Disrupting the Finances of Criminal Networks Responsible for Human Smuggling and Trafficking

Over the last two years, human traffickers and smugglers in East and North Africa have shifted their
business models in response to efforts to contain migration flows to Europe, resulting in notable shifts in
migration patterns. At the same time, the European Union (EU) has deepened its understanding of how
human smugglers and traffickers use money laundering and other illegal financial means to advance
their work. It is also investing in combating money laundering, as well as building the capabilities of the
InterYGovernmental Authority for Development (IGAD) and East African Community (EAC) member
states to gather evidence, share cases, and prosecute transnational criminal networks through training
and collaborative efforts. The evolution of both the criminal networks and the efforts of the EU, IGAD
and EAC have evolved in parallel with each other, often in a mutually influential relationship.
HighYlevel agreements and efforts to deter migration from Libya have had significant impact. The routes
previously used for migration out of Africa have shifted, and new ones (most significantly via Niger,
Algeria and Turkey) have emerged. In this context, two main developments have occurred in relation to
irregular migration and criminal networks.
Firstly, whereas in 2017 there were widespread reports of migrants (including asylum seekers)1 being
treated as ‘captive travellers’ or ‘slaves’, in 2018 there are increased reports of migrants and refugees
being treated as commodities or collateral. Over the past two years, they have become victims of even
more violent and exploitative treatment at the hands of human traffickers. They are routinely held
hostage and aggressively tortured for ransom and sold across several criminal networks in a cyclical
exchange. Indeed, while the number of migrants coming to Italy sharply dropped in 2018 (BBC 11
September 2018), the number of migrants in known Libyan detention centres nearly doubled from 5,000
to 9,300 between 2017 and 2018 (Mixed Migration Centre Aug. 2018). The actual figures of human
trafficking victims are likely to be much higher.
Secondly, smuggling and trafficking networks are evolving. Not only have they have broadened their
reach, they have also deYcriminalised many aspects of their smuggling business mode, employing
increasingly legal mechanisms to work from West Africa, Turkey and Europe. Today, the smuggling of
humans relies less on clandestine movement, and more on ‘commercial travel’.
Efforts to combat illicit financial transactions linked to trafficking and smuggling from Africa are still at
an early stage. At this time, national Financial Investigation Units (FIUs) have just begun to address these
types of financial transactions. Governments and investigators are constrained by a number of factors,
including: the lack of financial data; limited human and investigative resources; a lack of awareness or
concern from public authorities and the private sector; weak legal frameworks and corruption; and
limited domestic, regional and international cooperation and information sharing. Large sections of the
criminal networks’ topology remain superficially documented and analysed, while international
organisations often still use outdated data to map the main criminal networks.
In this context, relying on financial institutions, law enforcement and prosecution resources without
further integration, information sharing including with other stakeholders, is not enough to make a
significant impact in the fight against organised criminal networks. Most donors are investing in
providing technical assistance on AMLYCFT, mainly consisting of training and “Training the Trainers”
approaches, with their limitations. The EU AMLYCFT programme is also training FIUs, as are the Danish
government and UNODC. However, much more engagement is needed with law enforcement,
intelligence and in some instances with the military. Financial Investigations Units, prosecutors, judges,
civil society organisations, including human rights activists, private entities, banks and financial
institutions also need similar training and a platform for collaborative action. Undermining the capacities of criminal networks and affecting their financial capabilities requires a new
approach, outlined here, that uses innovative ways of gathering and sharing information, intelligence
and evidence of the processes that underpin smuggling and trafficking operations and the networks
behind them.