforcement human 
trafficking task forces, but lacks a plan to identify and focus the 
task forces' technical assistance needs. Since 2004, BJA has awarded 42 
task force grants (22 in fiscal year 2004 and 10 each in fiscal years 
2005 and 2006) of up to $450,000 each, for a 3-year period for a total 
of a total of $17,324,182. According to BJA, it has used $1,433,000 of 
its general funds to provide technical assistance to the task forces, 
including financing the development of a train-the-trainer curriculum 
on human trafficking, delivering training sessions using the 
curriculum, and funding the national conference on human trafficking 
held in New Orleans in October 2006. In addition BJA reported that it 
had taken steps to help it respond to human trafficking task force 
technical assistance needs, including using task force performance 
measures to help resolve task force performance issues; providing task 
forces with information to help them submit better performance data; 
and conducting site visits, in conjunction with other DOJ components, 
to some task forces. Nevertheless, DOJ officials and task force members 
also pointed to continued and additional technical assistance and 
training needs, including advanced training on techniques to facilitate 
law enforcement and nongovernmental organizations working together to 
interview trafficking victims, standardized protocols, or a Web site to 
facilitate information sharing among the task forces. At the time of 
our review, BJA did not have a technical assistance plan for its human 
trafficking task force initiative. Our previous work on federal grant 
programs has shown the need for agencies that administer grants or 
funding to state and local entities to implement a plan to focus 
technical assistance efforts on areas of greatest need.[Footnote 10] 
BJA told us that it was developing a plan to provide additional and 
proactive technical assistance to the task forces, but as of June 2007 
had not received the necessary approvals. 

To help ensure that the U.S. government maximizes its ability to 
enforce laws governing trafficking in persons, we recommend that the 
Attorney General and the Secretary of Homeland Security, with other 
agencies that support these enforcement efforts, develop and implement 
a strategic framework for investigating and prosecuting trafficking 
crimes that, at a minimum, defines and articulates a common outcome; 
establishes mutually reinforcing or joint strategies; agrees on roles 
and responsibilities; and establishes compatible policies, procedures, 
and other means to operate across agency boundaries. In addition, to 
enable BJA to better support the federally funded state and local human 
trafficking task forces, we recommend that the Attorney General direct 
the Director of the Bureau of Justice Assistance to develop and 
implement a plan to help focus technical assistance to the task forces. 

DOJ and DHS generally agreed with the content of our report and the 
need for enhanced collaboration to expand U.S. efforts to investigate 
and prosecute trafficking crimes. Regarding our recommendation to the 
Attorney General and the Secretary of Homeland Security to develop a 
strategic framework to coordinate U.S. efforts to investigate and 
prosecute trafficking crimes, DOJ proposed that the report identify the 
need for continued collaboration, but not mandate one particular 
collaborative model. We acknowledged that it was not our intent to 
prescribe a particular collaborative model and that specific elements 
of and structures for developing and implementing the strategic 
framework would be developed by the agencies involved. We added 
language to our report that reinforces this point. Commenting on this 
recommendation, DHS said that ICE would support such a framework if 
certain considerations were taken into account, such as recognizing 
that agencies' roles in a particular case would vary by available 
resources, local priorities, and the nature of the case and 
investigation. GAO would expect that the agencies involved in 
developing and implementing this framework would determine how to 
address these considerations. DOJ identified the efforts it would be 
undertaking by October 1, 2007, to address our recommendation that the 
Attorney General call on the Director of BJA to develop a plan for 
providing technical assistance to the human trafficking law enforcement 
task forces. 

Background: 

Congress passed the Trafficking Victims Protection Act of 2000 to 
combat trafficking in persons. As the centerpiece for U.S. 
antitrafficking efforts, the TVPA advanced a three-pronged victim- 
centered approach--prevention of trafficking, protection and assistance 
for victims of trafficking, and prosecution and punishment of 
traffickers. Among its provisions, the TVPA addressed identified gaps 
in existing law and enhanced the tools available to pursue these 
crimes. Specifically, the act criminalized the obtaining or maintaining 
of persons for commercial sexual activity, using force, fraud, or 
coercion for those 18 or over (but not for those under 18), and to use 
certain kinds of force or coercion to provide or obtain persons for any 
labor or services (e.g., work in farms, factories, and households). It 
also included nonviolent coercion and threats of harm to third persons 
in federal involuntary servitude laws; made attempted trafficking 
crimes punishable; criminalized the holding of actual or purported 
identity documents in the course of committing, or with the intent to 
commit, any trafficking crime; and increased the maximum penalty for 
slavery and involuntary servitude offenses from 10 to 20 years or to a 
life sentence if the offense involved factors like death, kidnapping, 
or aggravated sexual abuse. In addition, the TVPA required restitution 
for victims of trafficking and forfeiture of traffickers' assets and 
provided legal status and special benefits to aliens certified as 
trafficking victims in the United States who are willing to assist law 
enforcement efforts against traffickers.[Footnote 11] (App. II 
identifies specific statutory provisions relevant to investigating and 
prosecuting trafficking in persons crimes.) 

Responsibilities for pursuing trafficking crimes fall to multiple 
federal agencies, including the FBI and ICE, which investigate these 
crimes; CRT/CS, CEOS, and U.S. Attorney's Offices, which prosecute 
traffickers; and other agencies within DHS and DOJ and components of 
DOL and DOS that support U.S. efforts to investigate and prosecute 
trafficking in persons. Figure 1 depicts these key agencies and their 
respective responsibilities related to the investigation and 
prosecution of trafficking in persons crimes. 

Figure 1: Federal Agencies with Primary Responsibilities for 
Investigating and Prosecuting Trafficking in Persons Crimes: 

[See PDF for image] 

Source: GAO analysis of agency documents. 

[A] T visas grant eligible alien victims of trafficking nonimmigrant 
status for up to 4 years, with the possibility of an extension. 

[End of figure] 

In addition, to coordinate the implementation of the TVPA, the act 
directed the President to establish an Interagency Task Force to 
Monitor and Combat Trafficking in Persons and authorized the Secretary 
of State to create the Office to Monitor and Combat Trafficking in 
Persons to provide assistance to the task force. In February 2002, the 
President issued an executive order creating this cabinet-level task 
force and then in December issued National Security Presidential 
Directive 22, which identified trafficking in persons as an important 
national security issue and directed federal agencies to strengthen 
their collective efforts, capabilities, and coordination to support the 
goal of abolishing human trafficking.[Footnote 12] Subsequently, the 
2003 TVPA reauthorization statutorily established the Senior Policy 
Operating Group (SPOG) to address interagency policy, program, and 
planning issues regarding the TVPA's implementation.[Footnote 13] In 
addition, HSTC, which is staffed by detailees from DHS, DOJ, DOS, and 
the intelligence community, among other places, collects and 
disseminates intelligence information to build a comprehensive picture 
of human trafficking.[Footnote 14] 

Pursuing trafficking investigations and prosecutions also needs the 
support of state and local law enforcement, who may be in the best 
position to find trafficking victims because of their familiarity with 
their respective jurisdictions, and nongovernmental organizations, from 
whom victims may more readily seek assistance. To leverage these 
resources to support federal efforts to investigate and prosecute 
trafficking in persons, DOJ designed, developed, and instituted a task 
force approach that it presented during the first National Training 
Conference on Human Trafficking: Rescuing Women and Children from 
Slavery, held in Tampa, Florida, in July 2004. DOJ invited 21 teams of 
20 federal, state, and local law enforcement and nongovernmental 
service providers from communities that it believed to have potential 
trafficking problems to attend the conference. After the conference, 
the teams were expected to work together on human trafficking in their 
respective communities. To implement the approach, BJA, the DOJ 
component responsible for supporting local, state, and tribal efforts 
to achieve safer communities, developed and implemented a human 
trafficking law enforcement task force competitive grant program. These 
grants were to be awarded to state or local police agencies that work 
with the local U.S. Attorney's Office, federal law enforcement 
entities, and nongovernmental organizations that may come into contact 
with victims of trafficking. In addition, in spring 2003, the FBI's 
Crimes Against Children Unit, DOJ's Child Exploitation and Obscenity 
Section, and the National Center for Missing and Exploited Children 
launched the Innocence Lost National Initiative in 14 U.S. cities where 
the FBI field offices had identified a high incidence of trafficking of 
U.S. children for commercial sex. 

As trafficking in persons is a transnational crime, federal agencies 
may need to obtain information and assistance directly from individual 
foreign governments and through international law enforcement 
organizations in order to investigate and prosecute trafficking in 
persons cases in the United States. Multilateral and extradition 
treaties provide the authority for U.S. investigative and prosecutorial 
agencies to request information and assistance on criminal cases, 
including trafficking in persons, from approximately 175 individual 
foreign governments.[Footnote 15] Working through ICE and FBI personnel 
stationed at U.S. embassies, U.S. investigative and prosecutorial 
agencies have obtained a broad spectrum of assistance from individual 
foreign governments and with such assistance have successfully 
prosecuted traffickers. This assistance has included obtaining 
documentary evidence and corroborating witness testimony, protecting 
U.S. trafficking victims' family members in a foreign country, 
apprehending fugitive traffickers, and extraditing defendants. In 
addition, U.S. agencies may obtain information through the 
International Criminal Police Organization, Interpol, which serves as a 
conduit for a cooperative exchange of information on criminal 
activities from its 186 member countries.[Footnote 16] 

Federal Agencies Have Undertaken Key Activities to Combat Trafficking 
in Persons Crimes: 

Subsequent to the enactment of the TVPA, federal agencies reported 139 
prosecutions[Footnote 17] and hundreds of investigations of trafficking 
for commercial sex or labor as of June 2007. To support federal efforts 
to identify victims and investigate and prosecute these crimes, 
agencies (1) provided training to agency personnel to raise awareness 
and increase the skills needed to identify victims and pursue 
trafficking investigations and prosecutions, (2) carried out outreach 
and training to raise public awareness of and skills in identifying 
trafficking victims, and (3) engaged state and local knowledge and 
resources by funding state and local trafficking in persons task forces 
and developing and disseminating a model state law. In addition, to 
address their responsibilities related to trafficking in persons 
crimes, some agencies have established special units, agency-level 
goals, or plans or strategies. Federal investigative and prosecutorial 
agencies have generally drawn from existing resources to carry out 
these efforts (app. III provides information on resources). 

Federal Agencies Reported a General Increase in Investigations and 
Prosecutions of Trafficking in Persons Beginning in Fiscal Year 2001: 

With the enhanced tools available to federal investigators and 
prosecutors as a result of the enactment of the TVPA, federal agencies 
reported a general increase in the number of prosecutions and 
investigations of trafficking in persons crimes. These data are an 
indicator of the level of agency effort in pursuit of these crimes, 
since fiscal year 2001, although they are limited by a number of 
factors. Trafficking crimes and their victims are hidden and not 
readily identifiable. Traffickers may be charged or convicted of other 
than trafficking crimes (e.g., kidnapping, immigration violations, or 
money laundering) for strategic or technical reasons. Also, limitations 
of agency data systems, which are primarily case management systems, 
may not allow for the extraction of trafficking data per se. In 
addition, availability of individual agencies' data may be limited by 
factors pertinent to that agency; for example, ICE was only established 
in 2003. Moreover, agency data are not comparable across agencies nor 
can data on investigations be linked to data on prosecutions. As a 
result of these limitations, however, the actual number of 
investigations and prosecutions that have led to the incapacitation of 
traffickers may be greater than the numbers that have been reported by 
federal agencies. 

CRT/CS reported 139 prosecutions from fiscal year 2001 to June 14, 
2007,[Footnote 18] as compared with 19 cases for fiscal years 1995 to 
2000. These cases included 39 defined by CRT/CS as labor trafficking 
and 100 as trafficking for commercial sexual activity. According to 
CRT/CS officials, the number of prosecutions varies in any given year, 
because of differences in the complexity of the cases. (See app. IV for 
illustrations of the complexity of cases.) FBI and ICE provided data on 
numbers of trafficking cases opened. The FBI's Civil Rights Unit 
reported opening a total of 751 trafficking in persons cases between 
fiscal year 2001 and April 5, 2007. However, these data do not include 
investigations involving trafficking that are classified as other types 
of crime, for example, alien smuggling cases that also involve 
trafficking in persons. ICE reported opening a total of 899 trafficking 
in persons cases, for fiscal year 2005 through May 31, 2007.[Footnote 
19] Both FBI and ICE data may include cases involving investigations 
handled jointly by the two agencies. In addition, as part of the 
Innocence Lost National Initiative, the FBI's Crimes Against Children 
Unit reported 327 cases opened on trafficking of U.S. children for 
commercial sex between fiscal year 2004 and June 5, 2007. Appendix III 
presents additional data related to trafficking in persons 
investigations and prosecutions; including arrests; indictments; 
convictions; and restitution to the victims, as required under the 
TVPA, where appropriate. 

Federal Agencies Have Undertaken Training, Outreach, and State and 
Local Initiatives to Support Federal Efforts to Investigate and 
Prosecute Trafficking Crimes: 

National Security Presidential Directive 22 directed federal 
departments and agencies to ensure that all appropriate offices within 
their jurisdiction were fully trained to carry out their specific 
responsibilities to combat trafficking, including interagency 
cooperation and coordination on the investigation and prosecution of 
trafficking. FBI, ICE, CRT/CS, CEOS, and DOL all reported taking steps 
to ensure that their personnel received appropriate training, using a 
variety of means to do so, including the following: 

* training for new agents through the ICE and FBI training academies; 

* a Web-based training module, which is available to ICE agents through 
ICE's intranet;[Footnote 20] 

* guidance to ICE domestic and international field offices about 
conducting outreach, training, and coalition building; 

* training conference sessions by the FBI Civil Rights Unit and 
information on trafficking in the FBI's civil rights reference guide 
for FBI agents; 

* training of U.S. Attorneys and other prosecutors on trafficking in 
persons and trafficking of U.S. children for commercial sex, at the 
National Advocacy Center;[Footnote 21] 

* guidance to all U.S. Attorneys' Offices about prosecuting under the 
TVPA, a tool kit for prosecutors, and a law guide, developed by CRT/CS; 

* training for victim-witness coordinators, who are the federal 
government's liaisons to victims of federal crimes, and updating the 
Attorney General's victim/witness guidelines to include trafficking in 
persons; 

* a nationwide televised human trafficking training initiative on the 
Justice Television Network (JTN), initiated by CRT/CS in 2006 and 
continuing in 2007, transmitted from the National Advocacy Center to 
all 94 U.S. Attorneys' Offices. These offices and BJA-funded state and 
local human trafficking task forces hosted members of the law 
enforcement and nongovernmental organization communities to view these 
programs; and: 

* a week-long seminar on investigating and prosecuting cases involving 
child sex trafficking, developed by CEOS, FBI, and the National Center 
for Missing and Exploited Children for the joint training of state and 
federal law enforcement agencies, prosecutors, and social service 
providers in targeted cities. This seminar is given multiple times each 
year. 

In addition, to help identify victims of trafficking and support 
federal efforts to pursue trafficking investigations, agencies have 
used a variety of means to extend outreach and training to state and 
local law enforcement, nongovernmental organizations, and the general 
public. ICE developed laminated wallet-size cards, in five languages, 
identifying the differences between human smuggling and human 
trafficking as well as red flag indicators for human trafficking and 
also developed a police roll call/muster DVD describing human 
trafficking. CRT/CS publishes a newsletter on trafficking, available on 
the DOJ Web site, and in collaboration with other federal agencies and 
DOJ components, prepared and published the Report on Activities to 
Combat Trafficking: Fiscal Years 2001-2005. DOJ's Office of Legal 
Policy prepares the Attorney General's annual report to Congress on 
U.S. efforts to combat trafficking, as required by the TVPA of 2003, 
and the annual assessment of those efforts. DOJ also established, and 
subsequently permanently funded, a toll-free Trafficking in Persons and 
Worker Exploitation Complaint Line in February 2000 to provide a means 
for victims, witnesses, and others to report potential trafficking 
matters to law enforcement, get information, and obtain referrals to 
services in their area.[Footnote 22] In 2004 and 2006, federal agencies 
sponsored and participated in national conferences on human trafficking 
in Tampa, Florida, and New Orleans, Louisiana, respectively.[Footnote 
23] In 2006, CRT/CS, with the Attorney General, produced the film Give 
Us Freedom: Liberty and Justice for Victims of Modern Day Slavery. 

To further U.S. investigations and prosecutions of trafficking in 
persons crimes, federal agencies have also fostered antitrafficking 
efforts at the state and local levels. For example, federal agencies 
have sought to engage state and local law enforcement and 
nongovernmental organizations by funding the establishment of state and 
local trafficking in persons task forces that bring together local law 
enforcement, federal law enforcement, a U.S. Attorney, and 
nongovernmental victim service providers. In addition, to expand 
antitrafficking law enforcement authority and promote a uniform 
national legal strategy to combat human trafficking, DOJ developed a 
model state law, available on the DOJ Web site. According to DOJ, at 
the time of its initial dissemination in 2004, 4 states--Texas, 
Florida, Missouri, and Washington--had laws against trafficking in 
persons. As of June 2007, 31 states had enacted antitrafficking in 
persons legislation.[Footnote 24] 

Individual Federal Agencies Have Established Special Units, Agency- 
level Goals, or Plans or Strategies to Address Trafficking in Persons 
Responsibilities: 

National Security Presidential Directive 22 directed all federal 
agencies to develop and promulgate plans to implement the directive by 
March 2003. Plans for DOJ, DHS,[Footnote 25] DOL, and DOS enumerate 
activities relevant to the investigation and prosecution of trafficking 
in persons. Additionally, some agencies have undertaken various steps 
to address their respective responsibilities related to the 
investigation and prosecution of trafficking in persons, including 
establishing special units that focus on trafficking in persons, agency-
level goals, or plans or strategies. In doing so, each of these 
agencies has defined its responsibilities for pursuing trafficking 
crimes in accordance with its broader agency mission. 

Both ICE and CRT/CS have established specialized units focused on 
trafficking in persons. The ICE Office of Investigations' Human 
Smuggling and Trafficking Unit, consisting of a unit chief, with a 
staff consisting of program managers who oversee programmatic and 
operational issues globally, and victim witness coordinators, oversees 
ICE's efforts to identify criminal smuggling and trafficking 
organizations, prioritizes investigations based on risk factors, 
coordinates field office investigations into those targeted 
organizations, and coordinates victim assistance through approximately 
300 of ICE's collateral-duty victim witness coordinators.[Footnote 26] 
On January 31, 2007, the Attorney General and the Assistant Attorney 
General for the Civil Rights Division announced the formation of a 
special Human Trafficking Prosecution (HTP) Unit within CRT/CS. 
According to CRT/CS officials, the unit is to continue to play a role 
in coordinating intra-DOJ and interagency trafficking efforts (e.g., 
with ICE); develop new strategies to increase human trafficking 
investigations and prosecutions throughout the nation; enhance DOJ's 
investigations and prosecutions of trafficking crimes by pursuing cases 
that are multijurisdictional or involve financial crimes; and also 
continue to engage in training, technical assistance, and outreach 
initiatives to federal, state, and local law enforcement and 
nongovernmental organizations. 

The primary investigative agencies for trafficking in persons have laid 
out goals and activities for combating this crime. The top goal of 
ICE's trafficking in persons efforts--to disrupt and dismantle criminal 
organizations involved in trafficking, including intelligence gathering 
on these organizations--is aligned with DHS strategic goals of 
assessing vulnerabilities and mitigating threats to the homeland. In 
addition, ICE's trafficking goals of seizing assets of criminal 
organizations and rescuing and protecting victims of trafficking follow 
ICE's top goal. The FBI's Strategic Plan 2004-2009 identifies 
investigations of trafficking in persons crimes as a rising priority 
under its responsibility to enforce civil rights protections. In 
addition, the FBI Civil Rights Unit specifies the strengthening of its 
intelligence base on trafficking activity as a top priority among its 
programmatic goals and emphasizes coordination with other law 
enforcement entities and partnerships with nongovernmental 
organizations in pursuing trafficking investigations. 

Furthermore, both ICE and FBI have disseminated guidance on handling 
trafficking cases to their agents in the field. In December 2006, the 
ICE Director of Investigations disseminated to Special Agents in Charge 
(SACs) and ICE personnel assigned to U.S. embassies the ICE Office of 
Investigations' new strategy document for combating trafficking in 
persons, entitled ICE Trafficking In Persons Strategy, or ICE TIPS. ICE 
TIPS emphasizes outreach and education on ICE's role in trafficking 
investigations and ability to issue Continued Presence, a mechanism for 
authorizing victims without legal immigration status to remain in the 
United States; collaborations with other law enforcement entities and 
nongovernmental service providers, including task force participation; 
and performance evaluation to focus and refine ICE's efforts. In May 
2007, additional guidance from the ICE Office of Investigations and the 
ICE Office of International Affairs was sent to SACs and ICE personnel 
assigned to U.S. embassies overseas. The guidance provided direction on 
outreach, training, coordination, and coalition building and mandated 
periodic reporting of efforts to ICE headquarters. The FBI's guidance 
is contained in its Civil Rights Program Reference Guide, the fiscal 
year Civil Rights Program Plan, and memorandums to the field. The 
fiscal year 2007 Civil Rights Program Plan provides information similar 
to that contained in ICE TIPS and encourages working partnerships with 
other law enforcement entities and nongovernmental service providers, 
including providing training to these groups. 

As the lead prosecutorial agency for trafficking in persons, CRT/CS 
identified three levels of strategic planning for its trafficking 
efforts. DOJ's Strategic Plan (Fiscal Years 2003-2008) lays out broad 
goals and performance measures. Specifically, CRT/CS's efforts on 
trafficking in persons fall under goal two--enforce federal laws and 
represent the rights and interests of the American people, strategic 
objective 2.4--to uphold the civil and constitutional rights of all 
Americans and protect vulnerable members of society. According to the 
strategy, the Civil Rights Division intends to protect new immigrants 
to America by, among other things, vigorously prosecuting those who 
exploit their vulnerability through trafficking in persons, including 
increasing efforts to combat the criminal trafficking of children and 
other vulnerable victims, through more intensified efforts and 
interagency coordination. To achieve DOJ's strategic goals and 
objectives, CRT/CS's fiscal year 2007 internal priorities document lays 
out activities to be undertaken in three areas--investigation and 
prosecution; outreach and training; and policy development, including 
intergovernmental coordination. In addition, DOJ communicates direction 
and guidance on handling trafficking in persons cases through internal 
DOJ memorandums between CRT/CS and U.S. Attorneys, including guidance 
to U.S. Attorneys on how to prosecute trafficking cases, memorandums 
between CRT/CS and the FBI, and memorandums between DOJ and other 
federal agencies.[Footnote 27] 

In addition, DOL's Wage and Hour Division has an internal plan that 
addresses its role in federal interagency trafficking efforts. The plan 
presents current goals and measures for the division's involvement with 
human trafficking task forces in investigations, as appropriate with 
its mission, and in assisting trafficking victims in securing 
restitution, as well as long-term goals and measures for increasing 
these efforts. 

Federal Agencies Have Coordinated on Individual Trafficking Cases, but 
a Strategic Framework Could Help Further and Sustain Interagency 
Collaboration: 

Recognizing that investigating and prosecuting trafficking cases can be 
complex and multifaceted activities, federal agencies have taken steps 
to coordinate their efforts to leverage the expertise and resources 
required to resolve these crimes. Coordination of investigations and 
prosecutions has usually occurred as determined by the needs of the 
individual cases and personal relationships established between law 
enforcement officials across agencies. However, DOJ and DHS officials 
acknowledged the need to expand the scope of their efforts to 
investigate and prosecute trafficking crimes by, for example, 
undertaking proactive measures to identify trafficking victims and 
multijurisdictional and international trafficking in persons 
investigations and prosecutions. Pursuing such efforts requires more 
strategic collaboration among agencies, since no one agency can carry 
out these efforts alone. Our prior work has shown that a strategic 
framework that would include, at a minimum, a common outcome and 
mutually reinforcing strategies; agreed-on roles and responsibilities; 
and compatible polices, procedures, and other means to operate across 
agency boundaries can help agencies enhance and expand collaboration on 
issues that are national in scope and cross agency 
jurisdictions.[Footnote 28] However, the mechanisms that are currently 
in place to facilitate interagency cooperation on human trafficking do 
not address the greater collaboration needed for the expanded level of 
effort to investigate and prosecute trafficking crimes. Establishing 
such a strategic framework to investigate and prosecute trafficking in 
persons crimes, as developed by federal agencies to address the unique 
challenges posed by these crimes, could help federal agencies enhance 
and sustain the collaboration needed to expand their efforts to combat 
trafficking crimes. 

Federal Agencies Have Coordinated Trafficking Efforts on a Case-by-Case 
Basis: 

According to DOJ and DHS officials, in practice, agency coordination of 
investigations and prosecutions of trafficking in persons has occurred 
on a case-by-case basis. CRT/CS, CEOS, ICE, and FBI officials 
acknowledged that investigating and prosecuting trafficking in persons 
crimes made it necessary for federal agencies to work with one another 
and with state and local law enforcement, who were often the first ones 
to discover possible evidence of trafficking, and with nongovernmental 
organizations that provided assistance to the victims. Federal 
officials emphasized that they knew whom to call; for example, the 
victim-witness coordinators in ICE and CRT/CS know each other; ICE and 
FBI investigators knew the names of prosecutors in CRT/CS. 

ICE and FBI officials explained that they sometimes worked joint 
investigations or investigated different aspects of a case. For 
example, in one case, while ICE agents rescued the victims in one 
location, the FBI was investigating related brothel operations in other 
cities. Through their detailees to the HSTC, ICE and FBI may determine 
whether the two agencies may be working on a related case. Agents in 
the field may also contact their counterparts at other agencies to 
ascertain whether they are working on a similar case. DOL Wage and Hour 
Division officials told us that if they identified a potential 
trafficking situation, they would notify the FBI and the respective 
U.S. Attorney and the FBI might take over responsibility for the case, 
as DOL's Wage and Hour Division does not carry out criminal 
investigations related to trafficking in persons. In addition, victim 
witness coordinators across DOJ and DHS are in regular contact with 
each other to ensure victim care and services from the point of victim 
identification through investigation and prosecution. 

Investigative and prosecutorial agencies also work with nongovernmental 
agencies. For example, ICE officials said that they shared information 
with nongovernmental organization interviewers who helped the 
investigators determine which potential trafficking victims were actual 
victims and which were "victim enforcers" who were swept up in the raid 
but worked for the traffickers. CRT/CS and U.S. Attorney's Offices 
prosecute the cases developed by the investigative agencies. In 
addition, under the auspices of the Innocence Lost National Initiative, 
FBI investigators from its Crimes Against Children Unit, the National 
Center for Missing and Exploited Children, and CEOS prosecutors have 
joined forces with state and local law enforcement through the 
establishment of formal or ad hoc task forces in 23 cities across the 
country, as a grassroots operation to work on cases of trafficking of 
U.S. children for commercial sex. 

Two noteworthy trafficking cases illustrate the breadth and diversity 
of coordination and cooperation that occurs in pursuit of these crimes. 
For example, the prosecution of Kil Soo Lee brought together FBI 
investigators, DOL investigators from the Wage and Hour Division and 
the Occupational and Safety and Health Administration, CRT/CS 
prosecutors, and some nongovernmental organizations and resulted in the 
largest trafficking case brought to date. In a separate case, Gerardo 
Flores Carreto and Josue Flores Carreto were each sentenced to 50 years 
in prison in a case involving coordination among ICE, DOJ, 
international nongovernmental organizations, as well as the Mexican 
government. (See app. IV.) 

In addition to interacting as needs emerge, officials told us that 
various law enforcement procedures and protocols are in place to foster 
coordination. Upon initiating a trafficking in persons investigation, 
ICE and the FBI notify the local U.S. Attorney to determine if enough 
evidence exists to pursue a federal trafficking in persons prosecution. 
Moreover, U.S. Attorneys are required to report civil rights cases, 
including trafficking in persons cases, to CRT/CS, which then 
determines whether to accept the U.S. Attorney's staffing 
recommendation. In addition, DHS, DOJ, and the Department of Health and 
Human Services signed a memorandum of understanding that lays out the 
basic responsibilities and functions of the departments as they relate 
to the certification of victims' eligibility for certain federal 
benefits. 

Federal agencies have also developed tools to facilitate interagency 
coordination and even coordination with state and local law enforcement 
and nongovernmental organizations in trafficking cases, usually on a 
case-by-case basis. According to DOJ and DHS officials, training is 
provided to these stakeholders prior to raids; operations manuals are 
prepared both for law enforcement and victim-witness coordinators. 

A Strategic Framework Could Be Important to Implementing Expanded 
Approaches to Combating Trafficking: 

Although federal agencies have successfully coordinated on a case-by- 
case basis to investigate and prosecute trafficking crimes, officials 
described their approach to trafficking investigations and prosecutions 
as usually being reactive and acknowledged the need for additional 
proactive approaches to enhance interagency efforts to investigate and 
prosecute trafficking crimes. DOJ and DHS senior officials identified 
the need to expand the scope of efforts, including taking proactive 
measures to identify trafficking victims (e.g., expanding outreach to 
additional law enforcement agencies and nongovernmental organizations) 
and pursuing multijurisdictional and international trafficking in 
persons investigations and prosecutions. These efforts require more 
strategic collaboration among agencies, since no one agency has the 
authority to carry out these efforts alone. However, the current 
coordinating mechanisms and National Security Presidential Directive 22 
do not address the greater collaboration needed for this level of 
expanded effort, and individual agency plans only address individual 
agency efforts--none of which is linked to a common governmentwide 
outcome to address the investigation and prosecution of trafficking 
crimes. Additionally, differing perceptions among agencies exist on 
leadership and roles and responsibilities surrounding some of these 
expanded efforts. 

As our previous work has shown, a strategic framework that includes 
agencies working together toward a common outcome with mutually 
reinforcing strategies, agreed-on roles and responsibilities, and 
compatible policies and procedures can help enhance and sustain 
collaboration among federal agencies dealing with issues, such as 
trafficking in persons, that are national in scope and cross agency 
jurisdictions.[Footnote 29] In light of the unique challenges posed by 
trafficking in persons investigations and prosecutions, we acknowledge 
that a framework to address the investigation and prosecution of 
trafficking crimes needs to be flexible and incorporate different types 
of collaborative mechanisms. The agencies involved would determine the 
specifics of the elements enumerated above, any additional elements to 
be included in the framework, and the structures for developing and 
implementing such a framework. 

Federal Agencies Identified Need for Expanded Approaches: 

DOJ and DHS officials acknowledged the need to expand the scope of U.S. 
efforts to combat trafficking crimes by developing proactive approaches 
to identify trafficking victims (e.g., expanding outreach to non-law 
enforcement agencies, nongovernmental organizations, and other law 
enforcement agencies), pursuing multijurisdictional and even 
international trafficking in persons investigations and prosecutions, 
and establishing mechanisms for consistent communications and 
information sharing among agencies. 

Because trafficking victims are hidden and difficult to find, but are 
also the primary source of evidence of trafficking crimes, agency 
officials underscored the need to develop proactive approaches to 
identify trafficking victims in order to increase investigations and 
prosecutions. While current efforts to pursue trafficking crimes have 
drawn on the support of other federal agencies that do not have 
specific law enforcement functions or have benefited from the 
collaboration between law enforcement and nongovernmental 
organizations, officials expressed the desire to expand these efforts. 
For example, CRT/CS officials told us that they would like to prosecute 
more labor trafficking cases, but these situations were difficult to 
identify. While CRT/CS has worked with DOL's Wage and Hour Division on 
trafficking cases, such as the Kil Soo Lee prosecution, they hoped to 
work with DOL to proactively identify potential trafficking situations, 
possibly during Wage and Hour's self-initiated investigations of low- 
wage work sites. However, DOL officials said that to do so, the 
agencies would need to develop an approach that included regional 
planning and further training of DOL's program managers. This level of 
collaboration and planning could benefit from mutually reinforcing 
strategies or a joint strategy to identify additional victims of labor 
trafficking. 

In addition, the main goal of ICE's outreach efforts to state and local 
law enforcement, nongovernmental organizations, and foreign partners is 
identifying victims. While there are several jurisdictions across the 
country that are currently combating trafficking crimes in their 
communities, DOJ and DHS officials recognized the need to expand their 
outreach and training efforts to other law enforcement and non-law 
enforcement entities to identify victims and increase the number of 
investigations and prosecutions. Currently, coordination among agencies 
on training and outreach is largely episodic. However, developing 
collaborative outreach and training strategies to incorporate state and 
local law enforcement, nongovernmental organizations, and foreign 
partners, among others, could allow agencies to expand their efforts 
while making the best use of agencies' resources. 

DOJ officials also told us that they hoped to expand federal 
antitrafficking efforts by pursuing multijurisdictional and 
international investigations and prosecutions. For example, CRT/CS 
officials told us that they were striving to enhance investigations and 
prosecutions of significant trafficking in persons and slavery cases, 
such as multijurisdictional cases and those involving financial crimes. 
To do so, CRT/CS has engaged in training activities for federal 
prosecutors across the country to institutionalize ways to combat 
trafficking and allow CRT/CS attorneys to focus on multijurisdictional 
cases. However, CRT/CS has also been actively involved in the training 
of investigators, task forces, and foreign officials, as well as 
carrying out their responsibilities to prosecute trafficking cases. 
Folding CRT/CS's training and outreach efforts into a broader and more 
collaborative training and outreach strategy could disperse 
responsibility for training to other federal partners who are also 
engaging in training and outreach efforts. 

The DOJ officials identified the need to establish mechanisms for 
consistent communication and information sharing. While FBI officials 
said that case-by-case coordination between some field offices on 
individual trafficking cases was good, they said that there was also a 
lack of consistency in information sharing and communication among 
field offices. DOJ officials also cited the need to maintain 
information in a central repository to enhance tracking of the 
movements of traffickers and victims. For example, CEOS identified the 
lack of such a repository of information on trafficking and an 
institutionalized policy on information sharing as factors that can 
inhibit trafficking investigations. Working collaboratively with 
counterparts in the field and across agencies at the national level to 
establish mechanisms for consistent communication and information 
sharing could be incorporated into a strategic framework. Additionally, 
FBI and ICE officials pointed to the need to pursue information about 
trafficking organizations back to their country of origin and identify 
trafficking patterns in order to enhance efforts to dismantle 
trafficking organizations. However, HSTC officials told us that the 
intelligence community is not collecting as much information on 
trafficking as it is on other issues, such as human smuggling. HSTC 
officials also said that if HSTC could increase its analytical 
capability, it would be able to expand its current collection and 
dissemination of intelligence information on trafficking to develop 
more products and in so doing provide a more valuable resource to law 
enforcement and the intelligence community, among others. CRT/CS 
officials told us they are working with the FBI to obtain information 
that would help identify trafficking networks. With intelligence 
information from traditional intelligence sources being limited, 
agencies could work toward achieving their goal of tracking trafficking 
patterns and dismantling trafficking organizations by establishing 
collaborative practices to obtain needed information to support 
proactive investigations of trafficking crimes. 

Expanded Approaches Can Be Linked to a Common Outcome with Mutually 
Reinforcing Strategies: 

A strategic framework could promote a collaborative effort to define 
and articulate a common federal outcome for investigations and 
prosecutions of trafficking crimes. Agencies have identified agency- 
level goals and proactive approaches to expand their current efforts to 
combat trafficking crimes, but none of these approaches is linked to a 
governmentwide outcome defined by the key federal agencies that 
investigate and prosecute trafficking crimes. Our previous work on 
effective interagency collaboration has demonstrated that having a 
clearly defined governmentwide outcome could help align specific goals 
across agencies. 

While National Security Presidential Directive 22 instructed federal 
agencies to develop and promulgate plans to implement the directive, 
agencies primarily developed lists of activities that indicated 
individual agency efforts, and the plans, taken together, did not cut 
across agency boundaries and lead toward a common governmentwide 
outcome. As we have illustrated in our work related to national 
strategies to combat terrorism, a governmentwide outcome could hinge on 
an ideal "end-state" followed by a logical hierarchy of major goals, 
subordinate objectives, and specific activities to achieve 
results.[Footnote 30] Gathering intelligence on traffickers, 
dismantling trafficking rings, increasing prosecutions, and rescuing 
victims can be activities linked to broader objectives to achieve a 
common outcome for investigations and prosecutions of trafficking 
crimes, but at this time, agencies have not collectively articulated 
what that outcome might be. The scope of U.S. governmentwide efforts to 
investigate and prosecute trafficking crimes can be linked to a common 
outcome to provide an accountability framework. 

Our prior work has shown that without a clearly defined outcome, it may 
be difficult to overcome significant differences in agency missions, 
cultures, and established ways of doing business. For example, pursuing 
trafficking investigations and prosecutions involves collaboration 
between law enforcement and nongovernmental organizations that 
typically do not work together. Identifying a unified federal outcome 
for investigations and prosecutions of trafficking crimes could help 
align the goals and sustain the support of these agencies and 
organizations, thereby enhancing investigations and prosecutions. 

Our work has shown that after identifying a common outcome, 
collaborating agencies need to establish strategies that work in 
concert with those of their partners or are joint in nature. Such 
strategies help in aligning the partner agencies' activities, core 
processes, and resources to accomplish the common outcome. Some 
individual agencies have developed their own strategies to combat 
trafficking and implement the proactive approaches to expand current 
activities, but strategies have not been linked to a common 
governmentwide outcome for investigations and prosecutions of 
trafficking crimes. Since no single agency is undertaking these 
initiatives alone, mutually reinforcing strategies could help agencies 
better align their activities and resources to accomplish a common 
outcome. 

Roles and Responsibilities Can Be Clearly Defined through a Strategic 
Framework: 

As federal agencies expand their approaches to investigating and 
prosecuting trafficking crimes, a strategic framework could assist in 
clarifying respective roles and responsibilities. Such a framework 
could be important to ensure that agencies understand who will do what 
and help to reconcile differing perceptions of leadership that exist 
among the agencies on combating trafficking crimes. 

Our prior work has shown that generally agencies can enhance their 
collaboration by working together to define and agree on their 
respective roles and responsibilities, including how the collaborative 
effort will be led. Nonetheless, existing interagency collaborative 
mechanisms are not positioned to support the greater collaboration 
needed to coordinate expanded U.S. efforts to investigate and prosecute 
trafficking in persons. The Interagency Task Force to Monitor and 
Combat Trafficking, the SPOG, and SPOG working groups facilitate 
governmentwide policy on human trafficking. However, operational 
coordination on investigations and prosecutions of trafficking in 
persons rests with criminal justice personnel and currently occurs on a 
case-by-case basis. HSTC is an information clearinghouse and 
facilitates information sharing among investigative and prosecutorial 
agencies working on trafficking. HSTC is also available to assist 
agencies to avoid duplication of efforts by querying an array of 
participating agency databases to determine if more than one agency has 
an ongoing interest or open investigation on a specific target. The 
Trafficking in Persons and Worker Exploitation Task Force was involved 
in both policy and operations, but at the time of our review, DOL told 
us it understood that the task force was no longer functioning, and 
CRT/CS officials said they were in the process of reinvigorating DOJ's 
relationship with DOL on this issue. 

Furthermore, developing a strategic framework could help reconcile 
differing perceptions of who is in charge in coordinating 
antitrafficking investigations and prosecutions. Specifically, CRT/CS 
and investigative agencies perceived the interagency leadership role in 
pursuing trafficking crimes differently. CRT/CS officials told us that 
its newly formed Human Trafficking Prosecution Unit was positioned to 
take the leadership role in coordinating trafficking efforts across the 
federal agencies because investigative agencies historically work with 
CRT/CS prosecutors to complete cases. While FBI officials acknowledged 
CRT/CS as the leader on trafficking in persons, they also said that 
leadership needs to cut across agencies, since no one agency carries 
out trafficking cases alone. ICE officials said that agencies are all 
equal partners in the effort to combat trafficking and that while CRT/ 
CS may take the lead on prosecutions, the investigative agencies each 
take the lead on their own investigations, or work jointly on joint 
investigations, until they are handed to prosecutors. ICE officials 
also did not perceive the need for leadership beyond the SPOG for U.S. 
policy on trafficking, but acknowledged that the SPOG did not have 
oversight for investigations and prosecutions because of law 
enforcement sensitive matters. ICE officials suggested that should a 
problem with investigations and prosecutions arise, the SPOG could 
create a subcommittee to deal with these issues. However, according to 
DOJ officials, because investigative and prosecutorial agencies are 
governed at the operational level by confidentiality rules (e.g., grand 
jury secrecy) and limitations on sharing law enforcement sensitive 
information, the SPOG or its working groups were not appropriate 
vehicles for leading collaborative operational efforts to investigate 
and prosecute trafficking in persons. Since no one agency will be able 
to accomplish the steps identified to further U.S. efforts to combat 
trafficking on its own, collaboration among agencies will need to go 
beyond the current case-by-case coordination and views on leadership. 

Establishing Compatible Policies, Procedures, and Other Means to 
Operate across Agency Boundaries: 

Our prior work has shown that a strategic framework could also foster 
efforts to devise compatible standards, policies, procedures, and 
information systems that will be used in collaborative efforts for a 
range of topics across federal agencies. As agencies move forward in 
their efforts to expand current activities to investigate and prosecute 
trafficking crimes, such as tracking trafficking cases or addressing 
the limitations posed on current coordinating mechanisms, agencies 
could work jointly and consult with other stakeholders to determine 
what information on trafficking could be collected and shared as 
policies and procedures for developing information systems are being 
planned and created. Additionally, agencies working together to 
establish policies and procedures to provide guidance on how to achieve 
maximum coordination and cooperation across agencies to investigate and 
prosecute trafficking crimes, including the exchange of information, 
would address current inconsistencies that exist among the field 
offices of federal investigators. 

BJA Has Helped Support Federally Funded State and Local Human 
Trafficking Law Enforcement Task Forces, but Lacks a Plan to Identify 
and Focus Technical Assistance Needs: 

To help coordinate U.S. efforts to identify trafficking victims, get 
needed services to victims of trafficking, and investigate and 
prosecute trafficking in persons crimes in communities across the 
country, BJA established a program to fund state and local law 
enforcement human trafficking task forces. Each task force was to 
develop a strategy to raise public awareness, identify more victims, 
and establish protocols among government agencies and service providers 
and to meet related performance measures. Since 2004, BJA has awarded 
grants of up to $450,000 for a 3-year period to each of 42 task forces. 
BJA reported using its general funds to support some technical 
assistance to the task forces (e.g., sponsoring the development of a 
train-the-trainer curriculum on human trafficking and funding a 
national conference) and taking further steps to help respond to task 
force technical assistance needs. However, task force members we 
contacted and DOJ officials pointed to continued and additional 
technical assistance needs. BJA does not have a technical assistance 
plan for its human trafficking grant program. Our previous work has 
shown the need for agencies that administer grants or funding to state 
and local entities to implement a plan that focuses technical 
assistance and training efforts on areas of greatest need. BJA 
officials told us that they recognized the need for a technical 
assistance plan for its human trafficking initiative and had begun to 
prepare a plan to provide additional and proactive technical assistance 
to the task forces. 

BJA Funds State and Local Law Enforcement Human Trafficking Task Forces 
to Support Investigations and Prosecutions of Trafficking Crimes: 

In 2004, BJA established a program to fund state and local law 
enforcement human trafficking task forces to help support U.S. efforts 
to identify trafficking victims and investigate and prosecute 
trafficking in persons crimes in communities across the country. 
Working with OVC, which was already providing assistance to victim 
service providers serving trafficking victims, BJA solicited 
applications from state and local law enforcement for fiscal year 2004, 
and then again for fiscal years 2005 and 2006. Each task force was to 
develop a strategy that included the following: (1) a memorandum of 
agreement outlining the respective roles and responsibilities of the 
participating agencies and ensuring coordination and involvement of the 
local U.S. Attorney; (2) training materials for first responding 
officers and investigators, including written protocols and resource 
manuals to enhance coordination and information/resource sharing among 
law enforcement and victim service providers to identify and assist 
human trafficking victims; (3) distinct protocols for resource referral 
and service provisions for U.S. versus alien victims of human 
trafficking; and (4) definition of the role of law enforcement and 
service provider partners in training others in the community. The task 
forces were to meet specific program goals and performance measures 
focused on identification of and assistance to victims, training of law 
enforcement in the identification of victims, public awareness and 
outreach, and identification and collaboration with community 
stakeholders. Grantees were required to collect and report data on 
performance measures, including the number of potential and assisted 
trafficking victims; DHS applications made to obtain trafficking 
victims' benefits; law enforcement personnel and others trained; 
presentations given to law enforcement and the general public; service 
providers, community support groups, and community education groups 
identified; and memorandums of agreement signed. 

Under its human trafficking task force initiative, BJA has funded a 
total of 42 law enforcement task forces on human trafficking--22 in 
fiscal year 2004 and 10 in each of fiscal years 2005 and 2006.[Footnote 
31] Each task force grant award was for up to $450,000 for a period of 
3 years. BJA reported awarding a total of $17,324,182 to the 42 task 
forces. The core membership of each task force includes federal, state, 
and local law enforcement; the U.S. Attorney's Office; and 
nongovernmental organizations. However, the task forces vary, as 
evidenced by those we contacted, with respect to which federal agencies 
participate--FBI, ICE, DOL, or others; the number of state or local law 
enforcement agencies involved--a single or multiple police departments 
and sheriff's offices; and the number of nongovernmental groups. As 
shown in figure 3, the 42 task forces are located in 25 states, two 
territories, and the District of Columbia.[Footnote 32] 

Figure 2: BJA-Funded Human Trafficking Law Enforcement Task Forces: 

[See PDF for image] 

Source: GAO analysis of agency documents. 

[End of figure] 

BJA Has Provided Some Technical Assistance to the Task Forces: 

To support its grant programs, BJA can provide technical assistance to 
any justice-related state, tribal, or local agency or organization 
through on-site and off-site technical assistance; peer-to-peer 
information exchange and mentoring; publication drafting and 
dissemination; information sharing; aid with developing conferences, 
workshops, and training events; and curriculum development. According 
to BJA officials, technical assistance is available to human 
trafficking task forces, but BJA did not receive any specific funds to 
support its technical assistance to the human trafficking law 
enforcement task forces.[Footnote 33] BJA reported using $1,433,000 of 
its general funds to finance the development of a train-the-trainer 
curriculum on human trafficking, deliver training sessions using the 
curriculum, and fund the national conference on human trafficking held 
in New Orleans in October 2006.[Footnote 34] 

The train-the-trainer curriculum, prepared by the Institute for 
Intergovernmental Research to promote law enforcement awareness of 
human trafficking in the United States, was completed in October 2004. 
The curriculum included CD-ROMs with PowerPoint slides, instructor 
notes, and lists of additional resources. It addressed the following 
topics: introduction to human trafficking; legal overview; 
investigative considerations, including investigative techniques for 
trafficking cases; the roles of victim service providers in trafficking 
cases; immigration issues; interagency cooperation; and engaging the 
community. The curriculum was used to train trainers, including task 
force members, at BJA-sponsored train-the-trainer sessions held in 
California, Florida, and Illinois between November and April 2005, and 
a Human Trafficking Conference in Houston, Texas, in February 2005. 
According to BJA, some task force members attended the sessions and all 
22 task forces funded at that time were represented at the Houston 
conference. The trainers were to use the curriculum to train law 
enforcement in their respective communities. 

BJA worked with other DOJ components, DHS, and DOL, among others, to 
put on the national trafficking conference in New Orleans. The plenary 
and breakout sessions provided information on various aspects to 
trafficking--investigative strategies, victims services, and 
interviewing witnesses, among others. According to DOJ officials, 
sessions were specifically held for the task forces in addition to the 
public conference program. During these sessions, task force 
participants discussed such issues as collaboration and reporting 
progress using BJA's performance measures. 

In addition, BJA reported further steps taken to respond to the 
technical assistance needs of the task forces. According to BJA 
officials, task force grantees could request technical assistance by 
submitting the form found on the BJA Web site. BJA also reported if the 
data submitted by a task force in its semiannual report indicated the 
existence of performance problems, BJA would make routine calls to the 
particular task force to help resolve the issues or obtain additional 
information so that BJA could work with CRT/CS, OVC, or the appropriate 
U.S. Attorney's Office on these matters. Also, having recognized that 
some task forces were experiencing difficulties in collecting and 
reporting data on its performance measures (e.g., identifying the 
number of trafficking victims), BJA sponsored a special session on this 
topic during the New Orleans conference. According to BJA officials, 
after the conference it distributed to the task forces the materials 
used during the session. Furthermore, between 2006 and 2007, BJA, 
sometimes working in conjunction with OVC, conducted site visits to 8 
of the 42 task forces. The site visits provided the opportunity for BJA 
to identify challenges task forces were having, such as developing or 
implementing training for law enforcement, that might be addressed 
through training or technical assistance. In addition, CRT/CS reported 
that, in coordination with BJA, its attorneys had provided technical 
assistance and training to all but 8 of the task forces. 

Continuing and Additional Task Force Technical Assistance Needs Were 
Identified: 

DOJ officials and task force members we interviewed identified 
continuing and additional task force technical assistance and training 
needs. BJA said that it was aware of this need from weekly phone 
conversations with task force members; site visits to task force 
jurisdictions; and conversations with U.S. Attorneys, CRT/CS, and OVC. 
Continuing and additional technical assistance needs identified by DOJ 
officials and task forces we contacted included (1) substantive 
training about trafficking crimes and trafficking victims and (2) 
technical assistance and training to help task forces develop the 
components in their strategies required under their grants. 

DOJ officials and members of task forces we contacted suggested a range 
of training on substantive topics related to human trafficking. They 
acknowledged that there would always be a need for basic training on 
trafficking issues, as new task forces were formed, existing task 
forces reached out to new participants, and individuals participating 
in the task forces changed over time. In addition, to enhance the 
capacity of the task forces to support investigations and prosecutions 
of trafficking crimes, they identified the need for advanced training 
on such topics as seizing and forfeiting traffickers' assets, 
techniques to facilitate law enforcement and nongovernmental 
organizations working together to interview trafficking victims, and 
techniques for interviewing child victims of sex trafficking. To expand 
their ability to identify more trafficking victims, DOJ officials and 
some task forces we contacted pointed to the need for training of other 
agency personnel, such as other law enforcement, hospital workers, and 
social services personnel, who in the course of their jobs might come 
into contact with trafficking victims. They also indicated that it was 
sometimes necessary to tailor training and technical assistance to 
specific populations. For example, training could be focused on 
potentially vulnerable populations within the community where a task 
force was located (e.g., farm labor, restaurant workers, domestic 
service workers, alien victims, and U.S. children trafficked for 
commercial sex) or trafficking populations that have typically been 
more difficult to find, specifically victims of labor trafficking. 

By requiring each task force grantee to lay out a strategy to raise 
public awareness of trafficking, identify more victims, and establish 
protocols among government agencies and service providers, BJA 
demonstrated its awareness of the need for the task forces to have a 
mechanism to coordinate activities and operations in order to achieve 
program goals. Task force members we interviewed provided examples of 
the challenges they had confronted in addressing the various elements 
of their task force strategy. For example, some task force members said 
that after 2 years of BJA funding they were still trying to iron out 
protocols covering roles and responsibilities; experiencing tensions 
among key players on the task force, including nongovernmental 
organizations; or relying on informal contacts based on who knew whom 
or pre-established relationships among task force members (e.g., local 
law enforcement and FBI) rather than on positions or protocols. Members 
from one task force we interviewed even held different opinions 
regarding its protocols. The task force leader attributed the task 
force's success to its informal protocols. By contrast, another task 
force member told us that the protocols, which had not been developed 
in consultation with task force members, were merely guidelines and led 
to victims falling through the cracks because of the lack of standard 
services. Examples of types of possible technical assistance needs 
suggested by the task forces we contacted included (1) ways to improve 
communication and sharing information/intelligence between and among 
entities, including e-mail lists, a secure Web site, and training 
bulletins; (2) standardized protocols that outline roles and 
responsibilities of each member agency, which the task forces can adapt 
for their own jurisdictions; (3) help in strategizing; (4) regional and 
national meetings that bring smaller groups of task forces together; 
(5) interpreters/cultural assistance; and (6) safe and secure housing 
for victims. 

Technical Assistance Plan Could Enhance BJA's Support to Human 
Trafficking Task Forces: 

BJA does not have a technical assistance plan for its human trafficking 
grant program. Our previous work on federal agencies' administration of 
grants or funding to state and local entities has shown the need for 
agencies that administer grants or funding to state and local entities 
to implement a plan that focuses technical assistance efforts on areas 
of greatest need.[Footnote 35] BJA told us that it was developing a 
plan to provide additional and proactive technical assistance to the 
task forces. It said the plan would address developing BJA's capability 
to provide technical assistance as needed, identifying model task force 
leaders who could provide some technical assistance to other task 
forces, and establishing a means to ensure communication among the task 
forces. Officials said that they were working with OVC to develop an 
approach that would meet the needs of BJA and OVC human trafficking 
grantees. However, BJA reported that the development and review of the 
plan had been delayed pending final decisions on DOJ's funding for 
fiscal year 2007. 

As part of its plan, BJA might address outreach needs to ensure that 
task forces are aware of BJA's capacity to provide or facilitate the 
obtaining of technical assistance and training. DOJ and DHS officials 
emphasized the importance of the task forces to the overall U.S. effort 
to investigate and prosecute trafficking in persons. Working within 
communities, task force members are usually best situated to identify 
trafficking victims and crimes. Representatives of some of the task 
forces we contacted were not aware of BJA's capacity to respond to 
technical assistance needs. Accordingly, identifying steps needed to 
disseminate information on the types of assistance and training 
available is a necessary component of a technical assistance plan for 
these task forces. 

Also, BJA might incorporate into its plan a systematic assessment of 
its performance measures for the task forces. BJA reported that it 
collated and analyzed the performance data it received, would make 
routine calls to the particular task force to help resolve the 
performance issues, or obtain additional information to assist a task 
force in addressing a problem. However, systematically assessing task 
force reports on BJA performance measures could help BJA to identify 
common problem areas in collecting and reporting performance data. It 
could also provide BJA with the means to determine which measures might 
need to be modified or how BJA might enhance its measures to enable it 
to assess the impact of task force efforts. Such an approach should 
help BJA to facilitate the task forces' meeting the program's overall 
goals and objectives of identifying victims and supporting 
investigations and prosecutions. 

In addition, through its technical assistance plan, BJA might identify 
steps to obtain information from the task forces on areas for 
continuous improvement. This information could be used to determine 
common and emerging technical assistance or training needs, approaches 
for meeting those needs, and how best to provide that assistance. As 
part of its plan, BJA could also develop other means and mechanisms for 
providing technical assistance to the task forces effectively and 
efficiently. For example, as suggested by some of the task force 
members we contacted, a secure Web site could provide a means for task 
forces to share best practices, readily obtain samples of protocols or 
other documents, or ask for peer-to-peer assistance from other task 
forces. BJA could also use the Web site to disseminate information to 
the task forces. 

BJA's plan might also include a component for assessing the quality of 
its technical assistance. To ensure that the technical assistance and 
training provided to the task forces meet their needs, BJA might 
request information from the task forces on technical assistance and 
training provided to them, including evaluations of that assistance. 
Such information could help BJA demonstrate what it has done to support 
the task forces and the effectiveness of those efforts in meeting task 
force needs. This information could also be used to ascertain necessary 
modifications of or changes to technical assistance to better meet task 
force needs. 

To facilitate BJA's technical assistance to the task forces, the plan 
might identify available technical assistance and training resources 
from a variety of sources. BJA could then match a particular task 
force's needs with technical assistance and training that might be 
provided by other federal agencies, such as CRT/CS, or other task 
forces. While such training and technical assistance are currently 
provided on a case-by-case basis, within the context of a plan, BJA 
could more systematically galvanize these resources, incorporate them 
into its overall approach to meeting the task forces' needs, and assess 
their impact on task force efforts. Information on task force training 
needs could also be used to help BJA, working with other federal 
agencies, to plan the content and format of the legislatively mandated 
2007 and 2008 national trafficking conferences so that it meets the 
range of training and technical assistance needs for experienced task 
forces as well as new task forces. 

Conclusions: 

Federal agencies have made strides in several areas to combat 
trafficking crimes and to coordinate their efforts on a case-by-case 
basis. This approach has generally led to an increase in the number of 
investigations and prosecutions since the passage of the TVPA in 2000. 
However, as agencies look ahead to broadening their efforts while still 
maintaining coordination on individual cases, strategic planning will 
be necessary to ensure agency resources are being expended with the 
greatest return on investment. Defining a common governmentwide outcome 
for investigations and prosecutions of trafficking crimes, reconciling 
roles and responsibilities, and ensuring consistent communication and 
information sharing are vital to the investigation and prosecution of 
trafficking crimes. Yet no such outcome has been collaboratively 
defined by the agencies, perceptions of leadership differ among 
agencies, and policies are not in place to ensure consistent 
communication and information sharing. Furthermore, to sustain a 
coordinated victim-centered approach to combating trafficking, agencies 
must continue to educate and engage their own personnel, as well as 
supporting partners in the effort to combat this crime, such as state 
and local law enforcement, nongovernmental organizations, non-law 
enforcement agencies, and citizens. As our prior work on multi-agency 
collaboration has shown, a strategic framework that includes elements 
such as defining a common outcome, establishing mutually reinforcing or 
joint strategies, and agreeing on roles and responsibilities, among 
others, is particularly useful in addressing problems that are national 
in scope and involve multiple agencies with varying jurisdictions. Such 
an approach allows for the necessary flexibility and incorporation of 
different types of collaborative mechanisms to address the complexities 
of and unique challenges posed by such problems. Working in a more 
strategic fashion, agencies could build on their current cooperative 
relationships to establish a strategic focal point, ensure consistency 
of communication and partnerships, and sustain and expand a coordinated 
effort to investigate and prosecute trafficking in persons crimes. 

BJA's competitive grant program has funded state and local law 
enforcement human trafficking task forces to support U.S. efforts to 
identify trafficking victims and investigate and prosecute trafficking 
crimes. Given its mission to support state and local law enforcement, 
BJA has provided some training and technical assistance to the human 
trafficking task forces, sometimes through coordinated efforts with 
other agencies. However, the task forces we interviewed identified 
challenges they faced in implementing BJA's strategic planning 
requirements and carrying out their responsibilities, especially in 
identifying potential victims and establishing partnerships with key 
players. Our previous work on federal agencies' administration of 
grants or funding to state and local entities shows the importance of 
implementing a technical assistance plan that focuses the training and 
technical assistance efforts by agencies that administer grant funding. 
In the absence of such a plan, BJA may find it difficult to target 
technical assistance to the task forces most in need and ensure that 
task forces receive the technical assistance needed to meet the 
strategic planning requirements and performance measures outlined in 
the human trafficking task force grant solicitation. Implementing such 
a plan will help BJA focus its efforts, enabling BJA to better ensure 
that its efforts meet the needs of the task forces, achieve the 
objectives of the program, enhance collaboration across levels of 
government and between government and nongovernmental entities, and 
ultimately support U.S. efforts to investigate and prosecute 
trafficking in persons. 

Recommendations for Executive Action: 

To help ensure that the U.S. government maximizes its ability to 
enforce laws governing trafficking in persons, we recommend that the 
Attorney General and the Secretary of Homeland Security, in conjunction 
with the Secretaries of Labor, State, and other agency heads deemed 
appropriate, develop and implement a strategic framework to coordinate 
U.S. efforts to investigate and prosecute trafficking in persons. At a 
minimum this framework should: 

a. define and articulate a common outcome; 

b. establish mutually reinforcing or joint strategies; 

c. agree on roles and responsibilities; and: 

d. establish compatible policies, procedures, and other means to 
operate across agency boundaries. 

To better support the federally funded state and local human 
trafficking task forces, we recommend that the Attorney General direct 
the Director of the Bureau of Justice Assistance to develop and 
implement a plan to help focus technical assistance on areas of 
greatest need. 

Agency Comments and Our Evaluation: 

We requested comments on a draft of this report from the Attorney 
General, the Secretary of Homeland Security, the Secretary of State, 
and the Secretary of Labor. DOJ and DHS provided written comments, 
which are summarized below and included in their entirety in appendixes 
V and VI, respectively. In addition, these agencies and DOS and DOL 
provided technical comments, which we incorporated as appropriate. 

DOJ agreed with the contents of the report. Regarding our 
recommendation to the Attorney General and the Secretary of Homeland 
Security to develop a strategic framework to coordinate U.S. efforts to 
investigate and prosecute trafficking crimes, DOJ acknowledged that 
continued and increased collaboration could further efforts to 
investigate and prosecute trafficking in persons crimes. DOJ further 
noted that it is already pursuing a variety of such methods, including 
establishing the Human Trafficking Prosecution Unit and holding 
collaborative meetings and training sessions with its partners. As a 
result, DOJ proposed that the report identify the need for continued 
collaboration but not mandate one particular collaborative model. 

It was not our intent to prescribe a particular structure or 
collaborative model. We recognize that because of the unique challenges 
posed by trafficking in persons investigations and prosecutions, the 
proposed framework needs to be flexible. Our previous work has shown 
that the four elements outlined in our recommendation--a common 
outcome; mutually reinforcing or joint strategies; agreed-on roles and 
responsibilities; and compatible polices, procedures, and other means 
to operate across agency boundaries--are key to an effective strategic 
framework. However, the specifics of each of these elements, additional 
elements to be included in a strategic framework for the investigation 
and prosecution of trafficking crimes, and the structures for 
developing and implementing this framework would be determined by the 
agencies involved. In response to DOJ's comments, we have included 
language in our report that reinforces the need for flexibility in 
developing and implementing a strategic framework for investigations 
and prosecutions of trafficking in persons. 

Commenting on our recommendation that the Attorney General call on the 
Director of BJA to develop and implement a plan to help focus technical 
assistance to the human trafficking task forces, DOJ stated that to 
address the areas of task force technical assistance needs raised in 
our report, BJA and OVC planned to collaboratively develop and lead a 
facilitated working group, including representatives from these 
agencies, ICE, HSTC, DOL, and other DOJ components, by October 1, 2007. 
The working group is to provide input into BJA's collaborative outreach 
and improve training and technical assistance strategies to address 
issues raised in the report. DOJ enumerated the elements that its 
training and technical assistance plan was expected to include, such as 
a strategy for informing task force members, on a continuous basis, of 
the availability of training and technical assistance resources; a 
systematic assessment of performance measures; and methods to assess 
the quality of training and technical assistance. 

DHS generally agreed with the contents of the report. Specifically, DHS 
said that the report reflected an overall understanding of the 
complexities of the antitrafficking response; ICE's efforts in leading 
investigations, conducting outreach, and responding to trafficking 
victims; and properly characterized ICE's compliance with National 
Security Presidential Directive 22. In response to the report's 
discussion of interagency coordination and strategizing, DHS noted that 
ICE regularly conducted strategic planning with its partners, 
particularly in the field; worked with federally funded state and local 
trafficking task forces; and contributed to annual trafficking reports 
prepared by DOJ. Moreover, DHS maintained that interagency coordination 
through the SPOG ensured that trafficking policies and guidelines were 
carried out, and therefore ICE believed that a governmentwide framework 
or strategy was not needed. 

Our report acknowledged that the SPOG and its working groups help to 
facilitate coordination of governmentwide policy on human trafficking. 
However, the focus of our work was U.S. efforts to investigate and 
prosecute trafficking in persons crimes, the coordination of which 
rests with criminal justice personnel, primarily DHS and DOJ. Given DOJ 
and DHS senior officials' acknowledgment of the need to expand the 
scope of U.S. efforts to investigate and prosecute trafficking in 
persons and our finding that existing mechanisms and individual agency 
plans did not address the interagency collaboration needed to support 
this expanded level of effort, we recommended the development of a 
strategic framework for coordinating U.S. efforts to investigate and 
prosecute trafficking cases. 

Commenting on this recommendation, DHS said that ICE would support such 
a framework if certain considerations were taken into account. For 
example, DHS noted that mutual goal setting might be possible so long 
as the goals contained objectives that specifically addressed unique 
agency capabilities in combating trafficking. DHS also noted that any 
framework would also need to recognize that agencies' roles in a 
particular case would vary by available resources, local priorities, 
and the nature of the case and investigation. Agency resources for 
policy efforts and initiating any recommendations that arose from the 
framework would also be critical. GAO would expect that in developing 
and implementing such a framework for investigations and prosecutions 
of trafficking crimes, the agencies involved would determine how to 
address varying authorities, respective resources, and other relevant 
factors. 

We will send copies of this report to the Attorney General, the 
Secretary of Homeland Security, the Secretary of State, and the 
Secretary of Labor, and interested congressional committees. We will 
also make copies available to others upon request. In addition, the 
report will be available at no charge on GAO's Web Site at 
http://www.gao.gov. 

If you or your staff have any questions concerning this report, please 
contact me on (202) 512-2757 or goldenkoffr@gao.gov. Contact points for 
our Offices of Congressional Relations and Public Affairs may be found 
on the last page of this report. Major contributors to this report are 
listed in appendix VII. 

Signed by: 

Robert N. Goldenkoff: 
Acting Director, Homeland Security and Justice: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

To ascertain the status of U.S. efforts to investigate and prosecute 
trafficking crimes, this report discusses (1) key activities federal 
agencies have undertaken to combat trafficking in persons crimes, (2) 
federal efforts to coordinate on investigations and prosecutions of 
trafficking in persons crimes and whether these efforts might be 
enhanced, and (3) how the Bureau of Justice Assistance (BJA) supported 
federally funded state and local human trafficking task forces and 
whether these efforts might be improved. This review is part of a 
larger body of work that you requested on U.S. efforts to combat 
trafficking in persons, here and abroad.[Footnote 36] 

To determine key activities federal agencies have undertaken to combat 
trafficking in persons crimes, we reviewed pertinent documents and 
interviewed officials from the Department of Justice (DOJ), including 
the Federal Bureau of Investigation (FBI), Civil Rights Division/ 
Criminal Section (CRT/CS), Criminal Division/Child Exploitation and 
Obscenity Section (CEOS), and the Executive Office for U.S. Attorneys; 
the Department of Homeland Security's (DHS) U.S. Immigration and 
Customs Enforcement (ICE) and U.S. Citizenship and Immigration 
Services; the Department of Labor's (DOL) Wage and Hour Division; the 
Department of State's (DOS) Bureau of Diplomatic Security and Office to 
Monitor and Combat Trafficking in Persons; and the Human Smuggling and 
Trafficking Center (HSTC). We obtained and analyzed written responses 
to questions we provided, departmentwide strategic planning documents, 
agency plans, strategies, and memorandums and guidance on efforts to 
combat human trafficking. We obtained examples of training materials 
used to train investigative agents and to conduct outreach and attended 
the national human trafficking conference in New Orleans in October 
2006. From the FBI, ICE, CRT/CS, and CEOS, we obtained and analyzed 
relevant data on the cases investigated and prosecuted, including 
numbers of cases, defendants charged, and convictions, as well as, 
where possible, estimates of the resources used to do so. We discussed 
the sources of these data with federal agency officials to determine 
that these data were sufficiently reliable to show trends in agencies' 
activities undertaken to investigate and prosecute trafficking crimes. 
We did not seek data prior to the passage of the Trafficking Victims 
Protection Act in 2000 for investigative agencies since the 
establishment of the Department of Homeland Security transferred some 
human trafficking investigative duties from DOJ's legacy Immigration 
and Naturalization Service to DHS's Immigration and Customs 
Enforcement. 

To determine what efforts federal agencies have undertaken to 
coordinate investigations and prosecutions of trafficking in persons 
crimes and whether these efforts might be enhanced, we reviewed 
pertinent documents, such as agency reports, strategies, and 
memorandums to field offices. We interviewed officials from DOJ 
headquarters, including FBI, CRT/CS, CEOS, and the Executive Office for 
U.S. Attorneys; DHS's ICE and U.S. Citizenship and Immigration 
Services; DOL's Wage and Hour Division; DOS's Bureau of Diplomatic 
Security and Office to Monitor and Combat Trafficking in Persons; and 
the HSTC. We gathered and analyzed information from selected field 
personnel representing the FBI, ICE, and local U.S. Attorney's Offices. 
To ascertain how efforts to combat trafficking might be enhanced and 
identify applicable criteria to be used in our analysis, we consulted 
our prior work on agency collaboration, international crime, terrorism, 
organized crime, and the illegal importation of prescription and 
illegal drugs.[Footnote 37] We also interviewed agency officials to 
identify challenges they face in the investigating and prosecuting of 
trafficking crimes and to identify what elements may enhance their 
efforts. 

To assess how BJA has supported federally funded state and local human 
trafficking task forces and whether these efforts might be enhanced, we 
obtained and analyzed relevant documents from BJA, including task force 
grant proposals, grant reports written by program managers, performance 
measurement data, and information from its Web site.[Footnote 38] We 
interviewed BJA, Office for Victims of Crime (OVC), and CRT/CS 
officials on the origin of the task forces, when task forces were 
funded, and the types of assistance provided to the task forces. We 
also interviewed field personnel from the FBI, ICE, and DOL to 
determine what federal supports had been given to the task forces we 
selected for either site visits or telephone interviews. We developed 
case studies of seven task forces to provide us with in-depth knowledge 
about how the task forces are functioning, how they are working 
together, and what supports and technical assistance they have been 
provided. Gathering information for the case studies included site 
visits to task forces in Collier County, Florida; Los Angeles, 
California; and Washington, D.C; and telephone interviews with key 
participants from task forces in Houston, Texas; Hawaii; and Nassau and 
Suffolk Counties in New York. 

In selecting the 7 task forces we contacted, we limited our selection 
to the longest-running task forces (i.e., the 22 founded in fiscal year 
2004)--those that had had an opportunity to be established. From this 
group, we tried to include task forces located in various U.S. 
geographic regions, and with a primary focus on either sex trafficking, 
labor trafficking, or both sex and labor. To ensure that we included 
task forces of varying performance levels, we asked officials from BJA 
and CRT/CS for recommendations on task forces that were performing 
well. In addition to these recommendations, we also used BJA 
performance measures such as number of victims found and the number of 
continued presence visas provided to make our selections. As a part of 
our site visits or through telephone interviews, we interviewed the 
task force leader, the Assistant U.S. Attorney (who may or may not the 
leader), the primary local law enforcement contact, the dominant 
nongovernmental organization participant, and FBI and ICE 
representatives on the task force. BJA was not able to provide us with 
a list of task force participants, but a nongovernmental organization, 
Polaris Project, affiliated with the Washington, D.C., human 
trafficking task force, had networked with all the BJA-funded task 
forces at the federally sponsored human trafficking conference in New 
Orleans in October 2006, and provided us with a list identifying the 
"key players." From this list, we developed our list of interviewees 
based on our inclusion criteria. The FBI and ICE participant names were 
provided to us through the liaisons in each agency. Overall, through 
site visits and telephone interviews we interviewed a total of 50 task 
force members. We interviewed 13 Assistant U.S. Attorneys, 7 local law 
enforcement, 6 FBI participants, 5 ICE agents, 1 DOL participant, 13 
nongovernmental organization participants, and 3 task force leaders 
from an Attorney General's office. In addition, we interviewed a U.S. 
Attorney, who had recently set up a human trafficking task force, to 
obtain his perspective on challenges faced in putting a task force into 
operation. This approach does not allow for generalizing. In addition, 
we reviewed relevant GAO reports on federal agencies' administration of 
grants or funding to state and local entities.[Footnote 39] 

We conducted our work from June 2006 through June 2007 in accordance 
with generally accepted government auditing standards. 

[End of section] 

Appendix II: Statutory Provisions Used to Investigate and Prosecute 
Trafficking Crimes: 

During the 1990s, the United States began to take steps to address 
trafficking in persons at home and abroad. DOJ prosecuted trafficking 
cases under several federal criminal statutes, including the 
involuntary servitude statutes,[Footnote 40] the Mann Act,[Footnote 41] 
and labor laws on workplace conditions and compensation.[Footnote 42] 
However, various U.S. policymakers determined that existing U.S. 
statutes did not take into account some characteristics of contemporary 
trafficking in persons and, therefore, did not adequately protect 
trafficking victims, deter trafficking, and bring traffickers to 
justice. These statutes did not always treat trafficked persons as 
victims. Involuntary servitude was restricted to cases of physical 
abuse--force, threats of force, or threats of legal coercion, as 
opposed to the psychological coercion often used by today's 
traffickers.[Footnote 43] While the modern concept of trafficking in 
persons focused on compelled service, under the Mann Act trafficking 
was perceived as interstate transportation for prostitution. Moreover, 
these statutes scattered enforcement authority across the government 
and resulted in different case outcomes, depending on the charges 
brought or which agency learned of the allegations of abuse. 

The TVPA addressed limitations in existing law that made it difficult 
to prosecute traffickers, as well as adding new crimes and enhancing 
the penalties. Federal agencies continue to rely on a number of 
statutes to prosecute traffickers and halt their operations. Table 1 
lays out the primary statutes that support the investigation and 
prosecution of trafficking in persons crimes. 

Table 1: Primary Statutory Provisions Used for Trafficking in Persons 
Prosecutions: 

U.S. Code: 18 U.S.C.  241; 
Provision: Conspiracy against rights. 

U.S. Code: 18 U.S.C.  371; 
Provision: Conspiracy to commit federal offenses. 

U.S. Code: 18 U.S.C.  1581; 
Provision: Peonage. 

U.S. Code: 18 U.S.C.  1584; 
Provision: Involuntary servitude. 

U.S. Code: 18 U.S.C.  1589; 
Provision: Forced labor. 

U.S. Code: 18 U.S.C.  1590; 
Provision: Trafficking with respect to peonage, slavery, involuntary 
servitude, or forced labor. 

U.S. Code: 18 U.S.C.  1591; 
Provision: Sex trafficking of a minor or by fraud, force, or coercion. 

U.S. Code: 18 U.S.C.  1592; 
Provision: Holding or confiscation of passport or immigration 
documents. 

U.S. Code: 18 U.S.C.  1593; 
Provision: Mandatory restitution. 

U.S. Code: 18 U.S.C.  1594(a); 
Provision: Attempt to commit peonage, slavery, involuntary servitude, 
forced labor, trafficking, or sex trafficking. 

U.S. Code: 18 U.S.C.  1594(b); 
Provision: Asset forfeiture. 

U.S. Code: 18 U.S.C.  2421-2424; 
Provision: Mann Act (transportation for illegal sexual activity and 
related crimes). 

U.S. Code: 8 U.S.C.  1324; 
Provision: Bringing in and harboring certain aliens. 

U.S. Code: 8 U.S.C.  1328; 
Provision: Importation of an alien for immoral purposes. 

Source: GAO analysis. 

[End of table] 

Traffickers may also be charged with other offenses. Examples of these 
statutes are shown in table 2. 

Table 2: Other Related Statutory Provisions Used in Trafficking in 
Persons Prosecutions: 

U.S. Code: 18 U.S.C.  1546; 
Provision: Arranging a false visa for the victim. 

U.S. Code: 18 U.S.C.  1622; 
Provision: Witness tampering. 

U.S. Code: 18 U.S.C.  875; 
Provision: Interstate transmission of threats. 

U.S. Code: 18 U.S.C.  1001; 
Provision: False statements in any matter within the jurisdiction of 
the executive, legislative, or judicial branch of the U.S. government. 

U.S. Code: 18 U.S.C.  982; 
Provision: Asset forfeiture. 

U.S. Code: 18 U.S.C.  2; 
Provision: Aiding and abetting a federal offense (e.g., employment of 
unauthorized aliens). 

U.S. Code: 31 U.S.C.  5332; 
Provision: Bulk cash smuggling. 

U.S. Code: 18 U.S.C.  1956; 
Provision: Money laundering. 

Source: GAO analysis. 

[End of table] 

[End of section] 

Appendix III: Federal Efforts to Investigate and Prosecute Trafficking 
in Persons and Data on Resources: 

This appendix provides additional data on federal agencies' efforts to 
investigate and prosecute trafficking in persons crimes. It also 
presents available information on federal agency resources used to 
support these efforts. 

Federal Agencies Report Prosecutions and Investigations of Trafficking 
in Persons since fiscal year 2001: 

The FBI, ICE, and CRT/CS reported data on the investigations, 
prosecutions, indictments, and arrests related to trafficking crimes 
since the passing of the TVPA. These data are a general indicator of 
the level of agency effort on trafficking in persons, although they are 
limited by a number of factors. Because trafficking in persons is a 
hidden crime and victims are hesitant to come forward, it is difficult 
to estimate the extent of trafficking in persons crimes. Moreover, 
because prosecutors may charge traffickers with other crimes (e.g., 
kidnapping, the Mann Act, immigration violations, or money laundering) 
for strategic or tactical reasons, data on the number of trafficking in 
persons investigations and prosecutions do not provide a complete 
picture of the number of traffickers who have been thwarted. The data 
systems agencies use are primarily case management systems, which may 
not be able to extract trafficking data if trafficking was not listed 
as a charge. Additionally, if an investigation on smuggling later 
reveals a trafficking violation, some data systems will continue to 
store investigative data under the smuggling classification. 

The complexity of the investigations and the limitations of data 
systems make providing data on human trafficking a labor-intensive 
effort for agencies. Therefore, these data are not comparable across 
the agencies and it is not possible to associate arrest and indictment 
data with a particular case because of differences in agency data 
systems. Moreover, agency officials noted that investigations do not 
always lead to prosecutions, because situations that appear to be 
trafficking may prove to be alien smuggling or prostitution accompanied 
by abuse and, therefore, do not meet the criteria to be prosecuted as 
trafficking cases. In addition, ICE officials said that in situations 
involving children, the agency's priority was to rescue the victim 
whether or not the investigation led to the prosecution of the 
trafficker. 

Since fiscal year 2001, CRT/CS has reported an overall increase in the 
number of prosecutions for cases involving sex and labor trafficking, 
as defined by CRT/CS, based on the facts of the case. Table 3 shows the 
increase in number of prosecutions after the implementation of the TVPA 
in 2001, compared to those in the years leading up to the law's 
passage. CRT/CS officials noted that the number of defendants in each 
case varied, as well as the number of victims, and the complexity of 
the case (app. IV provides summaries of several cases to illustrate 
this variation.)[Footnote 44] 

Table 3: Trafficking in Persons Prosecutorial Statistics for Civil 
Rights Division/Criminal Section and U.S. Attorneys' Offices, Fiscal 
Year 1995 through June 14, 2007: 

Cases prosecuted[B]. 

Sex trafficking; 
Fiscal year: 1995-2000: 7; 
Fiscal year: 2001: 4; 
Fiscal year: 2002: 7; 
Fiscal year: 2003: 8; 
Fiscal year: 2004: 23; 
Fiscal year: 2005: 26; 
Fiscal year: 2006: 22; 
Fiscal year: 2007[A]: 10. 

Labor trafficking; 
Fiscal year: 1995-2000: 12; 
Fiscal year: 2001: 6; 
Fiscal year: 2002: 3; 
Fiscal year: 2003: 3; 
Fiscal year: 2004: 3; 
Fiscal year: 2005: 9; 
Fiscal year: 2006: 10; 
Fiscal year: 2007[A]: 5. 

Defendants charged[C]. 

Sex trafficking; 
Fiscal year: 1995-2000: 34; 
Fiscal year: 2001: 26; 
Fiscal year: 2002: 27; 
Fiscal year: 2003: 21; 
Fiscal year: 2004: 40; 
Fiscal year: 2005: 75; 
Fiscal year: 2006: 85; 
Fiscal year: 2007[A]: 35. 

Labor trafficking; 
Fiscal year: 1995-2000: 55; 
Fiscal year: 2001: 12; 
Fiscal year: 2002: 14; 
Fiscal year: 2003: 7; 
Fiscal year: 2004: 7; 
Fiscal year: 2005: 21; 
Fiscal year: 2006: 26; 
Fiscal year: 2007[A]: 15. 

Defendants convicted[C,D]. 

Sex trafficking; 
Fiscal year: 1995-2000: 20; 
Fiscal year: 2001: 15; 
Fiscal year: 2002: 23; 
Fiscal year: 2003: 16; 
Fiscal year: 2004: 30; 
Fiscal year: 2005: 25; 
Fiscal year: 2006: 60; 
Fiscal year: 2007[A]: 59. 

Labor trafficking; 
Fiscal year: 1995-2000: 47; 
Fiscal year: 2001: 8; 
Fiscal year: 2002: 5; 
Fiscal year: 2003: 5; 
Fiscal year: 2004: 3; 
Fiscal year: 2005: 10; 
Fiscal year: 2006: 38; 
Fiscal year: 2007[A]: 5. 

Source: GAO analysis of Civil Rights Division/Criminal Section data. 

[A] Data as of June 14, 2007. 

[B] CRT/CS classified cases as sex or labor trafficking according to 
the facts of the case; the categories are mutually exclusive. 

[C] Data on defendants charged and convicted are not associated with 
the data for cases opened in the same fiscal year. 

[D] Comparisons cannot be made between persons charged and convictions, 
since actions on some defendants may still be pending. 

[End of table] 

The data since fiscal year 2001 related to investigations of 
trafficking in persons provided by the FBI and ICE is shown in tables 4 
and 5, and also shows a general increase.[Footnote 45] As with the 
prosecutions of human trafficking cases, variation in numbers from year 
to year may be due to the complexity of a case. For example, factors 
such as a case with many victims, multiple defendants, a long period of 
victimization, and multiple jurisdictions from which to collect 
evidence may affect how many cases are able to be investigated from 
year to year. 

Table 4: Trafficking in Persons Cases Investigated by the FBI's Civil 
Rights Unit, Fiscal Year 2001 through April 5, 2007: 

Cases opened; 
Fiscal year: 2001: 54; 
Fiscal year: 2002: 58; 
Fiscal year: 2003: 65; 
Fiscal year: 2004: 86; 
Fiscal year: 2005: 146; 
Fiscal year: 2006: 126; 
Fiscal year: 2007[A]: 216. 

Indictments/information; 
Fiscal year: 2001: 29; 
Fiscal year: 2002: 26; 
Fiscal year: 2003: 40; 
Fiscal year: 2004: 32; 
Fiscal year: 2005: 45; 
Fiscal year: 2006: 97; 
Fiscal year: 2007[A]: 39. 

Arrests; 
Fiscal year: 2001: 67; 
Fiscal year: 2002: 65; 
Fiscal year: 2003: 32; 
Fiscal year: 2004: 16; 
Fiscal year: 2005: 51; 
Fiscal year: 2006: 142; 
Fiscal year: 2007[A]: 79. 

Convictions; 
Fiscal year: 2001: 15; 
Fiscal year: 2002: 15; 
Fiscal year: 2003: 18; 
Fiscal year: 2004: 22; 
Fiscal year: 2005: 14; 
Fiscal year: 2006: 70; 
Fiscal year: 2007[A]: 31. 

Source: FBI Civil Rights Unit. 

Note: These cases may include joint investigations with ICE. The number 
of cases includes both sex and labor trafficking. 

[A] Data as of April 5, 2007. 

[End of table] 

Table 5: Trafficking in Persons Cases Investigated by Immigration and 
Customs Enforcement, Fiscal Year 2005 through May 31, 2007: 

Cases opened. 

Sexual exploitation; 
Fiscal year: 2005: 183; 
Fiscal year: 2006: 213; 
Fiscal year: 2007[A]: 161. 

Forced labor; 
Fiscal year: 2005: 84; 
Fiscal year: 2006: 85; 
Fiscal year: 2007[A]: 88. 

Other[B]; 
Fiscal year: 2005: 55; 
Fiscal year: 2006: 26; 
Fiscal year: 2007[A]: 4. 

Total; 
Fiscal year: 2005: 322; 
Fiscal year: 2006: 324; 
Fiscal year: 2007[A]: 253. 

Indictments. 

Sexual exploitation; 
Fiscal year: 2005: 54; 
Fiscal year: 2006: 93; 
Fiscal year: 2007[A]: 60. 

Forced labor; 
Fiscal year: 2005: 11; 
Fiscal year: 2006: 10; 
Fiscal year: 2007[A]: 1. 

Other; 
Fiscal year: 2005: 46; 
Fiscal year: 2006: 27; 
Fiscal year: 2007[A]: 11. 

Total; 
Fiscal year: 2005: 111; 
Fiscal year: 2006: 130; 
Fiscal year: 2007[A]: 72. 

Arrests. 

Sexual exploitation; 
Fiscal year: 2005: 85; 
Fiscal year: 2006: 135; 
Fiscal year: 2007[A]: 93. 

Forced labor; 
Fiscal year: 2005: 15; 
Fiscal year: 2006: 6; 
Fiscal year: 2007[A]: 28. 

Other; 
Fiscal year: 2005: 86; 
Fiscal year: 2006: 43; 
Fiscal year: 2007[A]: 2. 

Total; 
Fiscal year: 2005: 186; 
Fiscal year: 2006: 184; 
Fiscal year: 2007[A]: 123. 

Convictions. 

Sexual exploitation; 
Fiscal year: 2005: 6; 
Fiscal year: 2006: 69; 
Fiscal year: 2007[A]: 54. 

Forced labor; 
Fiscal year: 2005: 5; 
Fiscal year: 2006: 7; 
Fiscal year: 2007[A]: 5. 

Other; 
Fiscal year: 2005: 80; 
Fiscal year: 2006: 26; 
Fiscal year: 2007[A]: 12. 

Total; 
Fiscal year: 2005: 91; 
Fiscal year: 2006: 102; 
Fiscal year: 2007[A]: 71. 

Source: Immigration and Customs Enforcement. 

Note: These cases may include joint investigations with the FBI. 

[A] Data as of May 31, 2007. 

[B] Human trafficking cases classified other than sex or labor 
trafficking. 

[End of table] 

Additionally, FBI's Crimes Against Children Unit reported data on cases 
of trafficking of U.S. children for commercial sex from its Innocence 
Lost National Initiative, as shown in table 6. 

Table 6: Innocence Lost Statistics, Fiscal Year 2004 through June 5, 
2007: 

Cases opened; 
Fiscal year: 2004: 67; 
Fiscal year: 2005: 71; 
Fiscal year: 2006: 103; 
Fiscal year: 2007[A]: 86. 

Indictments/Information; 
Fiscal year: 2004: 27; 
Fiscal year: 2005: 48; 
Fiscal year: 2006: 76; 
Fiscal year: 2007[A]: 36. 

Arrests; 
Fiscal year: 2004: 118; 
Fiscal year: 2005: 387; 
Fiscal year: 2006: 157; 
Fiscal year: 2007[A]: 137. 

Convictions; 
Fiscal year: 2004: 22; 
Fiscal year: 2005: 45; 
Fiscal year: 2006: 43; 
Fiscal year: 2007[A]: 72. 

Source: FBI's Crimes Against Children Unit. 

[A] Data as of June 5, 2007. 

[End of table] 

DOL's Wage and Hour Division reported participating in four cases 
involving criminal or potentially criminal allegations of trafficking 
in persons, which were concluded in fiscal year 2007. The division 
reported seven cases currently under investigation; seven cases at some 
stage of litigation or case development by the FBI, Assistant U.S. 
Attorney, or others; and one additional case in which it will be 
providing technical assistance following direct law enforcement action. 
According to the division, its involvement may have been as a result of 
a referral from another agency (e.g., FBI, Assistant U.S. Attorney, or 
local law enforcement), a referral from an advocacy organization, or a 
situation in which the division was the initial investigating agency. 
In addition to participation in cases involving violations of the 
trafficking statutes, the division has also assisted other law 
enforcement agencies in developing investigations or prosecutions of 
criminal violations of other statutes and may pursue criminal penalties 
under its own statutes. For example, according to CRT/CS, DOL has been 
involved in the calculation of back wages and overtime pay for victims, 
as in United States v. Calimlim. According to DOL, it provided 
technical advisory assistance to the prosecuting U.S. Attorney, 
furnishing sample back wage computations that would have been due had 
the victim fallen under the provisions of the Fair Labor Standards Act 
(FLSA), and had the case events occurred within the FLSA statute of 
limitations. In the subsequent prosecution, CRT/CS successfully secured 
a $940,000 restitution order. 

Resource Commitments of Federal Investigative and Prosecutorial 
Agencies to Meet Their Responsibilities for Pursuing Trafficking in 
Persons Crimes: 

To implement their respective plans and carry out activities related to 
the investigation and prosecution of trafficking in persons, agencies 
have generally drawn from existing resources. Therefore, according to 
DHS and DOJ officials, resource information may not be distinguishable 
from other activities and is generally an estimate. Information is also 
not consistent across agencies. 

Although the 2005 TVPA amendments authorized appropriations of 
$18,000,000 in fiscal years 2006 and 2007 to ICE and $15,000,000 in 
fiscal year 2006 to the FBI for trafficking investigations, these 
amendments were enacted after fiscal year 2006 had already begun and 
the amounts were not appropriated. ICE reported 53 full-time 
equivalents for fiscal year 2005, 68 in fiscal year 2006, and 32 
through the first half of fiscal year 2007 for trafficking activities. 
In midyear 2003, ICE received $3.7 million in supplemental funding, 
which mostly funded law enforcement operations to enforce the TVPA and 
domestic and overseas training activities. FBI officials told us they 
had not received a separate appropriation specifically for trafficking 
in persons. The FBI Civil Rights Unit reported as of April 2007, 141 
Special Agents are allocated to its Civil Rights Program throughout 56 
field offices. One Unit Chief, six Supervisory Special Agents, and 
eight support staff are assigned to headquarters. For fiscal year 2006, 
approximately 24 percent of these resources were directed toward human 
trafficking matters. 

In fiscal year 2006, the FBI's Crimes Against Children Unit received 
$500,000 from the Assets Forfeiture fund to support task forces and 
working groups investigating trafficking of U.S. children for 
commercial sex. The funds were used for overtime pay for state and 
local officers, equipment, and training. Additionally, to support the 
Innocence Lost National Initiative, the FBI received 16 positions (10 
agents and 6 analysts) in fiscal year 2005, and 10 agent positions in 
fiscal year 2006. The FBI said it requested 30 investigative, clerical, 
and analytical personnel to support the Crimes Against Children program 
initiatives for fiscal year 2008, including combating trafficking of 
U.S. children for commercial sex. 

In addition, the conference agreement for the fiscal year 2007 DHS 
appropriation designated $1 million to ICE for its contribution to the 
Human Smuggling and Trafficking Center (HSTC). HSTC officials said 
although these funds were not designated specifically for trafficking 
in persons, they would assist HSTC's trafficking efforts. Furthermore, 
because ICE was the only agency with funds specifically designated for 
HSTC, it would henceforth take on the responsibility for up-front 
administrative expenses at HSTC, for which other agencies, including 
DOS and DOJ, would then reimburse ICE. 

CRT/CS also reported that it had not received funds specifically 
designated for human trafficking prosecutions, but provided us with 
estimates of the numbers of positions, attorneys, and full-time 
equivalents for trafficking in persons. CRT/CS further noted that the 
actual number of positions is very difficult to track, because, as is 
true for all enforcement areas within the Criminal Section, most 
attorneys do not work exclusively on trafficking in persons, but carry 
other criminal enforcement cases as well. CRT/CS training, outreach, 
and technical assistance on trafficking in persons have also been 
provided from its operating funds. However, CRT/CS developed and 
provided us with estimates of various types of resources it used to 
address trafficking in persons, as presented in table 7. 

Table 7: DOJ Estimates of CRT/CS Trafficking in Persons Resources, 
Fiscal Years 2000-2007: 

Fiscal year: 2000; 
Positions: 6; 
Attorneys: [Empty]; 
Full-time equivalents: 3; 
Dollars in thousands: $401. 

Fiscal year: 2001; 
Positions: 9; 
Attorneys: [Empty]; 
Full-time equivalents: 9; 
Dollars in thousands: 980. 

Fiscal year: 2002; 
Positions: 21; 
Attorneys: 14; 
Full-time equivalents: 15; 
Dollars in thousands: 1,748. 

Fiscal year: 2003; 
Positions: 21; 
Attorneys: 14; 
Full-time equivalents: 21; 
Dollars in thousands: 2,527. 

Fiscal year: 2004; 
Positions: 21; 
Attorneys: 14; 
Full-time equivalents: 21; 
Dollars in thousands: 2,638. 

Fiscal year: 2005; 
Positions: 21; 
Attorneys: 14; 
Full-time equivalents: 21; 
Dollars in thousands: 2,687. 

Fiscal year: 2006[A]; 
Positions: 21; 
Attorneys: 14; 
Full-time equivalents: 21; 
Dollars in thousands: 2,900. 

Fiscal year: 2007[B]; 
Positions: 21; 
Attorneys: 14; 
Full-time equivalents: 21; 
Dollars in thousands: $3,100. 

Source: GAO analysis of DOJ-provided data and data found in fiscal year 
2008 congressional budget submission. 

[A] Reflects estimated costs for fiscal year 2006. 

[B] Reflects the fiscal year 2007 budget submission. 

[End of table] 

DOJ's fiscal year 2008 budget submission included a request for a CRT/ 
CS program increase of $1,713,000, 13 agent/attorney positions, and 7 
full-time equivalents for its trafficking efforts. 

According to CEOS, prosecuting sex trafficking and sex tourism cases 
can be enormously resource intensive, especially if foreign victims or 
investigators will be needed to testify at trial. As trafficking crimes 
were not a line item in the appropriation legislation, CEOS could not 
provide actual data on the resources used to prosecute these crimes. 
However, CEOS estimated that it has devoted approximately 15 to 25 
percent of its attorney time to trafficking crimes since 2003. FBI and 
CEOS officials noted the lack of facilities for these victims, who need 
special treatment. 

The TVPA authorized the Attorney General to make grants to develop, 
expand, or strengthen victim service programs for victims of 
trafficking. DOJ received approximately $10 million per year in fiscal 
years 2002 through 2006 for victim services programs for victims of 
trafficking, as authorized by section 107(b)(2) of the TVPA. In fiscal 
year 2002, OVC awarded these funds to nonprofit, nongovernmental victim 
services providers to develop, expand, or strengthen services for 
victims of trafficking. According to DOJ officials, in fiscal year 
2003, DOJ decided to use a portion of these funds to award BJA task 
forces grants on trafficking with the goal of expanding services for 
victims by identifying more victims and connecting them with needed 
services. In subsequent fiscal years, both OVC and BJA awarded grants 
with these funds. 

In addition, FBI, ICE, the Executive Office for U.S. Attorneys, and 
CRT/CS have emergency funds that may be used to provide immediate 
services to victims when services cannot be provided through other 
programs that support trafficking victims. According to OVC, the 
agencies coordinate these efforts through it to ensure that any use of 
emergency funds is appropriate, maximizes the use of trafficking 
appropriation dollars when they are available, and occurs when no other 
funds are available. 

[End of section] 

Appendix IV: Summary Case Studies: 

The following case studies illustrate several of the characteristics of 
human trafficking described in this report, including (1) the diverse 
purposes for which people are trafficked and the circumstances in which 
they work, both legally and illegally; (2) the variation in the number 
of victims; (3) case complexity; and (4) coordination among law 
enforcement and nongovernmental organizations in caring for the victims 
and prosecuting the perpetrators.[Footnote 46] 

United States v. Kil Soo Lee: 

United States v. Kil Soo Lee--the largest trafficking prosecution 
before a federal court--resulted from an investigation involving five 
languages, several countries and states, and numerous federal agencies 
and nongovernmental organizations. Between September 1998 and December 
2000, Lee recruited 250 skilled garment workers--mostly young women who 
had paid $5,000 and $8,000 recruitment fees--from China and Vietnam, 
locating his garment factory, named Daewoosa Samoa, in American Samoa 
to use the "Made in America" label and avoid drawing attention to his 
operation. The workers believed the fees to be legitimate payment in 
exchange for new jobs possibly leading to a better life. Instead, they 
lived, ate, and slept in barracks on the factory compound, surrounded 
by fences that remained locked and guarded during working hours. Lee 
and his associates seized passports--threatening the workers with 
deportation, bankruptcy, severe financial hardship to family members 
back home, and false arrest--and withheld food and pay. 

In March 1999, workers asked to be paid for several months' labor. Kil 
Soo Lee refused to pay them, and when the workers protested, he locked 
them inside of the Daewoosa compound and refused to provide them with 
food. Several workers climbed over the fence at night and contacted 
local residents to complain and seek food. Upon finding out that 
workers had left the compound, Kil Soo Lee notified the American Samoan 
police that the workers were causing a disturbance and had the police 
arrest three of the female workers who tried to leave the company 
grounds. The workers were unable to speak English or Samoan, and thus 
were unable to communicate the true version of events to the police. 
Attempting to communicate with the outside world, another worker threw 
a handwritten note from the window of the company car after visiting 
jailed coworkers. This note was found and passed on to the U.S. 
Department of Labor, which investigated allegations that Kil Soo Lee 
had withheld the workers' pay. Because of the investigation, DOL 
required Lee to make restitution to the affected employees. Following 
additional complaints and allegations that Lee was requiring workers to 
kick back the back wage payments, DOL again investigated. The garment 
manufacturers for which Lee was producing goods provided the back wage 
restitution for the underpaid employees in this second investigation. 

In November 2000, workers protested again by slowing production. On 
Lee's direction, guards entered the factory and conducted a mass 
beating of the Vietnamese, inflicting severe injuries on several. Local 
police investigated the uprising but dismissed the case, believing the 
guards' accounts that the Vietnamese workers had attacked the Samoans. 
The Occupational Safety and Health Administration of DOL then arrived 
to conduct inspections of the Daewoosa facility from November to 
February 2001, citing violations of workplace safety noted from earlier 
investigations concluded in June 1999. In March 2001, FBI agents and 
CRT/CS prosecutors traveled to American Samoa to investigate. They 
conducted interviews, surveyed the factory, and seized records, 
computers, and other evidence. Kil Soo Lee was then arrested on March 
23, 2001. He and four other defendants were indicted in August of that 
year on 22 charges of subjecting workers to involuntary servitude. The 
trial began in October 2002 and lasted 4 months. 

During prosecution, the nature of the crime and the cultural and 
linguistic backgrounds of the workers posed challenges for the Civil 
Rights Division. Attorneys had to prove that the workers--now witnesses 
in the trial--were victims rather than simply violators of labor and 
immigration laws. Lee had already had some of them deported, while 
others scattered to 20 states around the country after being given 
temporary immigration status to testify. During the pretrial 
preparations and the trial, more than 200 victims had to be housed and 
fed, while the sick and injured required medical care. Because the 
victims had limited or no English facility (languages spoken included 
Chinese, Vietnamese, Korean, and Samoan), interpreters had to be 
provided. Agents and attorneys also had to gain the victims' trust, 
overcoming their fears of law enforcement and authority, which Kil Soo 
Lee and the other defendants had earlier exploited. Finally, the 
victims needed to be assured that no harm would come from the 
proceedings either to them or their families back home and that they 
had done nothing to draw shame or fear of exposure upon themselves. 

In August 2001, two of the American Samoan guards entered guilty pleas 
to participating in the conspiracy to violate the civil rights of the 
garment workers and were later sentenced to 70 and 51 months in prison. 
Two codefendants were acquitted on all charges. In February 2002, Kil 
Soo Lee was convicted of conspiracy to violate the civil rights of the 
workers, 11 counts of involuntary servitude, 1 count of extortion, and 
1 count of money laundering. Lee, who was in his mid-50s, was sentenced 
in June 2005 to 40 years in prison, which at that time was the highest 
sentence handed down in a trafficking/slavery case that did not result 
in death, and ordered to pay restitution of $1,826,087.94. 

On April 16, 2002, the High Court of American Samoa in a separate 
consolidated civil case also ordered Daewoosa Samoa, Ltd. to pay $3.5 
million in back wages to the workers. 

United States v. Carreto: 

The Carreto case came to the U.S. government's attention on a tip from 
Mexican authorities that a victim was believed to have been held and 
forced into prostitution. An investigation led agents to locations 
where a number of young women and their traffickers were arrested. The 
defendants were members or associates of an extended family whose 
principal business was reaping the profits from compelling young 
Mexican women into prostitution through force, fraud, and coercion. The 
defendants, who often lured the women into romantic relationships, used 
deception, psychological manipulation, and false promises, along with 
physical beatings and rapes, to overcome the will of the victims, 
compel them into prostitution, and force them to turn over virtually 
all the proceeds to the defendants. 

During the investigation of this case, ICE and DOJ coordinated with 
international nongovernmental organizations, the Mexican government, 
and Mexican attorneys to remove the victims' children from the custody 
of the Carreto family, thereby removing one of the last means of 
control the Carreto family had exerted over the victims. The 
investigation revealed extensive sex trafficking activity between 
Mexico and the United States, prompting initiatives to coordinate 
multijurisdictional, multi-agency investigations. 

On November 16, 2004, a federal grand jury returned a 27-count 
superseding indictment charging Josue Flores Carreto, Gerardo Flores 
Carreto, Daniel Perez Alonso, Eliu Carreto Fernandez, Consuelo Carreto 
Valencia, and Maria de los Angeles Velasquez Reyes with victimizing 
nine young Mexican women. The indictment charged the six defendants 
with counts of conspiracy to commit sex trafficking, sex trafficking, 
attempted sex trafficking, forced labor, violation of the Mann Act, 
conspiracy to import aliens for immoral purpose, and alien 
smuggling.[Footnote 47] Two additional defendants, Edith Mosquera de 
Flores and Eloy Carreto Reyes were charged separately by complaint. 

On April 5, 2005, on the morning trial in this case was to begin, 
Gerardo Flores Carreto, Josue Flores Carreto, and Daniel Perez Alonso 
pled guilty to all charges in the 27-count indictment. On April 27, 
2006, Gerardo Flores Carreto and Josue Flores Carreto were each 
sentenced to 50 years in prison. Daniel Perez Alonso was sentenced to 
25 years in prison. Edith Flores had previously been sentenced to 16 
months. On June 1, 2006, Eliu Carreto Fernandez was sentenced to 80 
months in prison. Eloy Carreto Reyes is still pending sentencing. 

On January 19, 2007, the Mexican government extradited defendant 
Consuelo Carreto Valencia to the United States, along with 14 other 
criminal defendants, in an extradition that Attorney General Gonzales 
lauded as unprecedented in its scope and importance. Consuelo Carreto 
Valencia, the mother of two of the lead defendants, is charged with 
conspiring with the other defendants to compel the victims into forced 
prostitution. An additional defendant, Maria de los Angeles Reyes, 
remains in Mexico, where she has previously been arrested on related 
charges. CRT/CS is seeking her extradition. 

[End of section] 

Appendix V: Comments from the Department of Justice: 

U.S. Department of Justice: 
Washington, D.C. 20530: 

July 20, 2007: 

Mr. Robert N. Goldenkoff: 
Acting Director, Homeland Security and Justice: 
Government Accountability Office: 
Washington, D.C. 20548: 

Dear Mr. Goldenkoff: 

Thank you for the opportunity to review the final draft of the 
Government Accountability Office (GAO) report entitled "Human 
Trafficking: A Strategic Framework Could Help Enhance the Interagency 
Collaboration Needed to Effectively Combat Trafficking Crimes, GAO-07- 
915. " This draft report was reviewed by the Department of Justice (DOJ 
or Department) components that participated in the review. This letter 
constitutes the Department's formal comments. I request that the GAO 
include this letter in the final report. The Department's technical 
comments were provided under separate cover. 

Human trafficking programs are very complex, technical programs that 
require a large amount of training to both identify and explain the 
subject matter and to coordinate the response, which often includes 
representatives from law enforcement, the judicial system, victim 
service providers, and community leaders. As noted in this report, 
these programs are looking for victims who are deliberately hidden and 
are unfamiliar with our legal system or the rights and services 
available to them. Because both the crime of human trafficking and the 
needs of the victims are challenging to address, a significant 
investment in training and technical assistance is required for 
effective implementation of any human trafficking program. However, 
compared to technical assistance funding for other complex Department 
initiatives, two percent of the appropriation is a very small 
percentage of funding to be dedicated to technical assistance. 
Additionally, this two percent of appropriated funds must also be split 
between the Bureau of Justice Assistance (BJA) and the Office for 
Victims of Crime (OVC) to provide training and technical assistance to 
its nongovernmental victims service providers. 

As the GAO reports, since 2001, the Department has significantly 
increased the number of human trafficking prosecutions and 
investigations. The Department prosecuted six times more human 
trafficking cases from 2001 to 2006 than in the previous six years. 
Likewise, the Federal Bureau of Investigation (FBI) and, since 2003, 
the Department of Homeland Security (DHS) have investigated record 
numbers of human trafficking matters. These high numbers of 
prosecutions and investigations are the result of regular collaboration 
between the Departments of Justice, Homeland Security and Labor (DOL), 
the 42 BJA funded Human Trafficking Task Forces, and our other law 
enforcement partners. Also, DOJ and DHS have engaged in extensive 
outreach, and provided training and technical assistance to other 
federal and state law enforcement entities, to Non-Governmental 
Organizations (NGO), and foreign governments. As discussed more fully 
below, we agree with GAO that routine collaboration among the various 
partners is a key factor in the continued success of this program. 
However, we recommend that the GAO allow for more flexibility in 
determining the appropriate collaborative model. 

Despite the significant increase in the trafficking caseload since 
2001, using existing resources, it is important to reiterate that 
additional resources are needed if we are to continue our successful 
investigation and prosecution of human trafficking crimes and to 
further our collaborative efforts. 

Our comments about the proposed recommendations follow. 

Recommendation that the Attorney General and the Secretary of Homeland 
Security in conjunction with the Secretaries of Labor State and other 
agency heads deemed appropriate develop and implement a strategic 
framework to coordinate U.S. efforts to investigate and prosecute 
trafficking in persons. 

The GAO report states that interagency coordination on trafficking 
occurs primarily on a reactive, case-by-case basis and that "individual 
agency goals on trafficking are linked to individual agency missions, 
rather than to a common government-wide outcome for combating 
trafficking crimes." However, DOJ, DHS, Department of State (DOS), and 
the other agencies identified by GAO engage in regular strategic and 
proactive collaboration, in addition to what GAO calls "case-by-case" 
or "reactive" collaboration. Senior government officials regularly meet 
at the Senior Policy Operating Group (SPOG) to identify broad 
government-wide common outcomes or "end goals." Senior officials at the 
DOJ, DHS, and the other law enforcement agencies have met and developed 
subordinate goals. For example, DOJ and DHS senior officials met and 
created Memoranda of Understandings that identify "Joint strategies" 
and "agreed on roles." In addition, DOJ, working with our other 
partners, designed and implemented a proactive task force model that 
includes regular collaboration among task force representatives, 
including DOJ, FBI, DHS, DOS, DOL, the Internal Revenue Service (IRS), 
state law enforcement, and NGOs. Likewise, DOJ, DHS, DOS, the Central 
Intelligence Agency and other agencies proactively collaborated to form 
the Human Smuggling and Trafficking Center (HSTC). The Department 
regularly convenes conferences and other programs designed to bring 
together representatives from DOJ, FBI, DHS, DOL, and our other 
partners to proactively collaborate on enforcement objectives. 

Moreover, the Department's law enforcement activities in this regard 
are designed to achieve end goals and operational results determined as 
part of the collaborations with our partners at DHS, DOL, DOS, and 
elsewhere. For example, DOJ and its partners proactively established 
the victim-centered task force model for investigating and prosecuting 
human trafficking crimes. In each specific investigation and 
prosecution, FBI agents and DOJ attorneys implement and utilize this 
model, as GAO describes in the draft report. As GAO recognizes, this 
system has been successful and resulted in record numbers of 
investigations and prosecutions. 

We acknowledge that continued and increased collaboration could further 
our efforts to investigate and prosecute human trafficking crimes. We 
also agree that this heightened collaboration should be led by and be 
held primarily among law enforcement due to the sensitive and 
confidential nature of law enforcement activities and decisions. 
However, the "unique challenges" in these matters, identified by GAO in 
its report, counsel for more flexibility in determining the methods of 
collaboration among our law enforcement partners. We are pursuing a 
variety of methods already. For one, we established the Human 
Trafficking Prosecution Unit. Its members held collaborative meetings 
and training sessions with our partners. 

Therefore, DOJ proposes that the report identify the need for continued 
collaboration, but not mandate one particular collaborative model. 

Recommendation that the Attorney General direct the Director of the 
Bureau of Justice Assistance (BJA) to develop and implement a plan to 
help focus technical assistance on areas of greatest need. 

By October 1, 2007, BJA and OVC plan to collaboratively develop and 
lead a facilitated working group with representatives of their agencies 
and representatives from the Immigration and Customs Enforcement; the 
HSTC; the DOL; and from the following DOJ components: the CRT, National 
Institute of Justice, Bureau of Justice Statistics, Executive Office of 
U.S. Attorneys, and the FBI. The working group will address the 
following training and technical assistance needs which were raised by 
the GAO report: 

1. Substantive training about trafficking crimes and victims for the 
task forces; 

2. Technical assistance and training to help task forces develop the 
components in their strategies required under their BJA grants; 

3. Continuation of basic training on trafficking issues; 

4. Advanced training on such topics as: seizing and forfeiting 
traffickers' assets, techniques to facilitate law enforcement and NGOs 
working together to interview trafficking victims, and techniques for 
interviewing child victims of sex trafficking, 

5. Training of other agency personnel (other law enforcement, hospital 
workers, code enforcement personnel, and social services personnel); 

6. Tailored training and technical assistance to specific populations; 

7. Protocols covering roles and responsibilities, methods of 
communication, and establishing and maintaining relationships; 

8. Technical assistance on ways to improve communication and 
information sharing, assistance with strategizing, translator/cultural 
assistance, and issues around securing safe housings for victims; 

9. Identifying ways to enhancing communication among all parties, such 
as email lists, a secure website, and training bulletins; and: 

10. Regional and national meetings that bring smaller groups of task 
forces together. 

The working group will provide input to BJA regarding the development 
of collaborative outreach. Further, it will allow BJA to improve 
training and technical assistance strategies to address issues raised 
by GAO in its report The Training and Technical Assistance plan is 
expccted to include, at least: 

1. A strategy for informing task force members, on a continuous basis, 
of the availability of training and technical assistance and the wide 
variety of related resources. BJA will review its outreach strategies 
and develop a comprehensive strategy to disseminate training and 
technical assistance options and resources available to task force 
members and other key individuals; 

2. A systematic assessment of performance measures; 

3. Steps to obtain information from the task forces on areas for 
continuous improvement; 

4. An exploration of options for communication such as a secure 
website(s) to share best practices, obtain samples of protocols or 
other documents, and provide peer-to-peer assistance from other task 
forces. Additionally, BJA could use the website(s) to share information 
with task forces; 

5. Methods to assess the quality of training and technical assistance 
provided to recipients; and: 

6. A strategy for identifying training, technical assistance and 
related resources from all working group members, NGOs, task forces and 
foreign partners and matching particular task force's needs with such 
training and technical assistance. 

BJA believes that the creation of a facilitated working group composed 
of agencies actively involved in addressing human trafficking will lead 
to a strong training and technical assistance program which will 
enhance the ability of task forces to achieve their primary goal of 
identifying and rescuing trafficking victims. 

The extensive effort that your staff has put into this report and the 
opportunity to work with them on this important issue are appreciated. 

Sincerely, 

Signed by: 

Leo J. Lofthus: 
Assistant Attorney General for Administration: 

[End of section] 

Appendix VI: Comments from the Department of Homeland Security: 

U.S. Department of Homeland Security: 
Washington, DC 20528: 

July 18, 2007: 

Mr. Robert N. Goldenkoff: 
Acting Director, Homeland Security and Justice: 
U.S. Government Accountability Office: 
Washington, D. C. 20548: 

Dear Mr. Goldenkoff: 

Thank you for the opportunity to review and comment on this most 
important report, Human Trafficking: A Strategic Framework Could Help 
Enhance the Interagency Collaboration Needed to Effectively Combat 
Trafficking Crimes, GAO-07-915. The Department of Homeland Security 
(DHS) aggressively takes action against human trafficking through its 
Immigration and Customs Enforcement (ICE) component. 

DHS and ICE believe the audit report reflects an overall understanding 
of the complexities of the antitrafficking response as well as ICE's 
efforts in leading investigations, conducting outreach, and responding 
to victims of trafficking crimes. The GAO's assessment properly 
characterizes ICE's compliance with National Security Presidential 
Directive (NSPD)-22, which directs federal agencies to ensure that 
employees are fully trained to carry out investigative and 
prosecutorial responsibilities as well as to effectively coordinate 
efforts across agencies and disciplines. 

The report notes that coordination and strategizing among agencies is 
reactive and on a case-by-case basis, however interagency coordination 
does occur through the Senior Policy Operating Group (SPOG). The SPOG 
ensures that the U.S. Government anti-trafficking policies and 
guidelines are carried out; therefore ICE does not believe there is a 
need for a government-wide framework or strategy. 

Additionally, recommendations from various agencies that foster the 
development of frameworks are included in the annual "Attorney General 
Report to Congress" and the "U.S. Government Assessment of Efforts to 
Combat Trafficking in Persons." These annual reports also include plans 
of action to be applied in the upcoming fiscal years. 

Furthermore, ICE regularly conducts direct strategic planning with 
partner agencies. Most of the strategic planning with partner agencies 
occurs in the field. There are 42 Human Trafficking Task Forces, also 
referred to as the Human Trafficking Rescue Alliances around the 
country. Federal agencies, including ICE, the Federal Bureau of 
Investigations, U.S. Attorney Offices, local law enforcement agencies, 
and Non-Governmental Organizations. 

(NGOs) participate in these task forces. Each task force agrees to 
operational trafficking strategies or protocols. Protocols include 
which agency is the lead for the investigation, which NGOs are notified 
when a trafficking victim is discovered, which agency handles media 
inquiries, etc. The task force members also agree on outreach 
strategies, such as when and where training will be held, who will be 
the target audience, frequency of training classes, trafficking 
awareness campaigns, etc. The Human Trafficking Task Forces usually 
meet once per quarter, during which ongoing analysis and strategic 
planning is conducted. 

Recommendation 1 impacts ICE's roles and responsibilities in planning 
and orchestrating investigations related to human trafficking. 
Specifically, the GAO report indicates that interagency coordination on 
trafficking occurs primarily on a reactive, case-by-case basis and that 
federal investigative and prosecutorial agencies would "benefit from an 
overall strategic framework to help enhance and sustain interagency 
collaboration on trafficking in persons. individual agency goals on 
trafficking are linked to individual agency missions, rather than to a 
common government-wide outcome for combating trafficking crimes." 

The strategic framework suggested by the GAO would be developed and 
implemented by the Attorney General and the Secretary of Homeland 
Security, in conjunction with the Secretaries of Labor, State, and 
other agency heads deemed appropriate. The following are the items GAO 
would like to see addressed in the framework: 

-A commonly identified outcome, 

-Mutually reinforcing or joint strategies, 

- Roles and responsibilities, and: 

-The establishment of compatible policies, procedures, and other means 
to operate across agency boundaries (See page 36, Recommendations for 
Executive Action). 

ICE would support an interagency strategic framework if the 
considerations herein were taken into account. Mutual goal-setting may 
be possible as long as the goals contain several objectives that will 
specifically address unique agency capabilities in combating 
trafficking. Note that the agencies identified by GAO to develop and 
implement this common framework include agencies with both domestic and 
international responsibilities. On cases in which ICE and the FBI are 
involved in a joint investigation, it might be feasible to develop 
joint strategies for investigation and response. However, while ICE 
does not object to the creation of roles and responsibilities that 
would effectuate enhanced communication and collaboration among federal 
and local agencies, it is critical to note that such protocols must 
take into account that agencies' roles in a particular case will vary 
by available resources, local priorities, and --to a certain extent-- 
the nature of the case and investigation. ICE remains amenable and 
responsive to conducting human trafficking investigations where victims 
and offenders are not U.S. citizens. 

ICE notes that the 2003 Reauthorization of the trafficking Victims 
Protection Act established that the Attorney General prepare and submit 
an annual report to Congress on efforts to combat trafficking 
domestically. The report to Congress, though submitted by the 
Department of Justice, is prepared with input from all federal agencies 
involved in investigating and prosecuting trafficking crimes or funding 
programs to respond to victim coordination. While the report is 
primarily an update summarizing each agency's contributions in the 
areas of service provision to victims, investigations and prosecutions, 
international efforts, and training and outreach, it also includes 
language that identifies goals for each agency in improving their 
response to human trafficking issues. Although the Attorney General 
Report to Congress does not amount to a government-wide strategic plan 
or trafficking, it is a call for individual agencies to create a 
strategy for improved response within the context of existing 
resources. 

ICE was authorized appropriations amounting to $18 million for 
investigations involving trafficking in persons under the provisions of 
the Trafficking in Persons Reauthorization Act of 2005 (H.R. 972) in 
Fiscal Years 2006 and 2007. Congress has not yet provided funding to 
carry out the provisions of the Act, which would include conducting 
trafficking investigations, victim/witness support, outreach, and 
domestic and international training. ICE continues to conduct this 
important mission using baseline funding. Relying upon base 
appropriations is particularly challenging with respect to the victims 
and witnesses of this criminal activity. Presently, the funding vacuum 
precludes placement of full-time victim/witness coordinators in the 
field in the same way that our partner agencies do. In order to be 
fully responsive to the GAO's desire for ICE to develop and 
operationalize a common trafficking framework with our federal 
partners, it is critical to ensure that the necessary resources are 
allocated for policy efforts and for the initiating of recommendations 
that arise from the development of any common framework. 

We thank you for the opportunity to review this most important draft 
report and to provide comments. 

Sincerely, 

Signed by: 

Steven J. Pecinovsky: 
Director: 
Departmental GAO/OIG Liaison Office: 

[End of section] 

Appendix VII: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Robert N. Goldenkoff (202) 512-2757. 

Staff Acknowledgments: 

In addition to the individual named above, Glenn G. Davis, Barbara A. 
Stolz, Susanna R. Kuebler, Richard Ascarate, Kelly Bradley, Erin 
Claussen, Frances Cook, Stuart Kaufman, and Elizabeth Curda made 
significant contributions to the report. 

[End of section] 

Related GAO Products: 

Human Trafficking: Better Data, Strategy, and Reporting Needed to 
Enhance U.S. Anti-Trafficking Efforts Abroad, GAO-06-825 (Washington, 
D.C.: July 18, 2006): 

Human Trafficking: Monitoring and Evaluation of International Projects 
Are Limited, but Experts Suggest Improvements, GAO-07-1034 (Washington, 
D.C.: July 26, 2007): 

Results-oriented Government: Practices That Can Help Enhance and 
Sustain Collaboration among Federal Agencies, GAO-06-15 (Washington, 
D.C.: Oct. 21, 2005): 

International Crime Control: Sustained Executive-Level Coordination of 
Federal Response Needed, GAO-01-629 (Washington, D.C.: August 13, 
2001): 

Combating Terrorism: Evaluation of Selected Characteristics in National 
Strategies Related to Terrorism, GAO-04-408T (Washington, D.C.: 
February 3, 2004): 

Organized Crime: Issues Concerning Strike Forces, GAO/GGD-89-67 
(Washington, D.C.: April 11, 1989): 

Prescription Drugs: Strategic Framework Would Promote Accountability 
and Enhance Efforts to Enforce the Prohibitions on Personal 
Importation, GAO-05-372 (Washington, D.C.: September 8, 2005): 

Community Services Block Grant Program: HHS Should Improve Oversight by 
Focusing Monitoring and Assistance Efforts on Areas of High Risk, GAO- 
06-627 (Washington, D.C.: June 29, 2006): 

FOOTNOTES 

[1] The terms "human trafficking" and "trafficking in persons" are 
often used interchangeably. In this report, we use the term 
"trafficking in persons," as referred to in U.S. law, except where 
source documents use the term "human trafficking." 

[2] See GAO, Human Trafficking: Better Data, Strategy, and Reporting 
Needed to Enhance U.S. Anti-Trafficking Efforts Abroad, GAO-06-825 
(Washington, D.C.: July 18, 2006). 

[3] Pub. L. No. 106-386, div. A, 114 Stat. 1464, 1466-91 (2000). 

[4] Pub. L. No. 108-193, 117 Stat. 2875 (2003); Pub. L. No. 109-164, 
119 Stat. 3558 (2006). 

[5] As defined in previous GAO work, for the purpose of this report we 
define "collaboration" as any joint activity by two or more 
organizations that is intended to produce more public value than could 
be produced when the organizations act alone. We use the term 
"collaboration" broadly to include interagency activities that others 
have variously defined as "cooperation," "coordination," "integration," 
or "networking." See GAO, Results-oriented Government: Practices That 
Can Help Enhance and Sustain Collaboration among Federal Agencies, GAO-
06-15 (Washington, D.C.: Oct. 21, 2005). 

[6] See GAO, Human Trafficking: Monitoring and Evaluation of 
International Antitrafficking Projects Are Limited, but Experts Suggest 
Improvements, GAO-07-1034 (Washington, D.C.: July 26, 2007). We 
previously issued Human Trafficking: Better Data, Strategy, and 
Reporting Needed to Enhance U.S. Anti-Trafficking Efforts Abroad, GAO-
06-825 (Washington, D.C.: July 18, 2006). 

[7] The Intelligence Reform and Terrorism Prevention Act of 2004 
established the Human Smuggling and Trafficking Center, to be jointly 
run by the Departments of State, Justice, and Homeland Security, in 
order to collect and disseminate information to help prevent 
clandestine terrorist travel and facilitation of migrant smuggling and 
trafficking in persons. 8 U.S.C.  1777. 

[8] This number does not include any CEOS/Innocence Lost National 
Initiative prosecutions for trafficking of U.S. children for commercial 
sex or trafficking prosecutions brought by U.S. Attorney's offices and 
not reported to CRT/CS. 

[9] See GAO-06-15. 

[10] See GAO, Community Services Block Grant Program: HHS Should 
Improve Oversight by Focusing Monitoring and Assistance Efforts on 
Areas of High Risk, GAO-06-627 (Washington, D.C.: June 29, 2006). 

[11] Under the TVPA, certification that a victim is willing to assist 
law enforcement is made by the Secretary of Health and Human Services 
after consultation with the Attorney General. Certification is a 
prerequisite for benefits only for victims 18 and older. 

[12] National Security Presidential Directive 22 (NSPD 22), signed on 
December 16, 2002. 

[13] The SPOG had previously functioned under the name Senior Policy 
Advisory Group. 

[14] In December 2006, the HSTC Steering Group approved amendments to 
the HSTC Charter. DHS/ICE now nominates the Director. The nomination is 
still subject to the approval of the Steering Group. 

[15] Mutual Legal Assistance Treaties (MLAT) are intended to enable law 
enforcement to efficiently and effectively obtain evidence, 
information, and testimony from abroad in a form admissible in courts 
of the requesting state. Extradition treaties govern the preconditions 
for, and exceptions to, the surrender of a fugitive from justice found 
in one country to another country claiming criminal jurisdiction over 
the fugitive. 

[16] Located in Lyon, France, Interpol does not maintain a force of 
international police officers or agents. The United States has 
participated in Interpol since 1938, with the authority for that 
participation resting with the Attorney General (22 U.S.C.  263a). 
Established in 1969, the Interpol-U.S. National Central Bureau, headed 
since 2003 alternatively by officials from DOJ and DHS, is the central 
point of contact for Interpol business in the United States (Memorandum 
of Understanding between the U.S. Department of Homeland Security and 
the U.S. Department of Justice Pertaining to U.S. Membership in the 
International Criminal Police Organization [INTERPOL] and related 
matters, May 2003). 

[17] This number does not include any CEOS/Innocence Lost National 
Initiative prosecutions for trafficking of U.S. children for commercial 
sex or trafficking prosecutions brought by U.S. Attorney's offices and 
not reported to CRT/CS. 

[18] This number does not include any CEOS/Innocence Lost National 
Initiative prosecutions for trafficking of U.S. children for commercial 
sex or trafficking prosecutions brought by U.S. Attorney's offices and 
not reported to CRT/CS. 

[19] ICE data were for a more limited time period, because the agency, 
which was established in 2003, had initial problems in capturing 
trafficking in persons data. 

[20] ICE agents had to take a test to show that they had completed this 
training. On the basis of this test information, ICE headquarters 
officials told us that they believed that all agents have completed the 
training. 

[21] The National Advocacy Center is operated by the Department of 
Justice and Executive Office for United States Attorneys. 

[22] The toll-free number of the Trafficking in Persons and Worker 
Exploitation Complaint Line is 1-888-428-7581. It is operational 
between 9 a.m. and 5 p.m. Eastern Standard Time. Operators have access 
to interpreters and can talk with callers in their own language. 

[23] The 2006 conference was mandated by the 2005 TVPA reauthorization 
act. 

[24] The states are Alaska, Arizona, Arkansas, California, Colorado, 
Connecticut, Florida, Georgia, Idaho, Illinois, Indiana, Iowa, Kansas, 
Kentucky, Louisiana, Maryland, Michigan, Minnesota, Mississippi, 
Missouri, Montana, Nebraska, Nevada, New Hampshire, New Jersey, New 
York, North Carolina, Pennsylvania, South Carolina, Texas, and 
Washington. 

[25] DHS was established in March 2003. 

[26] ICE defines collateral duty as an additional part-time duty 
assigned outside the agent's or officer's regular duties, as the need 
arises. 

[27] For example, DOJ, DHS, and the Department of Health and Human 
Services have a memorandum of understanding on the basic functions and 
interrelationships of the departments as they relate to certification 
of persons as victims of a severe form of trafficking under the TVPA. 

[28] See GAO-06-15. 

[29] See GAO-06-15. 

[30] See GAO, Combating Terrorism: Evaluation of Selected 
Characteristics in National Strategies Related to Terrorism, GAO-04-
408T (Washington, D.C.: Feb. 3, 2004). 

[31] According to BJA and OVC officials, the task force grants are 
funded with a portion of the funds appropriated under the TVPA to 
develop, expand, or strengthen victim service programs for victims of 
trafficking. The agency's goal in using a portion of the funds in this 
way is to make services available to more victims by identifying more 
victims and then connecting them with needed services. 

[32] The BJA task forces are not the universe of human trafficking task 
forces directed toward law enforcement. For example, Philadelphia and 
Pittsburgh also have task forces. In addition, in 23 cities formal or 
informal task forces have been established as part of the Innocence 
Lost National Initiative on the trafficking of U.S. children for 
commercial sex. However the 42 BJA-funded task forces are considered to 
be part of the overall federal effort to investigate and prosecute 
trafficking in persons. 

[33] The TVPA allows 2 percent of the funds appropriated for the grants 
for victim service programs for trafficking victims to be set aside for 
training and technical assistance each fiscal year. For fiscal years 
2002 through 2006, DOJ received approximately $10 million for the TVPA 
grants, which means that approximately $200,000 (less rescissions and 
other allocations) were available for each fiscal year for training and 
technical assistance. OVC awarded Safe Horizon, a nongovernmental 
organization, a grant to provide technical assistance to victim service 
providers funded under the program. According to OVC, Safe Horizon was 
given a total of $596,595 for fiscal years 2002, 2003, and 2004. OVC 
officials also told us that OVC and BJA expect to award remaining 
technical assistance funds from subsequent fiscal years to provide 
technical assistance to both OVC and BJA human trafficking grantees. In 
the interim, Safe Horizon does provide some technical assistance to 
task force grantees, according to OVC officials. 

[34] BJA reported that it relied on funding from deobligated accounts 
at one time made available by the Office of the Assistant Attorney 
General. 

[35] See GAO-06-627. 

[36] See GAO-07-1034 and GAO-06-825. 

[37] See GAO-06-15; International Crime Control: Sustained Executive- 
Level Coordination of Federal Response Needed, GAO-01-629 (Washington, 
D.C.: Aug. 13, 2001); GAO-04-408T; Organized Crime: Issues Concerning 
Strike Forces, GAO/GGD-89-67 (Washington, D.C.: Apr. 11, 1989); 
Prescription Drugs: Strategic Framework Would Promote Accountability 
and Enhance Efforts to Enforce the Prohibitions on Personal 
Importation, GAO-05-372 (Washington, D.C.: Sept. 8, 2005). 

[38] The BJA task forces are not the universe of human trafficking task 
forces directed toward law enforcement. However, they were clearly 
defined as task forces focused on human trafficking, readily 
identifiable by federal agencies, considered by federal agencies to be 
part of the overall federal effort to investigate and prosecute 
trafficking in persons, and had a definite source of federal funding. 
For these reasons, we focused our work on the BJA-funded task forces 
that existed at the time of our review. 

[39] See GAO-06-627. 

[40] 18 U.S.C.  1581-1588. 

[41] 18 U.S.C.  2421-2424. 

[42] For example, 29 U.S.C. 1851 (criminal sanctions for violations of 
the Migrant and Seasonal Agricultural Worker Protection Act and related 
regulations). 

[43] See United States v. Kozminski, 487 U.S. 931 (1988). 

[44] According to CRT/CS officials, as a result of successful 
prosecutions, defendants have been ordered to pay restitution in 34 
cases since October 2000. The restitution amounts ranged between 
$257.55 to more than $1.8 million. The amounts can vary based on the 
length of time the victim was exploited, the wages associated with the 
labor or service performed, and the number of victims involved. 
However, when setting the amount of the restitution, a court may not 
consider the defendant's ability to pay. 

[45] Only limited data were available from ICE, because the agency was 
established in 2003 as part of the Department of Homeland Security and 
initially had difficulties capturing trafficking in persons data. 

[46] CRT/CS and DOL's Wage and Hour Division reviewed the summary of 
the Kil Soo Lee prosecution, and CRT/CS provided the summary of the 
Carreto prosecution. 

[47] 18 U.S.C.  371 conspiracy to commit 18 U.S.C.  1591 sex 
trafficking; 18 U.S.C.  1591 sex trafficking; 18 U.S.C.  1594 
attempted sex trafficking; 18 U.S.C.  1589 forced labor; 18 U.S.C.  
2421 Mann Act; 18 U.S.C.  371 conspiracy to import for immoral purpose 
under 8 U.S.C.  1328; and 8 U.S.C.  1324 alien smuggling. 

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