SEX TRAFFICKING
Online Platforms and
Federal Prosecutions
Report to Congressional Committees
June 2021
GAO-21-385
United States Government Accountability Office
United States Government Accountability Office
Highlights of GAO-21-385, a report to
congressional
committees
June 2021
SEX TRAFFICKING
Online
Platforms and Federal Prosecutions
What GAO Found
Two events in April 2018 disrupted the landscape of the online commercial sex
market. First, federal authorities seized the largest online platform for buying and
selling commercial sex, backpage.com. Second, the Allow States and Victims to
Fight Online Sex Trafficking Act of 2017 (FOSTA) was enacted. These events led
many who controlled platforms in this market to relocate their platforms overseas.
Additionally, with backpage.com no longer in the market, buyers and sellers
moved to other online platforms, and the market became fragmented.
From 2014 through 2020, the Department of Justice (DOJ) brought at least 11
criminal cases against those who control platforms in this market, including three
cases against those who control backpage.com, as shown below.
Federal Criminal Cases Brought against Those Who Control Platforms in the Online
Commercial Sex Market Under Various Laws Including FOSTA (from 2014 through 2020)
Note: Funds targeted by DOJ represents funds in accounts that have been seized, are subject to potential forfeiture,
or have been ordered to be forfeited. GAO uses the term “at least” because there is an unknown amount of funds in
many accounts. Funds in cryptocurrency are expressed in the equivalent of U.S. Dollars.
The current landscape of the online commercial sex market heightens already-
existing challenges law enforcement face in gathering tips and evidence.
Specifically, gathering tips and evidence to investigate and prosecute those who
control or use online platforms has become more difficult due to the relocation of
platforms overseas, platforms’ use of complex payment systems, and the
increased use of social media platforms.
Criminal restitution has not been sought and civil damages have not been
awarded under section 3 of FOSTA. In June 2020, DOJ brought one case under
the criminal provision established by section 3 of FOSTA for aggravated
violations involving the promotion of prostitution of five or more people or acting
in reckless disregard of sex trafficking. As of March 2021, restitution had not
been sought or awarded. According to DOJ officials, prosecutors have not
brought more cases with charges under section 3 of FOSTA because the law is
relatively new and prosecutors have had success using other criminal statutes.
Finally, in November 2020 one individual sought civil damages under a number
of constitutional and statutory provisions, including section 3 of FOSTA.
However, in March 2021, the court dismissed the case without awarding
damages after it had granted defendants’ motions to dismiss.
Why GAO Did This Study
Online marketing and communication
platforms
can enable sex trafficking—
the
commercial sexual exploitation of
adults through force, fraud or coercion,
or children under the age of 18
(with or
without force, fraud, or coercion)
—by
making it easier for traffickers to
exploit
victims and connect with buyers.
Section 3 of
FOSTA established
criminal penalties
for those who
promote or facilitate prostitution and
sex trafficking
through their control of
online platforms
. It also allows for
those
injured by
an aggravated violation
involving
the promotion of prostitution
of five or more
people or reckless
disregard of sex trafficking
to recover
damages in a federal civil action
.
It also
makes federal criminal restitution
mandatory for aggravated offenses
contributing to sex trafficking
.
FOSTA includes a provision for GAO to
provide
detailed information on
restitution and civil damages.
This
report examines: (1) DOJ enforcement
efforts
against online platforms that
promot
e prostitution and sex trafficking,
from 2014 through 2020
; and (2) the
extent to which criminal restitution and
civil da
mages have been sought and
awarded for aggravated violations
under section 3 of FOSTA.
GAO reviewed
federal criminal cases
b
rought against those who controlled
platforms in the online commercial sex
market from 2014 through 2020
;
visited
a selection of
online platforms in this
market
; and conducted a legal search
to identify criminal and civil cases
brought pursuant to section 3 of
FOSTA. GAO
also interviewed DOJ
officials and
representatives from third
parties.
View GAO-21-385. For more information,
contact Gretta L. Goodwin at (202) 512
-8777
or
Page i GAO-21-385 Sex Trafficking
Letter 1
Background 4
DOJ Enforcement Efforts and FOSTA Disrupted the Online
Commercial Sex Market, but Enforcement Challenges Exist 12
Criminal Restitution Has Not Been Sought and Civil Damages
Have Not Been Awarded under Section 3 of FOSTA 25
Agency Comments 30
Appendix I Objectives, Scope, and Methodology 32
Appendix II Types of Platforms in the Online Commercial Sex Market 39
Appendix III Federal Criminal Cases Brought Against Those Who Control Online
Platforms 45
Appendix IV GAO Contact and Staff Acknowledgments 50
Tables
Table 1: Models of Operation of Platforms in the Online
Commercial Sex Market 9
Table 2: Federal Law Enforcement Roles in Sex Trafficking Cases 11
Table 3: Categorization of 27 Platforms in the Online Commercial
Sex Market, as of November 2020 20
Table 4: Federal Criminal Cases Brought Against Those Who
Control Platforms in the Online Commercial Sex Market
(from 2014 through 2020) 46
Figures
Figure 1: Significant Events in the Online Commercial Sex Market
from 2010 through 2020 10
Figure 2: Federal Criminal Cases Brought against Those Who
Control Platforms in the Online Commercial Sex Market
from 2014 through 2020 13
Contents
Page ii GAO-21-385 Sex Trafficking
Figure 3: Use of Online Platforms to Solicit Buyers in New Federal
Criminal Sex Trafficking Cases from 2014 through 2019 17
Figure 4: Payment Methods Accepted by 27 Platforms in the
Online Commercial Sex Market, as of November 2020 23
Figure 5: Use of Social Media, Dating, Hookup, and
Messaging/Communication Platforms to Solicit Buyers in
New Federal Criminal Sex Trafficking Cases (from 2014
through 2019) 24
Figure 6: Screenshot from Advertising Platform in the Online
Commercial Sex Market 40
Figure 7: Screenshot from Hobby Board Platform in the Online
Commercial Sex Market 42
Figure 8: Screenshot from Sugar Dating Platform in the Online
Commercial Sex Market 43
Page iii GAO-21-385 Sex Trafficking
Abbreviations
CEO Chief Executive Officer
DOJ Department of Justice
EOUSA Executive Office for U.S. Attorneys
FBI Federal Bureau of Investigation
FOSTA Allow States and Victims to Fight Online Sex Trafficking
Act of 2017
HTI Human Trafficking Institute
This is a work of the U.S. government and is not subject to copyright protection in the
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Page 1 GAO-21-385 Sex Trafficking
441 G St. N.W.
Washington, DC 20548
June 21, 2021
Congressional Committees
Sex trafficking—the commercial sexual exploitation of adults through
force, fraud or coercion, or of children under the age of 18 (with or without
force, fraud, or coercion)—is occurring in the United States and abroad.
1
A type of human trafficking, sex trafficking deprives countless individuals
of their dignity and freedom. Traffickers may seek out those perceived to
be vulnerable, such as runaways, those living in poverty, or those with
drug addictions.
Online marketing and communication platforms can enable sex trafficking
by making it easier for traffickers to exploit victims and connect with
buyers. Two events in particular are reported to have altered the
landscape of online sex trafficking in recent years. First, federal
authorities seized the largest online platform for buying and selling
commercial sex, backpage.com, on April 6, 2018. Second, just 5 days
later, on April 11, 2018, the “Allow States and Victims to Fight Online Sex
Trafficking Act of 2017 (FOSTA),” was enacted.
2
Section 3 of FOSTA
established criminal penalties for those who promote or facilitate
prostitution and sex trafficking through their ownership, management, or
operation of online platforms.
3
Federal investigating agencies, such as the Federal Bureau of
Investigation (FBI), bring evidence related to online platforms to
Department of Justice (DOJ) components responsible for criminal
prosecutions (e.g. U.S. Attorneys’ Offices). These components bring
federal criminal charges against those acting in foreign or interstate
commerce who own, manage, or operate online platforms (hereafter
1
Sex trafficking is the recruitment, harboring, transportation, provision, obtaining,
patronizing, or soliciting of a person for the purpose of a commercial sex act. 22 U.S.C. §
7102(12). The term “commercial sex act” means any sex act on account of which anything
of value is given to or received by any person. See id. § 7102(4). Sex trafficking is one of
two “severe forms of trafficking in persons” when it involves force, fraud, or coercion, or
where the victim has not attained 18 years of age, in which case force, fraud or coercion
are not necessary elements. See id. § 7102(11)(A). The primary definition of the crime of
sex trafficking is similarly defined under section 1591 of Title 18, U.S. Code.
2
Pub. L. No. 115-164, 132 Stat. 1253.
3
Pub. L. No. 115-164, § 3(a), 132 Stat. at 1253-54.
Letter
Page 2 GAO-21-385 Sex Trafficking
“those who control” online platforms) that promote or facilitate prostitution
or sex trafficking. DOJ may also pursue civil law enforcement actions,
such as civil forfeiture.
4
Additionally, victims and their legal
representatives may file private civil suits against persons or
organizations that promote or facilitate prostitution or sex trafficking.
Section 8 of FOSTA includes a provision for us to report to Congress
detailed information on civil suits filed and orders of criminal restitution
related to aggravated violations established under section 3 of FOSTA.
5
Such aggravated violations involve those who control online platforms
promoting or facilitating the prostitution of five or more people, or acting in
reckless disregard of the fact that their conduct contributed to sex
trafficking.
6
This report examines: (1) DOJ enforcement efforts against
online platforms that promote prostitution and sex trafficking, from 2014
through 2020; and (2) the extent to which criminal restitution and civil
damages have been sought and awarded for aggravated violations under
section 3 of FOSTA.
To examine DOJ enforcement efforts against online platforms that
promote prostitution and sex trafficking, we reviewed selected literature,
reviewed specific federal criminal cases, reviewed selected online
platforms, reviewed data on the use of the internet in sex trafficking
cases, and interviewed DOJ officials and representatives from third
parties, such as Polaris (a nonprofit organization knowledgeable about
human trafficking). For our review of specific federal criminal cases, we
reviewed cases that DOJ brought against those who control platforms in
the online commercial sex market from January 2014 through December
2020.
7
We include in our scope cases against those who control
platforms that primarily promote commercial interactions between parties
4
Civil judicial forfeiture is an action brought in court against the property, with or without a
corresponding criminal proceeding against the property owner.
5
Pub. L. No. 115-164, § 8, 132 Stat. at 1255-56.
6
See id. § 3(a), 132 Stat. at 1253-54 (codified at 18 U.S.C. § 2421A(b)).
7
We selected January 2014 because during 2014 federal authorities seized
myredbook.com in connection with a federal prosecution that resulted in the first federal
conviction of an online platform operator for facilitation of prostitution. We concluded our
review of criminal cases December 2020.
Page 3 GAO-21-385 Sex Trafficking
where in-person sexual services may be expected or implied.
8
We used a
variety of means to identify these cases, including, among other things,
utilizing responses compiled from an email sent to all U.S. Attorneys’
Offices by DOJ’s Executive Office for U.S. Attorneys (EOUSA). For the 11
cases we identified, we reviewed court documentation related to charges
brought and assets seized and/or subject to potential forfeiture, among
other things.
To examine the extent to which criminal restitution and civil damages
have been sought and awarded for aggravated violations under section 3
of FOSTA, we used industry standard legal research tools to identify: (1)
all criminal cases including charges under 18 U.S.C. § 2421A(b)(2); and
(2) all civil cases brought under subsection 2421A(c), based on a violation
of subsection 2421A(b).
9
To corroborate our results for criminal cases, we
compared our results with the results of a search performed by EOUSA of
its CaseView system (the case management system for the Offices of the
United States Attorneys). This comparison confirmed our initial results,
which we updated to be current as of March 2021. To corroborate our
results for civil cases, we contacted the Human Trafficking Institute (HTI)
and the Human Trafficking Legal Center—both of which are organizations
that work with federal civil sex trafficking case data—and they confirmed
8
In this report, we focus on the online promotion of in-person commercial sex acts,
whether through prostitution, which is illegal in all states but Nevada; or sex trafficking,
which is a federal crime and with respect to which all 50 states and the District of
Columbia have criminal statutes that can be used for anti-trafficking efforts. See GAO,
Human Trafficking: Information on Cases in Indian Country or that Involved Native
Americans, GAO-17-624 (Washington, D.C.: July 24, 2017), page 9. Nevertheless, we
recognize that the production and distribution of visual sexual content is subject to
regulation or prohibition under state or federal law, depending on the relevant facts and
circumstances, including whether such content involves sexual exploitation and abuse of
minors (18 U.S.C. ch. 110).
9
18 U.S.C. § 2421A(d) states that “the court shall order restitution for any violation of
subsection (b)(2).” Subsection 2421(A)(b) states that “Whoever, using a facility or means
of interstate or foreign commerce or in or affecting interstate or foreign commerce, owns,
manages, or operates an interactive computer service . . . or conspires or attempts to do
so, with the intent to promote or facilitate the prostitution of another person and—(1)
promotes or facilitates the prostitution of 5 or more persons; or (2) acts in reckless
disregard of the fact that such conduct contributed to sex trafficking, in violation of [18
U.S.C.] 1591(a), shall be fined under this title, imprisoned for not more than 25 years, or
both.” Subsection 2421A(c) states that “Any person injured by reason of a violation of
section 2421A(b) may recover damages and reasonable attorneys’ fees in an action
before any appropriate United States district court.”
Page 4 GAO-21-385 Sex Trafficking
our initial results, which we updated to be current as of March 2021. See
appendix I for additional information about our scope and methodology.
We conducted this performance audit from May 2020 to June 2021 in
accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives. We conducted our related
investigative work in accordance with standards prescribed by the Council
of the Inspectors General on Integrity and Efficiency.
While prostitution and sex trafficking both involve commercial sexual
activity, sex trafficking is defined under federal law as inherently
exploitative in that it generally entails individuals being made to engage in
commercial sex acts against their will.
10
• Prostitution. Refers to the reciprocal, and in 49 of 50 states, illegal
process by which individuals seek to offer or obtain commercial sex
acts, which are any sex acts in exchange for which anything of value
is given or received.
11
There is debate among scholars and advocates
as to whether prostitution is a form of sexual exploitation.
12
While
prostitution itself is not a specific federal crime, there are some federal
provisions addressing prostitution-related conduct, which apply in
limited circumstances. For instance, it is a federal crime to knowingly
transport (or persuade, induce, entice or coerce to travel) another
person in interstate or foreign commerce, or in any U.S. territory or
10
Sex trafficking involves adult victims being forced, defrauded, or coerced into performing
commercial sex acts; and child victims being caused to engage in commercial sex, with or
without force, fraud, or coercion. 18 U.S.C. § 1591(a).
11
In Nevada, prostitution is permitted at certain licensed entities within 10 counties, either
on a countywide basis, or in particular municipalities or unincorporated areas.
12
See, for instance: Gerassi, Lara, A Heated Debate: Theoretical Perspectives of Sexual
Exploitation and Sex Work, Journal of Sociology & Social Welfare, Volume 42, Issue 4,
Pages 79-100, Dec 2015. National Center on Sexual Exploitation, Nevada’s Legalized
Prostitution is Still Exploitation, February 10, 2019, accessed March 10, 2021,
https://endsexualexploitation.org/articles/nevadas-legalized-prostitution-is-still-
exploitation/.
Background
Online Promotion of
Prostitution and Sex
Trafficking Defined
Page 5 GAO-21-385 Sex Trafficking
possession, with the intent for such person to engage in prostitution or
other criminal sexual activity.
13
• Sex trafficking. Sex trafficking is a form of human trafficking and
refers to the exploitative process through which adults (subject to
force, fraud or coercion) or children (by any means) are caused to
engage in commercial sexual activity.
14
Specifically, the crime of sex
trafficking is:
• Adults: Knowingly recruiting, enticing, harboring, transporting,
providing, obtaining, advertising, maintaining, patronizing or
soliciting by any means, a person, knowing or recklessly
disregarding the fact that force, fraud, or coercion will be used to
cause an adult to engage in a commercial sex act.
15
• Minors: Knowingly taking any of the same exploitative actions
listed above (for adults), but knowing or recklessly disregarding
that a minor will be caused to engage in a commercial sex act
(whether or not by means of force, fraud, or coercion).
16
13
18 U.S.C. §§ 2421, 2422(a).
14
Human trafficking refers to the exploitation of adults by force, fraud, or coercion, or of a
person under the age of 18 by any means, for such purposes as forced labor, involuntary
servitude or commercial sex. Pursuant to the Trafficking Victims Protection Act of 2000, as
amended, sex trafficking is the recruitment, harboring, transportation, provision, obtaining,
patronizing, or soliciting of a person for the purpose of a commercial sex act. 22 U.S.C. §
7102(12). Under section 7102(4), the term “commercial sex act” means any sex act on
account of which anything of value is given to or received by any person. Sex trafficking is
one of two “severe forms of trafficking in persons,” when it involves force, fraud, or
coercion, or where the victim has not attained 18 years of age, in which case force, fraud
or coercion are not necessary elements. 22 U.S.C. § 7102(11)(A).
15
When the act is advertising, then reckless disregard of force, threats of force, fraud,
coercion, or any combination thereof, is insufficient, and knowledge of such force, fraud or
coercion must be proven. 18 U.S.C. § 1591(a)(2).
16
18 U.S.C. §1591(a). Under paragraph (e)(3), the term “commercial sex act” means any
sex act on account of which anything of value is given to or received by any person.
Except in charges involving advertising (which always require proof of knowledge), it is not
necessary to show that a defendant knew or recklessly disregarded that a victim is a
minor if such defendant has had a reasonable opportunity to observe the victim. 18 U.S.C.
§ 1591(c). Knowingly benefitting from participation in a venture that engages in sex
trafficking, or attempting or conspiring to engage in sex trafficking, are also criminalized.
18 U.S.C. §§ 1591(a)(2).
Page 6 GAO-21-385 Sex Trafficking
Despite the term “trafficking,” the crime of sex trafficking need not
involve the defendant or victim crossing state or international lines.
17
The internet can be used to promote prostitution and sex trafficking.
18
Individuals often place online advertisements as a means to locate buyers
of commercial sex. Such advertisements may mask the sale of
commercial sex behind offerings of “time and company” or a massage
service, for example. According to DOJ officials, the advertisements
rarely, if ever, indicate that sex trafficking is taking place. That is, they do
not suggest that commercial sex acts will be performed by an adult
subject to force, fraud, or coercion, or a minor (although advertisements
may use insider language to indicate that the person is young, such as
“fresh” or “new in town”). Additionally, findings from an exploratory study
using a temporally and geographically limited sample lends support to the
idea that ads may make use of emojis to communicate the person is a
minor.
19
Those who control online platforms can promote prostitution and sex
trafficking by how they structure and oversee their platforms, how they
allow users to engage with commercial sexual content on their platforms,
and how they profit from such activities. This is in contrast to those who
use online platforms to promote prostitution and engage in sex trafficking
by posting or otherwise engaging with online content (e.g. commercial
sex-related advertisements and reviews).
17
The defendant must have knowingly acted in, or affected interstate or foreign
commerce, or acted within the special maritime or territorial jurisdiction of the United
States. 18 U.S.C. § 1591(a)(1).
18
For purposes of brevity, we use the term “promote” to refer to both “promote” and
“facilitate” throughout this report. In instances where we are specifically discussing or
referencing statutes that use both “promote” and “facilitate,” we defer to the statutory
language.
19
Whitney, Jennex, Elkins, Frost, Don’t Want to Get Caught? Don’t Say It: The Use of
EMOJIS in Online Human Sex Trafficking Ads, Proceedings of the 51st Hawaii
International Conference on System Sciences, 2018. The sample included ads posted on
Backpage between February 2017 and March 2017 for the major cities/counties of San
Diego, Los Angeles, and Orange County. The researchers analyzed ads to see if ads
using the terms “fresh,” “young,” “new,” “tiny,” “little,” “new in town,” “girl,” and “college,”
shown through prior research to be indicative of an underage victim, were more likely to
appear in ads that also used certain emojis thought to signify a minor or the movement of
a minor.
Page 7 GAO-21-385 Sex Trafficking
Federal law makes it a crime to control and use such platforms for
purposes of prostitution or sex trafficking, as described below.
• Controlling an online platform that promotes prostitution and
contributes to sex trafficking. Section 3 of FOSTA amended title 18
of the U.S. Code to add section 2421A, which states that it is a federal
crime for those who control online platforms to do so with the intent to
promote or facilitate the prostitution of others. Further, subsection (b)
of section 2421A establishes enhanced penalties for “aggravated”
violations when those who control online platforms (1) promote or
facilitate the prostitution of five or more persons, or (2) act with
reckless disregard that their conduct contributed to sex trafficking.
20
Those who control such platforms may also be held accountable
under other federal statutes, as discussed later.
• Using an online platform to promote prostitution or to engage in
sex trafficking. Using an online platform to promote prostitution, or
engage in sex trafficking, are both federal crimes.
21
20
18 U.S.C. § 2421A(a), (b).
21
Specifically, it is a federal crime to use any facility in interstate or foreign commerce,
such as an online platform, to promote, manage, establish, or carry on; or facilitate the
promotion, management, establishment, or carrying on of any unlawful activity, such as a
prostitution-related violation of state law. 18 U.S.C. § 1952. Regarding the crime of sex
trafficking, see 18 U.S.C. § 1591.
Page 8 GAO-21-385 Sex Trafficking
The internet has enabled an online market for commercial sex. This
market may be used to promote or profit from prostitution, child sex abuse
material, and sex trafficking. The services arranged on these platforms
may be in-person or could occur online, though this report focuses on in-
person commercial sexual activity. According to DOJ officials,
anecdotally, nearly all federal cases brought against sex traffickers
involve an online dimension, whether that be recruitment of victims,
advertisements to solicit buyers, reviews of providers, or communications
among parties involved.
Recent data on federal sex trafficking cases, collected by the Human
Trafficking Institute (HTI), illustrate the significant role of the internet in the
market for commercial sex.
22
Specifically, defendants used the internet as
their primary means of soliciting buyers of commercial sex in 84 percent
(390 of 466) of active federal sex trafficking cases in 2019 for which the
primary method of solicitation was available in public sources.
Additionally, defendants used the internet to recruit 37 percent (231 of
631) of victims in active federal sex trafficking cases in 2019 for which the
method of recruitment was available in public sources.
23
22
HTI is a nonprofit organization that, according to its website, exists to decimate modern
slavery at its source by empowering police and prosecutors to stop traffickers. Working
inside criminal justice systems, the Institute provides the embedded experts, world-class
training, investigative resources, and evidence-based research necessary to free victims.
23
HTI data are taken from federal criminal cases that involved: (1) one or more charges
under Chapter 77 of Title 18, U.S. Code, 18 U.S.C. §§ 1581-97 (Peonage, Slavery, and
Trafficking in Persons), or (2) one or more charges under statutes outside of Chapter 77
where there was substantial evidence of force, fraud, coercion, commercial sex with a
child, or an identified victim of trafficking. HTI data do not reflect the prevalence of sex
trafficking in the United States but instead represent key findings and trends in federal sex
trafficking prosecutions.
Nature of the Online
Commercial Sex Market
Online Commercial Sex Market
Terminology
Throughout this report, we use the following
terms to describe elements of the online
commercial sex market:
• The service exchanged in this market
refers to in-person sexual activity. Supply
is the amount of services available at a
given price.
• Providers refers to prostitutes or sex
workers who provide in-person sexual
services, or sex traffickers who compel
victims to provide such services against
their will.
• Victims refers to individuals who are
exploited by human traffickers for the
purpose of nonconsensual commercial
sexual activity.
• Sellers refers to those who solicit buyers
of in-person sexual services online.
Sellers can be prostitutes or sex workers
themselves; or sellers can be third
parties, such as pimps or sex traffickers.
• Buyers refers to consumers of in-person
sexual services promoted online.
Demand is the amount of services that
buyers are willing and able to purchase at
a given price.
Source: GAO. | GAO-21-385
P
age 9 GAO-21-385 Sex Trafficking
Most online advertisements for commercial sex are posted on the surface
web as opposed to the dark web, according to DOJ officials. According to
these officials, the success of platforms operating in the commercial
online sex market depends on their ability to connect buyers and sellers
in a specific geographic region, which is easier to do when the platform is
easy to find. Officials further noted that some buyers and providers may
not have access to the dark web or the expertise necessary to navigate it.
Platforms in the online commercial sex market have different models of
operation that generally fall within three broad categories, as shown in
table 1 below. Additional information and details are in appendix II.
Table 1: Models of Operation of Platforms in the Online Commercial Sex Market
Category of
platform
Description How platform monetizes
Advertising
Directory or classified service for escorts
a
or adult entertainers. The
majority of the content on these platforms are paid advertisements for
individuals or businesses providing commercial sex.
Sell individual ads, advertising
packages, or upgrades to feature ads
more prominently.
Act as affiliate marketers for other
platforms.
b
Hobby board
Allows commercial sex buyers (self-identified “hobbyists”) to review
individuals or businesses providing commercial sex and participate in
discussion forums on the subject.
Membership/subscription-based model.
Act as affiliate marketers for other
platforms.
b
Sugar dating
Connects individuals for romantic relationships under a commercial
arrangement in which sexual activity may be expected or implied.
Membership/subscription-based model
or pay-per-contact model.
Source: GAO analysis of information from Polaris (a nonprofit organization) and childsafe.ai (a software company) reports and representatives. | GAO-21-385
Note: Categories of advertising, hobby board, and sugar dating are not mutually exclusive as there
may be overlap in how these platforms function and monetize. For instance, a hobby board platform
may allow membership or advertising options to those who wish to advertise commercial sex.
a
According to the American Heritage dictionary, an “escort” is a person, often a prostitute, who is
hired to spend time with another as a companion.
Accessibility of Online Content
Online content is accessible to internet users
to varying degrees, as follows:
• Content on the surface web has been
indexed by traditional search engines
(e.g. Google, Bing) and is readily
available to the general public. Examples
include websites for news, e-commerce,
marketing, and social networking.
• Content on the deep web has not been
indexed by traditional search engines and
is not generally accessible. Examples
include content on databases, private
intranets (e.g. internal networks of
corporations or universities), and sites
protected by passwords or other
restrictions.
• Content on the dark web has been
intentionally concealed and requires
specific software to access. This access
is predominately designed to hide the
identity and location of the user. Many
users access the dark web to conceal
criminal or otherwise malicious activities.
Source: GAO analysis based on a Congressional Research
Service report, a Federal Bureau of Investigation website,
and input from Department of Justice
officials. | GAO-21-385
P
age 10 GAO-21-385 Sex Trafficking
b
Both legitimate and illegitimate companies use “affiliate marketing” whereby they offer performance-
based commission incentives to third-party promoters, or “affiliates,” who are often employed to direct
new web traffic and customers to companies’ platforms, according to a 2020 Polaris report (Polaris is
a nonprofit organization).
The online commercial sex market is subject to pressure from law
enforcement, enforcement actions, and market conditions. In 2010,
craigslist.org was the leading platform in the online commercial sex
market. However, under pressure from 17 state attorneys general who
were concerned about the use of craigslist.org for purposes of prostitution
and sex trafficking, craigslist.org voluntarily removed its “adult” section in
September 2010. Afterward, buyers and sellers shifted toward using
backpage.com, which then emerged as the market leader. Figure 1 below
shows significant events in this market from 2010 through 2020.
Figure 1: Significant Events in the Online Commercial Sex Market from 2010 through 2020
U
nder section 3 of FOSTA, it is a crime for those who control online
platforms to do so with the intent to promote or facilitate the prostitution of
Timeline of Significant
Events in the Online
Commercial Sex Market
DOJ’s Approach to
Holding Those Who
Control Online Platforms
Accountable
P
age 11 GAO-21-385 Sex Trafficking
others.
24
DOJ investigates and prosecutes those who control online
platforms that promote prostitution when there is an indication that
platforms also promote sex trafficking, according to DOJ officials. For
instance, DOJ may target a platform that promotes prostitution if it is
implicated in multiple sex trafficking cases. Table 2 below shows federal
law enforcement roles in sex trafficking cases.
Table 2: Federal Law Enforcement Roles in Sex Trafficking Cases
Agency/component
Role in addressing sex trafficking
Department of Justice’s (DOJ) Federal Bureau of
Investigation
Conducts investigations. Where appropriate, brings evidence to U.S. Attorney’s
Offices, the Civil Rights Division (Human Trafficking Prosecution Unit), or the
Criminal Division (Child Exploitation and Obscenity Section or Money
Laundering and Asset Recovery Section) for prosecution.
Department of Homeland Security’s Homeland
Security Investigations (part of U.S. Immigration and
Customs Enforcement)
DOJ’s U.S. Attorneys’ Offices
Prosecutes criminal cases.
DOJ’s Civil Rights Division
• Human Trafficking Prosecution Unit
Prosecutes criminal cases and supports U.S. Attorneys’ Offices’ efforts to
address sex trafficking of adults by force, fraud, or coercion by developing and
supporting investigations and prosecutions and providing training and guidance
to the field.
DOJ’s Criminal Division:
• Child Exploitation and Obscenity Section
• Money Laundering and Asset Recovery Section
Prosecutes criminal cases and supports U.S. Attorneys’ Offices’ efforts to
address child sex trafficking by developing and supporting investigations and
prosecutions and providing training and guidance to the field.
Prosecutes criminal cases and supports U.S. Attorneys’ Offices’ efforts to
address sex trafficking by developing and supporting investigations and
prosecutions and providing training and guidance to the field.
Source: GAO presentation of information from DOJ officials. | GAO-21-385
24
Additionally, it is a federal crime to use any facility in interstate or foreign commerce,
such as an online platform, to promote, manage, establish, or carry on; or facilitate the
promotion, management, establishment, or carrying on of any unlawful activity, such as a
prostitution-related violation of state law. See 18 U.S.C. § 1952.
Page 12 GAO-21-385 Sex Trafficking
In June 2014, federal prosecutors initiated a case against the owner of
myredbook.com. According to DOJ, this case resulted in the first federal
conviction of an online platform operator for facilitation of prostitution.
From 2014 through 2020, federal prosecutors have brought at least 10
other cases against those who control platforms in the online commercial
sex market.
25
Figure 2 provides a summary of federal cases brought, and
appendix III includes additional information.
25
We use the term “at least” because, although we used a variety of means to identify
these cases and thus have a reasonable assurance we identified most or all relevant
cases, it is possible our search was not exhaustive. See appendix I for more details.
DOJ Enforcement
Efforts and FOSTA
Disrupted the Online
Commercial Sex
Market, but
Enforcement
Challenges Exist
DOJ Has Brought at Least
11 Criminal Cases against
Those Who Control Online
Platforms from 2014
through 2020
Page 13 GAO-21-385 Sex Trafficking
Figure 2: Federal Criminal Cases Brought against Those Who Control Platforms in the Online Commercial Sex Market from
2014 through 2020
Note: Most of the cases in this figure were pending as of the end 2020. As a result, amounts
associated with assets seized and/or subject to potential forfeiture may change. In some instances,
we used a range because it was not clear whether funds listed in separate cases were duplicative or
not. Dollar amounts have not been adjusted for inflation. Dollar equivalency amounts for
cryptocurrency are based on July 2018 exchange rates.
a
Excludes assets in closed cases. Assets in those cases are represented under “Assets ordered to be
forfeited.”
b
Five-hundred of the 501 domain names were ordered to be forfeited through civil judicial
proceedings, which may occur in parallel to criminal proceedings.
As shown by figure 2, cases brought against those who controlled
backpage.com have significantly more organizational defendants (e.g.
Page 14 GAO-21-385 Sex Trafficking
corporations) and associated assets than cases brought against those
who controlled all other platforms combined. This highlights the market
dominance backpage.com held until it was seized in April 2018. The
figure also shows that federal prosecutors have largely used racketeering
and money laundering statutes to hold those who control these platforms
accountable.
26
The seizure of backpage.com and enactment of FOSTA occurred just 5
days apart in April 2018, and disrupted the landscape of the online
commercial sex market. Because these events occurred so close
together, it is not possible to trace changes to the market to one event or
the other. Nevertheless, taken together, these events have led to the
relocation of platforms overseas, fragmentation of the market, and
increased use of hobby board and sugar dating platforms.
In the wake of the events of April 2018, the controllers of many online
platforms relocated their platforms overseas in an attempt to shield
themselves from U.S. prosecution. More specifically, the controllers of
many platforms in the online commercial sex market shut down or
suspended operations in the United States while others moved their
operations overseas, primarily to Europe, according to a July 2020 Polaris
report and supported by a April 2019 childsafe.ai report.
27
DOJ officials
further clarified that many of those who control these platforms moved
their web servers, web hosting services, and the registration of their
26
Throughout this report, we use the term “racketeering” to refer to 18 U.S.C. § 1952 -
Interstate and foreign travel or transportation in aid of racketeering enterprises. This is not
to be confused with a separate set of statutes under chapter 96 of Title 18, U.S. Code (§§
1961-1968), Racketeer Influenced and Corrupt Organizations.
27
Polaris and childsafe.ai are entities with expertise in this area. Polaris’s July 2020 report
is titled: Using an Anti-Money Laundering Framework to Address Sex Trafficking
Facilitated by Commercial Sex Advertisement Websites. This report is comprised of two
separate documents: (1) the full report; and (2) an executive summary which is not
included in the full report. According to Polaris representatives, Polaris is a nonprofit
organization and is leading a data-driven social justice movement to prevent and reduce
sex and labor trafficking in the United States and Mexico. Since 2007, Polaris has
operated the National Human Trafficking Hotline, a project that is partially funded by the
U.S. Department of Health and Human Services. Childsafe.ai’s April 2019 report is titled:
Beyond Backpage: Buying and Selling Sex in the United States One Year Later.
Childsafe.ai is a software company that deploys machine learning and active collection
networks to observe actors that buy and sell human beings online.
The Seizure of
Backpage.com and
Enactment of FOSTA
Disrupted the Landscape
of the Online Commercial
Sex Market
Relocation of Platforms
Overseas
Page 15 GAO-21-385 Sex Trafficking
domain names to countries where prostitution is legal.
28
It is not clear,
officials said, whether those who control these platforms also moved
employees who run day-today operations overseas or moved their own
physical residences overseas.
With backpage.com no longer in the market, buyers and sellers moved to
other online platforms, and the market became fragmented. The July
2020 Polaris and April 2019 childsafe.ai reports state that since
backpage.com was removed from the market, there has been fierce
competition among platforms for market share, and no single platform has
emerged as dominant at the national level. DOJ officials confirmed this
assessment.
In addition to using platforms in the online commercial sex market to
solicit buyers, sellers also use social media and other platforms to do so.
Definitions of these platforms are shown below.
28
A “web server” is a computer that provides World Wide Web (WWW) services on the
Internet. It includes the hardware, operating system, web server software, and web site
content (web pages). “Web hosting” is the activity or business of providing storage space
and access for websites.
Fragmentation of the Market
Page 16 GAO-21-385 Sex Trafficking
Sellers Can Use a Variety of Types of Platforms to Solicit Buyers
For purposes of this report, “soliciting buyers” refers to (1) advertising or posting sexual
services online, or (2) any online communication from the seller to the potential buyer. Thus,
platforms used to solicit buyers may include platforms in the online commercial sex market
(i.e. advertising, hobby board, and sugar dating platforms) or other types of platforms, such
as social media platforms.
According to Federal Bureau of Investigation officials, after buyers and sellers initially
connect—either through platforms in the online commercial sex market or through other
types of platforms (e.g. mainstream dating platforms)—they often move their communication
to text, phone, social media, or messaging/communication platforms to coordinate and
complete the interaction.
Subcategories of platforms—such as social media, dating, hookup, and
messaging/communication platforms-—are not mutually exclusive. Some platforms perform
functions related to more than one subcategory. Thus, the following definitions and insights
may be helpful.
• Social media: Platforms that allow users to share messages, photos, and other
information in communities or forums based on shared interests or backgrounds.
• Dating: Platforms that connect users for dates or romantic relationships. Dating
platforms are to be distinguished from “sugar dating” platforms. Whereas both types of
platforms are designed to help users connect, sugar dating platforms seek to connect
them under a commercial arrangement in which sexual activity may be expected or
implied.
• Hookup: Platforms that explicitly connect users for casual sexual encounters (as
opposed to a serious relationship).
• Messaging/communication: Platforms that enable users to send and receive
messages (e.g. text, instant messaging, email, video).
Source: GAO analysis of dictionary definitions, platforms’ descriptions of themselves, and input from Federal Bureau of Investigation
officials and Human Trafficking Institute representatives. | GAO-21-385
The shift of buyers and sellers away from backpage.com and toward
other platforms is reflected in the number of federal sex trafficking cases
brought against defendants who used platforms other than backpage.com
to solicit buyers after the events of April 2018. Specifically, our analysis of
Human Trafficking Institute (HTI) data shows that after April 2018,
prosecutors began bringing fewer cases against those that solicited
buyers using backpage.com and more cases against those that solicited
buyers using other platforms, as shown in figure 3.
Page 17 GAO-21-385 Sex Trafficking
Figure 3: Use of Online Platforms to Solicit Buyers in New Federal Criminal Sex
Trafficking Cases from 2014 through 2019
Note: Data in this figure are from federal criminal cases that involved: (1) one or more charges under
Chapter 77 of Title 18, U.S. Code, 18 U.S.C. §§ 1581-97 (Peonage, Slavery, and Trafficking in
Persons); or (2) one or more charges under statutes outside of Chapter 77 where there was
substantial evidence of force, fraud, coercion, commercial sex with a child, or an identified victim of
trafficking. Multiple online platforms may be used to solicit buyers in a single criminal case; thus,
some cases may be double-counted. The downward trend in overall cases beginning in 2015 can
largely be explained by a broader trend wherein the Department of Justice has brought fewer federal
sex trafficking cases in recent years, according to Human Trafficking Institute representatives.
After the events of April 2018, there has been an increase in the use of
hobby board platforms, according to the April 2019 childsafe.ai report and
confirmed by FBI officials.
29
One reason for an increased use of hobby
29
Figure 3 shows that defendants in federal sex trafficking cases have increasingly used
commercial sex market platforms (other than backpage.com) to solicit buyers in recent
years. This category—commercial sex market platforms—includes hobby boards and
sugar dating platforms.
Increased Use of Hobby Board
and Sugar Dating Platforms
Page 18 GAO-21-385 Sex Trafficking
board platforms may be the reliability of their content relative to
advertising platforms. Specifically, since backpage.com was seized, there
has been an increase in spam and scam efforts on advertising platforms,
according to the April 2019 childsafe.ai report and confirmed by Polaris
representatives. The reason for this, according to the Chief Executive
Officer (CEO) for childsafe.ai, is that those who control platforms in the
post-backpage.com market may not be able to attract or afford technical
staff capable of screening ads for commercial sex, as backpage.com
did.
30
In contrast, the CEO said hobby boards are designed around
preserving legitimacy and reputation, and even have built-in mechanisms
whereby users moderate content on the platforms.
Moreover, hobby boards already function as de facto advertising
platforms, so buyers encountering spam and scam on advertising
platforms might migrate to hobby board platforms. According to the CEO
of childsafe.ai and our own review of platforms, hobby boards provide
more information than what is available on advertising platforms. For
instance, in addition to reviews from other buyers, buyers may be able to
see a detailed list of services provided and a graphic description of the
provider’s appearance. Further, provider profiles contain contact
information and pricing information with detail that is often banned on
advertising sites, such as rates and location, according to the April 2019
childsafe.ai report. Thus, the childsafe.ai CEO said, although buyers may
still shop on advertising platforms, they are increasingly relying on hobby
board platforms both to shop and to ensure they will be receiving the
services they will be paying for.
30
The superseding indictment against seven of the controllers of backpage.com discuss
the role of backpage.com’s ad “moderators” numerous times.
Page 19 GAO-21-385 Sex Trafficking
The use of sugar dating platforms has also increased since the events of
April 2018, according to the April 2019 childsafe.ai report and confirmed
by FBI officials. The CEO of childsafe.ai stated that at least one leading
sugar dating platform is growing in use, in part, due to its dual marketing
strategy whereby it seeks to attract (1) customers that would otherwise
not be in the online commercial sex market, and (2) customers that are
already shopping in the online commercial sex market (e.g., former
patrons of backpage.com).
As part of its strategy, this platform provides different landing pages to
internet users, depending on how users navigate to the platform. The
childsafe.ai CEO explained that if an internet user searches for the
platform using a search engine, the user will find a landing page that
presents the general idea of generous men and attractive women
entering into mutually beneficial relationships. However, if the user is
browsing other platforms in the online commercial sex market—such as
advertising or hobby board platforms—and then clicks on a “Sugar
Babies” button, the user will be taken to one of several possible landing
pages that market the platform as an “alternative to escorts” and include
images clearly insinuating that sex is part of the sugar dating commercial
arrangement. Polaris provided documentation corroborating this finding.
31
To illustrate where buyers and sellers may have migrated after the events
of April 2018, we reviewed 27 platforms in the online commercial sex
market and categorized them as advertising, hobby board, or sugar
dating platforms, as shown in table 3.
32
31
We also replicated this finding ourselves after initially being unable to do so. Initially, we
used the Mozilla Firefox browser. When we clicked “Sugar Babies” buttons from the
Firefox browser, we were taken to a landing page that included images of sugar babies
that did not insinuate that sex is part of the sugar dating commercial arrangement.
However, on a subsequent attempt, we used a Google Chrome browser and its “incognito
window” function. When we did this, we were able to replicate childsafe.ai’s and Polaris’s
findings.
32
A brief description of advertising, hobby board, and sugar dating platforms in the online
commercial sex market is in the background section of this report, and appendix II
provides additional details.
Promotion of In-Person Sexual Services
Online
Platforms in the online commercial sex market
operate on the premise of payment in
exchange for:
• Direct in-person sexual services. This
refers to platforms that directly promote
in-person sexual services. Such services
are not masked as legal services and do
not create the expectation of a continuing
relationship.
• Services that are seemingly legal. This
refers to platforms where the façade of
services that are seemingly legal—such
as massage or health/beauty services—
mask the promotion of in-person sexual
services that are expected or implied.
• A continuing relationship. This refers to
platforms that promote the services of a
continuing relationship—such as a dating
or escort relationship—where in-person
sexual services may be expected or
implied.
Source: GAO analysis of selected online platforms. |
GAO-21-385
Page 20 GAO-21-385 Sex Trafficking
Table 3: Categorization of 27 Platforms in the Online Commercial Sex Market, as of
November 2020
Advertising
Hobby board
Sugar dating
Direct in-person sexual services
13
5
-
Services that are seemingly legal where
in-person sexual services may be implied
or expected
6
-
-
A continuing relationship where in-person
sexual services may be implied or
expected
-
-
3
Source: GAO analysis. | GAO-21-385
Note: Platform models of operation—advertising, hobby board, and sugar dating—are not necessarily
mutually exclusive. Similarly, platforms may promote sexual services using more than one approach
(e.g. direct in-person sexual services and a continuing relationship where in-person sexual services
may be expected or implied). We reviewed platforms and selected the primary model of operation
and primary approach used to promote sexual services. We selected platforms for this figure that
promoted commercial interactions between parties the platforms sought to connect. Platforms
included in this figure are not exhaustive of platforms in the online commercial sex market.
The current landscape of the online commercial sex market heightens
already-existing challenges law enforcement face in gathering tips and
evidence. Specifically, gathering tips and evidence to investigate and
prosecute those who control or use online platforms has become more
difficult due to the relocation of platforms overseas; platforms’ use of
complex payment systems; and the increased use of social media, dating,
hookup, and messaging/communication platforms.
The relocation of platforms overseas makes it more difficult for law
enforcement to gather tips and evidence. According to DOJ officials,
successfully prosecuting those who control online platforms—whether
their platforms are located domestically or abroad—requires gathering
enough evidence to prove that they intended that their platforms be used
to promote prostitution, and, in some cases, that they also acted in
reckless disregard of the fact that their actions contributed to sex
trafficking.
The evidence needed to prove such allegations may include
documentation of communications, incorporation records, or financial
transactions that demonstrate that those who control these platforms had
the intent to promote the prostitution of others or to conceal the nature of
the material being posted on their platforms (if such material promoted
the prostitution of others), according to DOJ officials. According to these
officials, intensive evidentiary review and analysis is essential because
the needed evidence may be contained in voluminous electronic
Current Landscape of the
Online Commercial Sex
Market Heightens
Challenges for Law
Enforcement
Challenges from Platforms
Relocating Overseas
Page 21 GAO-21-385 Sex Trafficking
communications and financial records. Further, officials said, these
investigations are often national or international in scope, necessitating
interviews in various locations, and requiring extensive computer and
financial forensic expertise.
These existing challenges are heightened when those who control such
platforms host servers abroad, reside abroad, use offshore bank accounts
and financial institutions, or introduce third parties to attempt to obscure
or distance themselves from the day-to-day operation of their platforms,
according to DOJ officials. For instance, these officials said, following
laundered money through shell companies based in corporate secrecy
jurisdictions is significantly more difficult than following laundered money
through U.S.-based financial institutions that are subject to U.S. laws.
33
Such circumstances often require using mutual legal assistance requests
to coordinate and obtain evidence from foreign jurisdictions. Officials said
this can cause extensive delays in investigations and some countries’
extradition policies may further complicate prosecutions.
Separately, gathering evidence to bring cases against users of online
platforms has also become more difficult. According to a 2019 FBI
document, the FBI’s ability to identify and locate sex trafficking victims
and perpetrators was significantly decreased following the takedown of
backpage.com. According to FBI officials, this is largely because law
enforcement was familiar with backpage.com, and backpage.com was
generally responsive to legal requests for information. In contrast, officials
said, law enforcement may be less familiar with platforms located
overseas. Further, obtaining evidence from entities overseas may be
more cumbersome and time-intensive, as those who control such
platforms may not voluntarily respond to legal process, and mutual legal
assistance requests may take months, if not years, according to DOJ
officials. Despite these investigative challenges, DOJ officials said they
are committed to holding accountable those who control online platforms
that promote sex trafficking.
Those who control online platforms may use complex and opaque
payment systems, which can make it difficult to gather tips and evidence.
33
For more information about money laundering generally and the legal and regulatory
framework for preventing, detecting, and deterring money laundering, see GAO, Anti-
Money Laundering: U.S. Efforts to Combat Narcotics-Related Money Laundering in the
Western Hemisphere, GAO-17-684 (Washington, D.C.: August 22, 2017).
Challenges from Platforms’
Use of Complex Payment
Systems
Page 22 GAO-21-385 Sex Trafficking
In the United States, the Bank Secrecy Act, and implementing
regulations, require financial institutions to monitor and report suspicious
activity potentially indicating money laundering or other criminal activity
such as sex trafficking.
34
However, it has become increasingly difficult for
financial institutions to identify transactions and accounts associated with
platforms in the online commercial sex market, according to the July 2020
Polaris report. According to the report, platforms in the online commercial
sex market accept a variety of traditional and alternative payment
methods, and utilize evasive techniques—such as the use of third
parties—to facilitate illicit transactions (see sidebar).
One reason platforms might accept payment methods beyond credit and
debit cards may be the difficulty they have in maintaining reliable credit
and debit card payment systems, according to the July 2020 Polaris and
April 2019 childsafe.ai reports. The April 2019 childsafe.ai report states
that much of backpage.com’s operation focused on the “financial
gymnastics” required to take credit cards for advertising. Specifically, the
report states that constantly applying for new merchant accounts,
changing billing descriptors, and load balancing payments across
accounts to keep fraud/chargeback rates under acceptable limits requires
significant expertise and time.
35
Figure 4 shows the results of our analysis
of payment methods accepted by the 27 platforms we selected for our
review.
34
The Bank Secrecy Act imposes a range of recordkeeping and reporting obligations
across a wide sector of financial institutions, compliance with which is essential to
detecting, investigating, and deterring criminal activity, according to DOJ officials. There
are civil and criminal penalties for willful Bank Secrecy Act violations, including failure to
report criminal activity such as sex trafficking. In 2014, The U.S. Department of the
Treasury’s Financial Crimes Enforcement Network (FinCEN) published an Advisory:
Guidance on Recognizing Activity that May be Associated with Human Smuggling and
Human Trafficking – Financial Red Flags, FIN-2014-A008, September 11, 2014. In 2020,
FinCEN published a Supplemental Advisory on Identifying and Reporting Human
Trafficking and Related Activity, FIN-2020-A008, October 15, 2020.
35
According to the childsafe.ai CEO, a chargeback rate for a merchant account is the
number of charge disputes made against the total volume of transactions, expressed as a
percentage. If a merchant account keeps a chargeback rate too high for too long it will
often be closed by the issuing bank. Thus, to prevent an interruption of payments, a
successful operator will have multiple merchant accounts for processing and adjust their
transaction flow between them in order to avoid one account accumulating too much
fraud.
Payment Methods Accepted by Platforms
in the Online Commercial Sex Market
Platforms in the online commercial sex market
generally accept a combination of the
following payment methods:
• Credit/debit Cards: Payments through
credit or debit cards, including pre-paid
debit products.
• Virtual currency: Transfer of virtual
currency, including platforms that use
third-party wallet providers and
exchanges.
• Store-brand gift cards: Transfer of
store-brand gift cards directly to the
platform site or to a separate account
holder, or through a third-party gift card
transfer/redemption site.
• Check/wires/money orders: Sending
checks or money orders to a specified
address or wire transfers into a bank
account held by the commercial sex
advertising website or a separate account
holder.
Source: Polaris, Executive Summary: Using an Anti-Money
Laundering Framework to Address Sex Trafficking Facilitated
by Commercial Sex Advertisement Websites,
July 2020. | GAO-21-385
Page 23 GAO-21-385 Sex Trafficking
Figure 4: Payment Methods Accepted by 27 Platforms in the Online Commercial
Sex Market, as of November 2020
Note: Online platforms often accept more than one payment method, so the number of payment
methods listed above do not total to 27 (the number of platforms reviewed). Selected platforms may
not be representative of all platforms.
The increased use of social media, dating, hookup, and
messaging/communication platforms in the online commercial sex market
similarly makes it difficult for law enforcement to gather tips and evidence.
FBI documents, dated 2018 through 2020, indicate there has been an
increased use of social media, dating, hookup, and
messaging/communication platforms in sex trafficking, and this trend will
likely continue. HTI data support this information and show a general
increase in the number of these platforms used to solicit buyers in new
federal sex trafficking cases from 2014 through 2019, as shown in figure
5.
Challenges from the Increased
Use of Social Media, Dating,
Hookup, and
Messaging/Communication
Platforms
Page 24 GAO-21-385 Sex Trafficking
Figure 5: Use of Social Media, Dating, Hookup, and Messaging/Communication Platforms to Solicit Buyers in New Federal
Criminal Sex Trafficking Cases (from 2014 through 2019)
Note: Data in this figure are from federal criminal cases that involved: (1) one or more charges under
Chapter 77 of Title 18, U.S. Code, 18 U.S.C. §§ 1581-97 (Peonage, Slavery, and Trafficking in
Persons); or (2) one or more charges under statutes outside of Chapter 77 where there was
substantial evidence of force, fraud, coercion, commercial sex with a child, or an identified victim of
trafficking.
a
Includes Facebook Messenger
FBI information also indicates that the increased use of these platforms
hinder the ability of law enforcement to gather tips and evidence related
to sex trafficking. Specifically, FBI documents and our interviews with FBI
officials indicate that gathering information from social media, dating,
hookup, and messaging/communication platforms is difficult because:
Page 25 GAO-21-385 Sex Trafficking
• platforms employ varying levels of encryption of messages shared
between users;
36
• platforms allow users pseudo-anonymity through the use of false
identities;
• some platforms automatically delete content shortly after intended
recipients view the content; and
• the increasing number of these types of platforms and their legitimate
intent make separating, monitoring, and quantifying information
specific to sex trafficking difficult.
As of March 2021, DOJ had brought one case under the criminal
provision established by section 3 of FOSTA for aggravated violations
involving the promotion of the prostitution of five or more persons, or
acting in reckless disregard that conduct contributes to sex trafficking.
37
Specifically, in June 2020, federal prosecutors brought a case against the
36
In October 2020, DOJ issued an International Statement: End-to-End Encryption for
Public Safety that supports strong encryption for purposes of protecting personal data,
privacy, and intellectual property, among other things. The press release states that
“Particular implementations of encryption technology, however, pose significant
challenges to public safety, including to highly vulnerable members of our societies like
sexually exploited children. We urge industry to address our serious concerns where
encryption is applied in a way that wholly precludes any legal access to content.”
37
18 U.S.C. § 2421A(b).
Criminal Restitution
Has Not Been Sought
and Civil Damages
Have Not Been
Awarded under
Section 3 of FOSTA
DOJ Has Brought One
Criminal Case for
Aggravated Violations
under Section 3 of FOSTA
and Has Not Sought
Restitution
Page 26 GAO-21-385 Sex Trafficking
owner of cityxguide.com.
38
Prosecutors allege that, among other things,
the owner operated his platform with the intent to promote and facilitate
prostitution, and (1) promoted and facilitated the prostitution of five or
more persons, and (2) did so in reckless disregard that his conduct
contributed to sex trafficking. This case—USA v. Martono—is an ongoing
case and restitution had neither been sought nor awarded as of March
2021.
39
According to DOJ officials, one reason federal prosecutors have not
brought more cases with charges under 18 U.S.C. § 2421A in general, or
subsection 2421A(A)(b) in particular, is that the law is relatively new.
Specifically, FOSTA was enacted on April 11, 2018, and, because of the
Constitution’s Ex Post Facto Clause, only conduct engaged on or after
that date is punishable by this law.
40
DOJ officials note that another
reason why federal prosecutors have not brought more cases under the
FOSTA provision is because prosecutors have had success using
racketeering and money laundering charges against those who control
38
USA v. Martono, No. 3:20-CR-00274, Doc. 1, Sealed Indictment (N.D. Tex. June 2,
2020). The first case where DOJ charged a violation under section 3 of FOSTA was in
June 2019 in the USA v. Palms, No. 4:19-CR-00103 (N.D. Ok. June 6, 2019). However,
we excluded this case from our review because DOJ did not charge an “aggravated”
violation under 18 U.S.C. § 2421A(b) (which we focus on in this report); and the
defendant’s motion for judgment of acquittal as to two of the counts, including the alleged
§ 2421A(a) violation, was granted by the judge, and these counts were therefore not
submitted to the jury for a verdict.
39
On January 5, 2021, the Texas federal district court denied the defendant’s motion to
dismiss the case. USA v. Martono, No. 3:20-CR-00274, Doc. 28, Memorandum Opinion
and Order Denying Motion to Dismiss (N.D. Tex. Jan. 5, 2021). Specifically, the order
states that “Because FOSTA is not unconstitutionally vague or overbroad and the
indictment against Martono is sufficient, the Court denies Martono’s motion to dismiss.”
Section 3 of FOSTA makes federal criminal restitution mandatory for certain aggravated
violations whereby defendants acted with reckless disregard that their conduct contributed
to sex trafficking. See 18 U.S.C. § 2421A(d). Criminal restitution applies only to criminal
proceedings and refers to that which a convicted offender may be ordered to compensate
victims for actual—in other words, tangible or “out-of-pocket”—losses incurred due to the
offender’s crime. See, e.g., United States v. Frazier, 651 F.3d 899, 904-08 (8th Cir. 2011)
(limiting restitution to the full amount of victim’s actual, provable loss); Goodwin, Federal
Criminal Restitution, 256-257. Restitution may be ordered for lost income, property
damage, counseling, medical expenses, funeral costs or other financial costs directly
related to the crime. Federal courts are not authorized to order restitution for losses such
as pain and suffering and emotional distress to crime victims.
40
The U.S. Constitution states that “[n]o . . . ex post facto [l]aw shall be passed.” U.S.
CONST. art. I, § 9, cl. 3. An ex post facto law is a law that makes criminal an act that was
innocent under laws at the time of its commission.
Page 27 GAO-21-385 Sex Trafficking
such online platforms in the past.
41
Appendix III provides a list of such
cases brought from 2014 through 2020, and a few of these cases are
highlighted below.
Use of Racketeering and Money Laundering Charges
Both before and after the enactment of the Allow States and Victims to Fight Online Sex
Trafficking Act of 2017 (FOSTA)—enacted in April 2018—federal prosecutors used
racketeering and money laundering charges against those who control online platforms
that promote prostitution.
• USA v. Omuro et al (2014). Prosecutors charged the proprietor of the website
myredbook.com with violating various provisions of racketeering and money laundering
statutes (18 U.S.C. §§ 1952, 1957). These statutes both require an underlying “specified
unlawful activity.” The indictment cites prostitution offenses in violation of the laws of California
as the underlying specified unlawful activity for racketeering, and cites racketeering in support
of prostitution offenses as the underlying specified unlawful activity for money laundering.
• USA v. Lacey et al (2018). Prosecutors charged seven individuals who owned, managed, or
operated backpage.com with violating various provisions of racketeering and money
laundering statutes (18 U.S.C. §§ 1952, 1956, 1957). The indictment cites prostitution offenses
in violation of the laws of Arizona as the specified unlawful activity for racketeering, and cites
racketeering in support of prostitution offenses as the underlying specified unlawful activity for
money laundering.
• USA v. Reynolds (2020). Prosecutors charged two individuals in connection with their
ownership and operation of vipescorts.com and its affiliate websites, with committing various
money laundering-related crimes (18 U.S.C. § 1956). In this case, prosecutors did not charge
the defendants with racketeering. However, the complaint cites a violation of racketeering
laws—whereby defendants caused proceeds from their prostitution business to be transferred
to another business—as the underlying specified unlawful activity for purposes of money
laundering.
Source: GAO analysis of selected criminal cases. | GAO-21-385
Although federal prosecutors’ have rarely used 18 U.S.C. § 2421A(b),
DOJ officials said there are two reasons to consider using this provision
of law in the future, either alone or in tandem with racketeering and
money laundering charges. First, according to DOJ officials, this provision
allows the government the ability to secure the imposition of an increased
punishment, when appropriate. A violation of 18 U.S.C. § 2421A(b)
carries a maximum penalty of 25 years in prison, whereas violations of
racketeering and money laundering statutes typically carry 5, 10, or 20-
year maximum prison penalties, depending on the specific statute
violated.
42
Second, DOJ officials told us that charging 18 U.S.C. §
41
As noted previously, we use the term “racketeering” to refer to 18 U.S.C. § 1952 -
Interstate and foreign travel or transportation in aid of racketeering enterprises. This is not
to be confused with a separate set of statutes under chapter 96 of Title 18, U.S. Code (§§
1961-1968), Racketeer Influenced and Corrupt Organizations.
42
Where one travels, or uses the mail or any facility, in interstate or foreign commerce,
with intent to commit any crime of violence to further any unlawful activity, and thereafter
performs or attempts to perform such violent crime resulting in death, the sentence shall
be imprisonment for any term of years or for life. 18 U.S.C. § 1952(a).
Page 28 GAO-21-385 Sex Trafficking
2421A(b) alongside racketeering or money laundering statutes may help
ensure all criminal activity involved in a course of criminal conduct is
prosecuted. DOJ officials said charging multiple statutes also makes it
more likely prosecutors will obtain a conviction. For example, if juries or
courts find evidence to be insufficient to support one charge or the charge
is dismissed, prosecutors may still be able to obtain a conviction for
another charge.
As of March 2021, one individual had sought civil recovery in federal court
under section 3 of FOSTA, but no damages were awarded and the case
was dismissed. Section 3 of FOSTA establishes that persons injured by
an aggravated violation involving promotion of prostitution of five or more
persons, or reckless disregard of the fact that the alleged conduct
contributes to sex trafficking, may recover damages in a federal civil
action.
43
Specifically, in November 2020, an individual claiming to be a
victim of sex trafficking sought damages and other relief under the U.S.
Constitution and a number of federal statutes, including 18 U.S.C. §
2421A.
44
This individual sought a total of $26 million in civil damages from
the defendants.
45
In March 2021, the court dismissed the case, without
43
Specifically, section 3 of FOSTA added a new provision at 18 U.S.C. § 2421A(c) which
states: “Any person injured by reason of a violation of section 2421A(b) may recover
damages and reasonable attorneys’ fees in an action before any appropriate United
States District Court.” Private civil proceedings involve conflicts between people or
institutions and are separate from criminal or civil law enforcement proceedings, which are
brought by the government. Civil damages refer to money that a defendant pays a plaintiff
in a civil case if the plaintiff has won. In civil proceedings, courts can hold injurers liable for
compensatory damages to cover the “economic” or monetary cost of an injury—for
example, medical costs and lost wages—and the “noneconomic” or non-monetary costs of
pain and suffering and punitive damages intended to punish a defendant for willful and
wanton conduct
44
USA v. Brooks, No. 4:20-CV-40148, Doc. 1, Complaint (D. Mass. Nov. 27, 2020).
45
Plaintiff sought $13 million in compensatory damages and $13 million in punitive
damages. Plaintiff also sought a protection order, as well as declaratory relief.
Compensatory damages are intended to compensate the plaintiff for an injury or loss.
Punitive damages are awarded to punish the defendant and serve as a warning to others
to refrain from similar conduct.
One Individual Sought
Civil Damages under
Section 3 of FOSTA, and
No Damages Were
Awarded
Page 29 GAO-21-385 Sex Trafficking
finding in the plaintiff’s favor or awarding damages, in accordance with its
orders granting the motions to dismiss filed by defendants.
46
There is no definitive reason why victims have not brought more civil
cases under section 3 of FOSTA. However, one possible reason is that
the FOSTA provision that allows for civil remedy is relatively new and
untested.
47
Representatives from the Human Trafficking Institute—an
organization that performs human trafficking legal research—also
provided other possible reasons why more civil cases have not been
brought under the FOSTA provision:
• Victims may not want to bring cases years after crimes took place
because doing so might open old wounds for which they do not want
to relive the trauma.
• Successfully bringing a civil case could be easier when there has
been a related criminal conviction, and there have been no criminal
convictions for aggravated violations of section 3 of FOSTA.
• Victims and their attorneys may not have the resources to gather
sufficient evidence to prove that injury was suffered as a result of an
aggravated violation of section 3 of FOSTA.
48
46
Brooks v. D’Errico, No. 4:20-CV-40148, Doc. 71, Order of Dismissal (D. Mass. Mar. 22,
2021). The court granted defendants’ motions to dismiss on various grounds, including
plaintiff’s failure to state a plausible claim for relief, and the judicial immunity doctrine
(whereby judges are immune from liability or damages for actions taken within their
judicial jurisdiction). For further information, see the following court orders granting
defendants’ motions to dismiss: Brooks v. Love, et al., 2021 WL 1092634 (D. Mass. Mar.
22, 2021); Brooks v. Delaney, et al., 2021 WL 1092135 (D. Mass. Mar. 22, 2021); Brooks
v. Gilman, et al., 2021 WL 1092640 (D. Mass. Mar. 22, 2021); Brooks v. D’Errico, et al.,
2021 WL 1092644 (D. Mass. Mar. 22, 2021); Brooks v. Metro. Sec. Serv. Inc., et al., 2021
WL 1092636 (D. Mass. Mar. 22, 2021).
47
Relatively few civil cases have been brought using a pre-existing non-FOSTA provision
of law that allows for trafficking victims to bring federal civil actions against perpetrators.
See 18 U.S.C. § 1595(a). This provision states that “An individual who is a victim of a
violation of [Chapter 77 of Title 18] may bring a civil action against the perpetrator (or
whoever knowingly benefits . . .) in an appropriate district court of the United States and
may recover damages and reasonable attorneys fees.”
48
In order to successfully recover damages in a civil case pursuant to 18 U.S.C. §
2421A(c), victims and their attorneys would have to prove that victims were injured by “a
violation of section 2421A(b).” Proving that such a violation occurred would involve
gathering sufficient evidence to show that those who controlled the online platform(s)
involved in the case did so with the intent to promote or facilitate the prostitution of another
person, and that they promoted or facilitated the prostitution of five or more persons, or
acted in reckless disregard of the fact that such conduct contributed to sex trafficking.
Page 30 GAO-21-385 Sex Trafficking
We provided a draft of this report to DOJ and the Administrative Office of
the U.S. Courts for review and comment. DOJ and the Administrative
Office of the U.S. Courts informed us that they had no formal comments
on the draft report; however, they provided technical comments, which we
incorporated as appropriate.
We are sending copies of this report to the appropriate congressional
committees, the Attorney General, the Director of the Administrative
Office of the U.S. Courts, and other interested parties. In addition, the
report is available at no charge on the GAO website at
http://www.gao.gov.
If you or your staff have any questions about this report, please contact
me at (202) 512-8777 or [email protected]. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. GAO staff who made major contributions to
this report are listed in appendix IV.
Gretta L. Goodwin
Director, Homeland Security and Justice
Agency Comments
Page 31 GAO-21-385 Sex Trafficking
List of Committees
The Honorable Gary C. Peters
Chairman
The Honorable Rob Portman
Ranking Member
Committee on Homeland Security and Governmental Affairs
United States Senate
The Honorable Dick Durbin
Chairman
The Honorable Chuck Grassley
Ranking Member
Committee on the Judiciary
United States Senate
The Honorable Bennie G. Thompson
Chairman
The Honorable John Katko
Ranking Member
Committee on Homeland Security
House of Representatives
The Honorable Jerrold Nadler
Chairman
The Honorable Jim Jordan
Ranking Member
Committee on the Judiciary
House of Representatives
Appendix I: Objectives, Scope, and
Methodology
Page 32 GAO-21-385 Sex Trafficking
This report addresses:
1. Department of Justice (DOJ) enforcement efforts against online
platforms that promote prostitution and sex trafficking, from 2014
through 2020; and
2. the extent to which criminal restitution and civil damages been sought
and awarded for aggravated violations under section 3 of the Allow
States and Victims to Fight Online Sex Trafficking Act of 2017
(FOSTA).
1
To examine DOJ enforcement efforts against online platforms that
promote prostitution and sex trafficking, from 2014 through 2020, we:
reviewed selected literature; reviewed specific federal criminal cases;
reviewed selected online platforms; reviewed data on the use of the
internet in sex trafficking cases; and interviewed DOJ officials and
representatives from third parties.
We identified publications for potential review primarily based on (1) an
exploratory search of various online databases, and (2) recommendations
from DOJ officials. We selected 20 publications for review. Our selections
reflected publications that addressed the nature of the online commercial
sex market, the role and seizure of backpage.com, and the passage of
FOSTA, among other things. The publications we reviewed had
publication dates ranging from 2015 through 2020. These dates provided
a reasonable amount of time both before and after two key events that
occurred in April 2018: the seizure of backpage.com and enactment of
FOSTA. We ultimately used information from five publications in our
report. For two publications that provided extensive information on the
nature of the online commercial sex market, we reviewed the
methodologies described in the publications, asked the authors and
researchers follow-up questions about how they gathered data and
generated findings, and corroborated selected findings with DOJ officials.
We reviewed cases that were brought against those who control
platforms in the online commercial sex market from January 2014 through
1
Pub. L. No. 115-164, 132 Stat. 1253 (2018).
Appendix I: Objectives, Scope, and
Methodology
DOJ Enforcement
Efforts against Online
Platforms that
Promote Prostitution
and Sex Trafficking
Review of Selected
Literature
Review of Specific Federal
Criminal Cases
Appendix I: Objectives, Scope, and
Methodology
Page 33 GAO-21-385 Sex Trafficking
December 2020.
2
We excluded the first case where DOJ charged a
violation under section 3 of FOSTA because it did not allege an
aggravated violation under 18 U.S.C. § 2421A(b), and the court also
granted the Defendant’s motion for judgment of acquittal as to the count
involving a general violation under section 2421A(a).
3
We include in our
scope cases against those who control platforms that primarily promote
commercial interactions between parties where in-person sexual services
may be expected or implied; thus, we excluded cases relating to
platforms that primarily promote visual content (e.g. pornography and live
virtual sex shows).
4
We also limited our search to cases involving
platforms operating on the surface web or deep web, as opposed to the
dark web.
5
DOJ’s databases of federal criminal cases do not have search
parameters that allow for cases brought against those who control
platforms in the online commercial sex market to be readily identified.
2
We selected January 2014 because during 2014 federal authorities seized
myredbook.com in connection with a federal prosecution that resulted in the first federal
conviction of an online platform operator for facilitation of prostitution. We concluded our
review of criminal cases in December 2020.
3
The first case where DOJ charged a violation under section 3 of FOSTA was in June
2019 in USA v. Palms, No. 4:19-CR-00103 (N.D. Ok. June 6, 2019). However, we
excluded this case from our review because DOJ did not charge an “aggravated” violation
under 18 U.S.C. § 2421A(b) (which we focus on in this report); and the defendant’s motion
for judgment of acquittal as to two of the counts, including the alleged § 2421A(a)
violation, was granted by the judge, and these counts were therefore not submitted to the
jury for a verdict.
4
In this report, we focus on the online promotion of in-person commercial sex acts,
whether through prostitution, which is illegal in all states but Nevada; or sex trafficking,
which is a federal crime and with respect to which all 50 states and the District of
Columbia have criminal statutes that can be used for anti-trafficking efforts. See GAO,
Human Trafficking: Information on Cases in Indian Country or that Involved Native
Americans, GAO-17-624, (Washington, D.C.: July 24, 2017). Nevertheless, we recognize
that the production and distribution of visual sexual content is subject to regulation or
prohibition under state or federal law, depending on the relevant facts and circumstances,
including whether such content involves sexual exploitation and abuse of minors (18
U.S.C. ch. 110).
5
Content on the surface web has been indexed by traditional search engines (e.g. Google,
Bing) and is readily available to the general public. Content on the deep web has not been
indexed by traditional search engines and is not generally accessible, but may be
accessible—in the context of this report—through the use of memberships and
subscriptions. Content on the dark web has been intentionally concealed and requires
specific software to access. We excluded criminal cases brought against those who
control platforms on the dark web because, according to DOJ officials, most online
advertisements for commercial sex are posted on the surface web where it is easier for
buyers and sellers to connect.
Appendix I: Objectives, Scope, and
Methodology
Page 34 GAO-21-385 Sex Trafficking
Thus, we used a variety of means to identify these cases. Specifically, to
ensure we identified as many relevant cases as possible, we:
1. obtained a preliminary and non-exhaustive listing of cases from DOJ’s
Criminal Division;
2. searched DOJ’s online repository of press releases using keywords
“website and sex trafficking” and “website and prostitution;”
3. incorporated responses compiled from an email sent to all U.S.
Attorney’s Offices wherein DOJ’s Executive Office for U.S. Attorneys
(EOUSA) sought to identify any additional cases;
6
and
4. discussed and confirmed the results with officials from DOJ’s EOUSA
and Criminal Division.
These steps provide a reasonable assurance we identified most or all
relevant cases.
The 11 cases identified provide information on the level of DOJ
enforcement efforts. We reviewed case dockets, and, as applicable,
indictments, informations, complaints, forfeiture-related documents, and
judgments for information related to charges brought, assets seized
and/or subject to potential forfeiture, and case status, among other things.
We obtained these documents from industry standard legal research
tools, including Thompson Reuters Westlaw Dockets and Public Access
to Court Electronic Records.
7
All information was initially identified by one
analyst and confirmed by a second person (attorney or analyst, as
appropriate). In instances where information from cases was not clear, we
obtained clarification from DOJ’s EOUSA, DOJ’s Criminal Division, or the
Administrative Office of the U.S. Courts (part of the Federal Judiciary).
We reviewed selected platforms in the online commercial sex market. To
perform this review, we obtained lists of platforms from the FBI, Polaris,
6
According to an EOUSA official, the email was sent to individuals working within the 94
United States Attorneys’ offices. Two offices responded and identified a total of four
additional cases as possibly being within our scope. EOUSA did not capture responses
wherein offices reviewed the email but did not identify additional cases, according to this
official.
7
Thompson Reuters Westlaw Dockets enables users to track cases and get instant
access to electronic court docket materials. The Public Access to Court Electronic
Records service provides electronic public access to federal court records.
Review of Selected Online
Platforms
Appendix I: Objectives, Scope, and
Methodology
Page 35 GAO-21-385 Sex Trafficking
childsafe.ai, and the Human Trafficking Institute (HTI).
8
These lists were
current as of various points in 2020, with the exception of the list from
HTI, which was current as of the end of 2019. We excluded platforms for
review that were not included in at least two of the lists. A GAO
investigator visited the remaining 34 platforms from a U.S.-based Internet
Protocol address and gathered information to further exclude platforms
that:
• had inactive or inaccessible domains, or domains that automatically
redirected users to other platforms;
9
• primarily hosted content that, when clicked on, redirected users to
other platforms;
10
• only promoted services outside the United States; or
• primarily promoted visual content (e.g. pornography or virtual live sex
shows).
11
After applying these exclusionary criteria, the investigator reviewed the
remaining 27 platforms and categorized each platform based on: (1) its
primary model of operation (advertising, hobby board, or sugar daddy);
(2) the services it primarily promotes (direct in-person sexual services,
services that are seemingly legal and mask in-person sexual services that
8
Polaris is a nonprofit organization and is leading a data-driven social justice movement to
prevent and reduce sex and labor trafficking in the United States and Mexico, according to
Polaris representatives. Since 2007, Polaris has operated the National Human Trafficking
Hotline, a project that is partially funded by the U.S. Department of Health and Human
Services. Childsafe.ai is a software company that deploys machine learning and active
collection networks to observe actors that buy and sell human beings online. HTI is a
nonprofit organization that conducts human trafficking research, among other things
9
In one instance, we found that the domains for two platforms redirected users to a new
platform domain that blended the two original domains. Thus, we excluded the two original
platforms and included the new platform domain.
10
To determine whether a platform “primarily” hosted content that, when clicked on,
redirected users to other platforms, a GAO investigator visited the platform and used her
best judgment to determine whether a majority of the content redirected users to other
platforms. A second investigator confirmed the results.
11
To identify whether a platform “primarily” promoted or facilitated visual content, a GAO
investigator visited the platform and used her best judgment to determine whether a
majority of the content promoted or facilitated visual content, as opposed to in-person
sexual services. A second investigator confirmed the results. We also excluded two
platforms that sought to connect people for dating or casual sexual activities, but did not
promote a commercial interaction between parties. For purposes of this report, we do not
consider these platforms to be part of the online commercial sex market.
Appendix I: Objectives, Scope, and
Methodology
Page 36 GAO-21-385 Sex Trafficking
may be expected or implied, or a continuing relationship where in-person
sexual services may be expected or implied); and (3) the payment
methods it accepts (credit/debit cards, virtual currency, store-brand gift
cards, or check/wires/money orders). A second investigator confirmed the
analysis and results of the first investigator.
We reviewed HTI data on defendants’ use of online platforms to solicit
buyers in federal sex trafficking cases from January 2014 through
December 2019. We selected January 2014 because during 2014 federal
authorities seized myredbook.com in connection with a federal
prosecution that resulted in the first federal conviction of an online
platform operator for facilitation of prostitution. We selected December
2019 because this was the latest data available from HTI at the time of
our review. To ensure data were reliable we reviewed HTI reports’
methodology sections, interviewed HTI officials, and followed up with HTI
officials regarding specific questions that arose during our analysis. For
example, we clarified data related to defendants’ use of Facebook and
craigslist.org that was initially unclear. After completing these steps, we
determined that the HTI data we use in this report are sufficiently reliable
to convey trends and provide specific examples of platforms used to
solicit buyers in federal sex trafficking cases.
12
12
HTI data we reviewed included data from federal criminal cases that involved: (1) one or
more charges under Chapter 77 of Title 18, U.S. Code, 18 U.S.C. §§ 1581-97 (Peonage,
Slavery, and Trafficking in Persons); or (2) one or more charges under statutes outside of
Chapter 77 where there was substantial evidence of force, fraud, coercion, commercial
sex with a child, or an identified victim of trafficking. Beginning in 2018, HTI began
proactively identifying sex trafficking cases charged outside of Chapter 77, according to
HTI representatives; prior to 2018, representatives said, HTI relied exclusively on federal
prosecutors to identify and convey cases with non-Chapter 77 charges to HTI. To ensure
HTI identified all relevant cases, HTI solicited and obtained input from DOJ’s U.S.
Attorney’s Offices, DOJ’s Criminal Division, and the Human Trafficking Prosecution Unit in
DOJ’s Civil Rights Division. HTI representatives said they considered a criminal case to be
“new” in a given year if prosecutors initiated charges by complaint, information, or
indictment in a federal court during that year. HTI considered a criminal case to be “active”
in a given year if prosecutors initiated charges in federal court and at least one defendant
was still awaiting trial or sentencing, if a case was on appeal, or if at least one defendant
still had the option to file a direct appeal as of the end of that year. Data in the report
represent information from cases for which the method of victim recruitment or buyer
solicitation was available in public sources as of December 2019. According to HTI
representatives, in the few instances where more than one method of buyer solicitation
was identified in a case (e.g. internet and massage parlor), reviewing attorneys used their
professional judgment to select the predominant method in the case (the “primary”
method). According to HTI representatives, data from cases in more recent years may not
be as complete as they will be in the future. This is because criminal proceedings often
take years and more information may become available as cases progress.
Review of Data on Use of
the Internet in Sex
Trafficking Cases
Appendix I: Objectives, Scope, and
Methodology
Page 37 GAO-21-385 Sex Trafficking
Finally, to inform all previous efforts discussed, we interviewed DOJ
officials and representatives from third parties. Specifically, we
interviewed officials from DOJ’s Civil Rights Division (Human Trafficking
Prosecution Unit specifically), Criminal Division, EOUSA, and the FBI. We
also interviewed the Chief Executive Officer of childsafe.ai; an Associate
Professor at Texas Christian University; and representatives from Polaris,
HTI, and the Human Trafficking Legal Center.
13
To address our second objective—the extent to which criminal restitution
and civil damages have been sought and awarded for aggravated
violations under section 3 of FOSTA—we used industry standard legal
research tools to identify criminal cases including charges under 18
U.S.C. § 2421A(b)(2).
14
To corroborate our results, we compared our
results with the results of a search performed by EOUSA of its CaseView
system—the case management system for the Offices of the United
States Attorneys. The results of EOUSA’s search confirmed our initial
results, which we updated to be current as of March 2021. To obtain
context on the number of cases DOJ has brought that include charges
under 18 U.S.C. § 2421A(b)(2), we interviewed officials from DOJ
components that are involved in litigating sex trafficking cases (EOUSA,
Criminal Division, and Civil Rights Division). We also reviewed EOUSA’s
November 2017 Bulletin on Human Trafficking, which discusses
13
Childsafe.ai is a software company that deploys machine learning and active collection
networks to observe actors that buy and sell human beings online. The Associated
Professor at Texas Christian University has extensive experience researching human
trafficking issues. According to Polaris representatives, Polaris is a nonprofit organization
and is leading a data-driven social justice movement to prevent and reduce sex and labor
trafficking in the United States and Mexico. Since 2007, Polaris has operated the National
Human Trafficking Hotline, a project that is partially funded by the U.S. Department of
Health and Human Services. HTI and the Human Trafficking Legal Center are both
nonprofit organizations that conducts human trafficking research, among other things.
14
Specifically, we used Thompson Reuters Westlaw Dockets, which enables users to
track cases and get instant access to electronic court docket materials. 18 U.S.C. §
2421A(d) states that “the court shall order restitution for any violation of subsection (b)(2).”
Subsection (b) states that “Whoever, using a facility or means of interstate or foreign
commerce or in or affecting interstate or foreign commerce, owns, manages, or operates
an interactive computer service . . . or conspires or attempts to do so, with the intent to
promote or facilitate the prostitution of another person and—(1) promotes or facilitates the
prostitution of 5 or more persons; or (2) acts in reckless disregard of the fact that such
conduct contributed to sex trafficking, in violation of [18 U.S.C.] 1591(a), shall be fined
under this title, imprisoned for not more than 25 years, or both.”
Interviewed DOJ Officials
and Representatives from
Third Parties
Criminal Restitution
and Civil Damages
under Section 3 of
FOSTA
Appendix I: Objectives, Scope, and
Methodology
Page 38 GAO-21-385 Sex Trafficking
prosecutorial strategies that may be used against those who control
platforms that promote prostitution and sex trafficking.
15
To examine the extent to which civil damages were sought by and
awarded to victims of aggravated violations under section 3 of FOSTA,
we used industry standard legal research tools to identify civil cases
brought under 18 U.S.C. § 2421A(c), based on a violation of subsection
2421A(b).
16
We contacted HTI and the Human Trafficking Legal Center—
both of which are organizations that work with federal civil sex trafficking
case data—and they confirmed our initial results, which we updated to be
current as of March 2021. To obtain context on the number of cases
victims and their legal representatives have brought under subsection
2421A(c), based on a violation of subsection 2421A(b), we interviewed
officials from HTI and the Human Trafficking Legal Center.
We conducted this performance audit from May 2020 to June 2021 in
accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives. We conducted our related
investigative work in accordance with standards prescribed by the Council
of the Inspectors General on Integrity and Efficiency.
15
DOJ, EOUSA, United States Attorneys’ Bulletin: Human Trafficking, Volume 65, Number
6, November 2017.
16
Specifically, we used Thompson Reuters Westlaw Dockets, which enables users to
track cases and get instant access to electronic court docket materials. 18 U.S.C. §
2421A(c) states that “Any person injured by reason of a violation of section 2421A(b) may
recover damages and reasonable attorneys’ fees in an action before any appropriate
United States district court.”
Appendix II: Types of Platforms in the Online
Commercial Sex Market
Page 39 GAO-21-385 Sex Trafficking
Platforms in the online commercial sex market have different models of
operation that generally fall within three broad categories: advertising,
hobby board, and sugar dating. Nevertheless, these categories are not
mutually exclusive, as there may be overlap in how these platforms
function and monetize.
Advertising platforms usually promote themselves as a directory or
classified service for escorts or adult entertainers, according to a July
2020 Polaris Report.
1
According to this same report, the majority of the
content on these platforms are paid advertisements for individuals or
businesses providing commercial sex. According to an April 2019
childsafe.ai report, ads often include a title, photos, sentences of
unstructured text, and a unique identifier for contact like a phone number,
email address, or social media handle.
2
We confirmed this with our own
review of advertising platforms and found that ads often also included
emojis, acronyms, and other “insider” language known within the industry,
as shown in figure 6.
1
Polaris’s July 2020 report is titled: Using an Anti-Money Laundering Framework to
Address Sex Trafficking Facilitated by Commercial Sex Advertisement Websites. This
report is comprised of two separate documents: (1) the full report; and (2) an executive
summary which is not included in the full report. According to Polaris representatives,
Polaris is a nonprofit organization and is leading a data-driven social justice movement to
prevent and reduce sex and labor trafficking in the United States and Mexico. Since 2007,
Polaris has operated the National Human Trafficking Hotline, a project that is partially
funded by the U.S. Department of Health and Human Services. According to the American
Heritage dictionary, an “escort” is a person, often a prostitute, who is hired to spend time
with another as a companion.
2
Childsafe.ai’s April 2019 report is titled: Beyond Backpage: Buying and Selling Sex in the
United States One Year Later. Childsafe.ai is a software company that deploys machine
learning and active collection networks to observe actors that buy and sell human beings
online.
Appendix II: Types of Platforms in the Online
Commercial Sex Market
Advertising Platforms
Appendix II: Types of Platforms in the Online
Commercial Sex Market
Page 40 GAO-21-385 Sex Trafficking
Figure 6: Screenshot from Advertising Platform in the Online Commercial Sex
Market
According to the July 2020 Polaris report, advertising platforms monetize
through selling an array of advertising options which include posting an
advertisement for various lengths of time, upgrading an advertisement so
that it is more prominently featured, or purchasing banner
advertisements. Platforms allow users to purchase individual ads,
advertising packages, or bundles of “credits” which vary in worth
depending on the site. Lastly, according to this report, some sites offer
free basic ads but charge for ad upgrades.
Advertising platforms also monetize by acting as “affiliate marketers” for
other platforms in the online commercial sex market. Companies—both
legitimate and illegitimate—that use affiliate marketing programs offer
performance-based commission incentives to third-party promoters, or
“affiliates,” who are often employed to direct new web traffic and
customers to the company’s products or services, according to the July
2020 Polaris report. Specifically, the Chief Executive Officer (CEO) of
childafe.ai said that affiliate, or third-party, platforms post ads, buttons,
discounts, or pop-ups in exchange for kickbacks based on associated
clicks, referrals, or sales. According to the childsafe.ai CEO and the July
2020 Polaris report, affiliate marketing has become a significant aspect of
Appendix II: Types of Platforms in the Online
Commercial Sex Market
Page 41 GAO-21-385 Sex Trafficking
the online commercial sex market, although it is a common marketing
practice among all types of online markets.
Hobby board platforms allow commercial sex buyers (self-identified
“hobbyists”) to review individuals or businesses providing commercial sex
and participate in discussion forums on the subject, according to the July
2020 Polaris report.
3
Hobby boards also serve as de facto advertising
platforms. According to the CEO of childsafe.ai, hobby boards provide far
more information than what is available on advertising platforms. For
instance, in addition to seeing reviews from other buyers, buyers can see
a detailed list of services provided and a graphic description of parts of
the provider’s body. We confirmed this with our own review of hobby
board platforms. Further, provider profiles contain contact information and
pricing information with detail that is often banned on advertising sites,
like rates and location, according to the April 2019 childsafe.ai report. See
figure 7 below.
3
The July 2020 Polaris report uses the term “review board” instead of “hobby board,” and
does not use the term “hobbyist.”
Hobby Board Platforms
Appendix II: Types of Platforms in the Online
Commercial Sex Market
Page 42 GAO-21-385 Sex Trafficking
Figure 7: Screenshot from Hobby Board Platform in the Online Commercial Sex
Market
According to the July 2020 Polaris report, hobby boards primarily
monetize by charging commercial sex buyers a membership subscription
fee that allows them to review individual providers of commercial sex and
commercial sex-related businesses, participate in forum discussions, and
see reviews posted by other commercial sex buyers. For one hobby
board platform, the childsafe.ai CEO said non-paying members can
access general reviews, but must subscribe to access more detailed
reviews. We confirmed this was true for at least one hobby board
platform. Hobby board platforms also monetize by acting as affiliate
marketers for other platforms in the online commercial sex market,
according to Polaris representatives and the childsafe.ai CEO.
Sugar dating platforms connect individuals for romantic relationships
under a commercial arrangement in which sexual activity may be
expected or implied, according to the July 2020 Polaris report. According
to this same report, rather than presenting a more transactional “quid pro
Sugar Dating Platforms
Appendix II: Types of Platforms in the Online
Commercial Sex Market
Page 43 GAO-21-385 Sex Trafficking
quo” arrangement of sexual services directly for money or something of
value, sugar dating platforms tend to describe themselves as facilitating
longer-term relationships with a benefactor dynamic. For instance, one
platform states that attractive members seek financially supportive
partners, or providers, who have the means to help them with the cost of
living or education, or those who can afford the lifestyle they desire. The
CEO of childsafe.ai summarized this benefactor dynamic by saying that,
at their core, sugar dating platforms promote connecting wealthy older
men (“sugar daddies”) with attractive younger women (“sugar babies”).
See figure 8 below.
Figure 8: Screenshot from Sugar Dating Platform in the Online Commercial Sex
Market
Appendix II: Types of Platforms in the Online
Commercial Sex Market
Page 44 GAO-21-385 Sex Trafficking
According to the July 2020 Polaris report, sugar dating platforms
monetize by charging a membership subscription fee or by charging a
separate fee for each contact initiated. Although sugar dating platforms
may not monetize by acting as affiliate marketers for other platforms, they
often employ other platforms to be affiliate marketers to draw visitors to
their platforms, according to Polaris representatives and the childsafe.ai
CEO.
Appendix III: Federal Criminal Cases Brought
Against Those Who Control Online Platforms
Page 45 GAO-21-385 Sex Trafficking
In June 2014, federal prosecutors initiated a case against the owner of
myredbook.com. According to the Department of Justice, this case
resulted in the first federal conviction of an online platform operator for
facilitation of prostitution. Since 2014, federal prosecutors have brought at
least 10 other cases against those who control platforms in the online
commercial sex market.
1
Table 4 below provides information on each of
these 11 cases.
1
We use the term “at least” because, although we used a variety of means to identify
these cases and thus have a reasonable assurance we identified most or all relevant
cases, it is possible our search was not exhaustive. See appendix I for more details.
Appendix III: Federal Criminal Cases
Brought Against Those Who Control Online
Platforms
Appendix III: Federal Criminal Cases Brought Against Those Who
Control Online Platforms
Page 46 GAO-21-385 Sex Trafficking
Table 4: Federal Criminal Cases Brought Against Those Who Control Platforms in the Online Commercial Sex Market (from 2014 through 2020)
Case name / major
online platform
involved
Month and
year filed Summary of charges
a
Summary of assets
seized and/or subject
to potential forfeiture
b
Case status Case resolution
Summary of assets
ordered to be forfeited
USA v. Omuro et al
(myredbook.com)
June 2014
Two individuals charged
with racketeering, and
money laundering.
Over $5.4 million in
funds and property;
domains sfredbook.com
and myredbook.com.
Closed.
One individual convicted of
racketeering and sentenced to
13 months in prison.
Government dismissed
charges against other
individual.
One individual ordered to
forfeit nearly $1.3 million
and 2 cars.
USA v. Easy Rent
Systems, Inc. et al
(rentboy.com)
Aug 2015
One individual and one
organization charged
with racketeering, and
money laundering.
Nearly $1.6 million;
domain rentboy.com.
Closed.
One individual convicted of
racketeering and sentenced to
6 months in prison.
One organization convicted of
money laundering.
One individual and one
organization ordered to
forfeit nearly $1.5 million
and domain rentboy.com
(both the individual and
organization were ordered
to forfeit the same assets).
USA v. Lacey et al
(backpage.com)
March
2018
Seven individuals
charged with
racketeering and money
laundering.
Between $69.5 and
$75.8 million in 70
accounts; the equivalent
of between $13.9 and
$16 million in 4
cryptocurrency
accounts; unknown
amount of funds in 53
accounts; 26 real
properties; domain
backpage.com and 267
associated domains;
trademarks and other
intellectual property.
c
Pending as of the
end of 2020.
Case pending.
Case pending.
Appendix III: Federal Criminal Cases Brought Against Those Who
Control Online Platforms
Page 47 GAO-21-385 Sex Trafficking
Case name / major
online platform
involved
Month and
year filed
Summary of charges
a
Summary of assets
seized and/or subject
to potential forfeiture
b
Case status Case resolution
Summary of assets
ordered to be forfeited
USA v. Ferrer
(backpage.com)
April 2018
One individual charged
with racketeering, and
money laundering.
Included in USA v.
Lacey et al above.
c
Pending as of the
end of 2020.
Case pending.
Case pending.
USA v. Backpage.com
LLC, et al
(backpage.com)
April 2018
Six entities charged with
money laundering.
d
Included in USA v.
Lacey et al above.
c
Pending as of the
end of 2020.
Case pending.
Case pending.
USA v. Martin, et al
(flawlessescorts.com)
July 2018
Two individuals charged
with money laundering.
Unknown amount of
funds in 6 accounts;
domain
flawlessescorts.com.
Pending as of the
end of 2020.
Case pending.
Case pending.
USA v. Chen, et al
(supermatchescort.com)
November
2018
Five individuals charged
with racketeering.
$12,662; miscellaneous
jewelry.
Pending as of the
end of 2020.
Case pending.
Case pending.
Supermatchescort.com
and 499 associated
domains were ordered to
be forfeited through civil
judicial proceedings.
e
USA v. Lee
(wehavefuntimes.com)
March
2019
One individual charged
with racketeering, child
sex trafficking,
production of child
pornography, and
interstate transportation
for prostitution.
$1,140; 12 electronic
devices or storage
equipment (computers,
phones, storage drives,
etc.).
Pending as of the
end of 2020.
Case pending.
Case pending.
USA v. Greenberg
(independentgirls.com)
May 2019
One individual charged
with racketeering, sex
trafficking, and sexual
exploitation of children.
3 cameras and 1
storage device; domain
independentgirls.com.
Pending as of the
end of 2020.
Case pending.
Case pending.
USA v. Reynolds
(vipescorts.com)
February
2020
Two individuals charged
with money laundering.
Unknown amount of
funds in multiple
accounts; domain
vipescorts.com and 390
associated domains.
Pending as of the
end of 2020.
Case pending.
Case pending.
Appendix III: Federal Criminal Cases Brought Against Those Who
Control Online Platforms
Page 48 GAO-21-385 Sex Trafficking
Case name / major
online platform
involved
Month and
year filed
Summary of charges
a
Summary of assets
seized and/or subject
to potential forfeiture
b
Case status Case resolution
Summary of assets
ordered to be forfeited
USA v. Martono
(cityxguide.com)
June 2020
One individual charged
with promotion and
facilitation of prostitution
and reckless disregard
of sex trafficking,
racketeering, and money
laundering.
Unknown amount of
funds in 12 accounts;
precious metals; domain
cityxguide.com.
Pending as of the
end of 2020.
Case pending.
Case pending.
Source: GAO analysis of court documents and Department of Justice press releases. | GAO-21-385
Note: This table reflects the status of cases as of the end of 2020, and excludes cases brought against those who control
platforms on the dark web or control platforms that primarily promote visual content (e.g. pornography and live virtual sex
shows).
a
”Summary of charges” represents selected charges from the indictment (or the latest superseding indictment), if one has been
filed; if an indictment has not been filed, selected charges come from the criminal information or complaint, as applicable.
Selected charges generally illustrate the nature of the alleged criminal conduct charged by the government in the case. In this
table, we use the term “racketeering” to refer to 18 U.S.C. § 1952 - Interstate and foreign travel or transportation in aid of
racketeering enterprises. This is not to be confused with a separate set of statutes, under chapter 96 of Title 18, U.S. Code (§§
1961-1968), Racketeer Influenced and Corrupt Organizations.
b
”Seizure” involves the physical restraint of an asset or its transfer from the owner or possessor to the custody or control of the
government. Seizure generally occurs: (1) incident to an arrest; (2) pursuant to a search warrant; (3) pursuant to a civil or
criminal seizure warrant; or (4) pursuant to a restraining order. Seizure is not equivalent to “forfeiture,” which is the legal
process by which individuals may lose ownership of an asset through a court order. The Government is not required to seize
property subject to criminal forfeiture during the pendency of a criminal case. The type and number of assets seized and/or
subject to potential forfeiture may change throughout a criminal proceeding, and forfeiture is not final until a court issues a final
order of forfeiture. Following resolution of a criminal case, the court conducts “ancillary proceedings” to determine the rights of
any third parties to the property subject to potential forfeiture. See Fed. R. Crim. P. 32.2(c); 21 U.S.C. § 853(k), (n). After
ancillary proceedings are complete, the court must issue a final order of forfeiture. Fed. R. Crim. P. 32.2(c)(2). In addition, in
some cases law enforcement may continue to identify assets subject to forfeiture even after the entry of a final order of
forfeiture—for example, substitute assets may be forfeited to satisfy a forfeiture money judgment. See 21 U.S.C. § 853(p).
Dollar amounts have not been adjusted for inflation.
c
We combined assets seized and/or subject to potential forfeiture in separate criminal cases brought against those who
controlled backpage.com. We removed duplicates from the total when the same assets appeared to be listed in more than one
case. We used ranges because, in two instances, it was not clear whether funds listed in separate cases were duplicative or
not. Specific amounts of cryptocurrency included: 1334.7 Bitcoin, between 3802.7 and 6475.7 Bitcoin Cash, 509.8 Bitcoin
Gold, and 17094.8 Litecoin. We used exchange rates for the average of all days in the month of July 2018 to calculate U.S.
Dollar equivalencies. We used the month of July 2018 because the most comprehensive amounts of cryptocurrency were listed
in July 2018 court documentation. Using exchange rates for the average of all days in the month of December 2020, the U.S.
Dollar equivalency is between $32.2 and $33 million. We use the word “accounts” to represent the following terms used in
Appendix III: Federal Criminal Cases Brought Against Those Who
Control Online Platforms
Page 49 GAO-21-385 Sex Trafficking
court documents: “bank accounts,” “[cryptocurrency] wallet,” “security deposits and retainers/deposits for future services,” and
“reserves and accounts receivable.” According to DOJ officials, there is also a civil case related to seizure warrants and civil
complaints filed against property alleged to be related to the alleged criminal conduct of both organizational and individual
defendants connected to backpage.com (see USA v. In the Matter of Seizure of: Any and All Funds Held in Republic Bank of
Arizona Accounts Ending in 1889; 2592; 19538; 2912; 2500).
d
In addition to the six organizations charged, there are nine additional organizations and six individuals identified as “movants”
(i.e. parties that make motions) in this case. According to DOJ officials, the nine additional organizations are allegedly owned
by the six organizations charged in this case and the six individuals charged in the USA v. Lacey et al case. According to DOJ
officials, although there were seven individual defendants named in the USA v Lacey et al case, one pleaded guilty, leaving
only the six remaining individual defendants. These movants have asserted interests in the assets subject to potential criminal
and civil forfeiture, according to DOJ officials.
e
Civil judicial forfeiture is an action brought in court against the property. The property is the defendant and no criminal charge
against the owner is necessary.
Appendix IV: GAO Contact and Staff
Acknowledgments
Page 50 GAO-21-385 Sex Trafficking
In addition to the contact names above, Joseph P. Cruz (Assistant
Director), Jeff R. Jensen (Analyst-in-Charge), Nasreen Badat, Peter
Casey, Lilia Chaidez, Pamela Davidson, Robert Graves, Eric Hauswirth,
Leslie Holen, Sasan J. “Jon” Najmi, and Patricia L. Powell made key
contributions to this report.
Appendix IV: GAO Contact and Staff
Acknowledgments
GAO Contact
Staff
Acknowledgments
(104306)
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