As the FIAU joins the Blue Heart Campaign, a global initiative led by the United Nations Office on Drugs and Crime (UNODC) to raise awareness of human trafficking, support victims, and inspire action against exploitation, it also highlights the importance of following the money to combat the criminal networks that profit from these crimes.

Human trafficking, labour exploitation, fraud, and other forms of exploitation are often driven by financial gain. Criminals prey on vulnerable individuals through deceptive recruitment methods, false job opportunities, and fraudulent employment practices, leaving victims exploited, defrauded, and, in some cases, trapped in situations amounting to modern slavery. Behind these crimes lies a financial motive, the pursuit of illicit profit at the expense of innocent people.

By analysing financial intelligence and tracing suspicious financial activity, the FIAU plays a vital role in identifying the proceeds generated through such criminal conduct. Following the money helps expose the individuals and networks behind these schemes, disrupt their operations, and prevent criminals from enjoying the profits derived from exploitation. By targeting the financial gains that fuel these crimes, the FIAU contributes to broader efforts to protect vulnerable individuals and reduce the incentive for exploitation to occur.

The following sanitised case study demonstrates how deceptive employment practices can be used to exploit workers for financial gain. It also highlights how financial intelligence can uncover red flags, identify suspicious transactions, and support efforts to detect and disrupt criminal activity linked to exploitation and human trafficking.

Disclaimer

The following case study has been sanitised for public dissemination. Certain details and identifying information have been removed or altered to protect the identities of the individuals concerned. The purpose of the case study is to illustrate key typologies and indicators and should not be interpreted as a comprehensive account of the underlying case.

How was the Analysis Triggered?

Following the findings of the Strategic Analysis on Maltese massage parlours and their potential exposure to human trafficking for sexual exploitation, as well as the publication of the Intelligence Factsheet “Strategic Analysis on Maltese Massage Parlours and Their Possible Exposure to the Sexual Exploitation of Women” in May 2024, the Strategic Analysis Team initiated a further tactical analysis focusing on massage parlours which were assessed as posing a higher risk of involvement in illicit practices.

A Tactical Analysis is conducted proactively with the aim of identifying individuals, entities or networks that may warrant further analysis. By building on the findings from the initial Strategic Analysis, the exercise sought to develop a better understanding of the financial structures, ownership networks, and potential criminal associations connected to higher-risk massage parlours operating in Malta.

Through this analysis, Mr DOE was identified as having links to a higher-risk massage parlour, including indicators suggesting he may be the UBO of the entity. These links included the usage of a common registered address and common VAT Numbers.

Key Findings from the Analysis

Mr DOE’s Relationship

The analysis revealed a personal relationship between Mr DOE and a Foreign national (“Ms SMITH”). The relationship was considered noteworthy when assessed alongside the findings of the Strategic Analysis, which identified the prevalence of specific foreign nationalities within the sector.

Further intelligence gathered by the FIAU revealed that Ms SMITH had worked in several massage parlours and had formed a personal relationship with Mr DOE after being employed by him. When assessed alongside other intelligence and known human trafficking typologies, concerns were raised that Ms SMITH may have facilitated connections between individuals operating within the sector.

Transactional Analysis

A transactional analysis was carried out on Mr DOE’s and Ms SMITH’s accounts held with local credit institutions. The analysis revealed little to no transactional activity throughout the period of review. The lack of financial activity observed across both accounts raised several red flags, particularly in consideration of the fact that Mr DOE held involvements in various active Maltese registered companies.

Additionally, despite intelligence indicating that Mr DOE had acquired multiple massage parlours, the financial analysis carried out did not identify any transactional activities linked to business income nor routine living expenses. This discrepancy raised concerns regarding the potential use of funds outside the formal financial system in order to carry out day-to-day expenditures.

A similar pattern was observed in relation to Ms SMITH’s account whereby, despite the lack of activity, she was identified as possessing assets under her name, with no corresponding payment trail established through the analysis carried out. This thereby further raised concerns regarding the possible utilisation of funds outside the formal financial system.

Persons Employed by Mr DOE and Ms SMITH

In light of the minimal observable transactional activity, the analysis revealed a further noteworthy trend whereby several foreign nationals initially employed by Ms SMITH were later employed by other individuals who had been subject of law enforcement action in relation to human trafficking-related offences. Further analysis established that these employees had been moved between multiple massage parlours linked to persons associated with large networks of massage parlours and who were subjects of intelligence linking them to suspected involvements in prostitution-related activities.

Furthermore, additional intelligence obtained revealed that Ms SMITH employed numerous foreign nationals as masseuses at the massage parlours owned by Mr DOE. The analysis further revealed that a number of these employees were residing in a shared premises together with numerous other foreign nationals. This finding served as a further noteworthy indicator raising concerns of potential human trafficking related activity.

Unrelated Persons Residing at the Same Residential Address.

Additional intelligence obtained indicated that numerous foreign nationals had, over time, been associated with the same residential address as the report subjects. The relationship with the majority of these individuals could not be established, as they were not registered as being employed. Furthermore, the analysis revealed that these individuals originated from countries which were considered to be at higher risk for human trafficking, including for the purposes of sexual exploitation and forced labour. When considered alongside the other intelligence gathered, further concerns were raised that these individuals may have been victims of exploitation in the form of potential forced labour and forced domestic servitude.

Open-Source Screening

Open-source intelligence gathered in relation to Ms SMITH and Mr DOE revealed commonalities in their social media connections. Both subjects were observed as being connected with other persons who had been previously linked to intelligence pertaining to potential human trafficking activity.

Furthermore, the identified massage parlours were noted to be advertising prices which were unrealistically low in comparison to typical market prices. As was noted within the FIAU’s publication, this is a noteworthy red flag potentially indicative of illicit massage business activity.

Summary of Key Red Flags

• Minimal financial activity observed within local bank accounts raising concerns on how and where income is received.
• Report Subjects linked to other individuals who have been previously linked to intelligence pertaining to human trafficking for sexual exploitation and forced labour.
• Employees of the report subjects observed typically being employed by other individuals who were adversely known due to potential links to sexual exploitation and human trafficking. This raised further concerns that networks of massage parlours appeared to be utilising the same individuals, raising concerns that their employment as massage therapists may have been utilised as a front for human trafficking for sexual exploitation.
• The identified massage parlours were noted to be charging prices for services well below the market level, indicative of potentially illicit activities.