Human trafficking: keep your guard up as business returns

According to Deloitte’s 2022 Travel Industry Outlook, business is on the rise for hoteliers, bringing with it the ever-evolving challenges to operations and facility management. As travel increases, one challenge for hoteliers that continues to rear its ugly head is human and sex trafficking. Hotels can often serve as a venue for traffickers, leaving hoteliers in difficult situations.

Contributed by John Welty, SUITELIFE Underwriting Managers, Exton, Pennsylvania

Hoteliers find themselves with both a moral and legal responsibility to watch for signs of trafficking and report them. If hoteliers miss or fail to report signs of trafficking, they can be held both civilly and criminally responsible for allowing trafficking to happen on their premises.

Hoteliers have taken great strides in recent years to implement training programs to train staff on how to identify and report suspected incidents of trafficking. The global labor shortage makes it even more difficult for hoteliers to remain vigilant. Coupled with a new influx of business, it creates a perfect opportunity for traffickers to hide in plain sight in hotels.

Leading trafficking experts have reported that the pandemic has exacerbated the global trafficking problem. As a result, many U.S. state and government agencies are ramping up efforts to combat human trafficking, in addition to national and international trafficking laws already in place.

The possibility of increased incidents coupled with new state regulations can place mounting pressure on hotel owners and operators to take steps to prevent and report trafficking in their hotels. Hoteliers can stay up to date on various laws and regulations to train and inform their staff and potentially identify and deter human trafficking.

Recent incidents

Human trafficking continues to be a global problem, particularly for children, impoverished individuals, migrant workers and more of society’s most vulnerable people. Hotels are a hot spot for traffickers to frequent as they may allow for cash transactions, contactless check-ins and provide private spaces where traffickers can take advantage of the privacy afforded by a hotel guest room.

Just this past June, a Texas man was sentenced to more than 30 years in prison for sex trafficking a 14-year-old and an adult. The victims were reportedly trafficked through “multiple hotels in Dallas and California” and recovered in a Dallas hotel room.

Similarly, in July, a New York man was charged for “sex trafficking of a female minor victim at hotels in the Bronx and Brooklyn.” According to the U.S. Attorney’s Office for the Southern District of New York, the man led the minor to “engage in commercial sexual activity at hotels throughout the Bronx and Brooklyn for his own profit.” The teenage girl lived at a residential facility for at-risk youth.

In addition to the desire to protect vulnerable and at-risk populations, incidents such as these can also put hoteliers at risk for costly litigation, and reputational damage.

Keeping up with regulations

To cut down on and eliminate incidents like these, state regulators and other groups have been working to ramp up regulations and ensure hotel owners and operators stay in the know when it comes to human trafficking. Below are a few examples of regulations that are currently in effect:

Since 2020, a California law, SB 970, requires hotels and motels to provide a minimum of 20 minutes of training to hotel staff on human trafficking awareness and requires that the training is completed within six months of hiring. Hoteliers are then required to provide human trafficking training at least once every two years.

In Virginia, a new bill, HB 258, was signed into law, requiring training for all hotel and motel staff to help them recognize and report signs of human trafficking. The training is free for hotels and requires employees to take a course on human trafficking within their first six months of a new role and repeat training at least once every two years.

This June, the city of Scottsdale, Arizona, announced it has trained more than 75% of hotel employees to identify and report potential incidents of human trafficking, as part of an initiative with the Arizona Attorney General’s Office, The Arizona Anti-Trafficking Network and Homeland Security Investigations. Scottsdale is already seeing results from the training, as at least three hospitality industry employees have called in reports of human trafficking.

While these regulations are welcomed by hoteliers as a step in the right direction toward curbing and stopping this dehumanizing crime, different regulatory requirements across state lines can be difficult to track for national hotel groups. Hoteliers who are looking for helpful resources on this issue can take the following steps:

  • Review resources provided by ECPAT-USA, an anti-child trafficking organization, designed in partnership with the American Hotel and Lodging Association and Marriott International, that summarize state laws across the country regarding the display of human trafficking posters at hotels as well as employee training requirements. The DHS Resources for hotels – Hospitality Toolkit and training/Blue Campaign are also useful resources.
  • Consider joining an industry association for regular updates on industry initiatives and issues.
  • Monitor for updates from state and local regulators, including their social media channels and blogs.
  • Build relationships with your regulators and ask them to conduct regular risk assessments of your establishment, as well as make recommendations on how to strengthen programs and processes.
  • Document compliance processes to track progress and see where change is needed.

Staying vigilant

Ignoring signs of human trafficking is not just a moral problem. Hotels could be found liable under federal or state law. To serve best the interests of their guests and their business, hoteliers should consider the following in terms of human trafficking awareness and prevention:

  • Recognize the signs: Teach staff to look for signs of human trafficking. The S Department of Homeland Security suggests signs of human trafficking could be malnourishment, poor hygiene, guests dressing inappropriately, guests without identification or money, guests who only pay in cash, as well as guests who refuse to let staff enter the room but continue to request services. If surveillance cameras are on-site, videos can be reviewed frequently to identify any suspicious activity or guests coming and going outside normal hours.
  • Emphasize training: Training is critical for hoteliers to do their part to put an end to human trafficking. Hoteliers can access training resources from ECPAT-USA and many training courses are offered at no cost to hoteliers. Training should be conducted upon hiring, but also at regular intervals throughout the year. Training should incorporate red flags and how to report suspicious activity.
  • Make a plan: Develop a detailed plan around human trafficking awareness and training for your hotel. Address training, identification, response, reporting and documentation, and provide a clear protocol for employees.
  • Surround yourself with the right resources: Work with professional services firms that understand the industry and its risks, including human trafficking. Hoteliers should also work with local law enforcement to train staff, conduct drills and property walkthroughs and know who to contact when suspicious activity is identified. Law enforcement can also update staff on new trends and statistics that develop. The Department of Homeland Security frequently updates their website with training materials and videos that are useful for staff training.

Hoteliers are sure to have their hands full with increased travel demand and a paucity of team members. While focusing on the business of meeting and exceeding your guests’ needs, it is now, more than ever, important to watch for signs of guests with ulterior motives and work toward putting an end to human trafficking. 

Note: The information contained in this material is for information purposes only. This material should not be relied on or treated as a substitute for specific advice relevant to any particular circumstances. Appropriate steps to manage any of the risks described herein will vary depending on particular circumstances. This material should be considered in addition to all other relevant information, including the advice of professional advisors, best practices suggested by health and safety organizations and the requirements of any applicable policy of insurance.