Following the publication of the Egmont Group’s work focussing on the threat from online child sexual abuse and exploitation (CSAE), (See: https://egmontgroup.org/en/content/combatting-child-sexual-abuse-and-exploitation-iewg-project-report-now-available), Financial Crime News contacted Ian Mynot, Head of the UK Financial Intelligence Unit at the U.K. National Crime Agency to find out more about the level type and nature of the threat and the best way to respond.
Q 1 – Financial Crime News (FCN): What do we mean by online Child Sexual Abuse & Exploitation (CSAE).
A – Ian Mynot (IM): in the project we were focussing on the online, or live, streaming of child sexual abuse and exploitation (CSAE). A horrific crime that causes significant harm to children and to the wider society in which it pervades. It involves abuse of children taking place in one location, with the events streamed live and viewed by offenders in other locations, for money.
Q 2 – FCN: Is this a growing problem?
A – IM: there has certainly been a growth in online streaming of CSAE which has been facilitated by developing technology and the expanding reach of the internet. Access to technology has made it almost effortless for offenders to network and enable the exploitation of children. In addition, the work of LEAs may have discouraged some offenders from undertaking contact sexual abuse, including travelling to other countries to undertake such abuse.
Q 3 – Is this controlled by organised crime?
A – IM: It’s not clear to what extent organised crime groups (OCGs) are involved in online streaming of CSAE. It is possible that organised activity differs from disorganised activity due to a higher volume of funds movement. While it is noted that a lack of large profits means wide-scale involvement of OCGs is likely to be limited, there is some evidence of criminal business structures in developing countries exploiting the commercial opportunities presented by online streaming of CSAE.
Q – 4: FCN: How do the money movements work?
A – IM: The remittance of payments related to CSAE mainly occurs through MSBs and internet payment providers. However, some payments are observed via banks, as modern payment platforms and fintech products are often linkedto traditional bank accounts. We see the use of online money transfer platforms, as well as some remittance services paid for in cash. There are limited examples of the use of virtual currencies. The general pattern for payments is upfront before the material is streamed, reflecting the financial incentive for facilitators.
The project has demonstrated that it is difficult to delineate financial transactions related to payment for online streaming of CSAE from payment for adult sexual content, scam activity or payment other CSAE related material such as images. Other crimes in action such as some fraud typologies or ‘sextortion’ may have similar financial profiles. Of course in the UK there is still a potential benefit in receiving suspicious activity reports on these, but it does illustrate the challenges that there can be in accurately identifying online streaming activity.
The project has worked up further detail on what the payments look like, which is sensitive. However, in the UK we have issued an Alert for industry partners, based on the Egmont project, providing financial indicators and keywords to help firms better identify suspicious transactions.
Q 5: FCN: – Which Jurisdictions were identified?
A: IM: The project identified a large number of jurisdictions as receiving or remitting funds for live streaming. Typically, the country where the activity is facilitated is in the developing world, with the activity being purchased or viewed from more developed countries. A common victim country is the Philippines. The Anti-Money Laundering Council, the FIU of the Philippines, has co-led this project along with the UKFIU and AUSTRAC, and as done some excellent work on this. A large number of developed countries have been identified as being from where the activity is viewed.
Q6 – FCN: This work was a collaboration across the public and private sectors and using multiple data sets – did this prove beneficial?
A – 6 IM: This was a true collaboration. As well as collaboration between the leading FIUs, there was international cooperation across the project team by various FIUs from a wide range of affected countries, and Interpol. We also engaged with the private sector and had some fantastic input that helped us develop the strategic intelligence picture. We also then considered data sharing with the private sector, considering the respective merits of different forms of data exchange. The NGO sector is also important in this area, and we engaged with one in particular, the Child Rescue Coalition.
It is important that this work continues, and we have plans for this in the UK. By FIUs, LEAs, and financial institutions pooling data and leveraging various models of information exchange we will certainly identify further financial activity linked to offenders engaged in and/or facilitating online streaming of CSAE.
The report notes that the use of some forms of non-financial / cyber-related data, not normally held by FIUs, appears to result in high quality intelligence and indicates a potential value not achieved via other forms of data exchange. We have explored the benefit in combining financial information with other forms of information in this way and undertaking data exchange between non-FIU entities.
The collaboration was extensive and Jointly-led by AUSTRAC, Australia, UKFIU, United Kingdom and AMLC, Philippines, with collaboration with INTERPOL and the FIUs from: Canada, Denmark, France, Germany, Guatemala, Isle of Man, Indonesia, Latvia, Luxembourg, Malaysia, Mexico, Netherlands, Nigeria, Norway, Peru & the Seychelles together with a number of private sector entities such as: American Express, MoneyGram, PayPal, TransferWise, Western Union & WorldRemit.
Q7 – FCN: Are we going to see more of this type of collaboration?
IM: Certainly in the UK, we have established forms of public / private sector collaboration. Within the UKFIU we hope to continue to leverage our relationships with the private sector, gained through this project to generate better intelligence. There is a lot of important work yet to do on this subject.
Q8 – FCN: What happens to the SARs?
IM: Under the UK model SARs relating to online steaming and other high risk SARs are identified and handled very dynamically by the FIU. We analyse the material on reciept, package it up and disseminate it fast time to law enforcement partners for action. CSAE is a major priority for the NCA and UK law enforcement, and leads get progressed very actively.
Q8 – FCN: Whilst the public report is useful there is clearly and highlighted additional information that can’t be publicly released – how can those wanting to do more access this type of information?.
IM: We have shared additional material to help firms better identify suspicious activity via an Alert, and other jurisdictions may have other mechanisms for disseminating relevant material.