Management of the Office of Justice Programs’ Grant Programs for Trafficking Victims

Audit Report 08-26
July 2008
Office of the Inspector General


Human trafficking is a form of modern-day slavery in which adults and children are bought, sold, and held against their will in sexual slavery and involuntary servitude. Human trafficking deprives people of their human rights and freedoms, increases global health risks, and fuels organized crime. Victims also suffer physical and emotional abuse, rape, threats, document theft, and death.


In 1998, the President directed federal agencies to combat human trafficking through a three-pronged approach to prevent trafficking, protect victims, and prosecute traffickers. In 2000, Congress enacted the Trafficking Victims Protection Act (TVPA) to combat human trafficking. Through two reauthorization acts, one in 2003 and the other in 2005, Congress reauthorized the TVPA through fiscal year (FY) 2007. As of March 2008, congressional reauthorization beyond FY 2007 was pending.

The TVPA defines victims of “severe” forms of trafficking as those persons subject to: (1) sex trafficking in which a commercial sex act is induced by force, fraud, or coercion, or in which the person induced to perform such acts is under age 18; or (2) the recruitment, harboring, transportation, provision, or obtaining of a person for labor or services, through the use of force, fraud, or coercion, for the purpose of subjection to involuntary servitude, peonage, debt bondage, or slavery. A victim need not be physically transported from one location to another to be a human trafficking victim. The TVPA provides that an alien, who is identified as a victim of a severe form of trafficking in the United States and meets additional conditions, is eligible for special benefits and services.

The Departments of Justice, State, Labor, Health and Human Services, and Homeland Security share responsibility for implementing the U.S. government’s anti-trafficking efforts domestically and abroad. Each agency focuses on one or more prongs of the three-prong approach to anti-trafficking – prevention, protection, and prosecution. As shown in the following table, the Department of Justice’s (Department) responsibility addresses all three prongs.

Department of Justice Efforts to
Combat Human Trafficking

Prevention Efforts
Prosecutors and other Department personnel assist in training local law enforcement agencies, non-governmental organizations, and international representatives on human trafficking issues.
The National Institute of Justice’s International Center supports research and exchange of information by offering grants for academic research on trafficking in persons and child exploitation.
The Office of Justice Programs’ (OJP) National Criminal Justice Reference Service offers information to support research, policy, and program development worldwide on various criminal justice issues, including international trafficking.
Protection Efforts
OJP’s Office for Victims of Crime (OVC) awards cooperative agreements to service providers to supply direct services to victims of trafficking.
OJP’s Bureau of Justice Assistance awards grants to state and local law enforcement agencies to develop task forces that: (1) identify and rescue victims of human trafficking, and (2) collaborate with service providers to provide assistance to victims of trafficking.
The OVC offers victim support and education resources to trafficking victims and victim service providers.
The OVC maintains a resource center that victim advocates and caregivers can contact to obtain publications and tools to assist them in working with trafficking victims.
Prosecution Efforts
The Civil Rights Division's Criminal Section enforces the involuntary servitude and peonage statutes by working with the Federal Bureau of Investigation, the United States Attorneys Offices, and the Criminal Division’s Child Exploitation and Obscenity Section to investigate and prosecute cases of trafficking in persons and worker exploitation.
The Civil Rights Division funds and staffs the national complaint line for reporting of trafficking crimes.
Source: Department of Justice website and the Bureau of Justice Assistance

Our audit examined the Department’s protection efforts involving the Office of Justice Programs’ (OJP) Office for Victims of Crime’s (OVC) awarding of cooperative agreements to provide direct services to trafficking victims and OJP’s Bureau of Justice Assistance’s (BJA) awarding of task force grants to identify and rescue trafficking victims.

Cooperative Agreements and Grants

In FY 2003, the OVC began awarding cooperative agreements to nongovernmental organizations to provide trafficking victims with comprehensive or specialized services.1 Comprehensive services are direct services provided by the grantee organization that include:

Specialized services are services such as housing, legal assistance, or medical care that are provided over a broad geographic area.

In FY 2005, the BJA began awarding grants to state and local law enforcement agencies to develop task forces to identify and rescue victims of human trafficking. Details about the task force grants and why they were awarded are contained in Finding 1 of this report. The task forces were usually partnered with an OVC service provider and were required to refer identified trafficking victims to the OVC service provider.

The following table shows the number and dollar value of the OVC agreements and BJA grants awarded from FY 2003 through November 2007 under OJP’s human trafficking program. Appendix II contains a list of the agreements and grants awarded, including the receiving organization, award number, and award amount.

OVC Agreements and BJA Grants for
the Human Trafficking Program Awarded
from FY 2003 through November 2007

Type Award Number
OVC Agreements2 41 $31,706,668
BJA Grants 42 $19,188,219
Total Agreements and Grants 83 $50,894,887
Source: The Office for Victims of Crime and the Bureau of Justice Assistance

As shown in the following map, the OVC victim services agreements and the BJA task force grants are widely distributed throughout the United States and its territories.

Geographical Distribution of OVC Service Provider Agreements and
BJA Task Force Grants Awarded from FY 2003 through FY 2007

[Image Not Available Electronically]

Source: Office for Victims of Crime

Prior Audits

Several previous audits by the Department of Justice Office of the Inspector General (OIG) and the Government Accountability Office (GAO) have reported on the Department’s anti-trafficking efforts. These audits are summarized below.

Office of the Inspector General

From April 2007 through March 2008, the OIG issued audit reports on five cooperative agreements awarded by the OVC to provide services to victims of human trafficking, one audit report on multiple cooperative agreements, and one audit report on a human trafficking task force grant awarded by the BJA. The seven audits identified significant deficiencies in the OVC’s and BJA’s oversight of the grants and the grantees’ use of the funds, such as grantees: (1) not meeting project goals, (2) claiming unallowable and unsupported expenditures, (3) drawing down funds sooner than needed, and (4) not properly monitoring subrecipients. As a result of these and other deficiencies, the OIG questioned $2,914,257 in grant expenditures and recommended $97,686 be put to better use. Finding 2 and Appendix III of this report contain more details about the results of these audits.

Government Accountability Office

In a July 2006 report, the GAO reported on the United States’ international anti-trafficking efforts by examining: (1) estimates of the extent of global trafficking, (2) the government’s strategy for combating the trafficking problem abroad, and (3) the Department of State’s process for evaluating foreign governments’ anti-trafficking efforts.3 The GAO’s findings included the following:

The GAO recommended that the U.S. Secretary of State: (1) improve information on trafficking, (2) develop and implement a strategy that clarifies agencies’ roles and responsibilities and establishes a way to gauge results abroad, and (3) clearly document the rationale and support for country rankings.

In a July 2007 report, the GAO reported on: (1) key activities federal agencies have undertaken to combat human trafficking crimes, (2) federal efforts to coordinate investigations and prosecutions of these crimes, and (3) how the BJA supported federally funded state and local human trafficking task forces.4 The GAO found the following:

However, the GAO reported that officials from the Departments of Justice and Health and Human Services have identified the need to advance and expand U.S. efforts to combat trafficking through more collaborative and proactive strategies to identify trafficking victims.

The GAO also found, with regard to the task force grants awarded by the BJA, that it had awarded grants to 42 state and local human trafficking law enforcement task forces to support U.S. efforts to investigate trafficking in persons. The GAO also noted that the BJA funded the development of a train-the-trainer curriculum and a national conference on human trafficking and took further steps to respond to task force technical assistance needs.

However, the GAO reported that task force members from the seven task forces it contacted and DOJ officials identified continued and additional assistance needs. The GAO also found that the BJA did not have a technical assistance plan for its human trafficking task force grant program. The BJA officials said they were preparing a plan to provide additional and proactive technical assistance to the task forces, but had not received the necessary approvals for the plan as of June 2007.

The GAO recommended that: (1) the Attorney General and the Secretary of Homeland Security, in conjunction with the Secretaries of Labor, State, and other agency heads, develop and implement a strategic framework to coordinate U.S. efforts to investigate and prosecute trafficking in persons; and (2) the Attorney General direct the Director of the BJA to develop and implement a plan to help focus technical assistance on areas of greatest need.

OIG Audit Objectives and Approach

The OIG initiated this audit to: (1) assess the adequacy of OJP’s design and management of the human trafficking grant programs;
(2) evaluate the extent to which grantees have administered the grants in accordance with applicable laws, regulations, guidelines, and terms and conditions of the grant awards; and (3) assess the effectiveness of the grant programs in assisting trafficking victims.

We performed audit work at OJP’s Office for Victims of Crime and the Bureau of Justice Assistance, the Department’s Civil Rights and Criminal Divisions, and at the OVC service providers and associated BJA task forces listed in the following table.

OJP Service Provider Grantees BJA Task Force Grantees
Boat People S.O.S., Inc., Falls Church, Virginia Metropolitan Police Department of the District of Columbia, Washington, D.C.
Coalition to Abolish Slavery and Trafficking, Los Angeles, California City of Los Angeles, California
Heartland Alliance, Chicago, Illinois Chicago, Illinois Police Department

City of Milwaukee, Wisconsin
International Rescue Committee,
Miami, Florida
Collier County, Florida

Miami Dade County, Florida
Mosaic Family Services, Inc., Dallas, Texas Dallas, Texas Police Department

City of Fort Worth, Texas
Refugee Women’s Network, Inc., Decatur, Georgia City of Atlanta, Georgia

Cobb County, Georgia Board of Commissioners
YMCA of the Greater Houston Area, Inc., Houston, Texas Harris County, Texas

To answer the audit objectives, we performed multiple steps that included:

Appendix I contains further details on the audit objectives, scope, and methodology.

This audit report contains three finding sections. The first finding discusses the design and management of the OJP grant programs. The second finding discusses whether grantees administered the grants in accordance with applicable laws, regulations, guidelines, and the terms and conditions of the grant awards. The third finding discusses our assessment of the effectiveness of the grant programs in aiding trafficking victims.

  1. OJP primarily awards cooperative agreements and grants when the principal purpose of the relationship between OJP and the recipient is the transfer of money or anything of value to the eligible recipient to accomplish the public purpose of support as authorized by federal statute. OJP uses a cooperative agreement when substantial involvement is anticipated between OJP and the recipient during performance of the activity funded. When such substantial involvement is not anticipated, OJP uses a grant as the funding instrument. In this report we refer to the recipient of either a cooperative agreement or grant as a grantee.

  2. One of the 41 agreements totaling about $682,000 with the supplement was for training and technical assistance. The other 40 agreements were for services to trafficking victims.

  3. U.S. Government Accountability Office, Human Trafficking: Better Data, Strategy, and Reporting Needed to Enhance U.S. Antitrafficking Efforts Abroad,GAO-06-825 (July 18, 2006), 2-4.

  4. U.S. Government Accountability Office, Human Trafficking: A Strategic Framework Could Help Enhance the Interagency Collaboration Needed to Effectively Combat Trafficking Crimes, GAO-07-915 (July 26, 2007), 3, 5-8.

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