Human Trafficking in Illicit Massage Businesses About Polaris Polaris is a leader in the global fight to eradicate modern slavery. Named after the North Star that guided slaves to freedom in the United States, Polaris systemically disrupts the human trafficking networks that rob human beings of their lives and their freedom. Our comprehensive model puts victims at the center of what we do — helping survivors restore their freedom, preventing more victims, and leveraging data and technology to pursue traffickers wherever they operate. Polaris PO Box 65323 Washington, DC 20035 202-790-6300 [email protected] www.polarisproject.org 2 Table of Contents Letter from Rochelle Keyhan, Director, Disruption Strategies, Polaris 2 Acknowledgements 4 Special Acknowledgments: Service Providers 5 Introduction 7 SECTION 1: UNDERSTANDING HUMAN TRAFFICKING IN ILLICIT MASSAGE BUSINESSES 9 Overview of Illicit Massage Businesses in the United States 10 Marketing Illicit Massage Businesses to Buyers 14 Recruiting Women Into Illicit Massage Parlor Trafficking 19 Why Don’t They Just Leave? How Traffickers Use Force, Fraud and Coercion to Control Women 27 Illicit Massage Business Operations 35 SECTION 2: ENDING HUMAN TRAFFICKING IN ILLICIT MASSAGE BUSINESSES 43 A Complex Problem Requires a Multifaceted Solution 44 1. Overhauling Business Regulatory Frameworks 45 2. Unmasking Shell Companies to Reveal Business Owners 64 3. Supporting Effective, Survivor-Centered Law Enforcement 67 4. Closing Loopholes in the Commercial Real Estate Industry 72 5. Ending Online Practices that Legitimize Illicit Massage Businesses 74 6. Shifting the Media Narrative to Increase Public Understanding, Decrease Public Tolerance 77 7. Working Together to Ensure Victims Receive Robust, Culturally-Competent Services 81 Conclusion 85 Methodology 87 Polaris | Human Trafficking in Illicit Massage Businesses Letter from Rochelle Keyhan Director, Disruption Strategies, Polaris Dear Readers, I even had the chance to assess whether they The United Nations might be trafficking estimates that more victims. Meanwhile, the than 40 million people business owners and in the world today are operators who exploited living in some form of and abused them walked modern slavery. That free, having manipulated staggering figure makes the system to punish the one thing abundantly victim — not the trafficker. clear: We cannot end I knew this was a cycle human trafficking one that we could end. victim, one case, one Today, our team incident at a time. We approaches the work of have to scale up. ending IMB trafficking The Disruption by identifying exploiter- Strategies team at Polaris has taken on the challenge of focused, victim-centered strategies that work. We build scaling up by developing ways to make life difficult for off of the work of Polaris’ National Human Trafficking human traffickers. We are finding, testing and refining Hotline’s engagement with survivors, consulting and approaches that make it more risky and less lucrative working with survivors and direct service providers to for traffickers to do business, and bringing those assess the needs and realities articulated by victims approaches to stakeholders in cities, suburbs, and rural of human trafficking. We also meet with invested areas — anywhere we find dedicated, invested partners. local heroes around the country doing innovative, effective work to shut down trafficking in their Our work is guided by a groundbreaking 2017 communities, and we connect them to each other as Polaris report, The Typology of Modern Slavery, which well as to communities who are ready to learn from identifies 25 individual types of human trafficking in the them. Sometimes we connect agencies within a single United States today. Each type has its own business jurisdiction to help them understand how — and why — model, defying a one-size-fits-all approach to ending they can work together. We provide research and best human trafficking. If we want to disrupt trafficking, we practices to make sure that local anti-trafficking efforts have to do it one type at a time. are both informed by national trends and responsive Currently, the Polaris Disruption Strategies Team to local community needs, producing sustainable and is focusing on illicit massage businesses (IMBs), a relevant shifts in their local systems. unique form of trafficking that operates in plain sight I am proud to say that there are countless in communities across the country. Our mission is close communities that want to do this work, and do it right. to my heart. As a prosecutor for six years, I saw many There are also, of course, significant barriers, including potential trafficking victims arrested for prostitution lack of knowledge, resources, and support to serve in IMBs. In some cases, they were deported before survivors and keep them safe. 2 In the past two years, we have assisted with the passage of dozens of local laws, as well as three statewide laws that increase protections for survivors and accountability for traffickers in 709 U.S. cities. We have engaged more than 100 law enforcement jurisdictions across 31 states, helping them understand the difference between human trafficking and prostitution and both how and why to adopt an exploiter-focused, victim-centered approach to human trafficking in IMBs. This approach ensures that every future operation represents another step away from repetitious low-level arrests that typically only penalize potential victims, towards a future where traffickers are held accountable and our communities become inhospitable to them. As a result of consulting directly with survivors themselves, we have also empowered and connected more than two dozen service providers to improve the cultural humility and diversity of their services for IMB survivors, and to form a national safety net for survivors. I am incredibly proud of the work we do, and of the people who have collaborated with us, opened their hearts and eyes to new ways of doing things, and asked for and offered invaluable help. We are constantly learning, together. With this report, we invite you to join us. Rochelle Keyhan Director, Disruption Strategies, Polaris 3 Polaris | Human Trafficking in Illicit Massage Businesses Acknowledgements This report was a collaborative effort, spearheaded Thank you to Attorney General Bob Ferguson by Rochelle Keyhan, Director of Disruption Strategies, (WA), Attorney General Sean Reyes (UT), and and the Disruption Strategies team including Meghan the National Association of Attorneys General Carton, Anna Kegler, Veronica Buckley, Sydney Boone, (NAAG) for their early support, including leading Francheska Loza and Alexa Schaeffer who together the recruitment of their colleagues to partner with produced the original research and analysis, and were Polaris to disrupt trafficking in IMBs on a national scale. instrumental to the creation of this report. Bradley Thanks to their efforts, partnership among Attorney Myles, Nancy McGuire Choi, Caren Benjamin, and General Offices has ranged from making efforts to Sara Crowe generously provided input and edits understand the footprint of IMBs in a given state, to throughout, and we are also grateful to the many others joining a dialogue with other communities who are across Polaris who helped make this report a success. also undertaking this work, to deploying different We would like to thank the National Human Trafficking investigative strategies and prosecutorial tools to Hotline team for its dedication in serving survivors, with increase risk and decrease the profits for traffickers. a special thanks to Samantha Gillis for working to ensure We would like to thank all of the dedicated contract calls related to potential IMB trafficking are consistently researchers and volunteers who helped us map IMBs handled in a way that is culturally-competent and across the country, investigate recruitment patterns, sensitive to the particular needs of IMB survivors. and research laws and other aspects of IMB trafficking. We are grateful to the NoVo Foundation, whose Thank you to Eliza Carmen, Cristina Kinsella, Raydia generous financial support made this report possible. Martin, Andreia Martino, Leigh Creighton Bond, We would never have been able to complete this Stephanie Bagnell, Erica Avery, Annie Khan, Alison report without help from many passionate, dedicated Aminzadeh, and Victoria Ruby for researching laws individuals and partnerships. We would like to thank our and ordinances across the country. Thank you to Klara law enforcement partners for sharing their knowledge Wisniewska, Sarah Zalonis, Alisha Malkani, and Lori and experience investigating and prosecuting IMB Sturdivant for helping us map IMBs nationally, and trafficking cases. Thank you specifically to theLos Bailey Powe for analyzing recruitment data, and to Angeles Sheriff’s Department, Seattle Police Megan Rigabar for researching how Yelp and Groupon Department, King County Prosecutor’s Office, and allow IMBs to create a veneer of legitimacy. the San Francisco Department of Public Health for Most importantly, we would like to extend our their contributions. Thank you to Demand Abolition gratitude to the survivors of trafficking who have for sharing buyer data and insights in advance of its found the courage to share their experiences with upcoming report. We would also like to thank our our hotline advocates and service provider partners partners in business and finance for sharing their around the country. Without their testimony, this invaluable expertise