HUMAN TRAFFICKING

Implementation of Related 

Statutory Provisions, Law 

Enforcement Efforts, and 

Grant Funding

Statement of Gretta L. Goodwin, Acting Director, 

Homeland Security and Justice

Testimony 

Before the Committee on the Judiciary, 

U.S. Senate

For Release on Delivery 

Expected at 10:00 a.m. ET

Tuesday, June 28, 2016

GAO-16-748T

United States Government Accountability Office
Letter

Page 1 GAO-16-748T 

Chairman Grassley, Ranking Member Leahy, and Members of the 

Committee:

I am pleased to be here today to discuss our recently completed work on 

human trafficking.

Sometimes perceived to be a foreign issue, human trafficking— the 

exploitation of a person typically through force, fraud, or coercion for such

purposes as forced labor, involuntary servitude or commercial sex—is 

occurring in the United States. Human trafficking victims include women, 

men and transgender individuals; adults and children; and foreign 

nationals and U.S. citizens or nationals who are diverse with respect to 

race, ethnicity, and sexuality, among other factors. Human trafficking can 

take place in rural, suburban, and urban settings throughout the country, 

and often involves victims who are already vulnerable—such as missing 

and runaway youth or persons dealing with substance abuse addictions.

Over the past few decades, Congress has taken numerous legislative 

actions to help combat human trafficking and ensure that victims have 

access to needed services. The Justice for Victims of Trafficking Act of 

2015 (JVTA) contained a provision for GAO to assess federal and 

selected state efforts to implement provisions in six human traffickingrelated statutes— JVTA, Trafficking Victims Protection Reauthorization 

Act of 2005, Trafficking Victims Protection Act of 2000, Victims of Child 

Abuse Act of 1990, Runaway and Homeless Youth Act, and Missing 

Children’s Assistance Act. Federal agencies, including the Departments 

of Justice (DOJ) and Homeland Security (DHS), have taken steps to 

combat human trafficking in the United States and to assist victims, often 

through grant programs.

My testimony today summarizes our analysis of federal agencies’ efforts 

to implement provisions and our observations regarding federal and 

selected state law enforcement efforts to combat human trafficking in the 

United States. Specifically, this testimony addresses:

(1) actions federal agencies have taken to implement programs and 

initiatives that were authorized by the six statutes;

(2) challenges federal and selected state law enforcement and 

prosecutorial agencies have faced when combating human trafficking 

in the United States; and

Letter
Page 2 GAO-16-748T 

(3) grant programs intended to combat human trafficking and assist 

victims in the United States, and federal agencies’ efforts to reduce 

the potential for duplication across those grant programs.

This statement is based on a report that we issued in May 2016 and 

another report that we issued earlier today.1 For our work on efforts to 

implement provisions in certain human trafficking-related statutes, we 

reviewed the six statutes and identified the provisions that called for the 

establishment of a program or initiative. We identified the federal entities 

designated as the lead or co-lead for implementing the provisions and 

asked them to identify any actions taken to implement the provisions and 

to provide supporting documentation of those actions. Given the number 

of provisions included in the six statutes, the multiple federal entities 

responsible for implementing the provisions, and the timeframe in which 

we were to complete this review, we did not independently assess the 

extent to which the provisions were implemented. Instead, we reviewed 

the documentation provided by each entity to determine whether they had 

taken any action or no action towards implementing the provision. For 

those entities that did not take any action, we asked them to explain the

reason why. For our work on law enforcement efforts and grants to 

combat human trafficking, we reviewed trafficking data and agency 

documents, and conducted 32 interviews with federal, state and local law 

enforcement officials and prosecutors in four jurisdictions. We selected 

those jurisdictions based on the number of human trafficking tips they 

received, receipt of human trafficking task force funding and geographic 

variation. These officials’ perspectives cannot be generalized to all 

jurisdictions but they provide insights into anti-trafficking efforts. For our 

work on grant programs, we reviewed grant documentation and 

interviewed federal officials responsible for administering human 

trafficking-related grant programs and grantees. Further details on the 

scope and methodology for our previously issued reports are available 

within each published product. We conducted the work on which this 

statement is based in accordance with generally accepted government 

auditing standards.

 1

GAO, Human Trafficking: Actions Taken to Implement Related Statutory Provisions, 

GAO-16-528R (Washington, D.C.: May 26, 2016), and GAO, Human Trafficking: Agencies 

Have Taken Steps to Assess Prevalence, Address Victim Issues, and Avoid Duplication, 

GAO-16-555 (Washington, D.C.: Jun. 28, 2016).
Page 3 GAO-16-748T 

Several components within DOJ, DHS, and the Departments of Defense, 

Labor, and State have responsibility for investigating and prosecuting 

human trafficking crimes, as shown in figure 1.

Figure 1: Federal Agencies Responsible for Investigating and Prosecuting Human Trafficking Crimes in the United States

In addition to federal investigative and prosecutorial agencies, other 

agencies play a role in helping to identify human trafficking, such as 

DHS’s Transportation Security Administration (TSA), U.S. Citizenship and 

Immigration Services (USCIS), U.S. Customs and Border Protection, 

Federal Emergency Management Agency, and Coast Guard. These 

agencies may encounter human trafficking victims in their daily 

operations, including at airports, land borders, and seaports. The Equal 

Employment Opportunity Commission (EEOC) and the Department of 

Labor’s Wage and Hour Division may encounter human trafficking when 

conducting investigations related to their statutory authority. For example, 

EEOC investigates alleged violations of Title VII of the Civil Rights Act of 

Background
Page 4 GAO-16-748T 

1964, which prohibits employment discrimination based on, race, color, 

religion, sex, and national origin, which in certain circumstances involve 

human trafficking victims.

In addition to investigating and prosecuting human trafficking crimes, 

federal agencies, primarily DOJ and the Department of Health and 

Human Services (HHS), support state and local efforts to combat human 

trafficking and assist victims. Several components within DOJ’s Office of 

Justice Programs, including the Office of Juvenile Justice and 

Delinquency Prevention, Office for Victims of Crime, Bureau of Justice 

Assistance (BJA), and National Institute of Justice (NIJ), administer 

grants to help support state and local law enforcement in combating 

human trafficking and to support nongovernmental organizations and 

others in assisting trafficking victims or conducting research on human 

trafficking in the United States. HHS also provides grant funding to 

entities to provide services and support for trafficking victims, primarily 

through components of the Administration for Children and Families 

(ACF), including the Children’s Bureau, Family and Youth Services 

Bureau, and Administration for Native Americans. 2 Further, ACF 

established the Office on Trafficking in Persons in 2015 to coordinate 

anti-trafficking responses across multiple systems of care. Specifically, 

HHS supports health care providers, child welfare, social service 

providers, and other first responders likely to interact with potential victims 

of trafficking through a variety of grant programs. These efforts include 

integrated and tailored services for victims of trafficking, training and 

technical assistance to communities serving high-risk populations, and 

capacity-building to strengthen coordinated regional and local responses 

to human trafficking.

 2 See, e.g., 18 U.S.C. § 3014(a)-(h); 22 U.S.C. § 7105(b)(1), (f)(1), (2), (3); 42 U.S.C. § 

5714-41; Pub. L. No. 114-22, tit. VII, 129 Stat. at 261-63.
Page 5 GAO-16-748T 

In our May 2016 report, we identified 105 provisions across the six 

statutes that we reviewed that called for the establishment of a program 

or initiative.3 Many of the provisions identified more than one entity that is 

responsible for implementing the programs or initiatives. The breakdown 

of whether or not federal entities reported taking actions to implement 

these provisions is as follows:

• For 91 provisions, all responsible federal entities reported taking 

action to implement the provision.

• For 11 provisions, all responsible federal entities reported that they 

had not taken action to implement the provision.

• For 2 provisions, at least one of the responsible federal entities 

reported that they had not taken action to implement the provision or 

they did not provide a response.

• For 1 provision, none of the responsible federal entities provided a 

response.

The provisions cover various types of activities to address human 

trafficking and related issues, including: Grants (33), Coordination and 

Information Sharing (29), Victim Services (28), Reporting Requirements 

(26), Training and Technical Assistance (25), Research (24), Criminal 

Justice (20), Public Awareness (14), and Penalties and Sanctions (7).4

Agency officials provided various explanations for why they had not taken 

any actions to implement certain provisions for which they were 

designated as the lead or co-lead. For example, in three cases, officials 

cited that funding was not appropriated for the activity.

 

3 GAO, Human Trafficking: Agencies Have Action to Implement The Related Statutory 

Provisions, GAO-16-528R (Washington, D. C.: May 27, 2017), 3-4.

4

One provision could authorize more than one type of activity; therefore, the numbers in 

parentheses total more than 105. 

Federal Entities Have 

Taken Actions to 

Implement Most of 

the Provisions across 

Six Human 

Trafficking-Related 

Statutes
Page 6 GAO-16-748T 

In June 2016, we reported that federal, state and local law enforcement 

officials and prosecutors identified several challenges with investigating 

and prosecuting human trafficking, including a lack of victim cooperation, 

limited availability of services for victims, and difficulty identifying human 

trafficking. The officials told us that obtaining the victim’s cooperation is 

important because the victim is generally the primary witness and source 

of evidence. However, the officials said that obtaining and securing 

victims’ cooperation is difficult, as victims may be unable or unwilling to 

testify due to distrust of law enforcement or fear of retaliation by the 

trafficker, among other reasons. According to these officials, victim 

service programs, such as those that provide mental health and 

substance abuse services have helped improve victim cooperation; 

however, the availability of services is limited. Further, the officials 

reported that identifying and distinguishing human trafficking from other 

crimes such as prostitution can be challenging. Federal, state, and local 

agencies have taken or are taking actions to address these challenges, 

such as increasing the availability of victim services through grants and 

implementing training and public awareness initiatives.

With respect to training, we reported that federal agencies have 

implemented several initiatives to train judges, prosecutors, investigators 

and others on human trafficking. For example, in accordance with the 

JVTA, the Federal Judicial Center provided training to federal judges and 

judicial branch attorneys, including judicial law clerks, on human 

trafficking through a webinar in August 2015. 5 The training walked 

participants through the provisions of the JVTA and addressed how child 

exploitation manifests in human trafficking cases, among other things. 

According to Federal Judicial Center officials, 1,300 registered viewers 

participated in the webinar, which is now available for on-demand viewing 

on the Federal Judicial Center website. In addition, DHS’s Immigration 

and Customs Enforcement, Homeland Security Investigations provides a 

human trafficking training course that uses video scenarios and group 

discussions to teach its agents how to identify human trafficking, how to 

distinguish human trafficking from smuggling, and how to conduct victimcentered investigations, among other things. Similarly, the Federal 

 

5 The Justice for Victims of Trafficking Act of 2015 required the Federal Judicial Center to 

provide training for judges on ordering restitution for victims of certain trafficking-related 

offenses under chapter 77 of title 18, U.S. Code. See Pub. L. No. 114-22, tit. I, § 114, 129 

Stat. at 242 (section 114 is known as the Combat Human Trafficking Act of 2015, and is 

classified to 42 U.S.C. § 14044g).

Selected Law 

Enforcement Officials 

and Prosecutors 

Reported Lack of 

Victim Cooperation, 

Limited Services, and 

Difficulty Detecting 

Victims as 

Challenges, and 

Have Taken Steps to 

Mitigate Them
Page 7 GAO-16-748T 

Bureau of Investigation provides annual specialized training in the

commercial sexual exploitation of children and dealing with victims of 

child sex trafficking.

We reported that some federal agencies also have efforts related to 

increasing public awareness of human trafficking. For example,

• In January 2016, DOJ’s Office for Victims of Crime released 

resources to raise awareness and serve victims, including a video 

series called “The Faces of Human Trafficking” and posters to be 

used for outreach and education efforts of service providers, law 

enforcement, prosecutors, and others in the community. The video 

series includes information about sex and labor trafficking, 

multidisciplinary approaches to serving victims of human trafficking, 

effective victim services, victims’ legal needs, and voices of survivors.

• Since 2010, DHS, through the Blue Campaign, reported it has worked 

to raise public awareness about human trafficking, leveraging 

partnerships with select government and nongovernmental entities to 

educate the public to recognize human trafficking and report 

suspected instances. According to DHS officials, Blue Campaign 

posters are displayed in public locations including airports and bus 

stops.

• HHS established the “Look Beneath the Surface” public awareness 

campaign through its Rescue and Restore Victims of Human 

Trafficking program. These materials, which included posters, 

brochures, fact sheets, and cards with tips on identifying victims, were 

available in eight languages.
Page 8 GAO-16-748T 

In June 2016, we also reported that in addition to training and public 

awareness, federal agencies have established grant programs to, among 

other things, increase the availability of services to assist human 

trafficking victims. We identified 42 grant programs with awards made in 

2014 and 2015 that may be used to combat human trafficking or to assist 

victims of human trafficking, 15 of which are intended solely for these 

purposes. According to our prior work addressing overlap and 

duplication:6

• Overlap occurs when multiple granting agencies or grant programs 

have similar goals, engage in similar activities or strategies to achieve 

these goals, or target the same or similar beneficiaries.

• Duplication occurs when a single grantee uses grant funds from 

different federal sources to pay for the exact same expenditure or 

when two or more granting agencies or grant programs engage in the 

same or similar activities or provide funding to support the same or 

similar services to the same beneficiaries.

Each of the15 grant programs that are intended solely to combat human 

trafficking contained at least some potential overlap with other human 

trafficking grant programs in authorized uses. For instance, funding under 

each of the 15 grant programs can be used for either collaboration or 

training purposes. Similarly, 9 of the 15 grant programs provide support 

for direct services to victims of human trafficking. Further, of the 123 

organizations that were awarded grants specific to human trafficking in 

fiscal years 2014 or 2015, 13 received multiple grants for either victim 

services or for collaboration, training, and technical assistance from DOJ 

and HHS. Of the 13, 7 had multiple grants that could be used for victim 

services, and 3 had multiple grants that could be used for collaboration, 

training, and technical assistance.7

We also reported in June 2016 that there are circumstances in which 

some overlap or duplication may be appropriate. For example, overlap 

can enable granting agencies to leverage multiple funding streams to 

serve a single purpose. However, coordination across the administering 

 

6

GAO, Fragmentation, Overlap, and Duplication: An Evaluation and Management Guide, 

GAO-15-49SP (Washington, D.C.: April 14, 2015). 

7 The remaining 3 organizations received one grant for victim services concurrently with 

one grant for collaboration, training, and technical assistance.

Some Overlap Exists 

Across Human 

Trafficking Grant 

Programs, but 

Agencies Have 

Processes to 

Minimize Grant 

Duplication
Page 9 GAO-16-748T 

granting agencies is critical for such leveraging to occur. On the other 

hand, there are times when overlap and duplication are unnecessary, 

such as if a grantee uses multiple funding streams to provide the same 

services to the same beneficiaries. DOJ and HHS each have intra-agency 

processes in place to prevent unnecessary duplication. According to DOJ 

and HHS officials, each agency operates an internal working group to 

allow the components administering human trafficking grants to 

communicate on a regular basis. For example, HHS officials indicated 

that offices that administer human trafficking grant programs meet 

monthly to exchange information, which may include grant-related 

announcements and coordination of anti-trafficking activities. DOJ has 

taken action to implement recommendations from a prior GAO report to 

identify overlapping grant programs and mitigate the risk of unnecessary 

grant award duplication in its programs. 8 In response to these 

recommendations, DOJ also requires grant applicants to identify in their 

applications any federal grants they are currently operating under as well 

as federal grants for which they have applied.

DOJ and HHS officials also reported that they routinely shared grant 

announcements with one another in an informal manner. For instance, 

HHS officials noted that DOJ and HHS meet bi-weekly during co-chair 

meetings for the Senior Policy Operating Group (SPOG) Victim Services 

Committee and both agencies participate in the SPOG Grantmaking 

Committee meetings, which provide opportunities to share information for 

the purposes of coordination and collaboration.9 Since 2006, the SPOG 

 8 GAO, Justice Grant Programs: DOJ Should Do More to Reduce the Risk of 

Unnecessary Duplication and Enhance Program Assessment, GAO-12-517 (Washington, 

D.C.: July 12, 2012).

9 The Trafficking Victims Protection Act of 2000 (TVPA), as amended, established the 

Senior Policy Operating Group (SPOG), consisting of senior officials from 14 federal 

agencies and the White House National Security Council and the Domestic Policy Council, 

to coordinate activities of federal departments and agencies regarding policies (including 

grants and grant policies) involving international human trafficking and the implementation 

of the TVPA. Pub. L. No. 106-386, div. A, § 105, 114 Stat. 1464, 1473-74, as amended by 

the Trafficking Victims Protection Reauthorization Act of 2003, Pub. L. No. 108-193, § 6, 

117 Stat. 2875, 2881 (22 U.S.C. § 7103(g)). In addition to the Domestic Policy Council 

and the National Security Council, the 14 SPOG agencies are the Departments of State, 

Defense, Justice, the Interior, Agriculture, Labor, Health and Human Services, 

Transportation, Education, and Homeland Security, the Office of Management and 

Budget, the Office of the Director of National Intelligence, the Federal Bureau of 

Investigation, the U.S. Agency for International Development, and the U.S. Equal 

Employment Opportunity Commission. 
Page 10 GAO-16-748T 

has provided a formal mechanism for all agencies administering human 

trafficking grants to communicate with one another. According to the 

SPOG guidance, which was updated in March 2016, participating 

agencies are to share information with members of the grants committee 

prior to final decisions in at least one of the following ways: (1) share 

plans for programs containing anti-trafficking components during the grant 

program development process; (2) notify the SPOG of grant solicitations 

within a reasonable time after they are issued; or (3) notify SPOG partner 

agencies of proposed funding recipients prior to announcing the award. 

Further, agencies are also to share information with members of the 

Grantmaking Committee after final decisions are made.

Chairman Grassley, Ranking Member Leahy, and Members of the 

Committee, this completes my prepared statement. I would be pleased to 

respond to any questions that you may have at this time.

If you or your staff have any questions about this testimony, please 

contact Gretta L. Goodwin, Acting Director, Homeland Security and 

Justice at (202) 512-8777 or goodwing@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this statement. GAO staff who made key contributions to 

this testimony are Kristy Love, Assistant Director; Kisha Clark, Analyst-in 

Charge; Paulissa Earl; Marycella Mierez; and Amanda Parker. Key 

contributors for the previous work on which this testimony is based are 

listed in each product.

GAO Contact and 

Staff 

Acknowledgments

(100930)
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