Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 1 of 44 Table of Content Contents Acknowledgement..................................................................................................................................... 4 Executive Summary..................................................................................................................................... 7 1.0 Introduction ............................................................................................................................................ 8 1.1 Objective of the report ................................................................................................................... 8 1.2 Methodology...................................................................................................................................... 9 1.3 Understanding the Predicate Crime ......................................................................................... 10 2.0 Legal and Institutional Framework on Human Trafficking and Migrant Smuggling......... 13 2.1 Legal and institutional framework in Nigeria........................................................................... 13 2.2 Regional Framework ....................................................................................................................... 14 2.3 International Legal Framework.................................................................................................... 14 3.0 Fighting Human Trafficking and Migrant Smuggling: The Perspective of Nigeria’s Agencies...................................................................................................................................................... 15 3.1 Knowledge of the Crime ............................................................................................................... 15 3.2 Demography of Victims and Causes of the Crime................................................................ 15 3.3 Operational Mode of Human Traffickers & Migrant Smugglers in Nigeria ...................... 16 3.4 Geographical Location and Relationship with Crimes......................................................... 17 4.0 Categorization of Typologies........................................................................................................... 19 Typology 1: Use of cash in laundering proceeds of crime......................................................... 19 Typology 2: Use of non-financial sector to launder proceeds of crime................................. 20 Typology 3: Use of formal and informal international money transfer operators................ 21 Typology 4: Use of Non-Profit Organisations .................................................................................. 24 Typology 5: The use of migrants to smuggle cash........................................................................ 25 Typology 6: Organised criminal gangs in migrant smuggling................................................... 28 Typology 7: Integration of proceeds of crime into real estate................................................. 29 4.1 General Red flags & indicators....................................................................................................... 30 4.2 Human Trafficking and Migrant Smuggling Jurisdiction of Concern.................................... 31 5.0 Money Laundering Trends Associated with Human Trafficking and Migrant Smuggling32 5.1 Emerging trends and technologies ........................................................................................... 33

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 2 of 44 5.2 Vulnerable sectors.......................................................................................................................... 34 5.3 Other crimes associated with human trafficking & migrant smuggling.......................... 35 6.0 Nigeria’s Effort in Fighting Human Trafficking & Migrant Smuggling..................................... 35 6.1 Challenges in the Fight Against Human Trafficking and Migrant Smuggling in Nigeria . 38 7.0 Conclusion ............................................................................................................................................ 39 7.1 International Best Practices for Combatting Human Trafficking and Migrant Smuggling ........................................................................................................................................................................ 39 7.2 Recommendations............................................................................................................................. 41 Figure 1: Geographical Heat map/location of human trafficking and migrant smuggling in Nigeria ........................................................................................................................................................................ 17 Figure 2: Human Trafficking and migrant smuggling jurisdiction of concern ........................................ 32

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 3 of 44 A publication of the Nigerian Financial Intelligence Unit The Nigerian Financial Intelligence Unit (NFIU) is the central national agency responsible for the receipt of disclosures from reporting organizations, the analysis of these disclosures and the production of intelligence for dissemination to competent authorities. The NFIU is an autonomous unit, domiciled within the Central Bank of Nigeria and the central coordinating body for the country’s Anti-Money Laundering, Counter-Terrorist Financing and Counter-Proliferation Financing (AML/CFT/CPF) framework. No reproduction or translation of this publication may be made without prior written permission. Applications for such permissions, for all or part of this publication, should be made to The Director/Chief Executive Officer, Nigerian Financial Intelligence Unit 12, Ibrahim Taiwo Street, Aso Villa Abuja, Nigeria 1, Monrovia Street, Block 3, Wuse II, Abuja, Nigeria (e-mail: info@nfiu.gov.ng)

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 4 of 44 Acknowledgement We extend our profound gratitude to all those who contributed to the successful completion of this report on money laundering typologies through human trafficking and migrant smuggling in Nigeria. We would like to express our heartfelt appreciation to the following agencies for their tremendous support and contributions towards the completion of this project:

1. Department of State Services
2. Economic & Financial Crimes Commission
3. National Agency for the Prohibition of Trafficking in Persons
4. Nigerian Immigration Service
5. The International Criminal Police Organization – National Central Bureau This collaborative effort between government agencies is crucial in comprehending the intricate dynamics of money laundering through human trafficking & migrant smuggling, especially in the context of emerging technologies. The recognition of the high threat posed by money laundering through these crimes, as identified in Nigeria’s national inherent risk assessment of money laundering in Nigeria 2022, underscores the urgency and importance of this study. The outcomes of this research are poised to elevate our collective understanding and response to the ever-evolving challenges posed by human trafficking & migrant smuggling activities. This report will serve as a vital resource for reporting entities and competent authorities, equipping them with the knowledge required to detect and combat human trafficking & migrant smuggling cases effectively. Finally, we would like to express our gratitude to all of the Nigerian Financial Intelligence Unit (NFIU) team members whose persistent work and commitment made this study possible. We appreciate their efforts to this project and their excellent dedication to professionalism and quality. Thank you all for your support and contributions to this report on money laundering typologies through human trafficking & migrant smuggling in Nigeria. Hafsat Abubakar Bakari Director/CEO Nigerian Financial Intelligence Unit

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 5 of 44 LIST OF ACRONYMS AML Anti-Money Laundering ASEAN Association of Southeast Asian Nations CID Common Investigative Database CFT Counter Financing of Terrorism CPF Counter Proliferation Financing DSS Department of State Services ECOWAS Economic Community of West African States EFCC Economic and Financial Crimes Commission FATF Financial Action Task Force GBV Gender Based Violence GOA Government Accountability Office IDPs Internally Displaced Persons ILO International Labor Organization IMTOs International Money Transfer Operators INTERPOL￾NCB International Criminal Police Organisation - National Central Bureau LEA Law Enforcement Agencies MENAFATF MOU Middle East and Africa Financial Action Task Force Memorandum of understanding ML/TF MVTS Money Laundering/ Terrorism Financing Money Value Transfer Service NAPTIP National Agency for the Prohibition of Trafficking in Persons NCS Nigeria Customs Service NFIU Nigerian Financial Intelligence Unit NGO Non-Profit Organization NIS Nigeria Immigration Service NPF Nigeria Police Force NSDC Nigerian Civil Defence Corps

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 6 of 44 OSCE Organization for Security and Cooperation in Europe STR Suspicious Transaction Report THB Trafficking in Human Beings UNODC United Nations Office on Drugs and Crimes

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 7 of 44 Executive Summary The Nigerian Financial Intelligence Unit (NFIU), in collaboration with other competent authorities, embarked on this typology study in order to understand the money laundering risks posed by human trafficking and migrant smuggling. The study aims to categorise the various typologies and methods employed by criminal gangs involved in these crimes. It also aims to provide insights to law enforcement agencies and policymakers involved in the detection and disruption of the networks and groups perpetrating these crimes. The report emphasises the various legislation that the country has put in place to tackle these crimes and the regional and international frameworks that Nigeria is a signatory to. Respondent agencies shared their views on how these crimes occur. These views included the reasons behind the crimes and the methods used in finding new victims, as well as the ways that victims are transported and housed, including the type of safe houses where they are kept before they embark on their journey. The report also listed the frequent routes taken by both human traffickers and smugglers. In particular, this report focuses on the different typologies of human trafficking and migrant smuggling that are used in laundering the proceeds of crime. These include the use of cash, the use of international money transfer operators, the use of non-profit organisations, the use of money-mules to smuggle cash across borders, organised criminal groups engaging in fraudulent activities against migrants, and the integration of proceeds of criminal activities into the real estate sector. The use of new technologies to move and store the proceeds of crime were also considered It highlighted the most vulnerable sectors exploited in committing these crimes, along with other offences related to human trafficking and migrant smuggling. The report shed light on the various efforts of the Nigerian government to curb these crimes, including legislation, domestic and international collaboration, victim support, training and capacity building for officials, and public awareness campaigns. Additionally, respondent agencies outlined the challenges faced in combating these crimes. These crimes are global in nature; therefore, the report examines the strategies adopted in curbing these crimes by five countries: the Netherlands, Australia, the United States, Thailand, and Italy. This will help Nigeria learn from their success stories and replicate the various approaches they have taken to tackle these crimes. Recommendations were proposed to the government and policymakers, reporting entities, and the general public to reduce and prevent these crimes from occurring in the future.

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 8 of 44 1.0 Introduction In the global fight against human trafficking and migrant smuggling, Nigeria emerges as a significant focal point, grappling with the intricate web of criminal syndicates operating within its borders. This typology report meticulously dissects the methodologies employed by traffickers and criminal organizations, shedding light on the deleterious impacts of these crimes on public health, societal security, and economic resilience. With a comprehensive scope, the report aims to provide actionable strategies to disrupt and dismantle criminal networks. Drawing insights from diverse sources including literature reviews, prior typology reports, and international agreements, this report offers a thorough examination of the predicate crimes associated with human trafficking and migrant smuggling. Highlighting Nigeria's pivotal role as a source, transit point, and destination for human trafficking, the report underscores the urgent need to address the financial dimensions of these crimes. It emphasizes the importance of understanding the intricate financial networks that facilitate trafficking and smuggling operations, advocating for a robust 'follow the money' approach to combat these pervasive crimes effectively. Furthermore, the report delves into the risks of money laundering and terrorist financing arising from migrant smuggling activities, emphasizing the necessity of proactive strategies and international cooperation to disrupt illicit financial flows. It also explores policy responses to technology-facilitated trafficking, acknowledging the evolving challenges posed by technological advancements. By synthesizing insights from various stakeholders, including law enforcement agencies, investigative bodies, and border control authorities, this report offers actionable recommendations to reinforce the operational capabilities of stakeholders involved in combating human trafficking and migrant smuggling. Through a collaborative approach, informed by empirical evidence and international best practices, this report endeavours to contribute significantly to the ongoing efforts to eradicate these crimes and safeguard vulnerable populations. 1.1 Objective of the report The objective of this report is to systematically categorize and analyse the various typologies and methodologies employed by traffickers and criminal organizations involved in human trafficking and migrant smuggling activities, thereby providing valuable insights for law enforcement agencies, policymakers, and stakeholders to enhance prevention, intervention, and prosecution efforts. The objectives are listed as follows:

1. Examine the intricacies of human trafficking and migrant smuggling networks within Nigeria, dissecting their multifaceted impacts on public health, societal security, and economic resilience.

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 9 of 44 2. Understand and recognise the distinction between human trafficking and migrant smuggling and their connective relationship on how migration starts voluntarily and often turns into exploitation. 3. Scrutinize existing legal and regulatory frameworks to identify loopholes and hurdles hindering the effective enforcement of anti-human trafficking and migrant smuggling measures in Nigeria. 4. Foster collaboration and emphasize the importance of information sharing and capacity building initiatives vital for Nigeria's efforts in tackling human trafficking and migrant smuggling and other transnational crime networks. 5. Identify key sectors and geographical regions at heightened risk of human trafficking and migrant smuggling activities, uncovering distinct typologies associated with trafficking and money laundering. 6. Provide actionable recommendations tailored to bolster the operational capabilities of law enforcement agencies, policymakers, and stakeholders, fostering a collaborative approach to disrupt and dismantle criminal networks engaged in human trafficking and migrant smuggling. 7. Provide guidance to reporting entities in identifying the red flags and indicators of human trafficking and migrant smuggling to report suspicious activities surrounding their financial exploitation. 1.2 Methodology A working group was duly constituted by the NFIU to effectively conduct this research, with representatives from various law enforcement and security agencies. The assessment utilized a triangular research method, which combined qualitative and quantitative data from multiple datasets, it includes a review of literature, open-source reports, and various studies on human trafficking, migrant smuggling and money laundering, locally and internationally. A purposive sampling technique was employed to gather expert insights from various agencies to ensure the highest quality of information. A structured survey questionnaire was distributed among the working group members, returned validly by all respondents, and analyzed using a descriptive analysis method. The scope of datasets used in this report is from 2017 to 2024. This report only emphasizes the human trafficking that occurs across borders, to align with the discussions on migrant smuggling. Only a little segment of the report discussed the domestic trafficking because the proceeds of crime are not significant. The working group consisted of experts from Department of State Services (DSS), Economic & Financial Crimes Commission (EFCC), National Agency for the Prohibition of Trafficking in Persons (NAPTIP), Nigerian Financial Intelligence Unit (NFIU), Nigeria Immigration Service (NIS), The International Criminal Police Organization - National Central Bureau (INTERPOL￾NCB).

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 10 of 44 1.3 Understanding the Predicate Crime Human trafficking and migrant smuggling are complex phenomena that affect people in different ways. While sometimes linked, these are separate crimes. Human trafficking involves the recruitment, movement or harbouring of people for the purpose of exploitation, such as sexual exploitation, forced labour, slavery or organ removal. Victims can be children or adults, boys, girls, men or women, and are trafficked by the use of improper means such as the threat or use of force, fraudulent schemes, deception, or abuse of power. It can occur within a country or across borders. Human trafficking is therefore characterized by an act (recruitment, transportation, transfer, harbouring, or receipt of people), specific means (threats or use of force, deception, fraud, abuse of power, or abusing someone's vulnerable condition) for the purpose of exploitation. While human trafficking can take place within one jurisdiction or across multiple jurisdictions, migrant smuggling is a crime that takes place only across borders. It consists of assisting migrants to enter or stay in a country illegally, for financial or material benefits. Smugglers make a profitable business out of migrants' need and/or desire to enter a country and their lack of legal documents to do so. 1 A key difference is that victims of trafficking are considered victims of a crime under international law; smuggled migrants are not—they pay smugglers to facilitate their movement.2 Another distinction of these crimes is human trafficking involves exploiting men, women, or children for the purposes of forced labour or commercial sexual exploitation. Migrant smuggling involves the provision of a service—typically, transportation or fraudulent documents—to an individual who voluntarily seeks to gain illegal entry into a foreign country. It is possible the crime may start out as migrant smuggling but quickly turn into human trafficking. 3 There are several local and international reports that discuss the money laundering and terrorist financing risks posed by human trafficking and migrant smuggling; studies have shown the challenges faced by different nations as well as the approaches and strategies adopted by them. The 2022 National Inherent Risk Assessment report on the Money Laundering (ML) Threat in Nigeria4 reveals the country's significant role as a hub for human trafficking, acting as a source, transit point, and destination. The report highlights the complex network of criminal syndicates involved; particularly Nigerian organized criminal groups which have cultist origins or began as closed fraternities. These syndicates operate clandestinely to coerce 1 https://www.unodc.org/e4j/en/secondary/human-trafficking-and-migrant-smuggling.html 2 https://www.state.gov/wp-content/uploads/2019/02/272325.pdf 3 https://www.ice.gov/sites/default/files/documents/Report/2017/CSReport-13-1.pdf 4https://www.nfiu.gov.ng/Home/DownloadFile?filePath=C%3A%5CNFIU%5Cwwwroot%5Cdocuments%5CNMR￾O_9VZ5RH

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 11 of 44 primarily young women into forced sexual work through oath-bound commitments. The report also highlights the extensive reach of these criminal networks, which collaborate with counterparts in Europe, South East Asia, the Middle East, and North Africa. Despite the high profitability and low risk of human trafficking, the National Agency for the Prohibition of Trafficking in Persons (NAPTIP) is committed to prosecuting human trafficking and money laundering cases under existing legislation. The report also underscored the urgent need to address the financial dimensions of human trafficking, highlighting gender-based patterns in the apprehension of suspected traffickers. The report emphasizes that understanding these financial intricacies is crucial for developing effective strategies to combat human trafficking and its associated money laundering activities in Nigeria. The Financial Action Task Force’s (FATF) paper on Money Laundering and Terrorist Financing Risks Arising from Migrant Smuggling (2022)5 highlights the money laundering and terrorist financing risks associated with migrant smuggling. It demonstrates the alarming growth of the crime and the low number of smugglers arrested. According to the report, factors contributing to this disparity include inadequate international cooperation, a lack of resources, and a lack of focus on implementing a robust 'follow the money' approach. The report highlights the use of hawala, an informal money transfer system, and alternative methods like physical transportation and the use of regulated money value transfer service (MVTS) or pre-paid cards. The report also noted the outsourcing of money laundering activities by smugglers to professional networks, which complicates law enforcement efforts, and the limited understanding and reporting of these risks by many countries. The United Nations Office on Drugs and Crime (UNODC) 2022 Global Report on Trafficking in Persons6 is a crucial document in the fight against human trafficking. As the seventh report of its kind, it provides a comprehensive overview of global, regional, and national responses to trafficking, particularly in the context of the COVID-19 pandemic. Covering 141 countries, the report analyzes trafficking cases detected between 2018 and 2021, highlighting both the persistent threats of trafficking and the unique challenges brought about by the global health crisis. The report offers insights into the evolution of trafficking dynamics during this challenging period, revealing multifaceted responses employed by nations worldwide to counteract trafficking. It serves as a tool for gauging the effectiveness of anti-trafficking measures, urging nations to remain vigilant, adapt strategies to evolving circumstances, and reinforce their commitment to eradicating human trafficking. The report acts as a guiding compass, steering the collective will of nations towards a future free from human trafficking shackles. The Middle East and Africa Financial Action Task Force (MENAFATF) conducted a study on money laundering resulting from human trafficking and migrant smuggling crimes in 20217 , aiming to understand human trafficking and migrant issues at the national and regional 5 ML-TF-Risks-Arising-from-Migrant-Smuggling.pdf.coredownload.inline.pdf (fatf-gafi.org) 6 Trafficking in Persons (unodc.org) 7 Money Laundering Resulting from the Human Trafficking and Migrant Smuggling Crimes | MENAFATF Official Websites

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 12 of 44 levels. The report analyzed money laundering methods and identified challenges faced by MENAFATF member countries in disrupting the operations. It highlighted the global significance of money laundering and the adaptability of money launderers to various methods, leveraging technological advancements and exploiting regulatory gaps. The report also discussed international and regional efforts in form of treaties and conventions to combat these crimes. Challenges faced by countries in the Middle East and North Africa region include lack of understanding of trafficking laws and procedures, lack of inter￾agency coordination, and failure to prosecute and interrogate traffickers due to lack of evidence. The report also discussed the legal and institutional framework for combating these crimes and their proceeds in the MENA region, providing an overview of human trafficking and migrant smuggling crimes, methods, and characteristics. The Organization for Security and Cooperation in Europe (OSCE) paper on Policy Responses to Technology-Facilitated Trafficking in Human Beings (THB)8 provides an in-depth analysis of the policy approaches employed by OSCE participating States to combat the challenges posed by THB facilitated by technology. The paper begins by examining the impact of technology on THB and how crises such as the COVID-19 pandemic have exacerbated the situation. It evaluates the responses of States in their criminal statutes and procedures, noting the need for many countries to update their approaches to address the evolving challenges of technology-facilitated THB. Furthermore, the paper scrutinizes the regulatory approaches of countries towards the technology industry concerning THB, including the historical reliance on self-regulation and the recent trend towards State-led regulation. It also examines private sector and multi-stakeholder initiatives aimed at improving the industry's response to THB, assessing both successes and failures. The 2021 United States Government Accountability Office (GOA) paper, "Trafficking and Money Laundering - Strategies Used by Criminal Groups and Terrorists and Federal Efforts to Combat Them,"9 investigates the strategies used by transnational criminal organizations and terrorist groups. The report focuses on factors that these entities consider in executing trafficking schemes, money laundering strategies employed by TCOs and terrorist groups, and information-sharing efforts among federal agencies, financial institutions, and law enforcement to detect potential trafficking. The report was gathered through a thorough review of prior GAO reports, federal documentation, legislation, interviews with representatives from various federal agencies, experts from academia and the private sector, and financial institution groups. The paper also examined the Anti-Money Laundering framework, including the Bank Secrecy Act, other AML regulations, and FATF recommendations. 8 https://www.osce.org/cthb/514141 9 https://www.gao.gov/assets/gao-22-104807.pdf

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 13 of 44 2.0 Legal and Institutional Framework on Human Trafficking and Migrant Smuggling This section provides a brief overview of Nigeria's legal and institutional framework for the prohibition and prosecution of trafficking in persons and migrant smuggling, as well as other regional and international protocols ratified by the country. 2.1 Legal and institutional framework in Nigeria Nigeria has strong legislation for combatting human trafficking and migrant smuggling at both the federal and state levels. However, according to Organized Crime Index, the criminality score of Nigeria between 2021 and 2023 is 6th out of 193 countries, 2nd out of 54 countries in Africa, 1st out of 15 countries in West Africa. And the criminal market score for human trafficking is 7.5 and migrant smuggling 6.0 out of 10. Nigeria’s anti trafficking and related offences legislations include:

1. Trafficking in Persons (Prohibition) Enforcement and Administration Act, 2015: Nigeria's primary anti-trafficking law. Key provisions include: • Defines and criminalizes trafficking in persons, including forced labour, sexual exploitation, child trafficking, and organ harvesting. • Establishes penalties ranging from fines to life imprisonment, depending on the severity of the offense. • Provides for victim protection, rehabilitation, and reintegration. • Empowers the National Agency for the Prohibition of Trafficking in Persons (NAPTIP) to investigate, prosecute, prevent and partner with other relevant agencies in the fight against trafficking in persons.
2. Trafficking in Persons (Control of Activities of Organizations and Centers) Regulations, 2019 confers on the Agency the power to issue clearance certificate to all travel agents or tour operators and intending travelers for the purpose of:
3. Educational Excursions
4. Recruitment for Labour
5. Sporting activities
6. Cultural, music excursions or competition
7. All organizations, shelters and homes offering services for the purpose of rehabilitation of trafficked persons
8. Immigration Act, 2015: Regulates migration and addresses migrant smuggling. Key provisions include: • Criminalizes migrant smuggling and other immigration offenses. • Provides penalties for smugglers, including fines and imprisonment. • Grants powers to immigration authorities to intercept and investigate smuggling activities.

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 14 of 44 4. Child Rights Act, 2003: Protects children from exploitation and abuse, including trafficking. The Act prohibits child labour, child trafficking, and establishes penalties for violators and other forms of exploitation. 5. Penal Code and Criminal Code: The Penal Code applies in northern Nigeria (primarily Sharia law-compliant states), while the Criminal Code applies in southern Nigeria. Both codes criminalize human trafficking-related offenses, including forced labour, abduction, and sexual exploitation. 6. Money Laundering (Prohibition and Prevention) Act, 2022: This Act criminalizes the laundering of proceeds from crimes, including trafficking in persons, smuggling of migrants, sexual exploitation. The laws highlighted above are enforced by the following federal institutions and law enforcement agencies: • National Agency for the Prohibition of Trafficking in Persons (NAPTIP). The agency Implements anti-trafficking laws, investigates, and prosecutes offenders, and supports victims. • Nigeria Immigration Service (NIS) enforces immigration laws, monitors borders, and intercepts smuggling activities. • Economic & Financial Crimes Commission (EFCC). Combats money laundering and other financial crimes. • Other Law Enforcement Agencies such as: the Nigeria Police Force, Department of State Services (DSS), Nigeria Customs Service (NCS) and the Nigeria Security and Civil Defence Corps (NSCDC) collaborate with NAPTIP and NIS to address trafficking in persons and smuggling of migrants. 2.2 Regional Framework

1. ECOWAS Plan of Action against Trafficking in Persons. This action plan promotes collaboration among West African states in combating trafficking, including shared strategies, capacity building, and information exchange.
2. African Union (AU) Migration Policy Framework. It guides member states in addressing migration challenges, including smuggling and trafficking. 2.3 International Legal Framework
3. United Nations Protocols against Transnational Organized Crime • UN Trafficking Protocol (Palermo Protocol): Supplementary to the UN Convention against Transnational Organized Crime, ratified by Nigeria in 2001. It criminalizes trafficking in persons and promotes international cooperation in prevention, prosecution, and victim protection.

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 15 of 44 • UN Smuggling of Migrants Protocol: Also supplementary to the UN Convention against Transnational Organized Crime, ratified by Nigeria in 2001. It criminalizes migrant smuggling and protects the rights of smuggled migrants. 2. International Labor Organization (ILO) Conventions for the prohibition of forced labor (ILO Convention No. 29) and child labor (ILO Convention No. 182). 3. African Charter on Human and Peoples’ Rights (Ratification and Enforcement) Act, 1983. This charter Integrates human rights protections relevant to trafficking and smuggling into Nigerian law. 3.0 Fighting Human Trafficking and Migrant Smuggling: The Perspective of Nigeria’s Agencies A questionnaire was administered to the working group members to share their first-hand experiences, on knowledge of the crimes, the demography of victims, causes of the crime, operational mode of the traffickers, the sectors that are most susceptible to be exploited, how they detect and prevent occurrences, and the geographical areas that the crimes are most prevalent. 3.1 Knowledge of the Crime The respondents have indicated that they are all familiar with the crime of human trafficking and migrant smuggling and its links with money laundering and terrorism financing. Most of them have also encountered and recorded cases relating to those crimes. They also conduct parallel financial investigations with relevant stakeholders. 3.2 Demography of Victims and Causes of the Crime According to the respondents, the most trafficked gender in and out of Nigeria are predominantly females. 50% of the respondents indicated that the victims are within the age range of 10-20, while the other 50% mentioned that the victims’ age is between 20-40. Women and children constitute the most vulnerable groups of trafficked/smuggled victims. The respondents mentioned unemployment, illiteracy, and poverty as significant contributors to this vulnerability. In domestic trafficking, children are often subjected to domestic servitude, particularly those from poor families or rural backgrounds who migrate to urban areas in search of better opportunities. These groups are vulnerable as a result of being victims of crisis situations including conflict, and other social challenges that predisposes them to become out-of-school children, street hawkers, sex traders, and similar marginalized individuals. Internally Displaced Persons (IDPs) and students in informal religious schools are also at heightened risk. This aligns with the 2024 Global Report on Trafficking in Persons, that the majority of detected victims in Africa are women and children. These individuals are primarily subjected to forced labour, sexual exploitation, and forced begging. The report highlights

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 16 of 44 that children are more frequently detected as victims than adults in most parts of the continent, particularly in Sub-Saharan Africa10 . Poverty was identified as the primary factor facilitating human trafficking and migrant smuggling in Nigeria, as reported by 80% of the respondents. Other contributing factors include cultural and religious beliefs, the lure of overseas employment opportunities, and personal greed. Interstate migration within Nigeria, especially from the north to the south, has also increased the risk of illegal migrants from neighbouring countries with similar language and culture to falsely claim the indigeneship of Nigeria; sometimes these immigrants collaborate with traffickers to achieve their aim. Political instability, insecurity, economic challenges and inadequate parental care exacerbate the problem and create conditions of vulnerability. Structural issues such as extensive borders with other Sahelian countries and the ECOWAS protocol on free movement of people and goods provide traffickers/smugglers with an enabling environment. Moreover, the widespread aspiration for better opportunities abroad and limited awareness of safe migration pathways contribute to the persistence of this problem. 3.3 Operational Mode of Human Traffickers & Migrant Smugglers in Nigeria Based on their experiences, the respondents recognized a variety of recruitment strategies used by human traffickers and migrant smugglers. These include deception, violence, kidnapping, fraud, and compulsion. Traffickers frequently use social media platforms for marketing schemes, promoting bogus work possibilities and leveraging love relationships. Additionally, these traffickers exploit one-on-one contacts and the use of third-party intermediaries, including family and friends to entice victims with appealing promises to potential migrants' interests. According to the respondents, the transportation modes used to move victims of human trafficking and migrant smuggling in and out of Nigeria often involve traveling through the Sahara Desert into Europe. Land borders are the most commonly used routes, while air and sea routes are employed less frequently. The modes employed in transferring and harbouring victims of human trafficking and migrant smuggling are diverse and calculated. The victims are transferred through both legal and illegal borders and then handed over to the members of organized criminal gang based in the host countries. Transportation modes include the use of motorcycles, various types of vehicles such as cars, trucks, lorries, and buses, as well as commercial airplanes and boats. For harbouring victims, traffickers and smugglers often utilize safe houses and hotels as temporary shelters. Also, isolation and being under tight control to prevent escape are 10 https://www.unodc.org/unodc/en/press/releases/2024/December/unodc-global-human-trafficking-report_- detected-victims-up-25-per-cent-as-more-children-are-exploited-and-forced-labour-cases-spike.html

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 17 of 44 being used. They are kept in various locations, including brothels under disguise, private homes, or community settings such as local restaurants and food vendor outlets. Some migrants use false documentation when crossing the borders, and the agents facilitating these movements also exploit corrupt officials by engaging in bribery to facilitate their movements. Victims are sometimes handled through third-party intermediaries, with communication initiated via verbal interactions or phone calls. 3.4 Geographical Location and Relationship with Crimes On Nigeria’s exposure to human trafficking and migrant smuggling, 60% of the respondents identified the country as a source, while 40% identified it as both a source and transit or destination country. The key states identified by respondents as major hotspots for human trafficking and migrant smuggling are illustrated in the heatmap below. Notably, Edo State in the southern region emerged as the most frequently cited state for migrants and victims of trafficking. Figure 1: Geographical Heat map/location of human trafficking and migrant smuggling in Nigeria

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 18 of 44 The most frequented routes of human trafficking and migrant smuggling in and out Nigeria highlighted by some of the respondent agencies are shown below: NAPTIP

1. Nigeria (Kano)-> Saudi Arabia (Middle East), (for sexual exploitation and begging)
2. Nigeria (Sokoto)-> Niger Rep. -> Libya -> Europe (for sexual exploitation)
3. Nigeria -> Burkina Faso -> Mali -> Morocco -> Europe (for sexual exploitation)
4. Nigeria -> Morocco -> Middle East, (for sexual exploitation)
5. Nigeria -> Code Ivoire -> Burkina Faso -> Mali (graduated from Transit to Destination)
6. Nigeria -> Cameroun -> Gabon and Equatorial Guinea (domestic and agricultural labour). NIS
7. Nigeria (Sokoto) -> Illela (border) -> Niger -> Libya
8. Nigeria (Maiduguri)->Baga border -> Chad
9. Nigeria (Lagos) -> seme border -> Cotonou INTERPOL
10. For outgoing traffic: Through Katsina State (Jibia border) to Niger Republic and onward movement to Libya then Europe.
11. For inbound traffic from West Africa: Via Ogun State (Idiroko border) into Nigeria from Benin Republic for onward movement via the airports directly to Europe or land borders to Niger Republic and LIbya and subsequently to Europe.

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 19 of 44 4.0 Categorization of Typologies Typology 1: Use of cash in laundering proceeds of crime Case Study 1: The Use of Cash to Traffick Victims for Sexual Exploitation On 27th September 2017, a case of suspected human trafficking involving one Mr Abdul, who trafficked 24 women to Italy via Niger and Libya, was reported to NAPTIP, and investigation commenced immediately. The young women were lured under the pretence of legitimate jobs. Upon interception, the victims were interviewed. Following financial investigations, the victims stated that all transactions with the suspect were conducted in cash. The case remains pending as the suspect is still under investigation. Indicators ➢ The trafficking of 24 women for sexual exploitation points directly to human trafficking activities ➢ The exclusive use of cash transactions raises alarms, as cash is frequently employed in criminal activities to hide illicit financial movements. ➢ The trafficking route through Nigeria, Niger, Libya, and Italy is a known corridor for human trafficking, often exploited by traffickers. ➢ Consistent reports from the victims about cash transactions offer important insights into the financial mechanisms of the trafficking operation. Source: NAPTIP Case Study 2: The use of cash proceeds from forced marriage to purchase property Ms. AMS was trafficked to a foreign country under the pretence of an arranged marriage. However, upon arrival, she became a victim of forced marriage and domestic servitude. After escaping, she provided NAPTIP with information that led to the arrest of her guardian and facilitator, Alhaji NM. A financial investigation into Alhaji NM revealed that he had purchased several properties in a popular area using cash proceeds linked to the trafficking scheme. Further investigation uncovered his use of various marital contracts as a means to launder proceeds from forced marriages. He was ultimately charged with human trafficking. Indicators ➢ Victims being coerced into marriages in foreign countries, especially under deceptive or unfamiliar conditions, is a significant warning sign of trafficking. ➢ Victims experiencing involuntary labour, restricted freedom, or threats under the guise of marriage should raise alarms about trafficking and servitude. ➢ The presence of influential figures acting as "guardians" or facilitators indicates trafficking schemes designed to evade detection and gain legitimacy. ➢ The use of legal documents, like marriage contracts, to mask illicit financial transactions indicates money laundering connected to trafficking. ➢ Unexplained wealth, especially purchasing real estate without a legitimate source of income, is a red flag for illegal financial activities linked to trafficking.

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 20 of 44 ➢ Frequent, unexplained property purchases or complex financial transactions inconsistent with a person’s legitimate income suggest trafficking-linked financial activities. Source: NAPTIP Typology 2: Use of non-financial sector to launder proceeds of crime Case Study 3: Purchase of motor vehicle to launder proceeds of crime A case was opened in 2019 on Mr. KJ, a human trafficker based in Benin, Edo State, Nigeria, who was involved in recruiting underage girls from impoverished backgrounds for sexual exploitation in Libya. He deceived victims by promising them financial stability and a better life abroad. Upon arrival in Libya, the victims were trapped in debt bondage, forced into sexual exploitation, and subjected to violence, threats, and psychological abuse. Investigations revealed that Mr. KJ's trafficking operation was highly profitable, with proceeds being laundered through vehicle purchases. These vehicles were either resold for profit or used to facilitate further trafficking. Mr. KJ was convicted and his assets, including money in his accounts and vehicles, were forfeited to NAPTIP. Indicators ➢ Recruitment of young, impoverished girls with false promises of a better life. ➢ Use of deception and coercion (debt bondage, threats, and violence). ➢ Isolation of victims from their families and communities ➢ Proceeds of crime invested in high-value assets (motor vehicles). ➢ Vehicles resold to generate illicit funds. ➢ Use of multiple bank accounts to store and move illicit earnings. ➢ Cross-border movement of victims for exploitation. ➢ Use of transport networks to facilitate trafficking. ➢ Connection between human trafficking and other illicit activities (e.g., money laundering through vehicle sales). Source: NAPTIP Case Study 4: The Use of Gold Trade to Launder Proceeds from Human Trafficking A case was reported to the agency concerning a sophisticated human trafficking network operated by Madam X, who exploited young women from southern Nigeria for forced labour and sexual exploitation in Dubai. Using deceptive recruitment tactics, she lured victims with false job promises abroad. Upon arrival, victims were coerced into sex work and subjected to severe physical and psychological abuse. Financial investigations revealed that Madam X laundered her illicit earnings through the gold trade. She systematically purchased gold bullion using cash proceeds from trafficking, smuggled it back into Nigeria, and sold it through her legitimate gold business, creating a façade of legality to reinvest her criminal profits.

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 21 of 44 Typology 3: Use of formal and informal international money transfer operators Case Study 5: Use of MVTS to fund Families of trafficked victims. Ms. Helen was a student in one of the states in Nigeria known for high sex trade offences. She is seen to be receiving large MVTS transfers from Kuwait, also a known destination for child labour. Ms. Helen received transfers of USD 13,000.00 in 8 months into her account with the reason as family support from Mrs. Manal, a Kuwaiti resident without any family or business relationship. In addition, analysis revealed a large volume of other transactions that do not tally with a student profile. Ms. Helen also receives finances from other jurisdictions via MVTS with transaction red flags indicating the offences of trafficking, sex trade, and child labour. Further analysis revealed that most beneficiaries from her accounts are family associates and others believed to be her collaborators. Indicators ➢ Large transfers from a high-risk country suggest possible involvement in trafficking or exploitation networks. ➢ A lack of clear connections between sender and recipient is a key sign of potential trafficking or illicit support. ➢ Transactions inconsistent with a student's profile suggest involvement in illicit activities, possibly trafficking. ➢ MVTS are often used to move illicit funds anonymously across borders. ➢ Multiple beneficiaries engaged in illicit financial activities suggest involvement in a larger trafficking network. ➢ Financial transactions tied to such offenses likely support exploitation networks. Source: NFIU Madam X has been convicted but yet to be sentenced. Indicators ➢ Deceptive recruitment of young women with false job promises. ➢ Victims transported to Dubai and forced into labor/sex work. ➢ Use of coercion, violence, and psychological control to exploit victims. ➢ Use of gold bullion purchases as a money laundering mechanism. ➢ Conversion of illicit cash into high-value commodities for easy transport. ➢ Integration of proceeds into a legitimate gold business to disguise illicit origins ➢ Cross-border trafficking between Nigeria and Dubai. ➢ Use of gold as a financial instrument to move and clean illicit funds. ➢ Establishment of a seemingly legal business to provide legitimacy to criminal proceeds Source: NAPTIP

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 22 of 44 Case Study 6: Use of International Monetary Transfer Operators to receive funds from various senders A suspicious transaction report (STR) was received by the NFIU on Mrs. D from a financial institution. Preliminary analysis reveals that Mrs. D is a Nigerian residing in the capital city of a southwestern part of the country that is a well-known hub for human trafficking, based on previously conducted investigations. On 29th August 2022, Mrs. D received the sum of $1,515.00 (one thousand five hundred and fifteen US dollars) from one Mr. E, who is based in Lebanon. Mrs. D claimed that Mr. E is her friend and that the funds were meant for family support. However, the relationship between the duo could not be verified. Analysis revealed that Mrs. D has previously received MoneyGram transfers from various senders, all in the same month of August, 2022. Further analysis also revealed that, as soon as the suspect receives the MoneyGram transactions above, she almost immediately sends the same amount to one Mr. F (who is based in the same city as Mrs. D). Between 17th and 31st August, 2022, Mrs. D transferred $4,582.70 (four thousand five hundred eighty-two dollars and seventy cents) to Mr. F in 3 transactions. Mr. F was also reported to have received MoneyGram transfers from Cameroon, where his relationship with the sender could not be verified. Upon completion of analysis, the NFIU forwarded a detailed intelligence report to the local LEA for further investigation. Indicators ➢ Frequent transfers from unverified senders raise concerns about money laundering or trafficking. ➢ Rapid re-transfers often disguise the source and destination of illicit funds, a classic sign of money laundering. ➢ Inability to verify sender-recipient relationships often signals money laundering or trafficking activities. ➢ Individuals in high-risk trafficking areas should be closely scrutinized for illicit financial activities. ➢ Such patterns often indicate an organized trafficking network moving illicit funds. ➢ Suspicious financial behavior, lacking clear business or personal explanations, is a common indicator of trafficking or money laundering. Source: NFIU

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 23 of 44 Case Study 7: The Use of International Remittance from Victim of Domestic Servitude A case of human trafficking for labour exploitation was reported to the agency, involving one madam F, who trafficked young girls to work as domestic servants for wealthy families in Egypt. Their passports were confiscated, and they were subjected to severe working conditions. After several months, one victim managed to escape and reported her case to local authorities, who contacted the agency. A Financial investigation into the case revealed regular remittance payments sent to madam F. Further investigation uncovered a series of wire transfers between madam F and a local illegal recruitment agency in Nigeria. Indicators ➢ Remittances are often used in trafficking operations to move illicit funds, particularly in labor exploitation scenarios. ➢ The involvement of an illegal recruitment agency highlights organized crime and human trafficking. ➢ Forced labor and exploitative financial transactions are consistent with trafficking operations. ➢ Trafficking for domestic work in wealthier households often involves isolation and exploitation, difficult to detect without financial tracing. ➢ A lack of transparency in transactions adds to the suspicion that the funds are facilitating exploitation. Source: NAPTIP Case Study 8: The Use of Informal Financial Channels to Facilitate Human Trafficking On November 17, 2022, NAPTIP Kebbi Command received a case involving the trafficking of two young girls from Ibadan, Oyo State, to Libya. The trafficker, Madam BS Sokoto (at large), recruited the victims and arranged their transport through Sokoto, Kebbi, and Niger Republic. The investigation uncovered a financial network supporting the trafficking operation. One Mr. SHA, an unlicensed Bureau de Change (BDC) agent in Kano, had a financial arrangement with Mr. SY in Libya. When the victims ran out of funds, Mr. SY arranged payments to their accounts. Further analysis of Mr. SHA’s transactions revealed that he received ₦25 million weekly in U.S. dollars from agents in Dubai, who converted and transferred the funds as per Mr. SY’s payment instructions. Over two years, Mr. SHA laundered more than ₦1.5 billion through unregulated financial channels. The NFIU placed a Post No Debit (PND) order on Mr. SHA’s account, leading to his arrest in Kano. He was subsequently charged in Kebbi State High Court. Madam BS Sokoto and Mr. SY remain at large. Indicators ➢ Possible use of multiple bank accounts to store and move illicit earnings ➢ Recruitment of victims with promises of better opportunities abroad.

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 24 of 44 Typology 4: Use of Non-Profit Organisations ➢ Use of unlicensed Bureau de Change agents for illicit financial transactions. ➢ Frequent international money transfers to support trafficking operations. ➢ Cross-border movement of victims through transit hubs (Kebbi, Niger Republic). ➢ Large, unexplained cash inflows in an unregistered financial entity. ➢ Use of payment schedules and intermediaries to disguise fund origins. ➢ Connections between human trafficking and money laundering networks. Source: NAPTIP Case Study 9: The Use of Religious Disguise to Facilitate Child Trafficking (Disguised Benevolence) In October 2023, authorities received a report implicating Madam Ten in the illicit trade of infants and young children, disguised as religious charity work. Operating in Delta State, Nigeria, she posed as a reverend sister to gain the trust of financially struggling families, convincing them she was offering a better future for their children. NAPTIP made a request for financial intelligence from the NFIU. Analysis revealed that madam Ten received significant deposits from several individuals and entities, these funds were suspected to be support for activities of human trafficking and further transferred these received funds to other individuals. Further Investigations revealed that Madam Ten managed a sophisticated child trafficking network, with financial audits uncovering suspicious bank transactions and money transfers. These payments aligned with the timing of child recruitment and subsequent illegal adoptions, indicating a well-organized trafficking scheme. The case has been filed in court and remains in the trial stage. Indicators ➢ Use of religious identity to manipulate and deceive families. ➢ Targeting of vulnerable, low-income communities. ➢ Disguising trafficking under the pretense of charity or adoption. ➢ Unexplained deposits and transfers aligning with child recruitment and sales. ➢ Use of multiple bank accounts and money transfer services to receive payments. ➢ Potential involvement of third parties facilitating illegal transactions. ➢ Cross-regional movement of trafficked children. ➢ Demand-driven trafficking linked to illegal adoptions. ➢ Use of religious or charitable cover to evade law enforcement. Source: NAPTIP/NFIU

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 25 of 44 Typology 5: The use of migrants to smuggle cash Case Study 10: Exploiting VIP Privileges for Cash Smuggling This case involved the strategic exploitation of VIP status at an airport to smuggle large sums of cash. In 2019, several incidents were recorded where passengers booked VIP flights and used this privileged status to manipulate airport security and staff. The passengers worked with travel agents stationed at the airport to secure VIP bookings and bypass standard protocols. They arrived in expensive vehicles, dressed in intimidating designer outfits, and avoided direct interaction with airport staff except through the travel agent. Before boarding, these passengers would overpay the travel agent and distribute generous “welfare” (informal payments or gifts) to airport staff, including security personnel manning the VIP section. Initially, they travelled multiple times without carrying incriminating items, building trust and familiarity with airport staff. On subsequent trips, the passengers began to carry significant amounts of cash in their luggage, relying on their established rapport and influence to avoid scrutiny. The travel agent coordinated directly with security to ensure their luggage passed unchecked, leveraging the goodwill cultivated through repeated welfare payments. This pattern escalated over time, with the passengers progressively increasing the volume of cash smuggled. In one incident, a passenger attempting to board a flight to Lagos was intercepted carrying ₦69.5 million in cash, revealing the scale of the operation. Indicators ➢ A VIP passenger not widely recognized in public circles but carrying unusually heavy luggage. ➢ Self-proclaimed VIPs timing their travel to coincide with top government officials, arriving early to access the same VIP facilities. ➢ VIP luggage exclusively handled by a travel agent with minimal or no inspection. ➢ Frequent distribution of “welfare” or gifts to airport staff and security during each trip. ➢ Travel agents insisting that VIP luggage should not be subjected to checks. ➢ Absence or deliberate non-use of baggage screening equipment at VIP entrances. ➢ Attempts by VIP passengers to merge their luggage with that of official government entourages to benefit from diplomatic or official exemptions. Source: DSS Case Study 11: Use of Personal Couriers to Move Illicit Funds This case involved the use of a personal courier dedicated to transporting illicit funds across borders for third parties. In 2019, a traveller of Chadian origin was intercepted at Yola International Airport while boarding a flight to Lagos, found in possession of more than 50 ATM cards belonging to various individuals. Investigations revealed that the traveller intended to continue onward to Benin Republic, where he would use the

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 26 of 44 ATM cards to withdraw cash at ATMs and POS terminals on behalf of the card owners. The courier would then use the cash to purchase goods requested by the card owners, shipping the items back for a fee. Further investigation showed that the individual had engaged in this courier role even prior to the advent of ATM cards, when he was tasked with physically transporting cash between Chad, Nigeria, and Benin Republic. In some instances, the courier handed over cash to unknown individuals without question. Evidence indicated that clients of such personal couriers included legitimate traders seeking to avoid bank charges and levies to maximize profits, as well as criminal actors who concealed their identities by using third-party couriers for illicit transactions. Personal couriers traveling by road were found to be more difficult to detect, often working with experienced drivers who deliberately avoided security checkpoints and took steps to conceal their cargo. Indicators ➢ Possession of a high volume of ATM cards not matching the bearer’s identity. ➢ Travelers displaying unusually friendly behaviour toward security personnel and carrying minimal luggage. ➢ Use of commercial drivers specializing in long-distance trips. ➢ Drivers showing unusual willingness to defend passengers or resist searches. ➢ Mismatch between names on ATM cards and the bearer’s identification. ➢ Couriers making frequent, hurried return trips to secure more clients and profits. Source: DSS Case Study 12: The Concealment of Huge Cash with Teenagers The Nigeria Immigration Service, Seme Border, suspected a woman travelling from Nigeria to Cotonou along with two teenage girls. The ladies were asked to come down and were interrogated, only to discover a huge sum of money with the two teenage girls, who claimed the money was given to them by the woman they were travelling together with. They were all stopped from traveling, and the case was further transferred to the Nigeria Customs Service. Indicators ➢ Minors are often used by traffickers or smugglers to evade detection due to less scrutiny at border crossings. ➢ The need to evade customs scrutiny suggests illicit activities such as money laundering or trafficking ➢ A lack of verifiable information about the purpose of the funds suggests illegal activity. ➢ The smuggling of money across borders could indicate involvement in a larger illicit network. ➢ Attempts to bypass customs controls are a common sign of illegal money movement. ➢ Cross-border smuggling typically involves organized crime or money laundering.

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 27 of 44 Source: NIS Case Study 13: Illegal Immigrant Involved in Cross Border Cash Smuggling At the Seme Border, the Nigeria Immigration apprehended a 15-year-old girl, a citizen of Benin Republic, who falsely claimed to be Nigerian using a fake Nigerian passport. During interrogation, it was discovered that she was not Nigerian but had travelled to Nigeria to obtain a Nigerian passport through an agent to facilitate her journey to Ghana for work. Upon instructing the driver to unload her luggage, officials later found that she was carrying U.S. dollars equivalent to eleven million naira. According to the girl, the agent had given her the money to deliver to the woman she would be working for in Ghana Indicators ➢ Fake passports are commonly used by traffickers to facilitate illegal migration. ➢ Minors are often exploited in trafficking or smuggling operations, particularly when they carry large sums of money ➢ Carrying large amounts of cash without proper documentation suggests illicit cross-border transactions. ➢ The agent’s role suggests a trafficking or smuggling operation, indicating a larger criminal network. ➢ The lack of legitimate work verification suggests potential exploitation or forced labor in Ghana. Source: NIS Case Study 14: Cash Smuggling by a Foreigner without Valid Passport This case involved an irregular migrant woman from Benin Republic who attempted to smuggle thirty million naira into Nigeria through the border without a passport. When asked to present her luggage for further inspection, she was unable to comply, and the driver refused to allow the search. Customs officers were then involved, and upon conducting a search, they discovered she was carrying a large sum of money Indicators ➢ Absence of documentation is often used by criminals to avoid detection at border checkpoints. ➢ The driver’s refusal to allow a search is suspicious, implying an attempt to conceal illicit items (such as cash). Resistance often indicates awareness of illegal contents in the luggage. ➢ Large amounts of unreported cash can be used to evade financial regulations and are often linked to criminal activities like drug trafficking or corruption. ➢ Transporting thirty million Naira in cash without proper documentation ➢ Unexplained Source and Destination of Funds.

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 28 of 44 ➢ Her foreign nationality may indicate a larger scheme to bypass financial controls and evade detection by authorities in both countries. Source: NIS Typology 6: Organised criminal gangs in migrant smuggling Case Study 15: Nigeria as a Transit Route in Migrant Smuggling A case of criminal breach of trust and fraud was received from a Nigerian-based Ghanaian. However, in the process of investigation, it was discovered that both the complainant and suspect were involved with organized criminal gangs that specialize in the transportation of migrants from Ghana to Antigua via Nigeria. The migrants are transported to Nigeria and sent to Antigua and other countries via Abuja and Lagos on a chartered flight operation that has occurred a couple of times before their fallout with the aid of corrupt officials at the airports. Based on the statement of the suspects, the migrants escaped through Antigua to other parts of the world. The Bureau is still investigating the case with a view to bringing all the culprits and charging them at the conclusion of our investigation. Indicators ➢ The involvement of Organized Criminal Gangs. ➢ Use of Corrupt Officials at Airports to bypass checks ➢ The use of chartered flights indicates sophistication and the ability to bypass border controls. ➢ The use of Nigeria as a key transit point for smuggling migrants through airports (Abuja, Lagos) to countries like Antigua suggests Nigeria is part of an international human trafficking network. The use of chartered flights indicates sophistication and the ability to bypass border controls. ➢ Fraud and criminal breach of trust. the involvement of both the complainant and the suspect in criminal activities further illustrates the deceptive and exploitative nature of the operation. ➢ The escape of migrants to various global destinations is a sign of the network’s global reach. Once migrants reach Antigua, they are likely to be exploited for labor, sexual trafficking, or other illicit purposes. Source: INTERPOL Case Study 16: Fake Travel Agents Defrauded Migrants Based on a message received from INTERPOL Lome, Togo, on 24/07/2024, in which it was disclosed that two Togolese living in Nigeria posed as travel agents that would facilitate the movement of their countrymen to Canada and in the process defrauded the victims of millions of CFA. Many intending migrants were defrauded, and the case was reported at INTERPOL Lome.

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 29 of 44 The case is currently being investigated with intensified efforts to arrest the suspects who are currently hiding somewhere between Ibadan and Benin City. Indicators ➢ The absence of verifiable credentials for the travel agents suggests their operations are fraudulent ➢ The victims primarily being Togolese nationals suggests the suspects may have targeted vulnerable migrants from a specific region, a tactic commonly used by traffickers and fraudsters to exploit individuals seeking better opportunities abroad. ➢ The defrauding of victims of large sums of money (millions of CFA) for migration services is indicative of a fraudulent scheme. ➢ The suspects’ hiding in Ibadan and Benin City suggests they may have local networks or connections in these areas. ➢ The involvement of INTERPOL indicates that this case involves cross-border crime and could be part of a larger international scam. Source: INTERPOL Typology 7: Integration of proceeds of crime into real estate Case Study 17: Deception By an Agent for Financial Gain This concerns a case of suspected trafficking in persons reported to the agency by an anonymous caller that one Mr Tan is about to be trafficked to Spain under the deceit and guise of being offered a job in Spain as a house help by the suspect Madam A. Financial investigation into the case revealed that Madam A lures young girls into her trap by promising them jobs but pushes them into sexual exploitation. Financial investigation revealed that Madam A purchased valuable/landed properties with the proceeds of crime. ➢ Victims are deceived into traveling with the belief they will have a legal job, only to be coerced into sexual exploitation upon arrival, indicating clear human trafficking. ➢ Madam A’s purchase of valuable properties with the proceeds from trafficking activities is a key indicator of money laundering ➢ The anonymous report about the trafficking incident highlights that the suspect’s activities may be known within the community. This tip-off emphasizes the role of community awareness and involvement in identifying and reporting suspicious behavior, particularly regarding human trafficking. ➢ Madam A’s involvement in an organized trafficking network, where victims are exploited for sexual exploitation, indicates a larger, coordinated operation. Source: NAPTIP

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 30 of 44 Case Study 18: Purchase of Landed Properties from Proceeds of Crime This is a suspected case of human trafficking involving two victims rescued by the Nigerian immigration service on their way to Libya. The investigation led the agency to one Mr Abu as the main suspect. Abu recruits young Nigerians for labour exploitation in Libya. Investigation showed he has trafficked over 40 people to Libya. Financial investigation revealed wire transfers between him and his partners in Libya. Landed properties were also linked to him, acquired from the proceeds of crime. The case is ongoing while an interim order for forfeiture has been filed. Indicators ➢ Mr Abu’s trafficking of over 40 victims suggests a large-scale operation, possibly involving organized crime and multiple collaborators. ➢ Wire transfers between Mr. Abu and his partners in Libya are suspicious, indicating an organized criminal enterprise. ➢ The use of Libya as a trafficking route for labor exploitation highlights the organized, cross-border nature of the trafficking network. Mr. Abu’s international connections in Libya complicate the investigation, requiring careful monitoring of financial and immigration patterns between the two countries. ➢ The interim order for the forfeiture of Mr. Abu’s assets demonstrates efforts to seize criminal proceeds and prevent traffickers from benefiting from their illicit activities. Source: NAPTIP 4.1 General Red flags & indicators The following are indicators of human trafficking and migrant smuggling which were grouped into travel, transaction and behavioural indicators: Travel indicators • When a passenger indicates that the purpose of trip is a promised job in Europe or Middle East. • Lack of knowledge about destination or purpose from the passengers. • Suspicious travel patterns across different jurisdictions before final destination. • When a passenger has many travel documents or no valid passport. • A group of travellers consisting young girls from rural background being directed by an enlightened lady. • Inconsistent story as to the reason why each individual is travelling. • Shabby and/ or discordant dressing. • Declaring false destination; this is usually uncovered by interviewing the travellers separately or by comparing with the content of their luggage. • When travellers hide their state or city of origin in Nigeria.

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 31 of 44 • The engagement of the services of commercial drivers to transport victims from one destination to another. • The movement from Nigeria to Europe and other parts of the world via chartered flight operations. Transaction Indicators • When the transaction pattern in the account of suspect is linked to high-risk jurisdictions known for trafficking or migrant smuggling. • Lack of clear economic or familial justification for transactions from un-related parties. • Inconsistent or no explanation for transactions with narrations with certain keywords such as sponsorship, family support, upkeep etc • Multiple Transactions via Various IMTOs: frequent transfers from the same sender through different transfer mechanisms. • Possible attempt to obscure transaction pattern or bypass certain monitoring mechanisms. That indicates potential layering activity in a money laundering scheme or payments related to trafficking. • Transactions that have links to mutual depositors and beneficiaries that are suspicious or have been flagged for irregularities. • Financial ties to known persons of interest: whom have already been flagged in an investigation, or have been identified on domestic/international watchlists. • Immediate fund redirection: rapid transfer of received funds to a third party who is seen to have been receiving same suspicious IMTO transfers. • When purchases or alleged use of funds does not fit the profile of passenger e.g ordering plenty pharmaceutical drugs that may form part of travel essentials. Behavioural Indicators • When a passenger indicates that the purpose of trip is a promised job in Europe or Middle East. • Lack of knowledge about destination or purpose from the passengers, • Suspicious travel patterns across different jurisdictions before the final destination. • Responses to travel information provided by a chaperone; with inconsistencies in information provided. • Passports of a group of girls being held by a chaperone. • Nervousness, aversion of the eyes, fidgeting etc. 4.2 Human Trafficking and Migrant Smuggling Jurisdiction of Concern The respondents have highlighted some jurisdictions that are of concern with regard to these crimes. The map below highlights global jurisdictions of concern for human trafficking and migrant smuggling, categorized as high, medium, or low. High-risk regions are concentrated in North Africa, the Middle East, and parts of West Africa, some of these countries include Libya, Algeria, and Niger, as well as key transit countries like Turkey and Spain. Medium-risk regions include Mexico, South Africa, and parts of the Mediterranean. The map emphasizes the need for international collaboration, focusing efforts on high￾concern regions while maintaining vigilance globally.

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 32 of 44 Figure 2: Human Trafficking and migrant smuggling jurisdiction of concern 5.0 Money Laundering Trends Associated with Human Trafficking and Migrant Smuggling Money laundering associated with human trafficking and migrant smuggling involves various methods to conceal the proceeds of these illicit activities. The respondents have provided some common trends and examples: • Traffickers/smugglers often establish shell companies to create a facade of legitimate business operations. For example, a fake travel agency might be used to disguise the facilitation of illegal border crossings, allowing traffickers to maintain profitability while laundering the money through seemingly legitimate sales. • Human traffickers and smugglers frequently prefer cash payments to avoid detection. For instance, victims may pay for smuggling services in cash, which leaves fewer traces and complicates law enforcement efforts to track the funds. • Traffickers sometimes invest illegal proceeds into real estate to conceal illicit funds. For instance, a trafficker might purchase properties in cash, allowing them to integrate illegal gains into the legitimate economy, which can also serve as a means to provide housing for victims. • They also manipulate invoices and the value of goods to justify the movement of money. A trafficker might overstate the value of goods exported or imported to explain the transfer of large amounts of money without raising suspicion.

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 33 of 44 • Victims of human trafficking may be forced into illegal activities, such as organized crime or sexual exploitation, generating revenue for traffickers. Earnings from these activities are then laundered through various means, such as commingling them with legitimate business income. • The use of money mules to move funds: traffickers may exploit vulnerable populations who are unaware of money laundering risks and may become unintended accomplices. • Cash transactions, for instance involving individuals at borders, wire transfers from jurisdictions known for trafficking, multiple wages paid into a particular account amongst others • Traffickers may engage in different kinds of fraud for instance visa fraud, passport fraud, identity fraud, bribery & corruption, overstay & illegal employment, cash transaction to avoid being detected. • Splitting of cash via money mules; for instance, cash is split among the migrants to evade at border points the threshold for cash declaration. • Traffickers/smugglers use education as a cover to launder funds obtained from victims of trafficking or illegal migrants. For instance, payment narration with the caption “school fees, hostel expenses” etc. • Traffickers/smugglers sometimes use medical and religious tourism as a cover to launder illicit funds from victims across several jurisdictions. • Traffickers/smugglers launder funds under the guise of repayment of a non-existent loan. 5.1 Emerging trends and technologies The respondents identified various patterns related to money laundering through human trafficking. However, new forms of these crimes are emerging in addition to old approaches. One of the emerging trends is the trafficking of technology-savvy young men to forcefully work in scam centres across Southeast Asia and other countries across several continents, including Ghana in west Africa. Both UNODC and INTERPOL have found out that traffickers’ need to recruit victims with IT skills has increased, the traffickers require technical skills to supposedly recruit “information technology workers” and “digital sales executives.” Scam centre operators also seek to traffic individuals with IT skills such as data scientists, software developers, digital marketers, and social media managers to help them further integrate emerging technologies and “professionalize” their operations. 11 Some of those trends are mentioned below: • Acceptance of Virtual Assets as a Form of Payment o To Disguise the Source of The Illegal Activities. o They Trade with Coin and Pay Huge Sums into Wallets and Withdraw Outside the Country • The Use of Digital Financial Platforms 11 Cyber Scamming Goes Global: Sourcing Forced Labor for Fraud Factories

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 34 of 44 • The use of social media such as WhatsApp, Facebook, • The use of google maps to direct victims • Use Of Non-Profit Organization (NGO) • The Use of Diplomats and Diplomatic Networks • The Use of Cryptocurrency to launder funds across different jurisdictions. • The Use of Chartered/Private Aircraft to transport migrants. 5.2 Vulnerable sectors Based on the responses from the respondents, the following are the sectors that were observed to be most vulnerable to money laundering through human trafficking and migrant smuggling. S/N Sector Businesses involved

1. FINANCIAL SECTOR • Banks • International Money Transfer Services • Informal Transfer Service Like Hawala Are Very Common with Traffickers. • Digital payment systems • Virtual assets • Currency Exchangers
2. DESIGNATED NON￾FINANCIAL BUSINESSES & PROFESSIONALS • Travel agencies • Car dealers • Real estate • Maritime • Hospitality Industry • Entertainment Industry • Non-profit organisations • Mining Industry • Online business platforms using social media • Laundry businesses • Fashion businesses • Supermarkets

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 35 of 44 5.3 Other crimes associated with human trafficking & migrant smuggling Human trafficking and migrant smuggling are among the crimes that hide under others or are employed together with other forms of crimes for successful implementation. The respondents have highlighted several crimes that are associated with human trafficking & migrant smuggling as follows: • Kidnapping/Hostage-taking • Arms smuggling • Forgery • Sexual Assault (Sexual exploitation and forced sexual exploitation) • Creation Of Baby Factories • Organ trafficking (Human Organ Harvesting and Sales of Human Parts) • Illicit Drug trafficking • Drug abuse • Money laundering • Sextortion (Cybercrime) • Fraud (including Document fraud, Romance scam, Identity theft) • Forced labour, (including Child labour) • Gender Based Violence (GBV) • Robbery • Terrorism 6.0 Nigeria’s Effort in Fighting Human Trafficking & Migrant Smuggling Legislation In addition to the the Trafficking in Persons (Prohibition) Enforcement and Administration Act 2015, the immigration Act, 2015, establishing the two agencies responsible for tackling both crimes, the Child Rights Act, 2003 have been adopted as law in all the 36 states in Nigeria, in order to protect the child from abuse, exploitation and ensures that their best interest take precedent. Common Database The establishment of Common Investigative Database (CID). In collaboration with European Union under Action Against Trafficking in Persons and Smuggling of Migrants (ATIPSOM) implemented by FIIAPP, NAPTIP, Immigration and NPF launched the CID on 26/12/2023 in Abuja. The CID is designed to serve as a centralized platform where relevant law enforcement agents can seamlessly share intelligence information. This collaborative

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 36 of 44 effort aims to strengthen the collective response to combatting trafficking in persons and curbing the illicit activities associated with the smuggling of migrants.12 Victim Support NAPTIP has established a department for counselling and rehabilitation of victims of human trafficking. The department collaborates with relevant government ministries and agencies such as ministry of women affairs, NGOs and development partners such as International Organization for Migration (IOM) to ensure trafficked victims are reintegrated seamlessly into the society. It provides direct assistance to trafficked persons in vocational services such as knitting, weaving, fashion design, hair dressing, catering, hat making, beads making and photography. The counselling methods adopted in order to help the victims recover from trauma include psychosocial therapy, individual counselling, group counselling, career counselling, family counselling and case conferencing. The victims are also provided shelter facilities such as feeding, clothing, provision of regular hygiene products, physical exercises, basic educational courses.13 Awareness Campaign Recently, the Nigerian government launched a Smuggling of Migrants (SOM) Observatory infomercial documentary, “Know Before You Go: The Dark Web of Migrant Smuggling in Nigeria”. The documentary is a joint initiative of the Nigeria Immigration Service and United Nations Office on Drugs and Crime (UNODC) and supported by the Government of Canada. The documentary is to raise awareness about the dangers of trafficking in persons and smuggling of migrants, promote safety of regular migration particularly targeting Nigerian youths and enhance collaboration with civil society groups to prevent and combat trafficking in person and smuggling of Migrants.14 Domestic and International Collaboration Regarding collaboration in combatting money laundering through human trafficking and migrant smuggling, the respondent agencies in this report have unanimously stated that they engage in both domestic and international collaborations to fight these crimes. They collaborate nationally with relevant stakeholders, regionally through ECOWAS, and internationally through governmental and non-governmental organisations. The agencies collaborate domestically to exchange information, refer cases to relevant agencies with the mandate, and request information on financial analysis. In tackling domestic trafficking, Nigerian government has employed the presence of military and police checkpoints along the highways where they regularly query suspicious crowd movements especially when children and teenagers are involved. This measure has led to 12 https://www.fiiapp.org/en/noticias/a-database-to-investigate-human-trafficking-in￾nigeria/#:~:text=The%20features%20of%20the%20CID,uphold%20the%20rule%20of%20law. 13 https://naptip.gov.ng/counselling-and-rehabilitation-department/ 14 https://nta.ng/2024/12/01/fg-reaffirms-its-commitment-to-tackle-smuggling-of-migrants-and-trafficking-of￾persons/

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 37 of 44 several arrest all over the country while foiling Human Trafficking and Migrant Smuggling attempts. Internationally, they engage relevant partners such as to exchange information on the criminal network, the movement of funds, the deportation of victims, preventive and detection mechanisms, and capacity building. Some of the notable achievements of these engagements include the realisation of a legislative framework to fight these crimes, enhanced capacity of personnel, awareness campaigns, and successful investigations and prosecutions. Training and Resources Most of the respondents indicated that they receive specialized training on money laundering & terrorism financing trends related to human trafficking and migrant smuggling. These include basic trainings on investigation, induction courses for new staff, trainings by domestic and international partners, interagency trainings etc. some of the respondents also mentioned that they have Certified forensic laboratories, members of professional bodies such as accountants, fraud examiners and crime scene investigators. Investigation Capabilities The respondents use a variety of resources and methods to ensure that perpetrators were apprehended and their networks were dismantled. Some of the strategies adopted by the respondents to detect and interdict human trafficking and migrant smuggling activities include the following: • The agencies collaborate with relevant stakeholders to Conduct parallel financial investigations to Identify the Illicit proceeds of these crimes, in addition they also engage in processes to confiscate and forfeit such proceeds. • Some of the respondent agencies attest to the fact that they conduct Surveillance in vulnerable areas, and engage the services of informants to gather intelligence on activities of suspects. • Proactive analysis is carried out on identified reported suspicious transactions, and intelligence gathering and sharing. Border Control Officers at border points also carry out different methods in curbing these crimes such as travel document verification, profiling of individuals, monitoring of migration routes and collaboration with international organisations. The federal government of Nigeria has recently implemented automated verification system to fight migrant smuggling and enhance border surveillance.

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 38 of 44 6.1 Challenges in the Fight Against Human Trafficking and Migrant Smuggling in Nigeria Resources • Law enforcement agencies lack adequate training, experience, and resources to investigate complex, transnational organized crime. • Lack of adequate resources to carry out operations; such as surveillance, arrests etc. • Limited resources that will cover expenses of their specialized units, financial investigators, special centres for rehabilitation of victims, medical facilities etc. Technical Knowledge and Training • Limited financial crime expertise. • Gap in the knowledge of emerging technologies such as Virtual assets and crypto transactions. • Limited enlightenment and awareness of the populace. • Inadequate training of personnel on investigation and prosecution of money laundering and terrorism financing. • Complexity in addressing trafficking which involves multiple jurisdictions. Cooperation • Reluctance of Victims of trafficking to cooperate with investigative authorities either due to fear of retribution, distrust of officers or lack of understanding of the legal process. • International collaboration between law enforcement agencies is often required to prosecute transnational trafficking cases. • Bottlenecks in getting information across multiple jurisdictions. • There are variations in the definitions used for human trafficking, which can make it difficult to accurately tackle the crime across jurisdictions. • Failure of implementation of treaties by sister some jurisdictions. Criminal networks • Criminal networks are often well-organized and structured, and can adapt quickly to new law enforcement techniques and policies. • lack of analytical tools to aid in identifying the structure of criminal links. Financial services • Financial services engaged during the process of laundering illicit funds can be difficult to trace and monitor.

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 39 of 44 Social media • Criminals may use social media to communicate, which can be difficult to monitor. • Limited application of technology in aiding investigation and prosecution. • The anonymity makes criminals to use pseudonyms and encrypted communication methods, making them difficult to trace. Money laundering risks • Many countries do not consider migrant smuggling to be a high-risk crime for money laundering. • In some jurisdictions, there are sectors that are not fully or effectively regulated, which can make it easier to process funds and conduct financial transactions. 7.0 Conclusion The Nigerian government has put in different measures to tackle human trafficking and migrant smuggling. However, there are so many challenges being faced in this fight. And this may not be far from the duo crimes being global crimes that need global approach to tackling them. For every crime that thrives, there are activities that provide the fertile ground for them to grow. In these instance, financial flow is one of the factors that encourage them. Therefore, there is the need to disrupt these criminal networks. This typology report has noted that these crimes are related to several other crimes, and the trends and methods employed by the criminal actors are evolving constantly, especially with the emergence of new technologies. This calls for constant training and self￾development in order to keep abreast with the modern world. It Is important for the law enforcement agencies to understand the mode of operations of these criminal actors, the scope of their activities, the vulnerable sectors/groups they exploit and their collaborators within and outside the country in order to design measures that will effectively detect and combat these crimes. The reporting entities should also leverage on the production of this typology to familiarize themselves with the indicators of these crimes in order to identify and report Suspicious transaction report. 7.1 International Best Practices for Combatting Human Trafficking and Migrant Smuggling There are several strategies that countries have adopted to tackle these crimes and the attendant money laundering risks associated with them. Some of the countries’ efforts are reviewed below:

1. The Netherlands is recognized for its integrated and victim-centred approach to addressing human trafficking. The country has established the National Rapporteur on Trafficking in Human Beings, an independent body tasked with monitoring trafficking cases

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 40 of 44 and providing policy recommendations. This approach is complemented by robust victim support measures, including safe housing, psychological care, and reintegration programs. The Netherlands also places a strong emphasis on public awareness campaigns targeting at-risk populations and extensive training programs for law enforcement. In 2023, Dutch authorities rescued over 200 victims of trafficking and successfully prosecuted 70 traffickers15 . 2. Australia has taken significant strides in combating human trafficking and migrant smuggling through a mix of international cooperation and legislative enforcement. The Australian Federal Police’s Human Trafficking Team collaborates with international organizations to dismantle smuggling networks and prosecute offenders. The country has signed bilateral agreements with its neighbours to address cross-border trafficking issues effectively. Enhanced border surveillance and strict visa regulations have also reduced the prevalence of irregular migration routes. In 2024, Australia made over 300 arrests related to migrant smuggling operations, ensuring that victims were granted access to long-term residency and support services16 . 3. The United States employs a multi-agency approach to tackle human trafficking and migrant smuggling. The Trafficking Victims Protection Act (TVPA) lays the foundation for prosecuting traffickers and dismantling smuggling networks while ensuring comprehensive victim support. Additionally, the FBI-led Human Trafficking Task Forces operate across the country, focusing on disrupting organized smuggling operations. Public awareness initiatives, such as the Blue Campaign, play a critical role in training frontline personnel to identify signs of trafficking. By 2024, the U.S. had identified 3,200 trafficking victims and successfully dismantled 1,100 smuggling operations17 . 4. Thailand addresses human trafficking through a combination of legislative reforms and operational strategies, particularly in industries susceptible to forced labour. The Anti￾Trafficking in Persons Act criminalizes trafficking and ensures the protection of victims. The country conducts regular inspections of high-risk sectors, such as fishing and agriculture, significantly reducing forced labour incidents. Furthermore, Thailand collaborates with ASEAN member states to facilitate information sharing and victim repatriation. In 2024, Thailand rescued 180 trafficking victims and successfully prosecuted 92 offenders18 . 5. Italy has focused on disrupting migrant smuggling operations through maritime security measures and international collaboration. Coastal patrols and search-and-rescue missions not only prevent smuggling but also protect migrants from exploitation. The implementation of the Hotspot Approach helps identify trafficking victims among irregular migrants arriving at entry points. Italy also works closely with transit and origin countries to strengthen anti￾15 "Trafficking in Persons Report," U.S. Department of State, 2023. 16 "Australian Federal Police Annual Report," Australian Government, 2024. 17 "Combating Human Trafficking in the U.S.," National Institute of Justice, 2024. 18 "Thailand's Anti-Trafficking Report," Ministry of Social Development and Human Security, Thailand, 2024.

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 41 of 44 smuggling efforts. In 2024, Italian authorities intercepted 250 smuggling operations and provided humanitarian assistance to 1,500 victims19 . 7.2 Recommendations The key measures that can be implemented to prevent and reduce human trafficking and migrant smuggling are presented below: Government & Policy Makers • Enhancement of cooperation between all units within an investigating agency to ensure that parallel financial investigations are conducted when investigating the predicate crime of human trafficking & migrant smuggling. • Sensitisation & enlightenment: The victims of trafficking can be engaged in the sensitisation programs being conducted, these can be done in vulnerable communities, school campuses as well as on social media platforms on the dangers and red flags of trafficking and illegal migration. • Border control: responsible agencies should be educated on the common red flags for these crimes so that they can apply it in disrupting the network of criminals. • Using technology: upgrade technology to help identify where trafficked victims are being held. For example, the TraffickCam app allows members of the public to upload photos of hotel rooms they stay in to help locate victims. • Enhancement of law enforcement agencies with adequate human and financial resources to carry out their mandate. • Strict child protection law enforcement: all states in Nigeria should ensure that they have mechanisms in place to protect children from all harm. • Quality education: Nigeria should make an effort to ensure that it reduces the number of out-of-school children and that the schools are of high quality. • Security: Nigeria should tackle her security challenges to reduce the number of people that leave the country for safer countries. • Improve the economy, job creation, and cultural reorientation: the government should make efforts to provide job opportunities for youths with poverty reduction measures and social welfare programs that will reduce economic gains. Reporting entities • Reporting Entities should regularly update and test their transaction monitoring systems using the latest red flags and indicators of human trafficking (using a wide variety of sources). 19 "Italy’s Fight Against Migrant Smuggling," European Commission Report, 2024.

Money Laundering Typology Through Human Trafficking and Migrant Smuggling in Nigeria Page 42 of 44 • Financial institutions should identify shell companies that disguise themselves as legitimate businesses to launder illicit funds through their accounts. • DNFBPs should familiarize themselves with trends used by criminals in integrating the proceeds of crime, especially in the purchase of real estate and luxury cars. • IMTO should identify and report transactions that originate from destination countries to transit/source countries that are suspected to be proceeds of crime. • All reporting entities should familiarize themselves with the money laundering trends and indicators through self-development and continuous engagements with the NFIU. The Public • Parents should ensure that their children of school age attend schools and are given adequate support. • Community and religious leaders should learn from the experience of other victims to discourage others from embarking on uncertain migration. • Skills acquisition and wealth creation should be promoted amongst the youth within every community in order to reduce the craving for illegal migration. • Victims should cooperate with law enforcement agencies during investigations and victim support programs by raising the awareness of susceptible youths. International Cooperation • Nigeria should share valuable experiences and also learn from the international best practices adopted by other nations and replicate similar efforts to curb these crimes. • Partner with development partners on capacity building for law enforcement agencies and the judiciary on the AML/CFT risks posed by these crimes. • Information sharing with counterparts’ agencies across the globe with regards to illicit financial flows, deportation and rehabilitation of victims. • Nigeria should target the signing of memorandum of understanding (MOUs) with priority jurisdictions, such as mutual legal assistance (MLAs) to ensure that LEAs can obtain and use evidence/repatriate suspects, MoUs on victim support and asset repatriation etc. • There should be Joint AML/CFT trainings and investigations among Law Enforcement Agencies across jurisdictions.