T HE N ATIONAL A CTION P LAN

T O C OMBAT H UMAN T RAFFICKING

PRESIDENT DONALD J. TRUMP

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★ ★ ★ 
T ABLE OF C ONTENTS
Acronyms……………………………………………………………………..…3
Introduction………………………………………………………………..……5
Pillar 1: Prevention……………………………………………………………14
Pillar 2: Protection…………………………………………………………….22
Pillar 3: Prosecution…………………………………………………………...35
Pillar 4: Crosscutting Approaches and Institutional Effectiveness………...45
Appendix A: Glossary of Terms……………………………………………...53
Appendix B: Primary Authorities……………………………………………57

 
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★ ★ ★ 
A CRONYMS
ACF Administration for Children and Families, a component of HHS
ACTeam Anti-trafficking Coordination Team, an initiative of DOJ, DHS, and DOL
ATF Bureau of Alcohol, Tobacco, Firearms, and Explosives, a component of DOJ
BIA Bureau of Indian Affairs, a component of DOI
BJA Bureau of Justice Assistance, a component of DOJ
BOP Federal Bureau of Prisons, a component of DOJ
CB Children’s Bureau, a component of HHS
CBP United States Customs and Border Protection, a component of DHS
DEA Drug Enforcement Administration, a component of DOJ
DHS United States Department of Homeland Security
DOC United States Department of Commerce
DOD United States Department of Defense
DOI United States Department of Interior
DOJ United States Department of Justice
DOL United States Department of Labor
DOS United States Department of State
DOT United States Department of Transportation
DSS Diplomatic Security Service, a component of DOS
EEOC Equal Employment Opportunity Commission
EOIR Executive Office for Immigration Review, a component of DOJ
ERO Enforcement and Removal Operations, a component of DHS
FBI Federal Bureau of Investigation, a component of DOJ
FDA Food and Drug Administration, a component of HHS
FEMA Federal Emergency Management Agency, a component of DHS
FinCEN Financial Crimes Enforcement Network, a component of Treasury
FYSB Family and Youth Services Bureau, a component of HHS
GSA General Services Administration
HHS United States Department of Health and Human Services
HRSA Health Resources and Services Administration, a component of HHS
HSI Homeland Security Investigations, a component of DHS
HUD United States Department of Housing and Urban Development
ICAO International Civil Aviation Organization, an agency of the United Nations
 
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ICE United States Immigration and Customs Enforcement, a component of DHS

IRS Internal Revenue Service, a component of Treasury
ITA International Trade Administration, a component of DOC
LGBT+ Lesbian, Gay, Bisexual, Transgender, and other gender- or sexuality-related
identities, such as intersex
NIJ National Institute of Justice, a component of DOJ
NCMEC National Center for Missing and Exploited Children, an NGO
NGO Non-governmental organization
NOAA National Oceanic and Atmospheric Administration, a component of the
United States Department of Commerce
OFAC Office of Foreign Assets Control, a component of Treasury
OIG Office of Inspector General
OJJDP Office of Juvenile Justice and Delinquency Prevention, a component of DOJ
OJP Office of Justice Programs, a component of DOJ
OMB Office of Management and Budget, a component of the White House
OSHA Occupational Safety and Health Administration, a component of DOL
OTIP Office on Trafficking in Persons, a component of HHS
OVC Office for Victims of Crime, a component of DOJ
OVW Office on Violence Against Women, a component of DOJ
PITF President’s Interagency Task Force to Monitor and Combat Trafficking in
Persons
SAMHSA Substance Abuse and Mental Health Services Administration, a component
of HHS
SPOG Senior Policy Operating Group, PITF-designated representatives
T visa T nonimmigrant status
Treasury United States Department of the Treasury
TSA Transportation Security Administration, a component of DHS
TVPA Trafficking Victims Protection Act
U visa U nonimmigrant status
USAID United States Agency for International Development
USAOs United States Attorney’s Offices, components of DOJ
U.S.C.G United States Coast Guard, a component of DHS
USCIS United States Citizenship and Immigrations Services, a component of DHS
USDA United States Department of Agriculture
USMS United States Marshals Service, a component of DOJ
USPS United States Postal Service
USTR Office of the United States Trade Representative, a component of the White
House
WHD Wage and Hour Division, a component of DOL
 
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★ ★ ★ 
I NTRODUCTION
The United States Government is committed to eradicating human trafficking, commonly referred
to as a form of modern slavery or trafficking in persons, in all its forms. Human trafficking, a
crime of exploiting a person for compelled labor or commercial sex, has no place in a society that
values freedom and the rule of law. Nonetheless, it exists in every region of the United States and
around the world. Human trafficking poses a grave danger to individual well-being, public health,
public safety, national security, economic development, and prosperity.

Our Nation’s understanding of human trafficking, an underreported crime, has grown, and we have
learned that this crime is far more pervasive than previously understood. In 2019, 11,500 situations
of human trafficking were identified through the United States National Human Trafficking
Hotline.1 Globally, an estimated 24.9 million people are subjected to human trafficking,2 which
generates an estimated $150 billion annually in illicit profits.3

Human trafficking is defined as sex trafficking and labor trafficking or forced labor as follows
under United States law:
 Sex trafficking in which a commercial sex act4 is induced by force, fraud, or coercion,
or in which the person induced to perform such an act has not attained 18 years of age; or
 The recruitment, harboring, transportation, provision, or obtaining of a person for labor or
services through the use of force, fraud, or coercion for the purpose of subjection to
involuntary servitude, peonage, debt bondage, or slavery.5

                                                            
1
 See Polaris, 2019 Statistics from the National Human Trafficking Hotline (2019) available at
https://polarisproject.org/wp-content/uploads/2019/09/Polaris-2019-US-National-Human-Trafficking-Hotline-Data-
Report.pdf  
2
International Labour Organization and Walk Free Foundation, Global Estimates of Modern Slavery: Forced
Labour and Forced Marriage (2017). This report used data from the International Organization for Migration’s
victim assistance database and surveys of more than 71,000 respondents from 48 countries. Of the 24.9 million
victims, the report finds that “16 million were in the private economy, another 4.8 million were in forced sexual
exploitation, and 4.1 million were in forced labour imposed by state authorities.” Available at
https://www.ilo.org/wcmsp5/groups/public/@dgreports/@dcomm/documents/publication/wcms_575479.pdf.
3
See International Labour Organization. “Profits and Poverty: The Economics of Forced Labour.” 20 May 2014
available at https://www.ilo.org/wcmsp5/groups/public/---ed_norm/---
declaration/documents/publication/wcms_243391.pdf.
4
The term “commercial sex act” means any sex act on account of which anything of value is given to or received by
any person. 22 U.S.C. § 7102(4).
5
See 22 U.S.C. § 7102(11). For additional legal definitions, see 18 U.S.C. Chapter 77 (criminal definitions) and 19
U.S.C. § 1307 (includes customs definition of “forced labor”).

 
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Even though human trafficking may be considered a single crime with 2 main variants of sex and
labor trafficking, it takes many forms. Sex traffickers exploit victims through the use of escort
services, outdoor solicitation, cantinas, and online commercial sex advertising, among other
means. Also, as the definition above states, when someone under the age of 18 is caused to engage
in a commercial sex act, even if no force, fraud, or coercion is proven, Federal law considers that
minor to be a victim of sex trafficking.6 Labor trafficking occurs across many different industries,
such as domestic work, traveling sales crews, food services, peddling and begging, agriculture,
health and beauty services, construction, hospitality, and landscaping. In some industries, such as
illicit massage businesses or bars, strip clubs, and cantinas, there are often victims of both sex and
labor trafficking.7 The United States Government has found forced labor overseas in industries
– such as apparel, manufactured goods, electronics, and fishing – which produce goods that are or
are likely to be imported into the United States.8   Labor trafficking is often accompanied by the
presence of force, fraud, or coercion. Examples of types of force, fraud, or coercion that apply to
either sex or labor trafficking may include: actual force, threats of force, physical restraint, threats
of serious harm, abuse of the law, threats to the safety of family members, abuse of vulnerability,
restriction of movement, isolation, retention of identity documents, withholding drugs to induce
withdrawal sickness, threats of deportation, debt manipulation, sunk-cost schemes (false promises
to pay wages in the future), or threats to expose embarrassing conduct or imagery. Ultimately,
many victims of human trafficking do not leave their situation to get help because force, fraud, or
coercion and the associated fear compels them to remain in the exploitative situation.

Human trafficking is distinct from the separate crime of human smuggling, which is not covered
in this Action Plan. It is a misconception that human trafficking requires crossing a border.9 In
fact, it does not require movement at all. By contrast, human smugglers engage in the crime of
bringing people across international borders through deliberate evasion of immigration laws.10
While human trafficking and human smuggling are distinct crimes, individuals who are smuggled
are vulnerable to becoming victims of human trafficking. Understanding these distinct concepts
will support improved human trafficking prevention and victim identification efforts.

                                                            
6
 See Id. It should be noted that several states have adopted similar laws identifying minors to be victims of sex
trafficking without proving force, fraud, or coercion. 
7
 See The Typology of Modern Slavery: Defining Sex and Labor Trafficking in the United States (2017), available at
https://polarisproject.org/sites/default/files/Polaris-Typology-of-Modern-Slavery.pdf; Polaris, Growing Awareness.
Growing Impact. 2017 Statistics from the National Human Trafficking Hotline and BeFree Textline. (2017),
available at https://polarisproject.org/sites/default/files/2017NHTHStats%20%281%29.pdf ; and United States
Department of State Annual Trafficking in Persons Report, 2020, available at https://www.state.gov/wp-
content/uploads/2020/06/2020-TIP-Report-Complete-062420-FINAL.pdf.. 
8
 See List of Goods Produced by Child Labor or Forced Labor, United States Department of Labor, available at
https://www.dol.gov/agencies/ilab/reports/child-labor/list-of-goods; see also United States Customs and Border
Protection, Withhold Release Orders and Findings, available at https://www.cbp.gov/trade/programs-
administration/forced-labor/withhold-release-orders-and-findings.  
9
 See https://www.dhs.gov/blue-campaign/myths-and-misconceptions#.
10
See, e.g., 8 U.S.C. § 1324. 
 
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Characteristics of Human Trafficking

Who is victimized? Human trafficking victims can be of any age, race, ethnicity, sex, gender
identity, sexual orientation, nationality, immigration status, cultural background, religion,
socio-economic class, and education attainment level. Individuals particularly vulnerable to
human trafficking in the United States include children in the child welfare system or who have
encountered the juvenile justice system; runaway and homeless youth11; unaccompanied alien
children; foreign nationals who do not have lawful United States immigration status; American
Indians, Alaska Natives, Native Hawaiians, Pacific Islanders, and other indigenous peoples of
North America; Lesbian, Gay, Bisexual, Transgender, and other gender or sexuality-related
identities, such as intersex (LGBT+) individuals; foreign national laborers; persons with
disabilities; and individuals experiencing problematic drug use. While girls, women, and LGBT+
community members are notably more vulnerable, sex and labor traffickers also regularly target
boys and men. There are other factors that correlate with a higher risk of human trafficking
victimization, such as recent migration or relocation, substance misuse, unstable housing, abuse,
childhood trauma, and mental health issues.12

Human trafficking victims in the United States may be United States citizens or foreign nationals
who have lawful immigration status or who are unlawfully present; in some cases, a foreign
national’s unlawful presence is the primary driver of his or her manipulation and victimization by
traffickers. One of the biggest challenges facing law enforcement and service provider
professionals, due to multiple factors, is the ability to accurately identify human trafficking
victims. Nevertheless, information from these sources may still provide some insight into the
scope of the crime. A 2019 Non-Governmental Organization (NGO) study found that about
72 percent of calls to the National Human Trafficking Hotline related to sex trafficking, 11 percent
related to labor trafficking, 4 percent were both, and 13 percent were unspecified.13 According to
a 2019 Federal Bureau of Investigation (FBI) study based on data derived from its investigations
in the United States over a 3-year period (2015-2017), 80 percent of human trafficking victims
were victims of sex trafficking, 19 percent were victims of labor trafficking, and 1 percent involved
both sex and labor trafficking.14 The FBI study also found that 43 percent of victims recruited for
labor trafficking were foreign nationals residing outside the United States.15 In FY 2018, the

                                                            
11
 In this Action Plan, the term “youth” refers to older children and young adults. 
12
See Polaris, 2019 Data Report: The U.S. National Human Trafficking Hotline (2019), available at
https://polarisproject.org/wp-content/uploads/2019/09/Polaris-2019-US-National-Human-Trafficking-Hotline-Data-
Report.pdf.
13
See Polaris, 2019 Data Report: The U.S. National Human Trafficking Hotline (2019), available at
https://polarisproject.org/wp-content/uploads/2019/09/Polaris-2019-US-National-Human-Trafficking-Hotline-Data-
Report.pdf.
14
“Human Traffickers Almost Certainly Engage in Sex Trafficking as Most Prevalent Form of Human Trafficking,
Threatening Economic and Social Interests,” 8 February 2019, Federal Bureau of Investigation Intelligence Study.
The FBI study used data derived from a 3-year analysis of 309 investigations during the 2015-2017 timespan.
15
These FBI data comport with a recent ILO report finding that traffickers typically exploit 77 percent of victims in
their countries of residence. See Global Estimates of Modern Slavery, Alliance 8.7, available at
https://www.ilo.org/wcmsp5/groups/public/---dgreports/---dcomm/documents/publication/wcms_575479.pdf.
Similarly, according to a 2018 study by the United Nations Office of Drugs and Crime (UNODC), evidence shows
that for the first time ever, a majority of victims had been identified in their countries of citizenship. See Global

 
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United States Department of Health and Human Services (HHS) certified16 412 foreign national
adult victims of human trafficking, of which 69 percent experienced labor trafficking, 22 percent
experienced sex trafficking, 8 percent experienced sex and labor trafficking, and 1 percent were
unknown. Similarly, HHS certified 466 foreign national child victims of human trafficking, of
which 67 percent experienced labor trafficking, 27 percent experienced sex trafficking; and
6 percent experienced sex and labor trafficking.17 Historically, labor trafficking has been more
difficult to detect than sex trafficking.
 
In 2019, victims in the United States originated from almost every region of the world. The top
three countries of origin of federally identified victims were the United States, Mexico, and
Honduras. Both United States citizens and foreign nationals in the United States are exploited.
Also, victims from the United States are trafficked abroad, and foreign victims of child sex
trafficking are exploited by United States citizens in foreign countries or over the internet.18

Who are the human traffickers? Human traffickers come from a wide variety of backgrounds
and demographic categories. Human traffickers can be relatives, friends, individuals who are
politically connected in their country of origin, individuals operating alone, or those in loosely
affiliated groups or as part of gangs or transnational criminal organizations. Many times,
prosecutors obtain convictions of human traffickers and their associates for crimes other than
human trafficking, such as money laundering or fraud. Human trafficking networks may be linked
to other criminal activities, such as kidnapping, extortion, racketeering, foreign corrupt practices,
production of counterfeit goods, prostitution, drug trafficking, money laundering, document fraud,
visa fraud, immigration-related crimes, and public corruption.

More generally, human traffickers often operate a range of illicit enterprises both in the
United States and abroad. For example:

 Transnational criminal organizations engage in human trafficking, frequently in

conjunction with other criminal activities.
o The Zhao Wei drug trafficking organization engages in human trafficking to generate
funds to further its other criminal activities.19
o MS-13 engages in human trafficking both domestically and transnationally.20
                                                            
Report on Trafficking in Persons, 2018, United Nations, available at https://www.unodc.org/documents/data-and-
analysis/glotip/2018/GLOTiP_2018_BOOK_web_small.pdf.
16
 HHS certification enables foreign nationals who are human trafficking victims to be eligible to apply for Federal
and state benefits and services under certain circumstances. United States Department of State Annual Trafficking
in Persons Report, 2019, available at https://www.state.gov/reports/2019-trafficking-in-persons-report/, page 486-
87. 
17
 United States Department of State Annual Trafficking in Persons Report, 2019, available at
https://www.state.gov/reports/2019-trafficking-in-persons-report/, page 487. 
18
 United States Department of State Annual Trafficking in Persons Report, 2020, available at
https://www.state.gov/wp-content/uploads/2020/06/2020-TIP-Report-Complete-062420-FINAL.pdf.
19
United States Department of the Treasury Press Release, Treasury Sanctions the Zhao Wei Transnational
Criminal Organization, January 30, 2018, available at https://home.treasury.gov/news/press-releases/sm0272.
20
 MS-13 and Sex Trafficking, February 22, 2018, available at https://cis.org/Arthur/ms-13-and-sex-and-trafficking;
“The Nature and Extent of Gang Involvement in Sex Trafficking in San Diego County,” United States Department
of Justice Document No.: 249857, Date: April 2016. 

 
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o Mexican origin transnational criminal organizations engage in sex trafficking to

facilitate other illicit activity.21
 Terrorist organizations – including Islamic State in Iraq and Syria, Boko Haram and
Al-Shabaab22 – engage in human trafficking crimes.
 State actors such as Democratic People’s Republic of Korea, the People’s Republic of
China, and Cuba engage in state-sponsored forced labor.23

How do the human traffickers operate? To control their victims, human traffickers may use
tactics and techniques such as physically isolating their victim, emotionally manipulating a victim
through false promises of love, threatening a victim with various forms of harm, including harm
from the legal system, such as deportation or arrest, and manipulating a victim’s substance misuse.
Human traffickers also engage in debt bondage. Prospective victims are often led to take on debt,
ostensibly to support the costs of accessing a “good” job, via credible, but false, promises of a
better situation. Then, human traffickers and their co-conspirators ensure that the debts are
sufficient enough to place the victim in fear that if the debt is not paid, the victim or victim’s family
will suffer serious consequences threatening their life, health, and welfare. Human traffickers use
diverse modes of transportation to facilitate their illicit activities. Human traffickers also utilize
technology to facilitate the crime, such as online social media platforms to recruit and advertise
human trafficking victims. Law enforcement continues to make strides in interdicting illicit online
activity including the seizure of online platforms that advertise commercial sex involving human
trafficking. These seizures severely disrupt traffickers’ operations and those facilitating the illegal
activity. However, law enforcement must remain vigilant to the adjustments traffickers make to
avoid detection, including the movement of internet servers overseas. Some emergent
technologies, like anonymous browsing, also allow human traffickers to evade law enforcement.
Certain environments are more likely to enable human traffickers to conduct and profit from their
criminal exploitation. Human traffickers take advantage of breakdowns in the rule of law and
weakened social support caused by conflict, natural disaster, and other crises to recruit victims.
Corrupt government officials also enable human traffickers; for example, officials may accept
bribes from labor brokers engaged in deceptive practices.24 These breakdowns are compounded
when governments are actively hostile to civil society, precluding partnerships with NGOs that
otherwise could reinforce counter-trafficking efforts. The weakness of government institutions
fuels not only impunity, but also the desperation of individuals eager to support their families and,
in some cases, simply to survive. Human traffickers exploit these needs in order to lure victims
with false promises of a better situation in the United States or elsewhere. For example, Mexico
is the top origin country in human trafficking cases involving foreign national victims in which
                                                            
21
The United States Department of State Office to Monitor and Combat Trafficking in Persons-funded study,
“Trafficking in Persons Along Mexico’s Eastern Migration Routes: The Role of Transnational Criminal
Organizations,” Woodrow Wilson International Center for Scholars, March 2017.
22
See the Financial Action Task Force (FATF) 2018 report, Financial Flows of Human Trafficking, July 2018,
available at http://www.fatf-gafi.org/media/fatf/content/images/Human-Trafficking-2018.pdf.
23
  United States Department of State Annual Trafficking in Persons Report, 2019, available at
https://www.state.gov/reports/2019-trafficking-in-persons-report/. United States Department of State Xinjiang
Supply Chain Business Advisory, 2020, available at https://www.state.gov/xinjiang-supply-chain-business-advisory/ 
24
See UNODC. 2011. Issue Paper: The Role of Corruption in Trafficking in Persons, available at
https://www.unodc.org and United States Department of State Annual Trafficking in Persons Reports, 2020,
available at https://www.state.gov/wp-content/uploads/2020/06/2020-TIP-Report-Complete-062420-FINAL.pdf.  

 
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the United States is the destination.25 Recent cases involved sex trafficking enterprises linked to
a region in central Mexico, which recruited young victims who were then smuggled into the
United States and compelled into prostitution in New York, Atlanta, and other cities.26

In cases where human traffickers have recruited individuals outside the United States with the
intent of exploiting them in the United States, they may be moved through intermediary or “transit”
countries, sometimes for extended periods, during which victims may also be forced into labor or
commercial sex. Transit countries are chosen for the geographical location and are usually
characterized by weak border controls, proximity to destination countries, corruption of
immigration officials, or affiliation with organized crime groups that are involved in human
trafficking and human smuggling.

Financial activity from human trafficking activities can intersect with the formal financial system
at any point during the recruitment, transportation, and exploitation stages. The illicit proceeds
from human trafficking can include income associated with logistics, such as housing and
transportation of victims, as well as earnings from the exploitation of victims. The movement of
human trafficking proceeds can constitute money laundering27 or, if designated terrorist
organizations are involved, terrorist financing.28 Money launderers and human traffickers exploit
the fact that companies can be found without beneficial ownership information. Human traffickers
establish front companies to hide the true nature of a business, its illicit activities and its owners
and associates. There are strong indicators of the use of anonymous companies for money
laundering and human trafficking. For example, in a recent NGO study, only 21 percent of the
6,000 business records found for illicit massage businesses name the owner, and even in those
cases, the information may not be legitimate.29 When insufficient controls are in place, human
traffickers benefit from ready access to financial systems to maintain their enterprises.

Complex supply chains impede traceability and make it challenging to verify that goods and
services are free of forced labor.30 Globally and in the United States, forced labor and associated
harmful employment practices hide the true cost of labor and subvert the legitimate job market,

                                                            
25
 See HHS, Trafficking Victims Assistance Program, FY 2019, available at
https://www.acf.hhs.gov/sites/default/files/otip/tvap_infographic_fy_2019_508.pdf.
26
See DOJ, “Eight Members of Mexican Sex Trafficking Enterprise Plead Guilty To Racketeering, Sex Trafficking,
And Related Crimes” (April 21, 2017), available at https://www.justice.gov/usao-edny/pr/eight-members-mexican-
sex-trafficking-enterprise-plead-guilty-racketeering-sex.
27
Money laundering in violation of 18 U.S.C. § 1956(a)(1) is the crime of knowingly conducting, or attempting to
conduct, a “financial transaction” with proceeds from “specified unlawful activity” (SUA). Sex trafficking, forced
labor, and other crimes related to trafficking in persons are considered SUAs. Other money laundering statutes
relevant to human trafficking investigations include international money laundering, 18 U.S.C. § 1956(a)(2); the
“spending statute,” 18 U.S.C. § 1957; structuring in violation of 31 U.S.C. § 5324; operating unlicensed money
transmitting businesses in violation of 18 U.S.C. § 1960; and conspiracy to violate either Section 1956 or Section
1957 (or both) in violation of 18 U.S.C. § 1956(h).
28
See “25 Keys to Unlock the Financial Chains of Human Trafficking & Modern Slavery.” July 2017 available at
http://collections.unu.edu/eserv/UNU:6232/BreakingtheFinancialChains_FullBooklet_Web.pdf.
29
 See “Human Trafficking in Illicit Massage Businesses,” Polaris Project, April 19, 2018, available at
https://polarisproject.org/news/press-releases/corporate-secrecy-fuels-human-trafficking-united-states 
30
See the Financial Action Task Force (FATF) 2018 report, Financial Flows of Human Trafficking, July 2018,
available at http://www.fatf-gafi.org/media/fatf/content/images/Human-Trafficking-2018.pdf.

 
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such as displacing American workers, driving down wages, and corrupting the domestic and global
economy. These practices create an uneven playing field for responsible businesses that invest in
measures to prevent forced labor in their product supply chains. 31 The United States Department
of Labor (DOL) has identified 155 goods from 77 countries that are produced with child labor
or forced labor globally, some of which are connected to products imported into the
United States.32 Meanwhile, human traffickers benefit most from complex and nontransparent
supply chains as well as permissive regulatory environments abroad.
 
Strengthening efforts to combat human trafficking
 
Despite the United States’ global leadership in the fight against human trafficking,33 its
comprehensive legal framework, rule of law, and the resources devoted to combating human
trafficking, the crime persists. Through this Action Plan, the United States Government seeks to
enhance the impact of its broad-based, multi-disciplinary, whole-of-government efforts to combat
human trafficking. This Action Plan sets the priority actions needed to improve capabilities and
build on existing momentum over the next 3 years.

Mission Statement

The United States Government will fully leverage its authorities and resources to eradicate
human trafficking by preventing it from occurring, supporting and empowering survivors,
prosecuting traffickers, coordinating the United States Government’s response, and
strengthening Federal anti-trafficking efforts through external partnerships.
 
Guiding Principles

This Action Plan was informed by:

 the Trafficking Victims Protection Act (TVPA) of 200034 as amended,

                                                            
31
See Verité. 2017. Strengthening Protections against Trafficking in Persons in Federal and Corporate Supply
Chains, available at http://www.verite.org; Responsible Sourcing Tool available at
https://www.responsiblesourcingtool.org/resources/complianceresources.
32
See List of Goods Produced by Child Labor or Forced Labor, United States Department of Labor, September
2020, available at https://www.dol.gov/agencies/ilab/reports/child-labor/list-of-goods. 
33
 In 2000, the Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children
(the Palermo Protocol), supplementing the United Nations Convention against Transnational Organized Crime
(UNTOC), marked an important transition into the modern movement against human trafficking. The United States
was a key drafter of the Protocol and adopted the United States Trafficking Victims Protection Act (TVPA) the
same year. In part through United States leadership, as of March 31, 2019, 173 parties had ratified the Palermo
Protocol and 168 countries had passed domestic legislation criminalizing human trafficking according to this
framework. See https://www.unodc.org/unodc/en/organized-crime/intro/UNTOC.html. 
34
See Pub. L. No. 106-386 (2000) and subsequent amendments. Major provisions of the TVPA are codified at 22
U.S.C. §§ 7101-7114 and 18 U.S.C. Chapter 77. For more information on this legislation see
https://www.state.gov/international-and-domestic-law/.

 
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 the 2000 Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially
Women and Children (the Palermo Protocol), supplementing the United Nations
Convention against Transnational Organized Crime (UNTOC),35

 the 2017 National Security Strategy,36

 Executive Order 13773, Presidential Order on Enforcing Law with Respect to

Transnational Criminal Organizations and Preventing International Trafficking,37

 Executive Order 13627, Strengthening Protections Against Trafficking in Persons in

Federal Contracts,38

 Executive Order 13126, Prohibition of Acquisition of Products Produced by Forced or

Indentured Child Labor,39

 Executive Order 13898, Establishing the Task Force on Missing and Murdered American
Indians and Alaska Natives,40

 Executive Order 13903, Combating Human Trafficking and Online Child Exploitation in
the United States,41 and

 the Executive Office of the President, Office of Management and Budget Memorandum on
Anti-Trafficking Risk Management Best Practices and Mitigation Considerations.42

Further, as outlined in the President’s Interagency Task Force (PITF) Report on United States
Government Efforts to Combat Trafficking in Persons in October 2019,43 the following strategic
objectives from that document inform this Action Plan:

 Investigate and prosecute traffickers and dismantle the criminal networks that perpetrate
trafficking in persons.

 Enhance victim identification and the provision of relief and services for all victims of
trafficking.

                                                            
35
See https://www.ohchr.org/en/professionalinterest/pages/protocoltraffickinginpersons.aspx.
36
https://www.whitehouse.gov/wp-content/uploads/2017/12/NSS-Final-12-18-2017-0905.pdf.
37
See https://www.Federalregister.gov/documents/2017/02/14/2017-03113/enforcing-Federal-law-with-respect-to-
transnational-criminal-organizations-and-preventing.
38
See https://obamawhitehouse.archives.gov/the-press-office/2012/09/25/executive-order-strengthening-protections-
against-trafficking-persons-fe.
39
See https://www.govinfo.gov/content/pkg/WCPD-1999-06-21/pdf/WCPD-1999-06-21-Pg1105.pdf.
40
 See https://www.govinfo.gov/content/pkg/FR-2019-12-02/pdf/2019-26178.pdf. 
41
See https://www.govinfo.gov/content/pkg/FR-2020-02-05/pdf/2020-02438.pdf. 
42
See https://www.whitehouse.gov/wp-content/uploads/2019/10/M-20-01.pdf. 
43
See https://www.state.gov/2019-report-on-u-s-government-efforts-to-combat-trafficking-in-persons. 
 
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 Enhance training of stakeholders, including civil society, law enforcement entities, and
government officials, to increase identification of victims.

 Encourage foreign governments to combat trafficking through international diplomacy and

engagement.

 Forge and strengthen partnerships and other forms of collaboration to combat trafficking
in persons.

 Fund domestic and international anti-trafficking programs focusing on prosecution,

protection, and prevention.

 Integrate anti-trafficking components into relevant government programs.

 Promote public awareness about modern slavery.

 Spur innovation and improve capacity to combat modern slavery through data collection
and research.

 Gather and synthesize actionable intelligence to increase the number of domestic and
international trafficking prosecutions.

In addition to the strategic objectives from the PITF Report, this Action Plan will:

 Leverage financial authorities to identify human traffickers and their networks.

 Prevent their access to the United States and international financial system.

 Disrupt and disable the financial underpinnings of these networks.

 Prevent illegal immigration and enhance border security to reduce the number of people
vulnerable to human trafficking in the United States as well as the entrance of human
traffickers.

 Support law enforcement investigations that lead to accountability and justice.

 
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★ ★ ★ 
P ILLAR 1: P REVENTION
Prevent Human Trafficking
 
The United States Government remains committed to strengthening its approach to preventing human
trafficking. While all anti-trafficking efforts contribute to the vision of eradicating human trafficking,
prevention is fundamental to achieving this desired end state. Government and external stakeholders
face key challenges to preventing human trafficking, including a lack of information about highest risk
populations, environments, and circumstances; the difficulty in connecting to the most vulnerable
populations; and insufficient understanding and access to scientifically-rigorous data analysis and
program evaluation that could better inform which strategies are most effective. Strategic intervention
programs can be developed so that governments offer appropriate support to allow communities and
individuals to reduce their vulnerability through mitigating identified risk factors. Prevention efforts
are wide-ranging, from the targeted education of vulnerable populations to demand reduction efforts
to prohibiting goods produced with forced labor from entering United States markets. The
dissemination of targeted information helps communities and individuals understand how to reduce
human trafficking risks. Meaningful engagement with the private sector and civil society expands
awareness and leads to creative solutions informed by diverse expertise.

This goal presents 16 priority actions organized under six principles related to enhancing outreach and
education; strengthening efforts to address demand; addressing human trafficking in product supply
chains; building capacity to prohibit the importation of goods produced with forced labor; reduce the
number of people at risk of human trafficking due to unlawful presence through improved border
security and immigration enforcement; and improving aspects of nonimmigrant visa programs that
may facilitate exploitation of visa holders.

Priority Actions
Principle 1.1: Enhance outreach and education efforts to prevent human
trafficking
 
Communities benefit from knowing the threat they could be facing and what actions they could
take to prevent crime from occurring. Targeted information helps increase the public’s
understanding of the risks and vulnerabilities to human trafficking, including human traffickers’
deceptive and exploitive recruitment strategies. With this information, communities and
individuals are able to counteract human traffickers’ tactics and techniques, and reduce
vulnerabilities. In many cases, public outreach campaigns aim for prevention and protection where
 
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protection outreach may seek to identify victims and refer them to help. For priority actions related
to protection, see the Protection and Crosscutting Pillars of this Action Plan.

Priority Action 1.1.1: Enhance community-coordinated responses to human

trafficking  

The United States Department of Justice (DOJ) provides training on preventing and responding to
human trafficking to schools, law enforcement, courts, court systems, community programs,
medical providers, LGBT+ programs, foster care, and drop-in/homeless shelters. Additional grant
projects focus their intervention efforts on mentoring youth who are at risk for or are victims of
sex trafficking and sharing strategies focused on raising awareness of the crime in local
communities. DOJ will develop and disseminate training modules and tools to assist communities
in their efforts to respond to human trafficking. DOJ will fund, subject to the availability of
appropriations, the development of a toolkit to assist communities in creating
community-coordinated responses to human trafficking as well as referral networks.

HHS’s Office on Trafficking in Persons (OTIP), Children’s Bureau (CB), and Family and Youth
Services Bureau (FYSB) also provide community-coordinated responses to human trafficking of
youth through grants, programs, training, resources, and partnerships. HHS programs will provide
training and technical assistance for health and human service professionals working with
populations at high risk for human trafficking who are intersecting with health care systems, child
welfare, runaway and homeless, domestic violence, adolescent pregnancy prevention,
unaccompanied children, and community programs for American Indians, Alaska Natives, Native
Hawaiians, Pacific Islanders, and other indigenous peoples of North America.
 
Priority Action 1.1.2: Examine and recommend culturally appropriate prevention
efforts for American Indian, Alaska Native, Native Hawaiian, and Pacific Islander
youth
 
In partnership with HHS’s Administration for Native Americans, HHS OTIP convened an
American Indian, Alaska Native, Native Hawaiian, and Pacific Islander-specific class of the
Human Trafficking Leadership Academy in which 12 fellows, comprised of survivor leaders and
allied professionals, attended monthly leadership development seminars over a 6-month period.
The fellows developed recommendations to inform new research, policies, and programs on how
culture can be a protective factor for preventing human trafficking among youth who are American
Indian, Alaska Native, Native Hawaiian, or Pacific Islander in the United States and its territories. 
 
Priority Action 1.1.3: Implement the HHS Administration for Children and Families
National Human Trafficking Prevention Action Plan

HHS’s Administration for Children and Families (ACF) will release and implement the ACF
National Human Trafficking Prevention Action Plan, outlining a framework for action and agency
collaborations to increase the scale and quality of human trafficking prevention efforts across the
United States. Utilizing a collective impact strategy grounded in HHS’s principles of violence

 
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prevention, ACF will coordinate with government, non-government, and private sector partners to
reduce human trafficking in the United States.
 
Priority Action 1.1.4: Create a training for children in United States Department of
Defense Education Activity

The United States Department of Defense’s (DOD) Education Activity is responsible for planning,
directing, coordinating, and managing pre-kindergarten through 12th grade educational programs
for 163 schools. There are 996,069 military-connected children of all ages worldwide, of which
more than 70,000 are enrolled in DOD schools and served by approximately 8,700 educators. The
Combating Trafficking in Persons Program Management Office, in consultation with experts on
prevention programming for children, will work with the DOD Education Activity to raise
awareness of human trafficking and train students about understanding the risks of human
trafficking. DOD Education Activity will make the training available to parents as well.
 
Principle 1.2: Strengthen efforts to address demand reduction
Certain initiatives to reduce demand may be more effective than others in reducing instances of
human trafficking, including forced labor. Cultivating a better understanding of demand reduction
efforts will lead to more informed, evidence-based policymaking. 

Priority Action 1.2.1: Examine existing initiatives to reduce demand and encourage
research and evaluation of future initiatives 

The Frederick Douglass Trafficking Victims Prevention and Protection Reauthorization Act of
201844 recognized the need for increased efforts to address demand. However, there is limited
information on the range of initiatives intended to reduce demand, including law enforcement
initiatives specifically, and their effectiveness.

The Senior Policy Operating Group (SPOG) recently formed a Demand Reduction Working Group
to examine the role of demand reduction in preventing human trafficking or otherwise achieving
the purposes of the TVPA and the Justice for Victims of Trafficking Act. NJI/DOJ, in coordination
with the SPOG, will conduct a literature review regarding demand, subject to the availability of
funding, and provide recommendations to Federal agencies on initiatives that are likely to prevent
sex trafficking.

Principle 1.3: Strengthen efforts to identify, prevent, and address human

trafficking in product supply chains 
Governments, the private sector, and individuals can all make a difference when it comes to
addressing human trafficking in product supply chains. Each occupies a unique position to
leverage economic power to influence existing markets, and create new ones, where workers can
enjoy decent work and human dignity, and are free from coercion and the exploitation associated

                                                            
44
 See Pub. L. No. 115-425 (2019). 
 
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with human trafficking. The United States has a standing policy prohibiting government
employees, contractors, subcontractors, grantees, and sub grantees from engaging in trafficking in
persons. This policy was strengthened in the National Defense Authorization Act for Fiscal
Year 2013 “Title XVII Ending Trafficking in Government Contracting”45 and implemented in
2015 when the Federal Acquisition Regulation rule, entitled “Ending Trafficking in Persons,”46
implemented trafficking-related prohibitions for Federal contractors and subcontractors.  

Priority Action 1.3.1: Require select agencies to designate a senior accountable

official to ensure effective implementation of anti-trafficking acquisition rules and
best practices
 
Agencies with significant spend and/or heightened risk of human trafficking in government
contracts – including DOD, United States Department of State (DOS), United States Department
of Homeland Security (DHS), and United States Agency for International Development (USAID),
or other agencies as identified by Office of Management and Budget (OMB) – will designate the
Assistant Secretary for Management or equivalent to ensure effective coordination between the
procurement trafficking in persons point of contact and the agency trafficking in persons expert
outlined in the Anti-Trafficking Risk Management Best Practices & Mitigation Considerations
Memorandum.47 Not less than annually, the Chief Acquisition Officers should support a public
outreach session hosted by the SPOG Procurement and Supply Chains Committee for contracting
companies, NGOs, international partners, and associations of state, local, tribal and territorial
officials, to build understanding and awareness about the anti-trafficking requirements of the
Federal Acquisition Regulation.
 
Priority Action 1.3.2: Develop initiatives for engaging with various industries on
the issue of forced labor in product supply chains  

DOS, DOL, DHS, HHS, Department of Commerce’s International Trade Administration (ITA),
United States Department of the Treasury (Treasury), DOD, and USAID will work collectively to
develop initiatives to provide information about forced labor in product supply chains and
highlight existing Federal resources (e.g., the Comply Chain application, Responsible Sourcing
Tool, DOS’s Trafficking in Persons Report, and DOL’s List of Goods Produced by Child Labor
or Forced Labor) to key private sector partners. These initiatives would involve proactive outreach
to convene industry leaders and include presentations and webinars. Facilitated discussions will
include both general information sessions and deeper discussions to address specific challenges
and opportunities in the various industries.

Priority Action 1.3.3: Identify DOD contractors’ promising hiring practices and
expand outreach to inform workers of their rights under United States law 

DOD’s Combating Trafficking in Persons Program Management Office will engage contracting
authorities and debarment and suspension officials to identify promising practices on hiring,
                                                            
45
 See Pub. L. No. 112-239 (2013). 
46
 See Federal Acquisition Regulation Clause 55.222.-18,-19, and -50.  
47
See https://www.whitehouse.gov/wp-content/uploads/2019/10/M-20-01.pdf
 
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including the use of recruitment services. DOD will then share promising practices throughout
the Federal contracting community that aim to decrease the risk of labor trafficking. DOD will
also assess expanding the number of foreign languages in which its DOD Worker’s Rights cards
are available, which inform other country nationals working on DOD installations, and recruited
by contractors, of their rights under United States law.  

Principle 1.4: Build capacity to prohibit goods produced with forced labor
from entering United States markets

International trade frequently involves markets with extensive product supply chains. Trade
enforcement practices require constant modernization to prevent products produced with forced
labor from entering the United States. DHS enforces the customs law that prohibits the importation
of goods mined, produced, or manufactured, wholly or in part, with forced labor, including forced
child labor.

Priority Action 1.4.1: Publish accessible information on the Withhold Release

Order and Findings Process  

To help companies, foreign governments, and NGOs support or comply with the prohibition on
the importation of goods produced with forced labor, including any civil enforcement actions taken
against goods produced with forced labor, DHS’s United States Customs and Border Protection
(CBP) will publish an accessible explanation of its Withhold Release Order and Findings process,
such as a pamphlet on its website. CBP will link to other sources of information supporting due
diligence to remove goods produced with forced labor from its product supply chains, such as
information provided by DOL and DOS.

Priority Action 1.4.2: Seek to negotiate a provision in future trade agreements

whereby the parties commit to prohibit the importation of goods produced with
forced labor  

The Office of the United States Trade Representative (USTR) is responsible for trade policy and
negotiations with other countries. To prevent human trafficking, USTR coordinates closely with
other United States Government agencies, including DOS, DHS, ITA, and DOL, to ensure that
trade policy reflects United States anti-trafficking strategy and priorities. For example, as part of
the United States-Mexico-Canada Agreement, USTR negotiated ground-breaking commitments
that prohibit the importation of goods produced in whole or in part with forced or compulsory
labor. USTR will seek to negotiate similar provisions in future trade agreements with other
partners.

Principle 1.5: Reduce the number of people vulnerable to trafficking through

improved border security and immigration enforcement  
The number of foreign nationals in the United States without lawful immigration status is
unknown, but most estimates place it in the millions, and more enter the United States unlawfully

 
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every year. Although United States citizens and lawful immigrants are also at risk of victimization
by traffickers, traffickers can exploit a person's lack of lawful immigration status. Consistent with
the Administration’s focus on strengthening national security, one long-term strategy for reducing
the extent of, and harm from, human trafficking in the United States is preventing illegal
immigration and improving border security and enforcement of all Federal immigration laws.
Although smuggling and trafficking are distinct threats, reducing illegal entries into the
United States will decrease the number of foreign nationals who are susceptible to trafficking due
to their unauthorized status.

Priority Action 1.5.1: Continue and expand messaging campaigns to deter illegal
immigration 

DOS and DHS will conduct extensive messaging efforts to reach foreign nationals intending to
come to the United States and through diaspora communities in the United States. By providing
accurate information to foreign nationals about United States immigration enforcement, including
testimonials from foreign nationals who were removed from the United States, and from those who
were victimized once in the United States following their lawful entry, these messaging efforts
may deter illegal immigration into the United States, reducing the number of unauthorized foreign
nationals at risk of trafficking within United States borders due to their unlawful status.

Priority Action 1.5.2: Continue and expand efforts to secure United States borders
and improve immigration enforcement   
 
DHS, DOS, DOJ and other Federal agencies will continue their work to secure the United States
border and improve enforcement of immigration laws as directed in Executive Order 13767 on
Border Security and Immigration Enforcement Improvements, Executive Order 13768 on
Enhancing Public Safety in the Interior of the United States, and other relevant Presidential
directives. Securing the United States borders and taking measures to detect potential signs of
trafficking not only helps deny access to transnational criminal organizations, which often
facilitate human trafficking, but it also ensures that Federal law enforcement has full visibility of
entering populations and potential signs of trafficking. Federal, state and local law enforcement
collaboration with Federal and state labor inspection authorities will protect the integrity of
United States labor markets and increase economic opportunity for United States workers and
lawfully present foreign national workers. This collaboration will also increase opportunities to
detect and investigate labor trafficking by affording unauthorized foreign workers opportunities to
report labor trafficking violations and cooperate as witnesses in human trafficking investigations.

Principle 1.6: Address aspects of nonimmigrant visa programs that may

facilitate exploitation of visa holders  

Each year, hundreds of thousands of people enter the United States on temporary nonimmigrant
worker visas. Programmatic challenges can potentially increase an individual’s vulnerability to
being targeted by a trafficker. Ongoing reports from workers and advocates highlight the urgent
need to examine the ways in which current nonimmigrant visa programs could inadvertently
facilitate the exploitation of workers and exchange visitors.
 
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Priority Action 1.6.1: Monitor and support implementation of bilateral agreements

with key countries concerning United States temporary worker programs and
expand to additional countries  

The United States has signed bilateral agreements with El Salvador, Honduras, and Guatemala that
provide safeguards for temporary workers in the H-2 nonimmigrant visa programs. These
agreements aim to ensure H-2 nonimmigrant workers are less susceptible to criminal or
unscrupulous actors and are not charged prohibited recruitment and other fees to take part in the
nonimmigrant visa programs. The agreements will require the foreign governments to establish a
process for the regular application, bonding, and approval or renewal of registration for foreign
labor recruiters and prohibit such recruiters from subjecting H-2 visa program workers to any form
of human trafficking or forced, compulsory, bonded, indentured, or prison labor.
 
Separately, the United States Government will encourage United States companies to proactively
engage with recruiters they employ either directly or indirectly and verify recruiters and any
downstream agents, facilitators or similar employment services comply with applicable laws and
regulations, particularly rules surrounding the prohibition on worker-paid fees. In addition to
increasing engagement with employers and recruiters, agencies will continually emphasize the
information contained in the “Know Your Rights” pamphlet.  
 
Agencies will consider pursuing agreements with other countries who use the H-2 nonimmigrant
visa programs to better protect workers participating in these programs from abuse at home and in
the United States while working. 
 
Priority Action 1.6.2: Review current protections for workers across
employment-based nonimmigrant visa programs to identify gaps and inconsistencies
and propose recommendations  

Visa requirements and worker protections regarding recruitment or conditions of continued

employment vary by visa category. Many foreign temporary worker visa categories regulate the
process for recruiting workers, such as by prohibiting worker-paid recruitment fees and fees
imposed as a condition of employment and providing workers with written contracts in a language
they understand. Not all employment-based nonimmigrant visa categories include these
protections or require the employer to provide these protections. The SPOG will establish an
interagency working group to analyze and compare the rights and protections granted to workers
of each employment-based nonimmigrant visa category to identify which categories require
additional protections related to the labor recruitment and treatment of workers. The agencies will
then discuss ways to address any gaps and inconsistencies, including developing and proposing
necessary regulatory or legislative changes.

Priority Action 1.6.3: Identify enhancements to existing procedures through which

nonimmigrant workers may leave potentially exploitative situations to prevent
human trafficking  

 
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Workers sometimes find themselves in abusive work situations, but because their immigration
status is dependent on continued employment with the employer in whose name the visa has been
issued, workers may be left with few options to leave that situation. In many cases, workers believe
they must either endure the abuse or return home, and are not aware of other options. Under certain
visa programs based on employer petitions, such as the H-2 temporary worker programs, workers
are able to change employers while remaining in the United States but only if a new prospective
employer files another petition, a process that contributes to fewer workers changing employers.
DHS, DOL, and DOS will review existing procedures to identify what improvements can be
incorporated so that temporary foreign workers may leave potentially exploitative situations while
retaining their employment flexibility. If no improvements can be identified, agencies will
recommend statutory changes to Congress.

Priority Action 1.6.4: Increase general awareness of human trafficking among all
Exchange Visitor Program stakeholders

The DOS Exchange Visitor Program includes 15 different exchange categories. The Exchange
Visitor Program will expand its outreach to enhance awareness of human trafficking indicators
and potential risk factors among program stakeholders, including exchange visitors, sponsors, third
parties, and Exchange Visitor Program staff. The Exchange Visitor Program will partner with
agencies to identify human trafficking awareness materials and resources.

 
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★ ★ ★ 
P ILLAR 2: P ROTECTION
Identify, Assist, and Protect the Victims of Human Trafficking
The United States Government remains committed to offering a diversity of interventions,
services, and support to protect and help victims of human trafficking. Protection starts with robust
outreach and proactive identification efforts. Identifying victims of human trafficking can be
challenging, making it difficult to provide necessary protections and assist in rebuilding their lives.
It is incumbent on everyone encountering and working with possible victims to identify the
indicators of human trafficking, offer a protective response, and seek appropriate help. All actors
must work to build trust with victims. Protection of victims continues through providing
comprehensive services, including crisis intervention, medical and mental health care, substance
use disorder treatment, housing, basic needs, employment services, job training, education, legal
services, financial services support, English language learning and translation services, cultural
and religious support, and transportation assistance.

For foreign national victims, temporary immigration protections also exist, including Continued
Presence,48 T nonimmigrant status (“T visa”),49 and U nonimmigrant status (“U visa”).50 Victims
who receive comprehensive services are more likely to achieve safety, autonomy, healing, and
economic security. Consistent application of victim-centered, trauma-informed strategies enables
victims to safely come forward, report to law enforcement, and participate as witnesses in law
enforcement investigations and prosecutions. While human trafficking victim protections have
been in place for nearly 20 years, the effort to improve identification of more victims, increase
access to services to support more survivors, and refine the victim-centered approach is continually
underway and reflected in this Action Plan.

This goal presents 18 priority actions organized under six principles related to applying a victim-
centered approach to engaging with victims; safeguarding victims from inappropriate penalization;
improving access to immigration benefits and options; expanding and improving victim assistance
associated with Federal law enforcement; seeking financial remedies for victims; and offering or
connecting victims to social services.

                                                            
48
 See 22 U.S.C. § 7105(c)(3)(A)(i). 
49
 See 8 U.S.C. § 1101(a)(15)(T); 8 U.S.C. § 1184; 8 U.S.C. § 1255; 8 CFR § 214.11. 
50
 See 8 U.S.C. § 1101(a)(15)(U); 8 U.S.C. § 1184; 8 U.S.C. § 1255; 8 CFR § 214.14. 
 
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Priority Actions
Principle 2.1: Identify and engage with victims in a victim-centered,
trauma-informed, and culturally competent manner
The wide variety of professionals likely to encounter human trafficking victims should be familiar
with indicators of human trafficking, so these professionals can identify victims and refer them for
appropriate services. Professionals conducting such screening should determine if there is a
reasonable suspicion that human trafficking has occurred and should only request further details
when necessary. Professionals should immediately refer cases to service providers or investigative
agencies or both, as appropriate. The principles of a victim-centered, trauma-informed, and
culturally competent approach51 apply to professionals conducting screening as well as service
providers and investigators engaging with a potential human trafficking victim. As part of the
victim-centered approach, law enforcement’s drive for criminal justice should be appropriately
balanced with identifying victims, protecting them from harm, and supporting them through
comprehensive services.
 
Priority Action 2.1.1: Develop or update, validate, and implement screening forms
and protocols

The SPOG will convene an interagency52 working group to develop or update screening forms and
protocols as relevant for all Federal officials who have the potential to encounter a human
trafficking victim in the course of their regular duties that do not otherwise pertain to human
trafficking. Within a year, and subject to the availability of appropriations, each Federal agency
will have updated all forms and protocols unless these forms and protocols were recently updated
or the funding or validation required to complete this action would unduly impact the agency’s
operations. Recently enacted provisions of law direct DHS53 and DOJ54 to issue a victim screening
protocol for use in all Federal operations targeting human trafficking. Subject to the availability
of funding, this working group will also develop timelines and plans to validate the screening tools
in an effort to accurately identify all forms of human trafficking.
Immigration enforcement authorities will continue to improve their screening of all adults and
minors who pass through immigration custody or detention for indicators of human trafficking,
while implementing special screening protocols for minors. Minors suspected of having
experienced human trafficking will be referred to HHS within 24 hours, as required by law, for
                                                            
51
See Appendix A: Glossary of Terms for further explanation of these approaches.
52
 Participating agencies should include FBI, Homeland Security Investigations (HSI), CBP, United States
Immigration and Customs Enforcement (ICE), Enforcement and Removal Operations (ERO), United States Coast
Guard (U.S.C.G.), Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF), United States Postal Service
(USPS), DOJ, Offices of the United States Attorneys (USAOs), Transportation Security Administration (TSA),
Federal Emergency Management Agency (FEMA), Federal Bureau of Prisons (BOP), Drug Enforcement
Administration (DEA), HHS, DOS, USAID, USCIS, Wage and Hour Division (WHD), Occupational Safety and
Health Administration (OSHA), Equal Employment Opportunity Commission (EEOC), United States Marshals
Service (USMS), United States Department of Agriculture (USDA), Food and Drug Administration (FDA), Bureau
of Indian Affairs (BIA), and National Oceanic and Atmospheric Administration (NOAA). 
53
 Pub. Law No. 115-392, Section 5. 
54
 Pub. Law No. 115-393, Section 502. 

 
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further assessment, referral to social services, and determination of eligibility for benefits and
services.55
 
Children and youth in the child welfare and juvenile justice systems, or who are receiving services
as runaway and homeless youth, at-risk youth, youth in households experiencing domestic
violence, and child abuse victims are particularly vulnerable to human trafficking. The Federal
Government will aim to enhance the capacity of state child welfare agencies, court and legal
professionals, and systems for runaway and homeless youth to perform better assessments and
improve use of screening forms and protocols to screen minors and young adults for indicators of
human trafficking. All unaccompanied alien children will periodically be screened for human
trafficking, and HHS will ensure that they are not placed in situations where they are vulnerable
to trafficking. The intake assessment for sponsors of unaccompanied alien children will be updated
appropriately within 1 year. HHS will enhance training on identification and prevention of human
trafficking for grantees and staff that serve unaccompanied alien children and ensure that regular
welfare checks are conducted with unaccompanied alien children in Federal long-term foster care
placement.
 
Priority Action 2.1.2: Establish protocols and incorporate promising practices
regarding victim interviews for law enforcement
 
Evidence-based policymaking is more likely to lead to desired outcomes such as improved
identification of victims. When engaging with potential victims of human trafficking, Federal
officials should adopt a victim-centered, trauma-informed approach, which includes cultural
competence. Extra care is required when encountering minor victims.
 
DOJ’s National Institute of Justice (NIJ) will conduct a literature review within 3 years to collect
promising practices of law enforcement conducting victim interviews, including known victim-
centered practices around selecting the interview location, working with interpreters, putting
victims at ease, crafting interview questions, and recognizing trauma cues. Within a year of
completion of the literature review, Federal law enforcement agencies will convene to share and
standardize draft guidance that all participating investigatory agencies will implement.
 
The experience of human trafficking victims varies from person to person. Some victims of human
trafficking may initially be willing participants in a human smuggling scheme. DHS will provide
internal guidance regarding the distinction between human trafficking and human smuggling, the
possible circumstances where human smuggling may evolve into human trafficking, and, in such
cases, the recognition of smuggled individuals as victims of human trafficking.
 

                                                            
55
 See 22 U.S.C. § 7105b. 
 
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Priority Action 2.1.3: Regularly train Federal law enforcement and service provider
agencies on identifying human trafficking
 
The Federal Government conducts a significant amount of human trafficking training. Each
Federal department or agency represented on the SPOG will notify the National Security Council
staff within 3 months of the promulgation of this Action Plan:
 Which categories of personnel are likely to encounter victims of human trafficking in the
course of their duties;
 Of these categories of personnel, which should receive annual training. This training should
begin occurring within one year of the promulgation of this Action Plan; and
 What, if any, existing training could be enhanced to fulfill this priority action.  

Federal prison personnel will be trained on identifying human trafficking and traffickers’
recruitment efforts. All immigration officers will be trained on identifying human trafficking in
connection with visa applications and interviews. DOD will update its training for new civilian
and military hires as well as investigative and acquisition personnel on protocols for reporting
incidents of suspected human trafficking. All security personnel at military bases will be trained
in identifying indicators of human trafficking. DOS consular officers will be trained biennially on
identifying human trafficking and response protocols. HHS will develop training on indicators of
human trafficking available to relevant Federal, state, tribal, and territorial human service
professionals, such as social security, unemployment, and Medicaid program professionals. HHS
will update its training on identifying indicators of human trafficking and responding for Federal
child welfare officials working with the unaccompanied alien children program. Additionally,
HHS programs serving runaway and homeless youth, youth at-risk, and domestic violence
programs will receive an updated training on human trafficking indicators and screening processes.
 
Each Federal department or agency represented on the SPOG will ensure training and awareness
materials are tailored to context where possible and culturally relevant. For example, training and
awareness materials intended for tribal communities will be tailored to the type of human
trafficking present on tribal lands. The subjects in this training and awareness materials should
include American Indians, Alaska Natives, Native Hawaiians, and Pacific Islanders; and the
development of these training and materials will involve significant consultation with American
Indian, Alaska Native, Native Hawaiian, and Pacific Islander communities and survivors. This
consultation should be done in coordination with relevant interagency efforts, such as the
Operation Lady Justice Task Force56. Training must include information on how to respond
appropriately. All human trafficking training will be reviewed regularly to provide updated
information (such as news stories, social science research, and case studies) to ensure the training
remains relevant.

                                                            
 See Executive Order 13898, Establishing the Task Force on Missing and Murdered American Indians and Alaska
56

Natives, November 26, 2019, available at https://www.govinfo.gov/content/pkg/FR-2019-12-02/pdf/2019-

26178.pdf. 
 
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Accessible, quality training incorporating a victim-centered approach is greatly needed. Relevant
training for Federal law enforcement will be recorded, transcribed, and available online to law
enforcement across the country within one year. HSI Academy Advanced Human Trafficking
Training and the Federal Law Enforcement Training Centers’ Human Trafficking Awareness
Training will continue to be expanded. FBI and Drug Enforcement Administration (DEA)
Training Academies will introduce human trafficking awareness training into their basic training
within 2 years. DOJ’s Office for Victims of Crime (OVC) will promote a 4-hour self-paced online
training for service providers and others on identifying and responding appropriately to human
trafficking. DOJ and HHS will provide Federal law enforcement agencies, such as those in DHS
and DOJ, with already existing training on vicarious trauma for dealing with the experience of
working on emotionally challenging human trafficking cases. HHS FYSB will make its training
on the trauma-informed approach available to any United States law enforcement agency. The
BOP will add training on a trauma-informed approach. DOJ, in coordination with the working
group referenced above, will consider ways to offer human trafficking training curricula to state,
local, territorial, and tribal police academies and build their capacity to offer the training. The
SPOG will conduct outreach to leading accreditation organizations within 6 months of the
publication of the Action Plan to discuss developing standards for human trafficking awareness
training.
 
Priority Action 2.1.4: Increase access to public awareness materials focused on
victim identification, including by displaying those materials in priority locations
within 1 year
 
Information about indicators of human trafficking in awareness materials will be context
appropriate and specific to types of human trafficking. To the extent this or other direction in this
Priority Action requires the development of new material, such development will be subject to the
availability of appropriations. DHS will display notices describing the indicators of human
trafficking in Federally-controlled transportation areas, such as airport screening areas, land port
crossings, and train stations. The United States Department of Transportation (DOT) will expand
its awareness materials tailored to more modes of transportation and share them with public and
private transportation stakeholders across the country. Prisons and immigration detention centers
will provide inmates and detainees with information on human trafficking and hotlines for victims
of crime to receive assistance. DOL will include information on labor trafficking in its outreach
materials and targeted initiatives. EEOC will update its Youth@Work program materials to
include information on labor trafficking. The Department of Education will make guidance
available to schools on identifying and responding to human trafficking and child exploitation.
HHS will distribute information and sample resources on legislatively mandated57 posting
requirements of the National Human Trafficking Hotline in all Federal buildings. HHS will also
distribute information about human trafficking identification and services through its network of
stakeholders including early childhood education programs, runaway and homeless youth, family

                                                            
57
See Abolish Human Trafficking Act of 2017, Pub. L. No. 115-392 (2018) § 18.
 
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violence, adolescent pregnancy prevention, child welfare, and other relevant health and human
service programs. Additionally, the Department of Education will hold listening sessions for
education service providers and parents on the issue and its impact on vulnerable populations. In
coordinating with existing efforts led by National Indian Gaming Commission in conjunction with
the United States Department of Interior’s (DOI) Bureau of Indian Affairs, Treasury with support
of DHS and the departments and agencies will conduct outreach to tribal casinos to raise awareness
on the risks of human trafficking in the industry. Social media awareness campaigns will target
key demographics and be assessed on their effectiveness. Private sector, faith-based organizations,
and other partners that can display human trafficking awareness materials will be engaged and
prioritized based on where human trafficking victims are most likely to be encountered, such as in
emergency rooms or urgent care facilities, human service centers that administer public benefits,
mental health services, substance use treatment services, religious bulidings, and jails, prisons or
juvenile detention facilities. The SPOG Public Awareness and Outreach Committee will help
coordinate and track these efforts.

Principle 2.2: Safeguard victims of human trafficking from being

inappropriately incarcerated, fined, or otherwise penalized for unlawful acts
committed as a direct result of being trafficked

The Federal Government has been addressing this particular priority action in United States law
for almost 20 years. The initial criminalization of human trafficking in 2000 was in part a response
to the inappropriate treatment and penalization of human trafficking victims. The United States
Government will more effectively implement this principle and also encourage state, local, tribal,
and territorial governments to adopt and more effectively implement it, such as through training
and consultation with survivor experts.58
 
Priority Action 2.2.1: Review and update training, policies, and guidance for
Federal law enforcement to protect human trafficking victims
 
Federal training and policies must state that, once properly identified as a human trafficking victim,
an individual should not be inappropriately penalized for having engaged in unlawful activity as a
direct result of being a victim of human trafficking. Unlawful activity includes, but is not limited
to, engaging in prostitution, entering the country unlawfully, or working without documentation
or with false documents. All human smuggling cases being prosecuted will be screened by Federal
law enforcement officials for indications of human trafficking and, if there are indications present,
those human smuggling cases will be removed from early disposition (also known as “fast track”)
prosecutorial programs to allow prosecutors and criminal investigators the time to determine if
human trafficking was present. Federal law enforcement agencies will issue guidance to field
offices and task forces outlining best practices for victim-centered, trauma-informed law
enforcement operations, the use of appropriate shelter rather than jail or detention for individuals
properly identified as human trafficking victims, and screening for human trafficking during other
                                                            
58
The term “survivor expert” is used in this report to refer to a human trafficking survivor who has expertise on
human trafficking issues.
 
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operations, including worksite, drug, and gang-related enforcement operations, before arrest or
detention.
 
Priority Action 2.2.2: Provide human trafficking victims protection from removal
to assist law enforcement efforts
 
No category of individuals with an immigration violation is exempt from removal. However,
Federal law enforcement officials have discretion and the responsibility to assess the impact of a
potential removal on criminal enforcement efforts. The TVPA gives Federal law enforcement
officials the flexibility to allow human trafficking victims to remain in the United States
temporarily, because detaining and removing human trafficking victims can harm law
enforcement’s ability to effectively identify, investigate, and prosecute human trafficking crimes.
All relevant Federal law enforcement agencies will implement this as policy. ICE and the
Executive Office for Immigration Review (EOIR) will receive regular training on immigration
options for victims of human trafficking to assist officials when they encounter such victims during
removal proceedings.
 
Priority Action 2.2.3: Provide remedies for victims with inappropriate arrests and
criminal records
 
A Federal law enforcement working group will be convened by the DOJ to issue recommendations
for updating the notation on disposition of arrest records for human trafficking victims who were
not recognized as such at the time of arrest. The group will consider drafting, if needed, proposed
Federal legislation and model state legislation, in collaboration with relevant stakeholders. Human
trafficking victims with criminal records as a result of their victimization are sometimes unable to
access affordable housing, employment, higher education, and more and may be impacted in
immigration proceedings. Enabling human trafficking victims to shield or clear their criminal
records of crimes committed as a direct result of being trafficked through vacatur and expungement
may encourage victims to work with law enforcement that are investigating and prosecuting
traffickers. Federal agencies will review availability of current training on the issue of vacatur and
expungement and encourage states to adopt programs appropriate for their state to address
assistance with vacatur and expungement motions.

Priority Action 2.2.4: Encourage state, local, territorial, and tribal governments to
protect victims from inappropriate punishment for conduct committed as a direct
result of being trafficked
 
Federal law enforcement agencies will provide information to state, local, tribal and territorial
governments on policies that would prevent the inappropriate arrest of human trafficking victims
for unlawful conduct resulting directly from victimization and offer victim services instead. The
Federal Government will encourage state, local, tribal, and territorial partners to issue updated
recommendations, including the development of a model law to establish state vacatur and
expungement provisions for crimes committed as a direct result of an individual being trafficked
and a model safe harbor law for minors engaged in commercial sex acts. The Federal Government
will also offer training and technical assistance to state, local, territorial, and tribal law enforcement

 
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on the benefits of appropriately identifying child sex trafficking and protocols that mandate that
law enforcement refer minors engaged in commercial sex acts to child welfare or community-
based services rather than arrest them.

Principle 2.3: Improve access to immigration benefits and options programs to

efficiently and effectively provide assistance

Expeditiously providing immigration benefits and options to eligible victims of a crime contributes
to their ability to recover from trauma and participate in an investigation and prosecution of their
traffickers. Potential recipients of these benefits and options should be treated with respect for
their rights as crime victims. Delays in providing immigration benefits to foreign national human
trafficking victims affect a victim’s ability to stabilize, find employment, and access Federal
benefits and services. At the same time, these programs are subject to abuse by those simply
seeking legal immigration status in the United States. Efforts to improve access to and the integrity
of these programs will ensure that the United States Government fulfills its mandate to assist
foreign national victims of human trafficking in the United States.

Priority Action 2.3.1: Modernize immigration program systems connected to human

trafficking victims

Immigration program systems will be modernized, subject to the availability of appropriations. In

doing so, ICE, in coordination with United States Citizenship and Immigrations Services (USCIS),
will migrate the submission and approval process for Continued Presence from a paper-based
system to a digital process. This will reduce overall processing time and lower barriers for law
enforcement to make the requests. Shortcomings in the U visa electronic records system that
currently do not sufficiently support data analytics will be addressed by upgrading the system over
the long term. Law enforcement certifications of T visa applications and U visa petitions will be
submitted and processed electronically to improve usability and data integrity. All systems
changes will be in accordance with relevant privacy and confidentiality laws.

Priority Action 2.3.2: Provide immigration protections to ensure eligible victims

are not removed

Protecting victims of crime is critical to law enforcement. As with confidential informants, victims
of human trafficking may lack legal immigration status, yet can be necessary for the prosecution
of law enforcement’s criminal targets. Removing them from the country could keep an
investigation or prosecution from moving forward. Temporary immigration options and benefits
make it possible for victims to rebuild their lives, ultimately enabling them to cooperate with law
enforcement. On average, law enforcement officials have made fewer than 200 requests annually
for Continued Presence for foreign national human trafficking victims since the TVPA created the
program in 2000. The T visa program, which has an annual cap of 5,000 visas per year, has
averaged 570 T visa principals approved annually since 2008. In response, DHS and DOJ will
convene an departments and agencies working group to draft a legislative proposal to modernize
the Continued Presence statute if necessary and devise strategies, including targeted training, to
further encourage Federal, state, local, tribal, and territorial law enforcement to request Continued
 
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Presence, as appropriate, when they encounter a foreign national who is likely to be a victim of
human trafficking.

USCIS, ICE, and EOIR will coordinate to consider the most efficient means of exchanging
information about identified victims throughout removal proceedings. USCIS retains discretion,
on a case-by-case basis, to refer cases to the Prosecutorial Review Panels in order to not issue a
Notice to Appear – after considering USCIS and DHS guidance, DHS enforcement priorities, the
individual facts presented, and DHS interests implicated (e.g., litigation, deconfliction, etc.)
USCIS may also consider the nature of a technical denial (i.e., failure to provide a passport in time)
when exercising discretion in the initiation of removal proceedings. When conducting outreach
on immigration benefits and options for victims of crime, DHS will clarify immigration policies
impacting victims of human trafficking, including any applicable exclusions from the “public
charge” ground of inadmissibility.

Priority Action 2.3.3: Ensure program integrity in immigration benefits designed to

assist trafficking victims
 
Immigration benefits and options are truly beneficial to victims, to help them rebuild their lives,
and to law enforcement, to enable victims to cooperate as witnesses in trafficking investigations
and prosecutions. Fraudulent and non-meritorious claims for immigration benefits divert limited
resources and delay the grant of benefits to legitimate victims of trafficking. DHS and DOJ will
coordinate to consider anti-fraud and other program integrity measures, to ensure these benefits
are preserved for victims and that eligible victims receive timely access to benefits and protections
in accordance with the TVPA.

Principle 2.4: Expand and improve assistance to victims encountered by

Federal enforcement agencies
 
Federal victim assistance is not only required by law,59 but also provides critical support to the
victim in the aftermath of a crime and thus is an integral part of any law enforcement agency’s
human trafficking mission.

Priority Action 2.4.1: Increase victim assistance personnel

Federal criminal investigative agencies will ensure that there are victim assistance personnel in
locations where their agency participates in human trafficking task forces and available to cover
the entire United States to provide mandatory services under the law.60 HSI and Diplomatic
Security Service (DSS) will discuss funding options with OMB to enhance Federal victim
assistance staffing to the extent funds are available. Other Federal law enforcement agencies, such
as ICE ERO, BOP, and Internal Revenue Service (IRS), shall designate a victim coordinator

                                                            
59
See, e.g. the Trafficking Victims Protection Act as amended (22 U.S.C. §§ 7101-7114); the Crime Victims’ Rights
Act (18 U.S.C. § 3771 and 34 U.S.C. § 20141), the Victim Rights and Restitution Act (34 U.S.C. § 20141), and the
Mandatory Victim Restitution Act (18 U.S.C. § 3663A).
60
 See 18 U.S.C. § 3771 and 34 U.S.C. § 20141. 
 
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responsible for ensuring the agency implements training, policy, and identification efforts. HSI
will pursue additional staffing to support victim assistance programs. Increasing personnel would
provide the protections as intended under the TVPA and as mandated by the Crime Victim Rights
Act and the Victim Rights and Restitution Act and serve to inform victims of their rights, to advise
them on the process for restitution, and to provide information on emergency medical and social
services. DOJ will also consider ways to increase victim-witness assistance expertise and support
in human trafficking prosecutions.
 
Principle 2.5: Seek financial remedies for victims

For some victims, financial remedies are the most important aspect of justice. Victims may find
themselves penniless and in need of medical and mental health care, housing, job training, and
resources to care for family members, among other needs. Federal law mandates victims receive
restitution in human trafficking cases and victims are prioritized to receive the value of forfeited
assets.61 Courts have awarded victims restitution in only a small portion of cases, and even in
cases where courts ordered restitution, the full amounts were not recovered from the defendant for
transfer to the victim. Actions taken at each stage of a criminal case from investigation, to
charging, plea negotiations, and sentencing all affect whether victims will receive full and timely
restitution. Yet, in some cases restitution is not considered until the sentencing phase of a criminal
prosecution. Identifying and freezing the assets of traffickers as soon as possible during the
investigation makes more funds available to victims for restitution down the road. Further,
prosecutors and judges may lack awareness of who is entitled to restitution, what is recoverable,
and what information is required in determining which property and assets can be forfeited and
used toward restitution. While significant efforts have been made to ensure that prosecutors
vigorously pursue restitution and forfeiture on behalf of human trafficking victims, more effort is
needed to maximize the likelihood of recovering perpetrators’ assets and to ensure that courts are
well-informed about mandatory restitution under Federal law.

Priority Action 2.5.1: Create comprehensive training on restitution

To ensure that courts can assess and the government can maximize the funds they collect for use
as restitution for victims of human trafficking, DOJ and Federal investigative agencies should
conduct comprehensive training covering the investigation, imposition (charging through
sentencing), transfer of forfeiture to victims under the Justice for Victims of Trafficking Act,62 and
collection of restitution. A training plan should also include outreach to judicial branch via the
Administrative Office of the United States Courts and for probation officers at the United States
Probation and Pretrial Services National Training Academy. Training will explain the importance
of focusing on restitution at the early stages of investigation and the role of DOL in assisting with
calculating restitution. DOJ will develop public materials on advocating for restitution in a case
and the availability of other financial remedies, such as private civil causes of action and crime
victims compensation programs.

                                                            
61
See 18 U.S.C. §§ 1593 – 1594.
62
See Pub. L. No. 114-22, § 105 (a)(4) (2015)(18 U.S.C. § 1594(f)).
 
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Principle 2.6: Offer or connect victims to social services to increase short and
long-term stability

Human trafficking survivors who have experienced severe trauma or who have been deprived of
opportunities require social services and health care to rebuild their lives. The United States
Government funds a range of services and grant programs, some of which are already available to
human trafficking survivors in recognition of their need for comprehensive services. Some
programs require expansion while others require refinement in order to meet the needs of diverse
survivors and their equally diverse needs on the road to stability.
 
Priority Action 2.6.1: Increase access to mental health and other healthcare
services

The United States Government will support greater incorporation of funding for mental healthcare
into grant opportunities. Outreach and public awareness campaigns related to human trafficking
will stress the importance of mental health and well-being. HHS will ensure that the National
Human Trafficking Hotline is able to make referrals to mental health organizations and health care
providers with the appropriate expertise to work with human trafficking victims, to include those
who have cultural competency for working with indigenous peoples of North America and the
Pacific, foreign nationals, individuals with limited English proficiency, LGBT+ individuals, men
and boys, and formerly incarcerated individuals. HHS’s Substance Abuse and Mental Health
Services Administration (SAMHSA) acknowledges the importance of training of mental health
professionals to provide evidence-based treatment to address the short and long term trauma
experienced by trafficking survivors and their families. HHS’s FYSB will incorporate resources
on trauma into their training on human trafficking for service providers working with runaway
youth, high-risk youth, and domestic violence victims. HHS’s Health Resources and Services
Administration (HRSA) will provide programmatic and technical assistance on trauma-informed
models to support survivors of human trafficking in settings of care, including the Community
Health Center Program and the Ryan White HIV/AIDS Program. HRSA, in partnership with other
Federal agencies, will advance innovative health care delivery models at the state, local, tribal and
territorial levels that support survivors of human trafficking.

Priority Action 2.6.2: Increase access to shelters and safe housing

A shortage of emergency shelter space and homelessness are serious problems for survivors of
human trafficking. Federal agencies will commit to developing policies that facilitate safe and
secure emergency, short-term, transitional, and long-term housing options and address barriers that
human trafficking victims, particularly those with a criminal record directly resulting from their
victimization, may face in accessing public housing. The United States Department of Housing
and Urban Development (HUD) Office of Public and Indian Housing will conduct an awareness
campaign with public housing authorities working with human trafficking victims. The campaign
will address victims’ criminal records resulting from their victimization in order to remove any
barriers to entering public housing. OVC will continue to prioritize the human trafficking housing
program to support safe, stable housing options for human trafficking victims.

 
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The SPOG Victim Services Committee will continue to share best practices in housing for human
trafficking survivors by leveraging meetings and listening sessions initiated in Fiscal Year 2020
focused on identifying challenges and promising solutions. This will include disseminating
recommendations to address the great need for housing for male victims of both sex trafficking
and labor trafficking; placement for minor victims outside of their state of residence when it is in
their best interests; and strategies and technology related to locating available shelter beds and
other forms of emergency housing. HUD, HHS, General Services Administration (GSA), and
DOJ will convene periodically to discuss viable options for providing temporary shelter to human
trafficking victims – including through the McKinney-Vento Homeless Assistance Act of 198763
when local resources are overwhelmed. HHS and DOJ will strengthen safe housing options for
survivors of human trafficking. This directive operationalizes Executive Order 13903 on
Combating Human Trafficking and Online Child Exploitation.64

Priority Action 2.6.3: Increase access to employment

The United States Government will connect relevant grantees to facilitate referrals from human
trafficking victim assistance providers to DOL-funded employment and training programs for
which they are eligible in their communities (such as American Job Centers, Reentry Employment
Opportunities, Job Corps, and YouthBuild). DOJ will ensure that victims of human trafficking
leaving incarceration are connected to the appropriate reentry services. HHS will adapt resources
on 2-generation/whole family approaches to strengthen economic self-sufficiency through early
childhood development, postsecondary and employment pathways, social capital, and economic
assets.

Priority Action 2.6.4: Increase access to education

DHS will issue a Request for Information on the availability of academic scholarships for victims
of human trafficking and incorporate the feedback into advising victims on available services.

The United States Government will also look at leveraging existing resources or funding financial
literacy programs that support victims and teach skills related to budgeting, opening bank accounts,
and overcoming poor credit scores and identity fraud.

Priority Action 2.6.5: Increase access to assistance broadly

Strengthening coordination on existing Federal housing, employment, and social service programs
at the regional level may result in initiatives that better meet the needs of human trafficking
survivors. HUD, HHS, and DOL regional offices, in consultation with OVC, will explore
developing a pilot collaboration, in partnership with Federally funded service providers, to
overcome current challenges in connecting survivors of all forms of human trafficking to
sustainable housing and meaningful employment, including consideration of self-employment or
social enterprise opportunities.

                                                            
63
See Pub. L. 100-77 (1987), title V, § 501 (as amended) (42 U.S.C. § 11411).
64
 See https://www.govinfo.gov/content/pkg/FR-2020-02-05/pdf/2020-02438.pdf.
 
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HHS OTIP will offer technical assistance to bolster peer-to-peer support models for human
trafficking survivors.

 
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★ ★ ★ 
P ILLAR 3: P ROSECUTION
Dismantle Human Trafficking Networks
and Hold Traffickers Accountable
The United States Government remains committed to holding accountable individuals and entities
engaged in human trafficking and to dismantling human trafficking networks. The investigation
and prosecution of human trafficking present a distinct set of challenges. Many human trafficking
violations span years, involve dozens or hundreds of victims, and cross jurisdictions. The target
of an investigation may lead to an extensive network of potentially culpable co-conspirators,
including facilitators who benefit financially and buyers of goods, labor, or services who turn a
blind eye to victims. Enforcement of immigration laws, asset forfeiture, and restitution are
valuable and effective tools available in such cases. Multiple investigative agencies must deploy
experts to dismantle large criminal enterprises, to address offenses related to narcotics,
immigration, racketeering, money laundering, fraud, extortion, and sexual exploitation, and to
disgorge profits. Many human trafficking cases rely on victim testimony, yet there are challenges
in securing human trafficking victims’ participation as witnesses. Some may not identify as crime
victims, may fear retaliation from their trafficker, and may suffer from complex trauma, requiring
intensive support to victims (see additional discussion above under Pillar 2: Protection).
Accordingly, the commitment of significant resources over multiple years must be prioritized to
bring a human trafficking enterprise to justice. To confront these complexities, Federal human
trafficking investigators and prosecutors must improve coordination among themselves and their
partners; deploy a broad range of Federal enforcement tools; build strategies to combat labor
trafficking, which is prosecuted less frequently; and ensure advanced training on an ongoing basis.

This goal presents 13 priority actions organized under 4 principles related to increasing criminal
enforcement through improved coordination among enforcement partners; employing a broader
range of non-criminal enforcement tools; increasing accountability for labor trafficking; and
building capacity of law enforcement.

Priority Actions
 
Principle 3.1: Increase criminal enforcement through improved coordination
among law enforcement agencies and their partners
To target and dismantle complex human trafficking networks and hold human traffickers
accountable, Federal prosecutors and law enforcement agencies must leverage the diverse

 
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perspectives, skills, and capacities of many partnerships. These partners include survivor experts
and NGOs. Coordination will occur through creating Federally-led initiatives, partnering with
private entities that can disrupt trafficking, strengthening referral mechanisms, and expanding task
forces to a broad range of partners. Federal investigative agencies with significant human
trafficking responsibility include HSI, FBI, DSS, and DOL Office of Inspector General (OIG).
Numerous other investigative agencies have specialized jurisdiction or expertise that contributes
importantly to the mission of combating human trafficking. Federal prosecuting authorities
include 94 USAOs and 2 components at DOJ headquarters - the Human Trafficking Prosecution
Unit and the Child Exploitation and Obscenity Section - in coordination with specialized
prosecuting units as appropriate, including the Money Laundering and Asset Recovery Section,
the Human Rights and Special Prosecutions Section, the Organized Crime and Gang Section, the
Fraud Section, and the Computer Crime and Intellectual Property Section.

Priority Action 3.1.1: Develop a timeline and seek to secure necessary resources
for launching the third phase of the Anti-trafficking Coordination Team Initiative in
select districts 
 
The Attorney General, Secretary of Homeland Security, and Secretary of Labor launched this
initiative in 2011 to convene and train departments and agencies teams in select judicial districts
to develop high-impact human trafficking cases with the support of headquarters anti-trafficking
experts. Anti-trafficking Coordination Team (ACTeam) districts significantly increased the
overall number of human trafficking prosecutions as compared to previous years in the same
districts. ACTeam districts also prosecuted more cases on average than non-ACTeam districts
during the same period.65 During the pilot phase, ACTeam districts more than doubled the number
of cases filed and defendants prosecuted, and during the second phase, ACTeam districts again
saw increases in cases filed and defendants prosecuted. Notably, ACTeam districts investigated
and prosecuted a higher proportion of labor trafficking cases relative to overall human trafficking
cases, as compared to non-ACTeam districts, due in part to partnership with Federal agencies with
labor expertise. The combination of vertical accountability from cabinet-level involvement in the
initiative’s launch to regular engagement with agencies’ headquarters experts throughout the
initiative and horizontal partnership, involving intensive coordination among multiple Federal
agencies within each ACTeam district, resulted in a higher capacity to dismantle human trafficking
networks and bring traffickers to justice. Federal partners will seek to secure sufficient resources
in order to launch the third phase of this intensive effort including through their budget proposals
to OMB. During the preparation for the third phase, Federal partners, including DSS, will further
elevate labor trafficking as a priority for investigations and prosecutions, including through
updated guidance on proactive detection, and will continue to incorporate financial investigations.

Priority Action 3.1.2: Expand the United States-Mexico Bilateral Human

Trafficking Enforcement Initiative through intelligence-driven targeting 
 
The United States-Mexico Bilateral Human Trafficking Enforcement Initiative connects
United States and Mexican law enforcement counterparts on human trafficking operations to
                                                            
 See United States Department of Justice, Anti-trafficking Coordination Team (ACTeam) Initiative Fact Sheet,
65

available at https://www.justice.gov/opa/file/623176/download. 
 
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expedite the sharing of leads, evidence, information, and expertise that can result in dismantling
cross-border human trafficking networks. The initiative has proven highly effective at advancing
high-impact bilateral investigations and prosecutions to dismantle transnational human trafficking
enterprises. This impact has been effected through a series of United States Federal prosecutions
and related Mexican state and Federal prosecutions of associated traffickers. These networks have
trafficked highly vulnerable Mexican and Central American women and girls throughout the
United States. The networks have lured victims on false promises of love, marriage, and a better
life, then compelled them into prostitution by using deception, psychological manipulation,
beatings, rapes, isolation, intimidation, threats against victims’ families, and control over the
victims’ children. The traffickers have retained virtually all of the proceeds derived from
compelling the victims to perform dozens of commercial sex acts each day, then laundered these
criminal proceeds back to Mexico, while the victims retain next to nothing. Under the leadership
of DOJ’s Human Trafficking Prosecution Unit and DHS’s HSI, the initiative leverages the
expertise of multiple Federal agencies and incorporates case-mentoring exchanges. This initiative
also uses advanced analytics to conduct intelligence-driven targeting and incorporates financial
investigations and prosecutions.

DOJ and DHS will work to expand the impact of the United States-Mexico Bilateral Human
Trafficking Enforcement Initiative by leveraging DOJ, DHS, and partners’ intelligence analysis
assets to expedite simultaneous investigations and prosecutions in multiple United States and
Mexican jurisdictions. Treasury’s enforcement agencies will continue to augment human
trafficking investigations in coordination with DOJ to leverage anti-money laundering expertise.
Federal agencies will need to identify sufficient resources to most effectively expand impact. DOJ
and DHS will engage directly with additional USAOs and Federal law enforcement agency offices
to expand the scale and impact of the Initiative.

Priority Action 3.1.3: Evaluate the Enhanced Collaborative Model Task Forces to
Combat Human Trafficking and recommend implementation options
DOJ’s Enhanced Collaborative Model Task Forces to Combat Human Trafficking66 are
multidisciplinary human trafficking task forces bringing together professionals from a variety of
disciplines. These professionals collaborate to identify victims of all forms of human trafficking;
engage in victim-centered investigations; prosecute or refer sex and labor trafficking cases to state,
local, tribal, and territorial agencies; and address the needs of human trafficking victims through a
comprehensive array of services. Each task force may receive 2 separate grant awards – one to a
law enforcement entity and one to a service provider.

DOJ will complete an evaluation of the structure and impact of the Enhanced Collaborative Model
Task Force Program. The results of the evaluation will inform the evolution of the task force
model. DOJ will continue to consider enhancements to the program including increased
collaboration between law enforcement, victim services, and community stakeholders. Any
program modification will continue to be informed by survivor experts.

                                                            
66
 This task force program is funded under the TVPA, which authorizes OVC to make grants for direct services to
victims of human trafficking. OVC and the Bureau of Justice Assistance (BJA) developed the Enhanced
Collaborative Model Task Forces to support the development and enhancement of multidisciplinary task forces. 
 
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Priority Action 3.1.4: Seek to establish Federally-funded human trafficking task

forces that are sustainable and state, tribal, territorial, or locally-led  

DOJ will enhance efforts to establish state, tribal, territorial, or locally-led human trafficking task
forces that fulfill the principles of sustained state law enforcement leadership and comprehensive
victim assistance. These efforts will draw on lessons from evaluations of other collaborative
multidisciplinary efforts. Survivor experts will inform program development. DOJ will not
propose to diminish resources provided from current DOJ funding sources for victim assistance
grants.

Federally funded, state or locally led human trafficking task forces should include funding to state,
local, tribal and territorial law enforcement and victim assistance programs. Task forces should
be distributed broadly across the country building toward at least one task force, whether funded
through Federal or other sources, in each state. These task forces should build on lessons learned,
including the importance of sustaining law enforcement leadership to build, retain, and exchange
institutional knowledge. It is also important for task forces to sustain collaborations among grant
recipients and Federal law enforcement and promote actionable intelligence sharing, investigative
capacity, and a strategic approach to prosecution at all levels of government. A human trafficking
victim’s access to protection and resources regardless of whether and when victims collaborate
with law enforcement is equally important to successful enforcement. Providing assistance to
human trafficking victims also meets urgent United States Government protection goals (see Pillar
2). In the context of task forces, providing critical assistance to victims allows them to stabilize
and rebuild their lives and, in some cases, become ready to collaborate with law enforcement
investigations and prosecutions against human traffickers.

Priority Action 3.1.5: Develop a protocol to refer human trafficking cases that will
not be federally criminally prosecuted so that other criminal, civil, and
administrative authorities can be exercised 

Some human trafficking cases cannot be federally prosecuted or addressed through civil actions
by the Attorney General67 due to insufficient available evidence to meet the high burden of proof
or for other reasons. In such cases and in any other situations in which a Federal criminal human
trafficking case concludes without prosecution, Federal criminal investigative agencies should
adopt a protocol to consistently refer appropriate case information to state, local, tribal, and
territorial law enforcement agencies for criminal investigation and prosecution. When appropriate,
referrals will also be made to other Federal agencies or NGOs that may be able to pursue other
avenues to justice. Referrals could be made to other Federal agencies such as DOL, EEOC, and
Treasury; state, local, tribal, and territorial enforcement agencies; and legal services organizations
that may be able to assist victims with private civil claims. Federal investigative agencies,
including FBI, ICE, DSS, and DOL OIG, will collaborate to develop referral practices that can be
integrated into their respective policy or guidance documents.

                                                            
67
E.g. DOJ-initiated civil injunctions under 18 U.S.C. § 1595A; or Federal civil forfeiture actions. 
 
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Principle 3.2: Build capacity of law enforcement to investigate and prosecute

human trafficking 

Law enforcement investigators require advanced training to address the complex crime of human
trafficking. Training programs should be survivor-informed. Topics should include: strategies to
implement a victim-centered, trauma-informed approach; developing evidence of victims’ state of
mind to use in prosecutions for coercion-based crimes; engaging in proactive investigations relying
on financial and other intelligence; and investigating financial crimes and identifying assets. The
United States Government can build its investigative capacity by expanding partnerships, such as
with technology companies and child welfare systems in order to locate exploited children.

Priority Action 3.2.1: Engage relevant stakeholders, including state, local, tribal
and territorial law enforcement, to increase prosecutions related to child sex
trafficking 
 
DOJ will create a strategic operational working group that brings together investigative and
prosecutorial stakeholders from the Federal, state, local, tribal and territorial levels to describe the
child sex trafficking threat landscape, develop plans for investigation and prosecution, and identify
subject matter experts available to provide training and outreach. Since passage of the TVPA of
200068, Federal child sex trafficking investigations and prosecutions have steadily increased.
However, given that most crimes are not prosecuted federally, there are limitations on Federal
resources, and there are strong state, local, tribal and territorial equities, the Federal Government
must continue to invest in building capacity of these law enforcement partners. Partners should
be encouraged to enact laws with appropriate sentences for child sex trafficking and should be
trained on child sex trafficking investigations and prosecutions, including protecting trafficked
children (as compared to buyer stings that do not identify children). At the same time, Federal
prosecutors must prosecute child sex trafficking when states, tribes or territories lack jurisdiction
or appropriate penalties, including for buyers of commercial sex with children. This DOJ-led
working group’s engagement will occur through various forums and could include the National
Association of Attorneys General, the National District Attorneys’ Association, the International
Association of Chiefs of Police, the National Congress of American Indians, the National Native
American Law Enforcement Association, and the National Advisory Committee on the Sex
Trafficking of Children and Youth in the United States, which includes members of the judiciary,
prosecutors, law enforcement, survivors and other important stakeholders.

Priority Action 3.2.2: Enhance capabilities to locate children who are missing,
including those who have run away from foster care, and are vulnerable to human
trafficking

Enhanced efforts and abilities are needed to locate missing children, including youth who have run
away from foster care and are highly vulnerable to human trafficking.

                                                            
68
 Supra note 35. 
 
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DOJ, DHS, and HHS will pursue increasing the capacity of social media companies and internet
service providers to identify and locate potential victims of child trafficking and will pursue
facilitating the sharing of information on potential child trafficking victims between the technology
industry, state, local, tribal and territorial child welfare agencies, the National Center for Missing
and Exploited Children (NCMEC), and law enforcement at all levels. The aim will be to take an
old idea - putting photos of missing children on ubiquitous items like milk cartons to increase the
number of people looking for those children and modernize it to create a “virtual milk carton” to
help locate potential child trafficking victims, particularly those missing from foster care. When
a child goes missing from foster care, the state would notify NCMEC and provide a photograph of
the child. NCMEC would then provide that information and photo to law enforcement, social
media and internet service provider companies, and NGOs that scrape online sex trafficking
advertising and other internet data, all of which would look for any information on the identity and
location of the child. Any information that technology companies or NGOs found would be fed
back to law enforcement via NCMEC. DOJ and DHS, in consultation with HHS, will pursue
legislation needed to support this initiative.

DOJ and HHS, in consultation with the USMS, will also collaborate to expand Operation HOPE
nationally to identify children missing from foster care, screen recovered children for potential
trafficking, connect victims to appropriate care, and prosecute offenders as appropriate. The first
significant challenge in protecting children who are missing from care is in locating the missing
child. Operation HOPE has brought together Federal, state, and local authorities for joint regional
efforts led by HHS OIG Office of Investigations. Its aim is to locate and recover children missing
from foster care programs. Early iterations of this program have led to the recovery of 42 children
missing from care. HHS, DOJ, and USMS, will work to expand this operation to other regions, to
include incorporating it into other investigative efforts, and develop human trafficking
prosecutions as appropriate.

Priority Action 3.2.3: Develop improved technology for human trafficking

interdiction and identify technical barriers impeding investigations 

Because traffickers frequently use electronic platforms and devices to conduct their illicit
activities, including recruiting and maintaining victims, DOJ, DHS, and HHS will work with the
social media and technology industry to identify potential barriers to their voluntary reporting of
suspected human trafficking on their platforms, as well as possible solutions. DOJ, DHS, and
HHS will also work with the social media and technology industry, NGOs, and academia on the
development of innovative technical tools to interdict human trafficking, including demand, and
how to promote adoption of those tools by relevant stakeholders. The National Advisory
Committee on the Sex Trafficking of Children and Youth in the United States is a potential forum,
among others, for engaging with industry partners on these issues.

In many cases law enforcement officials are unable to access data due to general privacy and
security measures (e.g., encryption). These measures make it harder to identify current and
historical victims, prevent traffickers from recruiting new victims, collect evidence to assist in
bringing traffickers to justice, and may prevent the removal of harmful online data or images of
the victims, which causes re-victimization of trafficked persons by allowing harmful data or
images to remain online. DOJ and DHS, working with their international and domestic partners,
 
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will engage with the social media and technology industry to deny human trafficking and child
exploitation networks access to social media networks, and find creative solutions to these
networks’ use of emerging technologies.

Priority Action 3.2.4: Enhance focus on investigating and prosecuting the demand
and other facilitators of human trafficking 
 
Enhanced efforts are needed to target entities and individuals that knowingly contribute to or
facilitate human trafficking. Buyers in sex trafficking cases and businesses that knowingly procure
goods or services from entities or employers using forced labor must be considered as potential
enforcement targets. Likewise, facilitators such as hotel owners who knowingly profit from sex
trafficking or companies that recklessly disregard their labor recruiters’ involvement in labor
trafficking should also be considered as targets. These individuals may be important participants
in the criminal network and are sometimes overlooked by investigators and prosecutors.  

Focusing on the demand and facilitators serves two main purposes. First, these are persons or
entities directly involved in the crime of human trafficking and contributing to its profitability.
Second, these offenders may have assets that could be forfeited and used for restitution.
Restitution is one resource to assist the victims on a road to recovery. In sum, addressing all
participants in the crime will disrupt traffickers’ ability to victimize people and will hold all
responsible persons accountable. 
 
DOJ will train Federal, state, local, tribal and territorial investigators and prosecutors on
identifying and prosecuting the demand and facilitation aspects of human trafficking under
relevant statutes using a victim-centered, trauma-informed approach that is designed to build trust
with law enforcement among victims and potential victims. Federal prosecutors will identify
strong cases with Federal equities for Federal prosecution. DOJ will explore increased
collaboration with its state, local, tribal and territorial partners who may be able to pursue cases
that are not brought to Federal court for prosecution.
 
Principle 3.3: Enhance efforts to bring traffickers to justice by deploying a
broader range of Federal non-criminal tools
The United States Government can deploy a range of Federal enforcement tools including non-
criminal civil forfeiture actions, financial tools including sanctions and anti-corruption measures,
travel restrictions, and enforcement of reporting requirements in conjunction with or as an
alternative to criminal prosecution of human trafficking crimes, in order to disrupt human
trafficking networks and enhance accountability. While human trafficking criminal prosecutions
are critical, they cannot be undertaken in all cases and are highly resource intensive; the availability
of additional forms of accountability increases the effectiveness of United States Government
efforts.

 
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Priority Action 3.3.1: Deploy a wide range of administrative and regulatory tools
to disrupt human trafficking 

Federal agencies, including Treasury, DOS, and DOT, will seek to further leverage a broad range
of tools designed to target and deter malign actors. Those tools may be used in coordination with
criminal prosecutions of human trafficking and related financial crimes as well as alongside other
civil enforcement actions.

These tools include financial sanctions and other special measures. Within Treasury, components
of the Office of Terrorism and Financial Intelligence69 collect and analyze financial intelligence
and data to identify human traffickers and their networks; disrupt and disable the financial
underpinnings of these networks; and support law enforcement investigations that lead to
accountability and justice. Treasury’s Office of Foreign Assets Control (OFAC) applies financial
sanctions to combat human trafficking. OFAC oversees a range of sanctions programs that can
target human trafficking conduct. These programs include global and country programs focused
on human rights abuse and corruption as well as programs with the authorities to target activities
that overlap with human trafficking, including narcotics trafficking, malign cyber-enabled
activities, terrorism, and transnational organized crime. As a result of United States financial
sanctions, United States persons are generally prohibited from engaging in dealings with the
designated (sanctioned) person; and the designated person’s property is blocked. Treasury will
examine ways to further combat human trafficking using a range of tools, including financial
sanctions, as appropriate.

In coordination with DOJ and human trafficking investigative agencies, Treasury’s Financial
Crimes Enforcement Network (FinCEN) may be able to deploy special recordkeeping and related
measures against entities involved in human trafficking networks in order to assist investigations
and address money laundering concerns. FinCEN can require United States financial entities to
take certain “special measures” under Section 311 of the USA PATRIOT Act70 if a foreign
jurisdiction, foreign financial institution, class of transaction, or type of account is of “primary
money laundering concern.” Special measures include increased recordkeeping and reporting,
collection of account and transaction information, and limits on opening or maintaining accounts.
When appropriate, FinCEN will issue geographic targeting orders, which impose additional
recordkeeping or reporting requirements on domestic financial institutions or other businesses
relating to a specific geographic area for 180 days.

DOT will implement the No Human Trafficking on Our Roads Act71 and its final rule,72 which
requires every state to permanently ban drivers convicted of a severe form of human trafficking
from operating a commercial motor vehicle for which a commercial driver’s license or a
commercial learner’s permit is required. Under the final rule, states must come into compliance
with the Act and regulation no later than September 23, 2022.

                                                            
69
 Components of this office include the Office of Terrorist Financing and Financial Crimes (OFAC), the Financial
Crimes Enforcement Network (FinCEN), and Office of Intelligence and Analysis (OIA). 
70
See Pub. L. No. 107-56 (2001) (31 U.S.C. § 5318A).
71
See Pub. L. No. 115-106 (2018).
72
 See 84 FR 35335. 
 
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Priority Action 3.3.2: Propose legislation to facilitate revocation of passports and

other administrative actions against individuals convicted of certain travel-related
human trafficking and child sexual exploitation crimes  

The TVPA requires the Attorney General to notify the Secretaries of State and Homeland Security
whenever a defendant is convicted of violating certain child sex offenses involving travel and
transportation.73 For foreign defendants, the law authorizes DHS to take any action appropriate
under the Immigration and Nationality Act. The law further requires DOS to revoke or refrain
from issuing passports to United States citizen convicts who traveled internationally to commit the
offense. However, other laws74 constrain the Attorney General’s ability to effectively collect and
transmit the necessary information on convicted individuals to DOS and DHS. As a consequence,
the law has not been effectively implemented. The relevant agencies will work with the Congress
to propose legislation to resolve this issue. In addition, the statute could be broadened to cover
individuals convicted of similar crimes, such as human trafficking and the production of child
sexual abuse material, when those crimes involve international travel by the defendant.

Principle 3.4: Increase efforts to investigate and prosecute labor trafficking

Labor trafficking is prevalent across certain sectors in the United States. Governmental and
external stakeholders regularly recommend prosecuting more cases of labor trafficking, in the
United States and connected to global product supply chains. Labor trafficking often occurs
alongside otherwise legitimate business activity connected to companies widely perceived by the
public as reputable. As a result, successful prosecutions of labor trafficking, while resource
intensive, are likely to have a significant deterrent effect. Because many forced labor cases involve
foreign national victims, investigative agencies should convey that strong criminal law
enforcement need not be perceived as undermining immigration enforcement but instead can exist
alongside immigration enforcement, particularly when both are focused on accountability for
human traffickers.

Priority Action 3.4.1: Increase coordination and strategic engagement in

investigating and prosecuting labor trafficking 
Federal enforcement agencies have consistently prosecuted a few dozen labor trafficking
defendants per year in recent years, while service providers funded with Federal grants have
reported serving significantly more identified victims of labor trafficking.75 These cases are
resource intensive, which is a challenge for Federal prosecuting offices, because they currently
have no dedicated funding for human trafficking (or labor trafficking) prosecutors.

DOJ’s Human Trafficking Prosecution Unit, FBI’s Crimes against Children and Human
Trafficking Unit, and HSI’s Human Trafficking Unit will work to increase labor trafficking
investigations and prosecutions in select districts. These three agencies will identify districts that
commit to designating at least one Federal investigator and one Federal prosecutor to coordinate
                                                            
73
 See 18 U.S.C. § 2423 and 22 U.S.C. § 212a. 
74
 See 5 U.S.C. § 552a. 
75
 See Attorney General’s Trafficking in Person’s Reports for FY18 and preceding years, available at
https://www.justice.gov/humantrafficking/attorney-generals-trafficking-persons-report. 
 
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these efforts, drawing on the ACTeam Initiative’s lesson of strengthening coordination through
horizontal partnerships between investigators and prosecutors. The headquarters offices will
provide guidance on intelligence-driven targeting and proactive methods of investigation and will
facilitate coordination with other DOJ components and departments and agencies that can offer
special expertise in support of labor trafficking investigations and prosecutions, including DOL,
Treasury, DOS and others. The initiative will strengthen engagement with worksite enforcement
agencies that may encounter labor trafficking and promote the use of victim-centered, trauma-
informed approaches by all Federal enforcement partners.

Priority Action 3.4.2: Develop a memorandum of understanding to support the

initiation and development of criminal investigations and prosecutions of forced
labor occurring in United States business entities’ product supply chains 

Prosecuting novel cases against companies that knowingly benefit financially from forced labor
within their value chains holds significant potential to suppress global criminal conduct that poses
a threat to its victims and to United States markets. DOJ’s Human Trafficking Prosecution Unit,
HSI and other partner agencies have been meeting since February 2017 to coordinate criminal
investigations arising from allegations of forced labor in the production of goods imported into the
United States in violation of Federal criminal law. The law prohibits knowingly benefitting from
participation in a venture engaged in forced labor in cases where the potential violator knows of
or recklessly disregards the use of force or coercion to secure labor or services.76 These cases pose
special challenges because important evidence, including victims and witnesses, may be located
overseas, and because sometimes complex product supply chains or opaque ownership structures
must be traced in order to identify culpable actors. At the same time, successful prosecutions can
have a dramatic impact by bringing justice to numerous victims and by promoting sector-wide
changes in norms of responsible business conduct thereby preventing future human trafficking.
Engaging Federal partners including other DOJ components, DOL, DOS, Treasury and others, will
enhance the success of these investigations and prosecutions. Formalizing Federal partner
agencies’ efforts to conduct criminal investigations and prosecutions of forced labor occurring in
United States business entities’ product supply chains through a memorandum of understanding
signed by each agency’s leadership will elevate the mission; enhance further collaboration to
detect, investigate and prosecute these cases; and ensure continuity of the departments and
agencies commitment to addressing these complex violations.

                                                            
76
See 18 U.S.C. §§ 1589, 1593A.
 
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★ ★ ★ 
P ILLAR 4: C ROSSCUTTING A PPROACHES
AND I NSTITUTIONAL E FFECTIVENESS
Enable Prevention, Protection, and Prosecution through Collaboration
Effectively combating human trafficking requires lines of effort that complement and support
achievement of the other three aims of prevention, protection, and prosecution, in addition to
enhancing collaboration. Aiming to improve the United States Government’s institutional
capacity to combat this crime will lead to improved outcomes across multiple goals. In the 20
years since human trafficking became a Federal crime, the United States Government has made
significant progress in adapting its institutions to combat this threat effectively. This whole-of-
government approach will enhance opportunities to better partner together in this effort. In
particular, information gaps persist that hinder progress toward human trafficking prevention,
survivor protection, and enhanced prosecution. As a result, government agencies are seeking to
strengthen research, data collection, and integration. In order to enhance human trafficking
enforcement efforts, government agencies are also seeking ways to deliver strategic analysis,
generate actionable leads, and uncover evolving human trafficking trends.

This goal presents 18 priority actions organized under five principles related to strengthening
understanding of human trafficking; enhancing information sharing; incorporating survivor input;
conducting outreach to external partners; and evaluating authorities and resources to combat
human trafficking.
 
Priority Actions
Principle 4.1: Strengthen understanding of human trafficking impacting the
United States

The United States Government cannot effectively prosecute traffickers, assist victims, and prevent
trafficking, without first improving its understanding of the nature of the threat and its association
with transnational organized crime and illicit financial activity. Specifically, the United States
Government must better combine sources of information to map the threat: who is involved, what
illicit activity are they engaged in, and what are the associated financial flows. Using the most
current information to ensure that methodology to combat human trafficking keeps pace with
current illicit practices is imperative to successful actions. Access to strategic analysis of

 
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meaningful information about human trafficking is critical to leveraging all United States
Government tools to prevent and disrupt human trafficking and recover illicit proceeds.
 
Priority Action 4.1.1:  Conduct an intelligence assessment on human trafficking  
 
Within 120 days of the publication of the Action Plan, Federal law enforcement agencies with
support of the Intelligence Community will develop an intelligence assessment of human
trafficking with a nexus to the United States. The intelligence assessment will address both sex
trafficking and labor trafficking of adults and children with a nexus to the United States, as well
as the different typologies77 of human trafficking and methods of operation. The intelligence
assessment will integrate information from NGOs, and state, tribal and local Government entities
as appropriate and may be strategically focused on specific aspects of human trafficking. The
intelligence assessment will delineate the difference between human smuggling and human
trafficking while also depicting the means by which smuggled foreign nationals may become
victims of human trafficking.

Priority Action 4.1.2: Identify research gaps to better serve vulnerable populations
and underserved victims 

The SPOG Research and Data Committee will convene Federal agencies to determine what
additional research is needed to understand the impact of human trafficking on underserved or
vulnerable groups of victims, such as men and boys, LGBT+ individuals, American Indians,
Alaska Natives, Native Hawaiians, Pacific Islanders, racial and ethnic minorities, individuals with
disabilities, and youth in the child welfare system. From agency-funded research and analysis,
recommendations will be provided on how human trafficking programs can better support and
collaborate with these specific groups and how to bolster effective prevention and intervention
efforts. Such research would be beneficial for enhancing training and outreach, developing
policies, programs, and partnerships, and allocating resources. In addition, relevant Federal
agencies will continue to take steps to address the factors that increase vulnerabilities to human
trafficking.

Priority Action 4.1.3: Solicit research to identify effective interventions to combat

labor trafficking

More research is needed to understand labor trafficking and how best to address it. Enhanced
partnerships with DOL, DHS, HHS and other agencies may provide new avenues for increased
identification, refined measurement practices, and better understanding of recruitment patterns.
Additional research is needed to better understand the most at-risk industries, needs, and specific
vulnerabilities of victims. This research should include an analysis of gaps in agency authorities
to address at-risk industries and in programs to assist victims of forced labor. The analysis will be
disseminated to law enforcement and other first responders for integration into training.
 

                                                            
77
See The Typology of Modern Slavery: Defining Sex and Labor Trafficking in the United States (2017) available at
https://polarisproject.org/sites/default/files/Polaris-Typology-of-Modern-Slavery.pdf.
 
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Principle 4.2: Enhance information sharing to achieve a strategic outcome  

Efforts are underway to streamline departments and agencies access to relevant, actionable data
and intelligence on human trafficking crimes. This includes surveying existing data-sharing efforts
and technologies to identify gaps, challenges, and opportunities, both domestically and
internationally.

Enhanced information sharing is needed to support national-level planning and policy, leveraging
whole-of-government information and data holdings, to include law enforcement and Intelligence
Community information. Encouraging multidisciplinary approaches and department and agency
coordination on enforcement actions is imperative to successfully preventing human trafficking,
protecting victims, and prosecuting human traffickers to maximize the use of all United States
Government tools against significant threats.
 
Priority Action 4.2.1: Formalize routine law enforcement and Intelligence
Community engagement to ensure consistent knowledge sharing

The Intelligence Community will regularly meet with Federal law enforcement to exchange
information about current initiatives and information gaps and disseminate expertise from the field
including external partners. This group will share financial intelligence from financial institutions,
as appropriate and in accordance with applicable law and policy. This effort will facilitate
leveraging all source intelligence, identifying common aims, and harmonizing missions to support
departments and agencies coordination.

Priority Action 4.2.2: Ensure existing departments and agencies mechanisms – to

include international forums – are employed to counter specific transnational
human trafficking threats with a significant impact on the United States 

Collaboration, information sharing, and coordinated efforts with international counterparts for all
United States Government components in this process are necessary to fully understand and
disrupt illicit transnational activities. Anti-trafficking activities need to be synchronized at the
national level to unify a whole-of-government approach. Activities in this space will take into
account complementary efforts within the Intelligence Community and law enforcement agencies.
Dismantling of human trafficking entities would prevent future harm to the United States. The
National Security Council will convene Federal agencies within 30 days of publication of the
Action Plan to discuss and select options to leverage existing mechanisms to target and apply
existing authorities to significant human trafficking threats.

Priority Action 4.2.3: Integrate financial intelligence into anti-trafficking efforts

across the United States Government 
 
Leveraging financial intelligence is critical to identify, disrupt, and dismantle human trafficking
related threats. Financial intelligence provided by financial institutions includes currency
transaction reports, data about financial transactions indicative of money laundering and predicate
offenses including human trafficking, reports on the physical transportation of currency or certain
 
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other monetary instruments, and reports on foreign financial accounts. United States Government
agencies should further incorporate financial intelligence in existing efforts and proactively
implement actions to disrupt the financial flows of human traffickers and deny revenue sources to
human traffickers and corrupt facilitators. DOJ, DHS, DOL, and Treasury should coordinate and
leverage financial intelligence to target, investigate, and apply the full range of enforcement
actions to disrupt the illicit use of the financial system by targeting priority human traffickers and
facilitators. The Intelligence Community will support this effort with information, as available.

Additionally, appropriate law enforcement agencies and appropriate Federal agencies will work to
improve human trafficking-related information sharing between such agencies and financial
institutions, as well as information sharing among financial institutions.78

Priority Action 4.2.4: Ensure human trafficking data collection, fusion, analysis,
and dissemination efforts are included in the proposal of the National Security
Presidential Memorandum-7 transnational organized crime process 

The National Security Council staff will convene a working group involving intelligence and law
enforcement agencies and PITF agencies with significant relevant data sets in order to develop a
proposal for data collection, fusion, analysis and dissemination. The proposal will contribute to
the National Security Presidential Memorandum–7 process79 for the transnational organized crime
executive agent, which is charged with developing a data fusion solution. The proposal will also
address intelligence analysis and dissemination efforts. Dissemination can support enforcement
operations, awareness or influence campaigns conducted by other agencies, and other important
government purposes. The proposal will identify relevant data sets, study existing fusion
mechanisms that can be leveraged, and identify dissemination needs.

Principle 4.3: Strengthen Federal anti-trafficking efforts by incorporating

survivor input  
Survivor input into anti-trafficking efforts is critical, as reflected in law and Federal policy
priorities. Survivor voices are a vital part of establishing effective and comprehensive anti-
trafficking strategies that advance prosecution, protection, and prevention efforts.

                                                            
78
See Section 7154(a) of the National Defense Authorization Act for Fiscal Year 2020 (Pub. L. No. 116-92), which
provides an analysis of anti-money laundering efforts of the United States Government, United States financial
institutions, and international financial institutions related to human trafficking and recommendations to strengthen
the efforts of those institutions.
79
National Security Presidential Memorandum–7 is the Presidential Memorandum that outlines the policy in which
the United States Government analyzes, evaluates, integrates, correlates, and shares classified national security
information and other information concerning threat actors and their networks, and then uses that information to
support a broad array of national security missions and activities, which is an essential component of our national
security strategy. See: https://www.whitehouse.gov/presidential-actions/national-security-presidential-
memorandum-7/.

 
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Priority Action 4.3.1: Prioritize implementation of the United States Advisory

Council on Human Trafficking’s recommendations 

Each member of the United States Advisory Council on Human Trafficking is a survivor of
trafficking; as part of its mandate,80 the Council advises the Federal Government on how to
strengthen its anti-trafficking policies and programs. The Council provides specific
recommendations through an annual report, regular engagement with Federal agencies, and via its
participation in PITF meetings. United States agencies should continue to strengthen engagement
with the Council and consider implementation of its recommendations.

Priority Action 4.3.2: Leverage Federal survivor-consultant networks and Federal

training and technical assistance centers to ensure survivor input is consistently
incorporated into Federal policies and programs  

The United States Government has engaged with survivor experts in various ways throughout the
years. For example, DOJ, HHS, DHS, and DOS have mechanisms to integrate survivor consultant
expertise into policies and programs. All PITF agencies will examine their efforts to incorporate
survivor input into their work. In developing and implementing Federal anti-trafficking policies
and programs, each Federal agency will receive and consider incorporating survivor input. Some
Federal entities’ programs are informed by survivors through training and technical assistance
centers, robust consultant pools or recommendations from formal advisory bodies. Other agencies
should develop a plan to begin working with survivors who have subject-matter expertise and
relevant skills. Such plans should be trauma-informed, and build on survivors’ knowledge and
skills while also making a positive contribution toward further empowerment. Through the Human
Trafficking Expert Consultant Network, DOS will lead an effort to assess successes and challenges
of Federal efforts to engage survivors.

Principle 4.4: Strengthen Federal anti-trafficking efforts through external

partnerships  
Engagement, information sharing, and consistent messaging from the United States Government
with external partners is essential. Partners and the public need information on human trafficking
to take action.

Priority Action 4.4.1: Conduct future outreach initiatives based on a review of prior
Federal outreach efforts 

Targeted outreach is needed to stakeholders and communities that typically underreport human
trafficking and to high-risk industries, especially those that do not have corporate responsibility
efforts to combat human trafficking in global supply chains. The SPOG Public Awareness and
Outreach Committee will convene Federal agencies to create a comprehensive inventory and
description of Federal human trafficking prevention and protection outreach efforts, awareness
campaigns, and toolkits and any evaluations of their effectiveness. This will lead to
                                                            
80
See Pub. L. No. 114-22, § 115 (2015).
 
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recommendations on adapting these efforts and materials going forward to be more inclusive,
victim-centered, and survivor-informed. This review will be updated annually after completion.

Priority Action 4.4.2: Provide information to the private sector on the threat of
human trafficking to better identify human trafficking facilitators and victims  

DHS and FBI will offer targeted information and messaging on the nature of human trafficking
impacting the United States. Treasury, in collaboration with law enforcement, will provide
outreach to financial sector partners on illicit finance associated with human trafficking. Targeted
information and assessments will include precise typologies, indicators, regionally specific
information, and methodologies of traffickers. In addition to information on traffickers,
information related to human trafficking indicators is necessary for prevention efforts. Critical
partners to receive this information and provide their insight include industries that intersect with
human trafficking such as agriculture, transportation, hospitality, health, education, technology,
social media, and the financial sector, including cryptocurrency exchangers. The DHS Blue
Campaign will develop targeted human trafficking indicator cards in partnership with survivors
and agencies to raise awareness among these various sectors, as well as faith-based organizations.
HHS will provide a series of information briefs on how human trafficking impacts health and
human service systems, including impact on health sector procurement. Agencies can leverage
the Sector Coordinating Councils81 to provide information to the private sector. DOT will expand
Transportation Leaders Against Human Trafficking outreach efforts to private sector partners
through leadership engagement, employee training, public awareness, and development of a
multimodal training, expanded public awareness materials, and an anti-trafficking toolkit.

Priority Action 4.4.3: Regularly provide information on threats, vulnerabilities,

trends, and investigations to state, local, tribal, and territorial governments

Each FBI and HSI field office will provide periodic briefings to senior state government officials
and select local, tribal, and territorial government officials within their area of responsibility. The
Attorney General through the Enforcement Working Group, composed of state and local
prosecuting authorities, will provide information including on United States Government activities
to combat human trafficking.

                                                            
81
 The Sector Coordinating Councils (SCCs) are self-organized and self-governed councils that enable critical
infrastructure owners and operators, their trade associations, and other industry representatives to interact on a wide
range of sector-specific strategies, policies, and activities. The SCCs coordinate and collaborate with sector-specific
agencies (SSAs) and related Government Coordinating Councils (GCCs) to address the entire range of critical
infrastructure security and resilience policies and efforts for the sector. 
 
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Priority Action 4.4.4: Develop a recommendation for Secretary-level, 5 country

multilateral meeting on human trafficking

Partnering with foreign governments is critical to combating transnational human trafficking and
its facilitators. For the next Five Country Ministerial82 meeting, Federal agencies will develop a
recommendation on how to better collaborate on human trafficking. Potential recommendations
for areas of collaboration include intelligence and information sharing, emerging technologies,
joint investigations and assessments, victim protection, and policy initiatives.

Priority Action 4.4.5: Strengthen international frameworks to combat human

trafficking in the maritime domain

The United States Government has limited ability to enforce provisions under 18 United States
Code Chapter 77 on non-United States flagged vessels outside of the United States’ territorial sea.
As such, the United States Government’s responses to suspected human trafficking on such vessels
rely heavily on intergovernmental cooperation. Accordingly, the United States Coast Guard, DOS,
USAID, DOJ, and other Federal agencies will work to create frameworks to coordinate and
cooperate with international partners to promote the identification and protection of victims of
human trafficking as well as the investigation and prosecution of perpetrators.

Priority Action 4.4.6: Engage with international multilateral fora to develop

transportation-specific anti-trafficking educational resources

DOT will review and assess transportation-related anti-trafficking efforts within Asia Pacific
Economic Cooperation countries to develop a set of training and awareness best practices and
educational resources to be shared through a series of webinars and a workshop. These resources
may be used by Asia Pacific Economic Cooperation’s 21 member countries to educate
transportation employees and the traveling public to recognize and report potential instances of
human trafficking to the proper authorities. DOT will also engage with the International Civil
Aviation Organization (ICAO) to develop guidance for ICAO’s 193 member countries to combat
human trafficking. This guidance could include a comprehensive strategy to combat human
trafficking in aviation with key components such as policies and protocols, employee training,
public awareness, data and information sharing, and partnerships.
 
Priority Action 4.4.7: Improve and consolidate human trafficking tip line operations
The United States Government will conduct a review of all available Federal agencies’ tip lines
on human trafficking in the United States. Following this review, HHS will follow up with DHS,
DOJ, and other agencies to assist these agencies in consolidating outreach efforts and directing
callers to the National Human Trafficking Hotline. These consolidation efforts will include
                                                            
82
 The Five Country Ministerial is a forum whereby Australia, Canada, New Zealand, the United States and the
United Kingdom meet to discuss shared emerging threats. See: https://www.gov.uk/government/publications/five-
country-ministerial-communique.  
 
 
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recommendations for streamlining United States Government tip line intake channels specific to
the importation of goods produced with forced labor and making intake information available in a
timely manner within the United States Government to relevant enforcement agencies.

Principle 4.5: Continuously evaluate the authorities and resources of the

United States Government to combat human trafficking 
 
Through the development of the Action Plan, Federal agencies identified gaps and challenges that
require new administrative and statutory authorities or funding allocations to combat human
trafficking. Identifying gaps and challenges should not be a one-time exercise, but rather be
continuously evaluated to ensure the government is adapting to new challenges, threats, and needs.  
 
Priority Action 4.5.1: Explore opportunities for legislative proposals
 
Executive agencies will identify gaps in their ability to prevent human trafficking, protect victims
of trafficking, and prosecute human traffickers that require legislation to address. As appropriate,
executive agencies will consult with departments and agencies, survivor experts, and external
stakeholders to develop these proposals. Agencies will have the opportunity to submit these
proposals for consideration as part of the President’s Budget. 
 
Priority Action 4.5.2: Conduct an assessment of United States Government
allocation of existing resources to combat human trafficking
 
Currently, the United States Government lacks a comprehensive assessment of how personnel and
resources are allocated in Federal efforts to combat human trafficking. This gap hinders the
government’s ability to prioritize efforts. Agencies will assess the delineation of human trafficking
specific resources, should departments and agencies conduct a similar assessment on transnational
organized crime. 

 
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★ ★ ★ 
A PPENDIX A: G LOSSARY OF T ERMS
 
Forms of Human Trafficking83

Forced Labor84: The term forced labor is defined in two separate sections of the United States
Code. In the criminal statutes of Title 18, it encompasses the range of activities involved when a
person uses force or physical threats; psychological coercion; abuse of the legal process; a scheme,
plan, or pattern intended to hold a person in fear of serious harm; or other coercive means to obtain
the labor or services of a person. Once a person’s labor is obtained by such means, the person’s
previous consent or effort to obtain employment with the trafficker does not preclude the person
from being considered a victim, or the government from prosecuting the offender. In the customs-
related statute of Title 19, it is also defined in connection with the prohibition on the importation
of goods produced wholly or in part by forced labor, including forced child labor; convict labor;
and indentured labor under penal sanctions.

 Debt Bondage: United States law prohibits the use of a debt as a form of coercion to
compel a person’s labor. Some workers fall victim to traffickers or recruiters who
unlawfully exploit an initial debt assumed as a condition of employment, while in certain
countries some workers “inherit” the debt. Although contract violations and hazardous
working conditions for foreign national laborers do not in themselves constitute human
trafficking, the imposition of costs and debts on these laborers can contribute to a situation
of debt bondage. In other cases, employment-based temporary work programs in which
the workers’ legal status in the country is tied to a particular employer present challenges
to workers who would like to flee from such an employer.

 Domestic Servitude: Working in a private residence can create unique vulnerabilities,

particularly because what happens in a private residence often is hidden from the world,
and it is easy to isolate a worker in a private residence. Domestic workplaces are often
informal, connected to off-duty living quarters, and not shared with other workers. Such
an environment is conducive to exploitation because authorities cannot inspect private
homes as easily as formal workplaces. The use of informal, or even verbal, employment
                                                            
83
 See President’s Interagency Task Force Report on United States Government Efforts to Combat Trafficking in
Persons (December 2017), available at https://www.state.gov/wp-
content/uploads/2018/12/report_usg_tip_efforts.pdf. 
84
While the term “labor trafficking” does not appear in the United States Code, it is another term that the United
States Government uses to refer to human trafficking involving compelled labor, as distinct from sex trafficking.
 
 
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contracts compounds vulnerability. Foreign domestic workers are particularly vulnerable

to abuse due to factors such as language and cultural barriers and lack of community ties.

 Forced Child Labor: Although children may legally engage in certain forms of work,
forms of slavery or slave-like practices – including the sale of children for exploitation,
forced or compulsory child labor, and debt bondage and serfdom of children – continue to
exist, despite legal prohibitions and widespread condemnation.

Sex Trafficking: When a person is required to engage in a commercial sex act as the result of
force, threats of force, fraud, coercion or any combination of such means, that person is a victim
of human trafficking. Under such circumstances, perpetrators involved in recruiting, enticing,
harboring, transporting, providing, obtaining, advertising, maintaining, patronizing, or soliciting a
person for that purpose are guilty of the Federal crime of sex trafficking. This is true even if the
victim previously consented to engage in commercial sex.

 Child Sex Trafficking: Any child (under the age of 18) who has been recruited, enticed,
harbored, transported, provided, obtained, advertised, maintained, patronized, or solicited
to engage in a commercial sex act is a victim of human trafficking regardless of whether
or not force, fraud, or coercion is used. The use of children in the commercial sex trade is
prohibited both under United States law and by legislation in most countries around the
world.

Transnational or extraterritorial child sexual abuse

Transnational or extraterritorial child sexual abuse (formerly referred to as child sex

tourism): Though not every instance of transnational or extraterritorial child sexual abuse is child
sex trafficking, this offence can involve child sex trafficking when the offender engages in a
commercial sex act with a child. Transnational or extraterritorial child sexual abuse is a crime that
occurs when an American citizen or legal permanent resident travels to a foreign country or resides
abroad (whether permanently or temporarily) and engages in illicit sexual conduct with a child. It
is also a crime to arrange or facilitate such travel for the purpose of commercial or private profit.
This conduct is a crime whether or not the offender had the intent to engage in sexual activity with
a child before the travel took place. 18 U.S.C. § 2423(b)-(d).

Additional Terms

Victim: This term means a person that has suffered direct physical, emotional, or pecuniary harm
as a result of the commission of a crime. 34 U.S.C. § 20141(e)(2).

Survivor: A term used for an individual who suffered harm as a result of criminal conduct and
that recognizes the strength it takes to continue on a journey toward healing in the aftermath of a
traumatic experience.85

                                                            
85
This definition was adapted slightly from the Federal Strategic Action Plan on Victim Services for Victims of
Human Trafficking in the United States 2013-2017 available at
https://ovc.ojp.gov/sites/g/files/xyckuh226/files/media/document/FederalHumanTraffickingStrategicPlan.pdf.
 
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Victim-centered approach: Placing the crime victim’s priorities, needs, and interests at the
center of the work with the victim; providing nonjudgmental assistance, with an emphasis on self-
determination, and assisting victims in making informed choices; ensuring that restoring victims’
feelings of safety and security are a priority and safeguarding against policies and practices that
may inadvertently re-traumatize victims. A victim-centered approach should also incorporate a
trauma-informed, survivor-informed, and culturally competent approach.86

Trauma-informed approach: A trauma-informed approach recognizes signs of trauma in

individuals and the professionals who help them and responds by integrating knowledge about
trauma into policies, procedures, practices, and settings. This approach includes an understanding
of the vulnerabilities and experiences of trauma survivors, including the prevalence and physical,
social, and emotional impact of trauma. A trauma-informed approach places priority on restoring
the survivor’s feelings of safety, choice, and control. Programs, services, agencies, and
communities can be trauma-informed.87

Survivor-informed: A program, policy, intervention, or product that is designed, implemented,

and evaluated with intentional leadership, expertise and input from a diverse community of
survivors to ensure that the program, policy, intervention, or product accurately represents their
needs, interests, and perceptions.88

Cultural competence: The ability of an individual or organization to interact effectively with

people of different cultures. This includes drawing on knowledge of culturally based values,
traditions, customs, language, and behavior to plan, implement, and evaluate service activities.
Some organizations use the terms “cultural accountability” or “cultural responsiveness.” 89

Immigration Options
Continued Presence: A temporary immigration designation provided to individuals identified by
law enforcement as victims of “severe forms of trafficking in persons” who may be potential
witnesses. This status allows human trafficking victims to lawfully remain in the United States
temporarily and work during the investigation into the human trafficking-related crimes committed
against them and during any civil action under 18 U.S.C. § 1595 filed by the victims against their
traffickers. Continued Presence is initially granted for 2 years and may be renewed in up to

                                                            
86
This definition was adapted slightly the Department of Justice, Office for Victims of Crime Model Standards for
Serving Victims and Survivors of Crime, available at https://ovc.ojp.gov/sites/g/files/xyckuh226/files/model-
standards/5/glossary.html.
87
This definition was adapted slightly the Department of Justice, Office for Victims of Crime Model Standards for
Serving Victims and Survivors of Crime, available at https://ovc.ojp.gov/sites/g/files/xyckuh226/files/model-
standards/5/glossary.html.
88
This definition was adapted slightly from the Department of Justice, Office for Victims of Crime Model Standards
for Servicing Victims and Survivors of Crime, available at https://ovc.ojp.gov/sites/g/files/xyckuh226/files/model-
standards/5/glossary.html.
89
This definition provided is from the Department of Justice, Office for Victims of Crime Model Standards for
Serving Victims and Survivors of Crime, available at https://ovc.ojp.gov/sites/g/files/xyckuh226/files/model-
standards/5/glossary.html. 

 
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2-year increments. Continued Presence recipients also receive Federal benefits and services.
22 U.S.C. § 7105(c)(3)(A)(i)

T nonimmigrant status (“T visa”): An immigration benefit that is available to eligible victims
of “severe forms of human trafficking.”90 To be eligible, the victim must have complied with any
reasonable request for assistance in a Federal, state, local, tribal, or territorial investigation or
prosecution of human trafficking cases, and meet other requirements. Victims under the age of
18 and victims unable to cooperate because of physical or psychological trauma are not required
to comply with any reasonable law enforcement requests for assistance. T nonimmigrant status is
valid for 4 years; T nonimmigrants may be able to adjust their status and become lawful permanent
residents if they qualify. 8 U.S.C. § 1101(a)(15)(T); 8 U.S.C. § 1184; 8 U.S.C. § 1255; 8 CFR §
214.11

U nonimmigrant status (“U visa”): An immigration benefit that is available to victims of certain
qualifying crimes in the United States – including human trafficking – who have been helpful, are
being helpful, or are likely to be helpful to law enforcement in the investigation or prosecution of
the qualifying criminal activity, and meet other requirements. The U visa is a tool intended to
strengthen the ability of law enforcement agencies to investigate and prosecute certain types of
crimes, while also protecting crime victims and encouraging them to come forward and assist law
enforcement. U nonimmigrant status is valid for 4 years and can be extended in limited
circumstances; U nonimmigrants may be able to adjust their status and become lawful permanent
residents if they qualify. 8 U.S.C.. § 1101(a)(15)(U); 8 U.S.C. § 1184; 8 U.S.C. § 1255; 8 CFR §
214.14
_____________

                                                            
90
 The term “severe forms of trafficking in persons” is defined in 22 § U.S.C. 7102(11).
 
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★ ★ ★ 
A PPENDIX B: P RIMARY A UTHORITIES
 
Trafficking Victims Protection Act (TVPA)
 Victims of Trafficking and Violence Protection Act of 2000, Pub. L. No. 106-386 (2000)
 Trafficking Victims Protection Reauthorization Act of 2003, Pub. L. No. 108-193 (2003)
 Trafficking Victims Protection Reauthorization Act of 2005, Pub. L. No. 109-164 (2005)
 William Wilberforce Trafficking Victims Protection Reauthorization Act of 2008, Pub. L.
No. 110-457 (2008)
 Violence Against Women Reauthorization Act of 2013, Pub. L. No. 113-4 (2013)
 Trafficking Victims Protection Act of 2017, Pub. L. No. 115-393 (2018)
 Abolish Human Trafficking Act of 2017, Pub. L. No. 115-392 (2018)
 Trafficking Victims Protection Reauthorization Act of 2017, Pub. L. No. 115-427 (2019)
 Frederick Douglass Trafficking Victims Prevention and Protection Reauthorization Act of
2018, Pub. L. No. 115-425 (2019)
Criminal Statutes
 18 U.S.C. § 1589 – Forced Labor
 18 U.S.C. § 1590 – Trafficking with respect to peonage, slavery, involuntary servitude, or
forced labor
 18 U.S.C. § 1591 – Sex trafficking of children or by force, fraud or coercion
 18 U.S.C. § 1956 – Laundering of monetary instruments
 18 U.S.C. § 1963 – Racketeer Influenced and Corrupt Organizations (RICO) Criminal
penalties
 18 U.S.C. § 2422 – Coercion and enticement of minor
 18 U.S.C. § 2423 – Transportation of minors
 18 U.S.C. § 2251 – Sexual exploitation of children
 18 U.S.C. § 2252 – Certain activities relating to material involving the sexual exploitation
of minors
 18 U.S.C. § 2252A – Certain activities relating to material involving the sexual exploitation
of minors
 18 U.S.C. § 2260 – Production of sexually explicit depictions of a minor for importation
into the United States
 18 U.S.C. § 1351 – Fraud in foreign labor contracting
 18 U.S.C. § 1597 – Unlawful conduct with respect to immigration documents
 
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Trade and Goods Produced with Forced Labor Statutes and Regulations
 18 U.S.C. §§ 1761, 1762 – Importation and Transportation in Interstate Commerce of
Prison-Made Goods
 19 CFR §§ 12.42 – 12.45 – Merchandise Produced by Convict, Forced, or Indentured Labor
 United States – Mexico – Canada Agreement Implementation Act of 2020, Sec. 741 – 744
on forced Labor (Pub. L. 116 – 113)
 Section 307 of the Smoot-Hawley Tariff Act of 1930 (19 U.S.C. § 1307)
 Countering America’s Adversaries Through Sanctions Act (CAATSA), Pub. L. No. 115-
44(2017)
 Executive Order 13627 of Sept. 25, 2012 (Strengthening Protections Against Trafficking
in Persons in Federal Contracts)
 Executive Order 13126 of June 12, 1999 (Prohibition of Acquisition of Products Produced
by Forced or Indentured Child Labor)
 Executive Order 13923 of May 15, 2020 (Establishment of the Forced Labor Enforcement
Task Force Under Section 741 of the United States – Mexico – Canada Agreement
Implementation Act of 2020)

Other Key Mandates and Regulations

 Justice for Victims of Trafficking Act of 2015, Pub. L. No. 114-22 (2015)
 The PROTECT Act (Pub. L. No. 108-21) created 18 U.S.C. § 2423(c), which targets those
United States citizens or aliens admitted for permanent residence in the United States that
travel abroad for purpose of engaging in sex with a minor.
 National Defense Authorization Act of 2013 (Pub. L. No. 112-239), which provides
authorities to end human trafficking in government contracting in Title XVII.
 Preventing Sex Trafficking and Strengthening Families Act of 2014 (Pub. L. No. 113-183)
which prevents and addresses sex trafficking of children in foster care and establishes the
national advisory committee on the sex trafficking of children and youth in the United
States.
 Every Student Succeeds Act of 2015 (Pub. L. No. 114-95) authorizes support for safe and
healthy students, including providing high quality training for school personnel on violence
prevention topics including human trafficking.
 SOAR to Health and Wellness Act of 2018 (Pub. L. No. 115-398), which amended the
Public Health Service Act to strengthen training and response to human trafficking in the
health care system.
 FAA Reauthorization Act of 2018 (Pub. L. No. 115-254) expands the 2016 requirement
for air carriers to train flight attendants to recognize and report human trafficking to
customer-facing employees. Combating Human Trafficking in Commercial Vehicles Act
(Pub. L. No. 115-99) authorizes DOT to establish the DOT Advisory Committee on Human
Trafficking, appoint a human trafficking prevention coordinator, and expand motor carrier
funding and educational outreach programs to encompass prevention activities. No Human
Trafficking on Our Roads Act of 2018 (Pub. L. No. 115-106) includes a lifetime
 
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Commercial Drivers License disqualification for an individual who uses a commercial

motor vehicle in committing a felony involving a severe form of human trafficking.
 Department of Homeland Security Blue Campaign Authorization Act of 2018 (Pub. L. No.
115-125)
 Missing Children’s Assistance Act of 2018 (Pub. L. No. 115-267) improves support for
missing and exploited children in the juvenile justice system including the identification,
location, and recovery of victims of and children at risk for child sex trafficking.
 Juvenile Justice Reform Act of 2018 (Pub. L. No. 115-385) strengthens protections for
victims of human trafficking, including screening, identification, and documentation of
victims and those at risk for human trafficking upon intake.
 International Megan’s Law (Pub. L. No. 114-119) – Signed into law on February 8, 2016,
to Prevent Child Exploitation and Other Sexual Crimes through Advanced Notification of
Traveling Sex Offenders.
 31 U.S.C. §§ 5311 – 5330 – Bank Secrecy Act of 1970
 22 U.S.C. § 7108 – Actions Against Significant Traffickers in Persons (2019)
 Allow States and Victims to Fight Online Sex Trafficking Act of 2017, Pub. L. No. 115-
164.
 8 CFR § 214.11 – Alien victims of severe forms of trafficking in persons
 8 CFR § 214.14 – Alien victims of certain qualifying criminal activity
 48 CFR § 52.222-50 – Combating Trafficking in Persons
 Executive Order 13773 of Feb. 9, 2017 (Enforcing Federal Law with Respect to
Transnational Criminal Organizations and Preventing International Trafficking)
 Executive Order 13581 of July 25, 2011 (Blocking Property of Transnational Criminal
Organizations)
 Executive Order 13818 of Dec. 21, 2017 (Blocking the Property of Persons Involved in
Serious Human Rights Abuse or Corruption)
 Federal Acquisition Regulation 55.222-18,-19, and -50
 The Crime Victims’ Rights Act – 18 U.S.C. § 3771 and 34 U.S.C. § 20141
 Victim Rights and Restitution Act – 34 U.S.C. § 20141
 Mandatory Victim Restitution Act – 18 U.S.C. § 3663A

 
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