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Organ trafficking: The lesser-known form of financial exploitation

By Kristina Davis, BSA/AML Investigator

In September, I attended the Association of Certified Anti-Money Laundering Specialists’ (ACAMS) 18th Annual AML & Financial Crime conference in Las Vegas, Nevada. Every year, ACAMS hosts a three-day conference full of information, speakers, and seminars focused on the ever-changing needs of today’s BSA/AML professional. While at this conference, one course stood out and piqued my interest. Titled “The Body Snatchers: AML Tools to Fight Transplant Organ Smuggling,” the main takeaway from this course was that organ trafficking is nothing new; it has been going on for many years. It’s just not as widely known as other forms of exploitation, such as forced labor or sex trafficking.

Organ trafficking may not seem like a big problem in the financial world, but it is. Not only is organ trafficking illegal, but it leaves the financial industry exposed as unwilling participants in a black-market business where low supply meets an even higher demand. Today’s article offers a few helpful tips on how to spot the red-flags of organ trafficking. First, let’s briefly look closer at this lesser-known form of financial exploitation.

What is organ trafficking?

Organ trafficking is the illegal sale and purchase of human organs (and in some cases, human cells and tissue) with the intent of transplantation. Organ trafficking can be voluntary (although still illegal), such as when someone makes the decision to sell their organ(s) for profit. Organ trafficking can also involve the sale of unsolicited organs where the organ is taken from an unsuspecting individual and without their permission. Organ trafficking deals in all organs within the human body, but the highest sought out organs are the kidneys. The estimated prices for parts of the human body in U.S. dollars include $30,000 for corneas, $150,000 for lungs, and $62,000 for kidneys (Source: Bloody Harvest, Matas & Kilgour 2007).

Preying on the needs of the vulnerable

In desperate times, people turn to desperate measures, and in some cases that involves going on the black market or the dark web to locate the needed organ despite the risk. That’s what makes this illicit trade so lucrative for those who engage in organ trafficking; they prey on the needs of the vulnerable. The harsh reality is that there is a shortage of organs, tissue, and cells needed for saving the lives of those who so desperately need it. This is a worldwide problem, and it impacts individuals no matter their financial status, ethnicity or, religion. The sad truth is that in some cases people are in such dire need of money that they are willing to sacrifice their health and life to get that money -- no matter the risk, no matter the amount. An equally sad reality is that for some people, the will to live is so strong they are willing to pay thousands of dollars for these organs and go wherever they can to obtain the organ in need.

Not just a medical problem

Organ trafficking may sound like a topic intended for those in the medical field more than in the financial sector, but this is an issue that affects everyone, including those in the financial industry. This is financial exploitation because organ traffickers prey on people’s vulnerabilities and needs. Moreover, this process is still illegal in the U.S. and in most other countries throughout the world. As such, it is still the responsibility of those of us in the financial industry to identify this illegal activity and report it.

Tips for spotting the signs of organ trafficking

Here are a few red flags to look for to identify a possible organ trafficking scheme. Keep in mind that organ trafficking may be hard to spot, as these activities can look like legitimate travel. Be on the lookout for the following signs:

  • Wire transfers to entities in high-risk jurisdictions with names that include variations of medical companies or medicinal purposes.
  • Payments among charities and medical tourism sites. This could also be considered ‘transplant tourism’ in which persons travel abroad to either obtain organs or to finish an organ transplantation.
  • For professional staff on the front lines, notice possibly ill customers moving large amounts of funds to numerous companies or charities prior to travel, especially to those in high-risk jurisdictions.
    • A good follow-up would be to conduct a thorough search for negative news and adverse media of all parties involved in the transaction.

While this is a sensitive topic, organ trafficking is a serious issue that must be reported. It is exploitation, and it is illegal. The red flags may be hard to spot, but hopefully these tips will help stop someone from preying on the needs of the vulnerable and save your financial institution from becoming an unwilling accomplice.