Joint initiative targets human trafficking in Tribal casinos

October 30, 2023 6:46 PM
  • Steve Chen — Special to CDC Gaming Reports
October 30, 2023 6:46 PM
  • Steve Chen — Special to CDC Gaming Reports

Every year, thousands of Americans are victims of human trafficking. Two years ago, over 10,000 incidents were reported to the National Human Trafficking Helpline. Responding to this ever-growing problem, in June 2023, a significant stride was made in the fight against human trafficking within the tribal-gaming and hospitality industries.

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The National Indian Gaming Commission (NIGC), Bureau of Indian Affairs (BIA), Department of Homeland Security (DHS), and U.S. Treasury Department unveiled an online toolkit designed to combat this pressing issue and give advice on how to identify signs of human trafficking in tribal casinos. The toolkit explains that we need not only enforcement and punishment, but more education and support. It stresses the importance of social responsibility and raising awareness of the signs of human trafficking.

Although this specific report and the efforts associated with it are aimed at Tribal casinos, many other sectors within the gambling industry face similar challenges, with various jurisdictions overlapping and no one clear source of authority that has jurisdictional power to enforce action.

News writer Steve (Ziv) Chen from the Major League Content news company recently took the opportunity to sit in an industry panel on the topic at the Global Gaming Expo in Las Vegas and meet with the major figures involved in this joint effort to battle human trafficking.

A new tool for tribal casinos to take on human trafficking

The toolkit’s release earlier this year was a culmination of collaborative efforts, recognizing the unique vulnerabilities within the tribal gaming and hospitality sectors. Human trafficking, a shadowy and pervasive crime, often exploits industries where oversight might be challenging and victims might go unnoticed. Unfortunately, the tribal-gaming and hospitality industries, with their vast networks and diverse clientele, (may) present such an environment.

Informed by survivors and tailored specifically for these sectors, the toolkit offers a blend of culturally relevant survivor-informed tips and resources. It provides clear definitions, distinguishing between crimes like sex trafficking and prostitution and emphasizing the manipulation or force that characterizes the former. Recognizing that signs of human trafficking can manifest differently based on one’s role, it also offers insights tailored to various positions within the industry.

Awareness and knowledge of the warning signs are the best ways for gaming- industry staff to prevent potential human trafficking. The toolkit identifies key things to look out for, including recent relocation, mental-health or substance-use concerns, unstable housing, and homelessness. It’s important to note that relocation/migration is the most significant risk factor, with an estimated 40% of victims being new to the country.

Human trafficking can affect anyone, regardless of gender, race, or age. It’s crucial to acknowledge that victims may hesitate to seek help due to language barriers and distrust of authority. However, resources are available so the industry can learn the signs and implement strategies to combat it.

Research suggests that American Indians and Native Alaskans are particularly at risk. Law-enforcement issues within Indian lands play a part in the significant impact of trafficking on indigenous groups.

Collaboration is key

Jeannie Hovland, Vice Chair of the National Indian Gaming Commission (NIGC), and Eddie Ilko, the NIGC’s Safety and Occupational Health Manager, spoke to journalists about the collaboration, as well as how the toolkit represents an unprecedented step in collaboration and a positive development for tribal authorities in the pursuit of eliminating human trafficking on its lands.

Hovland’s previous roles, including her tenure as the Commissioner of the Administration for Native Americans, have seen her champion Indigenous rights and welfare. Hovland has been involved in the mitigation of these issues for some time. Notably, she was appointed to Operation Lady Justice, a presidential task force against human trafficking, underscoring her commitment to combating this problem in Native American populations.

Both Hovland and Ilko emphasized the role of education in the process and highlighted the pitfalls in existing laws — creating the need for agencies and communities to work together.

“Usually, if a human trafficking-related violation was identified by the tribal casino staff or regulatory authority, casino management and the law-enforcement agencies with jurisdiction would be notified. If a gaming operation’s primary management officials or key employees are involved in human trafficking, the NIGC will notify the Tribe that it must suspend these employees’ gaming licenses. And if these individuals seek employment at other Tribes’ gaming operations, the NIGC will object to the issuance of their gaming license,” Hovland said.

“To date, the NIGC has not had to take any enforcement actions in regard to human trafficking. The NIGC is encouraging and educating people about the need to know how to safely identify and report suspected human trafficking,” Hovland continued.

NIGC’s Human Trafficking Bulletin, issued in 2021, provides specific details on the agency’s collaboration with tribes and other federal agencies and its responsibilities under IGRA, Hovland added.

Ilko said, “This is where the debate about education versus enforcement comes into play. There are many factors to this problem and there is no one-size-fits-all solution. We need to teach communities about the size of the problem and give people in the community solutions and best practices. We put a lot of effort into teaching people in the community to spot red flags and we’re working with tribal elders to warn about this situation in gaming. Ensuring safe gaming is the only way tribal gaming can succeed.”

He continued, “So many jurisdictions overlap. It’s a maze of jurisdictions and perpetrators know the loopholes. We at NIGC don’t have the experience and resources to cover everything, so we rely on our federal law-enforcement partners to collaborate with tribes and local authorities to ensure tribes receive the resources they need.”

Historically, hotels and casinos are often used in human-trafficking crimes, so it’s more important than ever to be alert. Examples of warning signs include someone who doesn’t seem to be in charge of their ID, not knowing the hotel name or area where they are, appearing unforthcoming about their name or address, or allowing another person to speak for them.

When asked about the prevalence of human trafficking in tribal-gambling establishments, Hovland is uncertain how widespread it is, but insisted, “We want our community and people to feel safe and our training can help in supporting safe communities.”

A unique opportunity

The gambling industry has identified this unique opportunity and obligation to patrons and potential victims to spot suspicious activities and prevent harm. The efforts of the NIGC, BIA, DHS, and other bodies have underlined a desire to make a meaningful difference and save lives by staying informed about what to look out for.

Structural, cultural, and agency staffing problems are also a factor and an official from the Bureau of Indian Affairs highlighted problems with understaffing, compounding the need for agencies and community leaders to work together to pool resources. The official stressed this with a pertinent question: “If people are facing issues, who are they going to call? Who is their partner?”

The official also said, “We need to encourage tribes to be open and report. Therefore, we need support and education, not only enforcement.”

The toolkit’s inception saw collaboration from tribal leaders, gaming employees, and indigenous communities. Hovland, co-author of the document, is a member of the Flandreau Santee Sioux and has been at the forefront of this initiative. On how the collaboration came about, Hovland said, “A lot has to do with Native American leaders. They decided we should all join forces to find a solution to this problem on a local, tribal, and federal level.”

An official from the Department of Homeland Security echoed this point. “[This is] a natural development on the work that has been done before, and the product of a decision that something needed to be done about this issue,” adding, “This problem can only be solved with a whole-world approach; agencies, tribal elders, and the whole community must work together.”

Partnership points the way forward

In line with this collaborative spirit, the DHS has also been instrumental through its Blue Campaign, a national public awareness initiative. The Blue Campaign aims to educate the public, law enforcement, and other industry partners to recognize the indicators of human trafficking and respond appropriately to possible cases.

Situated within the Office of Partnership and Engagement and in alignment with the DHS Center for Countering Human Trafficking, the campaign utilizes partnerships with the private sector, NGOs, law enforcement, and state/local authorities to enhance public engagement in anti-human trafficking efforts. Its educational objectives are foundational in both the prevention of human trafficking and the protection of exploited persons.

However, the impacts of this knowledge sharing are already evident. Several strategies are being implemented by casino security staff to effectively deal with human-trafficking activity occurring on-site. The next step is training and educating casino, hotel, and hospitality staff, as well as gaming regulators, to raise awareness and recognition of the indicators of human trafficking. Casino workers should be provided with recurrent training on indicators of human trafficking and current trends in sex trafficking.

Ultimately, ending human trafficking in America requires a long-term commitment and a collective determination to abolish this modern-day slavery once and for all. It is a challenge that strikes at the heart of our values and by addressing it head-on, we can strive to create a safer and more just nation for all.

The toolkit has been incredibly successful, with nearly 43,000 downloads since its publication. It also represents a fruitful partnership between agencies to tackle this horrendous issue and as one official told journalists, “Partnership is where it’s at.” Even though there is much work to do, the collaboration among different jurisdictions and agencies is a remarkably positive development in combating this crime.

Applying these lessons to other areas in the gambling industry, especially the fragmented online gambling sector, the key takeaways are a common sense of purpose of all parties involved, the openness to look inward and admit the industry can cause problems and exploitation, the realization that there isn’t one responsible authority that can enforce action and solutions, and the ability and willingness for all parties to collaborate and work together to self-regulate and help those in need.

Steve Chen initially came looking for points of comparison and lessons to be learned and applied to the wider gambling industry. But having spoken to the people involved, he found a group of honest and inspirational leaders who openly discuss problems and are driven to make a change.