The Federal Bureau of Investigation's Efforts to Combat Crimes Against Children

Audit Report 09-08
January 2009
Office of the Inspector General

Chapter 4: Non-Cyber Sexual Exploitation of Children

Besides child abductions, the FBI’s CACU investigates two types of non-cyber related sexual exploitation of children crimes: criminal enterprises that systematically recruit, transport, and exploit minors through prostitution; and the sexual exploitation of children across state or foreign boundaries, including child sex tourism committed by U.S. citizens and legal aliens.117 This chapter analyzes the FBI’s efforts to address its responsibilities in investigating and coordinating on cases of child prostitution and the sexual exploitation of children across state and foreign boundaries.118

Child Prostitution

The exact number of child prostitution victims is not known, and estimates of children at risk of commercial sexual exploitation vary widely.119 Nevertheless, the FBI’s research has identified the following characteristics of prostituted children:

According to CACU officials, the FBI’s mission and resource limitations cause child prostitution to rank as a lower priority. The FBI categorizes non-cyber crimes against children as violent crimes, which currently rank eighth on the FBI’s overall priority list. For crimes against children specifically, child abductions are given a higher priority than child prostitution related crimes.120 Despite the lower priority, we found that through its Innocence Lost National Initiative the FBI CACU has made a focused effort to investigate crimes where children are forced into prostitution.

Innocence Lost National Initiative

In June 2003, the FBI implemented its Innocence Lost National Initiative (Innocence Lost) to address the trafficking of children for commercial sexual exploitation. Innocence Lost brings together the FBI, the Child Exploitation and Obscenity Section (CEOS) of the DOJ’s Criminal Division, and NCMEC to combat the prostitution of children. In this coordinated approach, the FBI developed task forces to investigate, with the help of local law enforcement agencies, criminal enterprises that prostitute children; NCMEC provided training opportunities to educate law enforcement officers on how to address child prostitution; and the CEOS provided prosecutorial expertise. In support of Innocence Lost, the FBI also conducted intelligence assessments to evaluate the severity of child prostitution in the United States and to identify new ways offenders exploit children through prostitution. Furthermore, the FBI began tracking investigations of child prostitution enterprises by creating a unique classification code. From its inception in June 2003 through September 2007, the Innocence Lost program dismantled 31 enterprises that exploited children through prostitution and located 281 victimized children. Based on these statistics, the Innocence Lost initiative has resulted in an overall increase in the amount of FBI investigations of prostituted children and the number of offenders convicted nationwide between 2004 and 2007. The following table displays these and other accomplishments reported by the FBI.


  FY04 FY05 FY06 FY07 Total
Cases Opened 66 71 103 125 365
Located Child Victims 24 32 44 181 281
Enterprise Dismantlements 10 6 4 11 31
Arrests 118 382 157 308 965
Indictments 26 44 68 55 193
Convictions 22 45 43 106 216
Sentences 15 38 27 89 169
Source: FBI

In 2003, the CACU identified 13 U.S. cities with a high incidence rate of child prostitution and designated these locations as High Intensity Child Prostitution Areas where the FBI would establish Innocence Lost task forces.122 As of June 2008, there were 24 Innocence Lost task force locations across the country. Of these 24 locations, 13 had formal task forces and 11 had informal working groups.123

As part of Innocent Lost task forces, police officers from local law enforcement agencies meet regularly, receive training provided by NCMEC, cooperatively investigate leads of child prostitution, and forward leads of victims of domestic trafficking to the FBI for further review. When warranted, a federal investigation of enterprise-level child prostitution is initiated and investigated by the task force. Working groups are generally led by an FBI Special Agent and may be comprised of other FBI Special Agents as well as representatives of local law enforcement agencies involved in investigating the prostitution of children.

Investigations of the Prostitution of Children

The FBI receives leads on commercial sexual exploitation of children from a variety of sources, including: (1) street‑level investigations and surveillance at locations frequented by prostitutes and their patrons; (2) monitoring of Internet social networking sites and advertisements for escort services; (3) tips received through NCMEC’s 24-hour CyberTipline®; and (4) local law enforcement agencies that reach out to the FBI. Additionally, the FBI’s liaison at NCMEC reviews incoming reports from NCMEC and, if the report on a missing child contains prostitution-related concerns, forwards the information to the appropriate FBI field office.

During our fieldwork we reviewed a total of three child prostitution cases to examine the FBI’s investigative efforts and coordination with other agencies in this sample of cases. Our review of these case files identified evidence that in these cases the FBI field offices pursued leads on allegations of child prostitution. In one of the three cases, the FBI received a referral from a child welfare organization and investigated the lead. In another case file that we reviewed, we noted evidence that the FBI worked closely with local police agencies in investigating possible allegations of child prostitution. Although our limited sample does not permit us to draw an overall conclusion of the FBI’s efforts in addressing child prostitution, information from these case files suggest that coordination exists between the FBI and local agencies.

Database of Prostituted Children

Prostituted children frequently relocate because their pimps: (1) try to evade detection by law enforcement agencies; (2) move the prostituted children to venues with a perceived demand for prostitution; and (3) trade children like property. In response, FBI has been developing an Innocence Lost nationwide database of information regarding prostituted children and pimps to identify and track their interstate movements. This database is accessible to FBI personnel and authorized local law enforcement officers through the shared Law Enforcement Online network.124 In early June 2008, the FBI reported that it had imported into the database 17,000 records from prior investigations of child prostitution. When the database is officially deployed later in 2008, authorized users will be able to add additional records from their ongoing investigations of child prostitution into this nationwide database.

According to the FBI, the Innocence Lost database is designed to include basic facts on pimps and their victims, such as names, aliases, and physical characteristics. In addition, the database is capable of storing images or audio files. Information such as the number of pimps that have victimized a child or other states through which the victim has been transported can also be collected within this database. Information in the database can be used to locate targets and victims and help establish the existence of an interstate criminal enterprise trafficking children for sexual exploitation.


The FBI provides training hosted by NCMEC on the Innocence Lost initiative, which helps to educate state and local law enforcement officers on the chief characteristics of domestic trafficking of children for prostitution. The FBI’s curriculum on child prostitution typically includes two topics: task force formation and the initiation of child prostitution investigations. Documentation provided by NCMEC revealed that the FBI participated in 16 1-week training sessions held at NCMEC from the inception of Innocence Lost from 2003 through August 2007. During our fieldwork, we obtained from NCMEC the course evaluations from these training sessions completed by course participants. The average overall participant satisfaction rating for these training sessions was very high.125

Intelligence Assessments

In recent years, the FBI has emphasized the need to gather strategic intelligence to help it “connect the dots” and discern trends regarding crimes, including child prostitution. In January 2007, the CACU issued a 24‑page report entitled, “Child Prostitution in America,” which synthesized information from FBI investigations and relevant research by external organizations and discussed child prostitution enterprises in terms of recruitment, marketing, transportation, venues, and control and punishment of victims. The report noted new trends in advertising victims and sexual services on social networking and community bulletin board Internet sites. The report also identified nine areas in which there was limited intelligence regarding child prostitution, including the number of children victimized through sex trafficking, the nature of the operators who traffic children for sexual exploitation, the extent of involvement by gangs or other organized criminal enterprises in the prostitution of children, and the use of the Internet and technology in sexual trafficking of children. We believe that the report is a useful primer on the severity and complexities of child prostitution in the United States.

In addition to intelligence on a national level, we also found that intelligence assessments have been conducted at the local level to aid programs and investigations targeting child prostitution. For example, in June 2007 an Intelligence Analyst at the FBI’s Resident Agency in Santa Ana, California, produced an intelligence assessment report describing the extent of child prostitution in Orange County, California. As a result of this assessment, the FBI’s CACU established an Innocence Lost task force to address the sexual trafficking of youths in Orange County. We were told that the Intelligence Analyst at the Santa Ana Resident Agency was asked to train the FBI San Diego Field Office on developing a similar assessment of prostitution in that jurisdiction.

However, during our fieldwork, we identified FBI regions that had some difficulties in obtaining intelligence assessments on prostituted children in their jurisdictions. For example, in April 2007 a San Francisco Field Office Assistant Special Agent in Charge for criminal matters stated that the office would benefit from an updated intelligence assessment on child prostitution. However, no Intelligence Analysts were available until November 2007 to initiate this assessment of domestic trafficking of children for prostitution.

The CACU Chief informed us that Intelligence Analysts have made significant contribution to the efforts to combat crimes against children. However, Intelligence Analysts at field offices are supervised by and report to local management and are not directed by the CACU. Based on what we observed at the FBI’s Resident Agency in Santa Ana, California, an intelligence assessment can be helpful in identifying the severity of the crime of prostituted children and the potential value of a task force dedicated to addressing the problem. At the time of our audit, the FBI did not have training materials for conducting intelligence assessments of the domestic trafficking of children for sexual exploitation. While the Intelligence Analyst from the Santa Ana Resident Agency provides such training to the FBI’s San Diego Field Office, we believe that the FBI could build on this Intelligence Analyst’s work to create training materials for developing future intelligence assessments on prostituted children.

Sexual Exploitation of Children

Another responsibility of the CACU is to respond to leads on individuals who exploit children sexually across state and foreign boundaries without evidence of prostitution. Cases involving individuals who travel overseas for the purpose of engaging in sexual activity with minors – a crime referred to as child sex tourism – are complex investigations.126 The FBI’s responsibility in this area includes identifying, investigating, and helping prosecute U.S. citizens and legal aliens who travel to foreign countries with the intent to engage in illegal sexual relations with minors. According to the FBI, two regions with a high incidence of child sex tourism are Latin America and Southeast Asia.

We interviewed officials of the CACU at FBI headquarters and Supervisory Special Agents and Special Agents at the field offices we visited, surveyed two FBI Legats, and examined four recently closed investigative case files to assess the FBI’s coordination and investigative efforts regarding child sex tourism. Our review found that the FBI conducts both reactive and proactive investigations to combat child sex tourism. In reactive investigations, the FBI responds to allegations that individuals are suspected of having sexually exploited children overseas. Through its proactive investigations, the FBI conducts undercover operations directed against those who intend to travel abroad to engage in sexual activities with minors.

Reactive Investigations

As part of our fieldwork, we reviewed four reactive investigations on child sex tourism, one case at each of the Miami, Boston, Los Angeles, and St. Louis field offices.127 Although we found evidence that FBI Special Agents pursued various leads in these cases, all four cases were closed without prosecution because the allegations could not be substantiated.

In the four cases that we reviewed, we found that FBI Special Agents experienced difficulties in pursuing subjects who have allegedly exploited children overseas because these crimes occurred on foreign soil. One CACU Supervisory Special Agent stated that it is difficult to identify and obtain cooperation from victims living in a foreign country. Some children exploited by foreign tourists come from disadvantaged backgrounds, and instances of bribery of victims and their families can prevent their cooperation with law enforcement. Even in cases where the victims agree to cooperate with law enforcement, traveling to the United States and staying through an investigation and prosecution can be complicated and expensive for law enforcement agencies.

To further understand the FBI’s efforts overseas in conducting child sex tourism investigations, we surveyed two Legats assigned to countries identified as having a severe problem with this crime, Thailand and Costa Rica. The FBI official responsible for Costa Rica was stationed in Panama City, Panama. He stated that he met with government officials in Costa Rica who investigate and prosecute child sex tourism cases to facilitate the exchange of case-related information. However, this official stated further that additional investigative resources through undercover operations and Special Agents with language training would be required to adequately address this crime.

The Bangkok Legat stated that it is difficult to respond timely to leads on child sex tourism because the Legat consists of only two individuals and they have other priority matters that take precedence. According to this official, a small investigative staff and corruption at local law enforcement agencies also impede efforts in addressing child sex tourism in Thailand. Nevertheless, this official stated that the FBI launched a new working group in early 2008 with ICE and the Royal Thai Police in Thailand with the intention of addressing child sex tourism in a proactive manner, with an emphasis on Pattaya, Thailand, and Phnom Penh, Cambodia. By establishing partnership overseas with the Thai Royal Police as well as ICE representatives, the FBI has shown an initiative in pursuing investigations overseas where local children are sexually exploited by tourists—including those from the United States.

Pro-active Investigations

In 2002 the FBI launched an undercover program targeting child sex tourism. This proactive initiative consisted of creating a fictitious travel agency website managed by the FBI’s Miami Field Office – the only location conducting this initiative. This travel agency pretends to arrange trips to Latin America for individuals who express an interest in traveling overseas to engage in sexual activities with minors. According to the FBI, a proactive undercover operation on child sex tourism allows law enforcement to gather evidence while controlling the pace of the investigations as the potential subjects interact with the fictitious travel agency in finalizing plans for such trips. In successful proactive investigations, subjects are arrested at the airport prior to departure and the case is referred to the U.S. Attorney’s Office for prosecution. As of Summer 2008, 15 individuals were convicted for arranging child sex tourism trips through the FBI Miami Field Office’s undercover operation.

When we compared the FBI’s management of child sex tourism cases with its management of domestic child prostitution cases, we found several contrasts. For example, unlike the Innocence Lost, we found no goals and guidance established for child sex tourism investigations. Moreover, investigations on child sex tourism are classified under the same classification used for all other types of sexual exploitation of children. As a result, it is difficult for the FBI to track its efforts and accomplishments in this area. By contrast, Innocence Lost accomplishments are tracked by a separate classification. Also, we did not find research projects by the BAU-3 or Intelligence Analysts that would provide greater insights into child sex tourism and the types of investigative techniques that could aid FBI Special Agents. Consequently, we recommend that the FBI create the appropriate program structures – goals, guidance, research projects, and a separate investigative classification – to more fully develop its investigative efforts to combat child sex tourism.


Our audit found that in 2003 the FBI developed a nationwide program to combat non-cyber commercial sexual exploitation of children known as the Innocence Lost National Initiative. According to FBI statistics, between FYs 2004 and 2007, 365 Innocence Lost investigations resulted in the dismantling of 31 criminal enterprises, the arrest of 965 subjects, and the conviction of 216 persons involved in child sexual exploitation.

Compared to its efforts to address sexual exploitation domestically through Innocence Lost, the FBI does not have a similar strategy to address the victimization of children internationally through child sex tourism. We recommend that the FBI develop for its child sex tourism operations an organizational strategy, guidance and goals for its domestic and foreign offices, and a unique investigative classification code.


We recommend the FBI:

  1. Develop for child sex tourism cases a programmatic strategy, goals, guidance, and a separate investigative classification for tracking such investigations.


  1. The statute on sex trafficking of children, codified at 18 U.S.C. § 1591, criminalizes the movement of minors in interstate or foreign commerce for the purpose of having the child victim “engage in a commercial sex act,” defined as “any sex act, on account of which anything of value is given to or received by any person.”

  2. Besides investigating child prostitution and the sexual exploitation of children across state lines, the FBI also began operating an inspection program in 2006 to assess the adult entertainment industry’s compliance with recordkeeping requirements codified at 18 U.S.C. § 2257. These requirements are intended to ensure that no minors are employed in the production of adult entertainment. However, in October 2007 the U.S. Court of Appeals for the Sixth Circuit decided in Connection Distributing Co., et al v. Keisler that 18 U.S.C. § 2257 was “overbroad and therefore violates the First Amendment.” Consequently, the FBI suspended the inspection program in February 2008. As a result, we did not review this inspection program as part of our audit.

  3. David Finkelhor and Richard Ormrod, “Prostitution of Juveniles: Patterns From NIBRS,” OJJDP Juvenile Justice Bulletin, June 2004: 10. These co-authors noted that “[m]ost discussions of the prostitution of juveniles rely heavily on anecdotal case studies. . . . . Statistics on the prostitution of juveniles have often been based on guesswork.”

    Richard J. Estes and Neil Alan Weiner, The Commercial Sexual Exploitation of Children In the U.S., Canada and Mexico, (Philadelphia, PA: University of Pennsylvania, September 18, 2001, Revised February 20, 2002), 142. This particular study stated that “[r]eliable estimates of the number of commercially sexually exploited children in the United States do not exist.”

  4. A Supervisory Special Agent assigned to the CACU at the FBI headquarters expressed the opinion that a prostituted child should also be elevated to the status of a “child in imminent danger” and receive immediate attention. This Supervisory Special Agent stated that despite the extensive media attention generally paid to children abducted by strangers, the number of such cases is relatively few when compared to minors victimized by prostitution at the enterprise level.

  5. Before the establishment of Innocence Lost in FY 2004, all forms of sexual exploitation of children were classified under the same code. When the FBI established its Innocence Lost initiative in FY 2004, it also created a new classification code to track investigations of prostituted children at the enterprise level. Therefore, there are no statistics available from before the launch of Innocence Lost in FY 2004 to which we can compare more recent statistics.

  6. The 13 High Intensity Child Prostitution Areas were: (1) Los Angeles, California; (2) Minneapolis, Minnesota; (3) Dallas, Texas; (4) Detroit, Michigan; (5) Tampa, Florida; (6) Chicago, Illinois; (7) San Francisco, California; (8) San Diego, California; (9) Miami, Florida; (10) New York City; (11) Washington, D.C.; (12) Las Vegas, Nevada; and (13) St. Louis, Missouri.

  7. The 13 task forces include: (1) Miami, Florida; (2) Cleveland and Toledo, Ohio; (3) Las Vegas, Nevada; (4) Reno, Nevada; (5) Dallas, Texas; (6) Boston, Massachusetts; (7) Newark and Atlantic City, New Jersey; (8) San Juan, Puerto Rico; (9) Los Angeles, California; (10) Phoenix, Arizona; (11) Detroit, Michigan; (12) Wichita, Kansas; and (13) Orange County, California. The 11 informal working groups include: (1) Indianapolis, Indiana; (2) San Francisco, California; (3) Denver, Colorado; (4) Oklahoma City, Oklahoma; (5) Houston, Texas; (6) Chicago, Illinois; (7) New York City; (8) Washington, D.C.; (9) Jacksonville, Florida; (10) Honolulu, Hawaii; and (11) Sacramento, California.

  8. We did not audit the database or the information entered into it, and we reach no conclusions on the accuracy of the data. According to the CACU officer who provided a demonstration to us in June 2008, the FBI had completed a DOJ-required privacy impact assessment as a part of the process of creating the database of child prostitution. Furthermore, records in the database submitted by state or local law enforcement agencies must comply with local laws and regulations regarding such records on minors, and would be purged from the database in accordance with applicable laws and regulations when the minors reach the age of majority.

  9. According to the evaluation results of “Protecting Victims of Child Prostitution” training sessions provided by NCMEC, all five training sessions between 2003 and 2004 received an average rating of 4.52 or better on a 5-point scale in the following six categories: (1) time allocation, (2) training topics, (3) curriculum organization, (4) manual, (5) training design, and (6) overall rating. Beginning in 2005 NCMEC switched to a 10-point scale for course evaluation rating, and all 11 training sessions for “Protecting Victims of Child Prostitution” between 2005 and 2007 received an average rating of 9.42 or better in the same six categories.

  10. The 2003 Prosecutorial Remedies and Other Tools to End the Exploitation of Children Today (PROTECT) Act increased existing penalties to a maximum of 30 years in prison for engaging in or attempting to engage in child sex tourism. In addition, it is no longer necessary to prove that the traveler intended to engage in illicit sexual conduct at the time of travel, merely that the traveler actually engaged in or attempted to engage in illicit sexual conduct.

  11. We also visited the FBI field office in San Francisco as part of our fieldwork, but it had no child sex tourism cases for us to select and review.


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