Judgement: European Court of Human Rights failure to adequately protect potential victims of child trafficking in landmark case of VCL and AN v UK

Philippa Southwell, founder of HTMSE and leading modern slavery lawyer represented one of the victims, VCL, in the landmark ECHR case, in relation to victims of human trafficking. Philippa represented VCL in both domestic proceedings and in his application to the European Court of Human Rights in Strasbourg.  

The ECHR judgement finds failure to adequately protect potential victims of child trafficking. Judgement in the case of V.C.L. AND A.N. v. the United Kingdom (applications nos. 77587/12 and 74603/12) was handed down last week held, unanimously, that there had been:  

  • a violation of Article 4 (prohibition of forced labour) of the European Convention on Human Rights, and  
  • a violation of Article 6 § 1 (right to a fair trial).  

This case is likely to have wide reaching impact for victims of human trafficking.   

As part of VCL’s legal team also instructed were Henry Blaxland QCEmma Fitzsimons and Stephen Clark of Garden Court Chambers alongside Michelle Brewer, a former tenant who left Chambers to become a First-Tier Tribunal judge in the Immigration and Asylum Chamber.  Liberty (National Council for Civil Liberties), GRETA (Group of Experts on Action against Trafficking in Human Beings) responsible for monitoring the implementation of the Council of Europe Convention on Action against Trafficking in Human Beings and Anti-Slavery International intervened in this case.   

You can find the full judgement here.  

 

Photo Credit @ Wikimedia Commons

United States: National Human Trafficking Awareness Day

January 11th marked the National Human Trafficking Awareness Day in the US. Designated in 2007, it aims to raise awareness in the United States about human trafficking and modern slavery on national level.

The Human Trafficking and Modern Slavery Expert Directory was established to bring together leading professionals and specialist organisations working in the counter human trafficking and modern slavery sector and provides access to specialists from around the globe, from all different professions and disciplines.

We encourage all professionals, NGOs, charities, businesses, lawyers, medical practitioners, or other experts or specialist organisations not listed in the HTMSE directory to sign up to create a profile here: https://humantraffickingexperts.com/main/signup

Anti-Slavery Day, 18th October 2020

October 18th was the UK’s Anti-Slavery Day, enacted back in 2010 as an Act of Parliament, with the intention to acknowledge and raise awareness for the estimated 40 million victims of modern slavery and human trafficking victims worldwide. Though the UK made strides in the global fight against modern slavery by enacting the Modern Slavery Act 2015, the first of its kind, in 2019, there were over ten thousand potential modern slavery victims identified in the UK alone. Each year Anti-Slavery Day reminds us of the individuals, communities, and even business exposed to the crime of Modern Slavery.

This year, over 50+ NGOs, academics and law firms have signed an open letter directed to the Prime Minister Boris Johnson, calling for better protections and improved immigration policies for survivors of Modern Slavery. The letter highlights the plight of victims in immigration detention centres run in ‘prison-like’ conditions, and the practical disparity whereby more survivors than perpetrators are held ‘behind bars’.

Experts are calling on the UK Government to ‘turn the tide’: by ensuring victims of trafficking do not face punitive immigration control measures and Modern Slavery survivors receive needed support, particularly urging the Government to ensure victims receive support and immigration protection for at least 12 months – in line with the proposed Modern Slavery (Victim Support) Bill. At present, traffickers threats of detention and deportation as a mechanism to control vulnerable whilst victims already struggle to secure protection under the current asylum process as it is ‘notorious for disbelief’.

Several signatories to the letter can be found in the HTMSE Directory which connects modern slavery and human trafficking victims with experts in modern slavery across all areas of practice. We encourage anyone, whether a professional, NGO, charity, business, lawyer, medical practitioner, or other expert or specialist organisation not listed in the HTMSE directory to sign up to create a profile here: https://humantraffickingexperts.com/main/signup

Super-Complaint Against Police Practice in Responding to Modern Slavery

Photo credit: Shutterstock

Amongst specialists, experts and organisations that work towards combatting modern slavery and human trafficking, there is acknowledgement that a weak link in the chain of response is with the initial interaction between victims of slavery and the police. This leads to downstream issues in an effective slavery response as cooperation with the victim is critical to prosecuting the offenders. Modern slavery operations reported by UK police forces raised by 250% in 2018, however only 7% of the recorded cases of modern slavery are reported to the Crown Prosecution Service (CPS). This produces subsequently low numbers of prosecutions for perpetrators of modern slavery within the UK. 

This issue has triggered UK charity Hestia to make the first police super-complaint on modern slavery response. This aims to highlight the harmful patterns in policing seen within the actions of non-specialist police as first responders, and create plans to overcome these barriers. Testimonials from victims of modern slavery, and experts including academic researchers, legal experts, voluntary sector organisations that work in the slavery response, including HTMSE founder and director Philippa Southwell gave evidence during 2018-2019 to the Home Affairs Select Committee on Modern Slavery towards the complaint. This highlights: 

Within the police forces, there is a lack of understanding of modern slavery, human trafficking and exploitation and the process in which they should respond. Officers often fail to recognise the signs of exploitation, and therefore fail to engage with the National Referral Mechanism (NRM) and the duty to notify the Home Office upon identification of a potential victim. 

“There is a duty to notify under the Modern Slavery Act and the police are first responders, but I am not seeing the police making NRM referrals at that initial stage.” Evidence by Philippa Southwell.

Subsequently, as victims are treated as criminals upon their first interaction with the police, they are being alienated by the CJS. They are often treated as immigration offenders, or if they are engaged in crimes which they have been forced to commit by their exploiters they are treated as criminals. Treating victims with this contempt undermines the system by creating barriers for the victim to trust the police or the process in which they are rehabilitated. 

“We are still prosecuting individuals on a daily basis when there are key trafficking indicators. […] If we continue to prosecute victims of forced criminality, we will continue to have low prosecution rates for modern slavery-related cases. Almost all of my clients that have been prosecuted do not want to co-operate with a subsequent or parallel investigation into their exploitation because they feel they are not believed.”  Evidence by Philippa Southwell 

Some of the bad police practice highlighted by Hestia is when police forces fail to adequately investigate cases that come to their attention. If they do pursue investigation, issues in their response often include: 

  • victims feeling like they were not believed by the police officers;
  •  officers prioritising pursuing immigration offences over protecting victims;
  • female victims of sexual exploitation being interviewed by male officers using male interpreters; 
  • and victims not being informed by the police that they had decided to drop the investigation into their exploiters and traffickers.

This exacerbates the potential mistrust of authority caused by the trauma of their exploiters, or the fear that cooperating with police may cause retributions from their exploiters. Further trauma may be caused by their experience in the system, particularly in having to relay information about their exploitation.

“Victims are often criminalised and will be interviewed as suspects under caution. The current College of Policing guidance regarding interrogations of victims involved in forced criminality is inadequate. Police are regularly arresting victims and treating them as suspects first and foremost, even when there are significant trafficking indicators present when arrests are made. In our experience, victims who are treated as suspects and/or defendants at any stage are highly unlikely to cooperate with the authorities as a victim either at that time or at a later stage.” Evidence by Ben Douglas QC, Michelle Brewer (Barrister) and Philippa Southwell (Solicitor Advocate)

Although the Modern Slavery Act 2015 was a landmark forward in tackling modern slavery from a legislatorial standpoint, the message it sends must be carried through the to grass roots actions of policing. Good practice of police depends upon an understanding of the complex trauma that victims have experienced. Creating a safe space to conduct interviews of victims is critical, which allows for the flexibility of individual cases, engaging trusted support workers and the use of neutral and non-judgmental language. There has been advancement in police practice by the operation of specialist modern slavery units, as well as funding for the Modern Slavery Police and Transformation Unit in 2017.  Although some training of police forces exists, it is absent from the ongoing professional development of forces in the UK. Mandatory and effective modern slavery training must be integrated into police practice in order to adequately combat this complex crime. 

Millions more cases of FGM, Child Marriage and Gender Based Violence due to Coronavirus Pandemic

Child marriage constitutes forced marriage, FGM constitutes organ removal, and both acts are considered exploitation under the umbrella of Modern Slavery

By exacerbating existing vulnerabilities and subjecting more potential victims into vulnerable status, Coronavirus has uprooted much progress made towards protecting women’s rights around the world. The United Nations Population Fund (UNFPA) deems 19 medical practices rooted in gender inequality a violation of human rights, including practices such as breast ironing and virginity testing. Their 2020 report Against My Will focuses on female genital mutilation (FGM), child marriage and extreme bias against daughters in favour of sons as three widespread practices that constitute a “silent and endemic crisis“. These acts involve exploitation and fall under the umbrella modern slavery or violate fundamental human rights of female victims. Furthermore, the COVID-19 pandemic has led to an exponential increase in gender based violence and the breakdown of critical sexual health services which deprive women of their reproductive health rights. 

FGM 

FGM involves surgical manipulation of a girls body in a way that diminishes their ability to achieve equal rights as men. It is a targeted act to subjugate and control a woman’s sexuality, thereby violating their right to equality and exposing them to extreme health risks. Despite most countries in the world deeming the practice illegal, FGM is rooted in the choice of a girls family or community, and goes ahead within this private sphere often without the knowledge of the state. This means it usually takes place in unsterile, black market conditions posing higher risk of infection and other complications such as haemorrhage, sepsis and even death. Mental and physiological repercussions include depression, irreversible loss of sexual pleasure and potentially sexual function. UN treaty bodies and international health organisations reject medicalisation of FGM to achieve safer sterile conditions because it would make the health professionals complicit in human rights violations. The UNFPA estimates the Coronavirus led disruption to preventative programs will lead to 2 million more cases of FGM between 2020 – 2030. 

Child Marriage 

Rates of child marriage have begun to rise as a result of the delay to preventative programs and the extreme economic hardship that vulnerable families are are experiencing as a result of the pandemic. UNFPA predicts an additional 13 million child marriages between 2020 – 2030 that could have been prevented by intervention services disrupted by the pandemic. Deepening poverty incentivises parents to marry off their daughters at a young age, to avoid the cost of their living. Although most countries follow the international Child Rights Convention and thereby establish a minimum age of consent between 16 and 21, the majority of countries allow parental consent to override age restrictions of their children to marry. Governments have a duty to end the harm to children, whereby effective laws need to be supported by economic and social restructuring to promote the equal rights and opportunities of vulnerable girls. 

Sex Selection & Reproductive Health Rights 

A preference for boy babies over girl babies leads to prenatal sex selection in favour of boys, or girl babies being neglected in infancy. 140 million females are ‘missing’ in the world population due to extreme bias against daughters in favour of sons, most significantly in China and India. Whilst in some cases this results in direct physical harm to baby girls, this mentality of systemic gender bias manifests in the ongoing issues of female subjugation later in their lives, such as through child marriage or domestic violence.  During the Coronavirus pandemic, there are restricted means to regulate such abuses. Due to overrun health systems, women’s reproductive health rights and sexual health are being neglected in both contexts of the developing world and developed world. The distribution of contraceptives have been severely disrupted due to supply chain issues. UNFPA assessed service disruptions in minimum lockdown cases (of three months) predicting 13 million women being unable to access contraception, leading to 325,000 unintended pregnancies. Malta, for example, has recorded 12 unintended pregnancies per day since lockdown. This in turn, will increase cases of neglect and murder of baby girls, due to an inability to access abortion practices during the pandemic. 

Coronavirus lockdown: Gender based violence 

Coronavirus lockdown posed an unprecedented necessity for families to stay indoors, that has led to increased gender based domestic violence and exploitation. Crisis centres, justice officials and domestic violence hotlines received increased reports during the lockdown period, indicating an increase in total acts of violence, whilst women and girls were forced to stay indoors with their abusers. Increased stresses caused by the pandemic has, and will continue to exacerbate tensions between families, causing violent outbreaks. Furthermore rates of abuse have increased due to disruptions to support programs such as open victim shelters, safe houses and intervention services. UNFPA predicts six months of lockdown would result in up to 31 million additional cases of gender based violence.

2030 Target 

Statistics provided by UNFPA along with partners Avenir Health, Johns Hopkins University (USA) and Victoria University (Australia) estimates the vast human cost of the pandemic in relation to the rights and health of women and girls. The report includes targets for 2030 to gain back the global progress disrupted by Coronavirus, including: keeping girls in school for as long as possible, engaging men and boys in social change, and investment of $3.4 billion per year dedicated to ending FGM and child marriage. This will alleviate the suffering of approximately 84 million young females over the next decade. Along with the necessity for legal obligations around women’s rights and equality, UNFPA stresses the need for a social and cultural shift to prevent these harmful practices going ahead. Raising awareness within communities, empowering women through education and economic opportunities, and providing effective protective services to vulnerable women are essential to addressing this “silent and endemic crisis”, brought about by the Coronavirus pandemic.

UK’s Largest Anti-slavery Prosecution ‘Operation Fort’ Provides Lessons for Business and a Framework to Analyse Compliance to the Modern Slavery Act, June 2020

Operation Fort is the UK’s largest anti-slavery prosecution, with eight members of a Polish criminal gang convicted of slavery, trafficking and money laundering offences on 5th July 2019.

The Independent Anti-Slavery Commissioner report highlights “Operation Fort is important not only because of the number of victims, but also the length of time the criminal gang was able to operate without disruption.” The gang’s activities were traced back to 2012 and continued four years after the Modern Slavery Act was passed in 2015.

The case involved 92 victims aged between 17- 60 who spoke minimal or no English, who were forced to work on farms, in factories, waste recycling plants, warehouses and live in dire conditions in the Birmingham area, although West Midlands PD estimated 400 Polish nationals may have been subject to this exploitation. Operation Fort was a complex case of modern slavery involving many criminal elements, including labour exploitation, human trafficking, fraud, deception, theft and physical abuse.

A key lesson from this case lends to employers and businesses being educated and proactive in spotting the signs of slavery and exploitation, and having effective measures in place to report concerns. There must be particular safeguards in place for temporary workers. Lessons to banks suggest they must proactively look for the signs of slavery within their branches, and also by analysing financial data. Furthermore, recruitment agencies can learn lessons from this case. They have an important role in identifying victims during interview or inductions, carrying out effective checks to detect anomalies, and an ongoing responsibility to check on worker welfare.

“Operation Fort sends a clear warning that no supply chain is safe from worker exploitation. Modern slavery and human trafficking gangs are highly adaptable; organisations must continually evolve to keep pace with entrepreneurial criminality.”

The Independent Anti-Slavery Commissioner provides a maturity framework for business’ compliance to the Modern Slavery Act:

BARELY ACHIEVING COMPLIANCE

  • Superficial modern slavery statement – policy but no action
  • Little or no mapping of supply chains
  • Minimal awareness of modern slavery amongst staff
  • Sole reliance on audits
  • No protocol for dealing with labour abuse 

 

MEETING BASIC EXPECTATIONS

  • Evidence of activity or improvement in modern slavery statement
  • Identifying areas of high-risk in the business and supply chains
  • Educating suppliers on policy and setting expectations
  • Regular staff training and awareness-raising exercises
  • Basic protocols for dealing with labour exploitation cases
  • Installing whistleblowing hotlines

 

EVOLVING GOOD PRACTICE

  • External challenge or working groups informing strategy
  • Going beyond auditing – deep dives and unannounced visits
  • Cascading ethical standards throughout supply chains
  • In-depth training for staff in key roles, such as procurement
  • Commitment to worker engagement
  • Implementing the Employer Pays principle

 

LEADING ON HUMAN RIGHTS INNOVATION

  • Board leading on human rights strategy
  • Using data analytics to identify risk
  • Local, national, international intelligence gathering
  • Supporting suppliers to develop ethical competencies
  • Pioneering new ways of worker engagement, using technology
  • Factoring in the true cost of labour

 

Find the full Independent Anti-Slavery Commissioner report here.

The Continuing Impact of Coronavirus on Human Rights and Modern Slavery

The continuing coronavirus pandemic poses risks to members of society beyond the immediate virus itself. Since governments around the world began introducing new legislation and lockdown procedures to enforce social distancing measures many organisations have highlighted the need to maintain protections for basic human rights, and ensure appropriate safeguards are in place for the some of the most vulnerable in society, such as victims of human trafficking and modern slavery; victims of domestic violence; children at risk of exploitation; and serving prisoners for whom an inability to socially distance may have severe consequences.

Domestically, NGOs and academics have warned many victims of modern slavery and forced labour trapped in exploitative situations will be unable to seek medical assistance or stop working, and many may further actively avoid seeking help for fear of contact with the authorities. Whilst some positive measures have been put in place to aid those impacted by coronavirus and lockdown measures domestically, such as the UK Government’s measures allowing victims of modern slavery to remain in government funded safe-house accommodation for three months, significant concerns continue to be raised for workers in international supply chains. Reductions in international trade have caused thousands of workers to have been left jobless, or facing joblessness, leaving them potentially vulnerable to exploitation and modern slavery. In Cambodia, over 20,000 workers in the garment industry alone faced job losses due to factory closures resulting from a reduction in trade with China, the US and Europe. Similar reports have emerged from other countries, impacting workers across all industries. However, the risks extend beyond becoming trapped in exploitative employment. Loss of income has led some workers and families having to resort to seeking high interest loans in order to survive, leading to many becoming victims of debt bondage; being forced to work to pay off the debt. This has become a particular concern for millions of informal workers in countries such as India, where many workers do not have bank accounts or official paperwork causing difficulties in accessing Government aid.

In addition to concerns for workers across the world becoming extremely vulnerable to modern slavery, forced labour, and other forms of exploitation as a result of losing their job and income, there are substantial concerns for those working in supply chains for high demand items. In particular, manufacturers of personal protective equipment used in medical services, such as rubber gloves, have come under scrutiny for their labour practices; with the conditions of migrant workers in rubber glove factories in Malaysia being described as ‘slave like’. With demand for these items continually rising, human rights organisations have implored governments not to ignore labour conditions and exploitation occurring across global supply chains in their production.

These impacts of the global pandemic may have profound effects beyond the individuals forced into exploitative situations, causing substantial delays in the progress of programmes to improve human rights globally. The UNFPA has conducted an analysis that suggests the economic impact of coronavirus, in conjunction with delays to programmes tackling issues such as FGM and child marriage, could lead to an estimated 13 million child marriages in the next decade, and an additional 2 million cases of FGM above what was previously predicted.

The coronavirus pandemic has increased the risks and vulnerability for many in society and will continue to do so for many years after the initial pandemic itself has ended. In addition to those trapped in violent, abusive, and exploitative situations at home, for many around the world the economic impacts of coronavirus have raised their vulnerability to potentially becoming trapped in bonded labour, forced labour or other forms of modern slavery. The raised demand for certain products, alongside an increased demand for work, has also exposed may factory workers potentially exploitative working conditions, and the impact on global programmes focusing on human rights have been delayed; potentially resulting in millions of additional cases in the coming years. It is vital to ensure that in tackling the global public health crisis much of the positive development in addressing human rights around the world is not undone, and Governments and private sector actors continue to address and improve the situations of society’s most vulnerable individuals.

UK Home Office releases new statutory guidance on the Modern Slavery Act 2015

The Home Office has this week published statutory guidance under section 49(1) of the Modern Slavery Act 2015. The guidance covers indicators of trafficking, support, and the decision making process. The statutory guidance will replace a number of existing documents, namely:

  • Guidance: Duty to Notify the Home Office of potential victim of modern slavery
  • Victims of modern slavery: frontline staff guidance
  • Victims of modern slavery: competent authority guidance
  • Multi-Agency Assurance Panels Guidance

 

The guidance also provides clear and practical explanations on the fundamental definitions of human trafficking and modern slavery under the Modern Slavery Act 2015, providing examples of actions, means employed by offenders, and different forms of exploitation victims may be subjected to, whilst also including a section dispelling commonly held myths about human trafficking and modern slavery; for example, for human trafficking to occur an international border must be crossed. The guidance also provides important information on the distinction between human trafficking and human smuggling (also termed ‘people smuggling), listing a range of factors that might be used to identify the distinctions. More complex cases, surrounding issues such as forced marriages, potential ‘sham’ marriages, and illegal adoption are discussed in the guidance, which indicates how these issues may relate to human trafficking and modern slavery, but also how they may operate as distinct and independent offences.

A link to the full guidance can be found here.

Criminal Exploitation in the Context of Homelessness

Criminal Exploitation, Forced Criminality and Homelessness

Homelessness continues to be a major risk factor for individuals’ becoming victims of human trafficking and modern slavery. HTMSE previously analysed the links between homelessness, human trafficking, and modern slavery, and the critical requirement for ongoing, long term support provisions. Homelessness itself leads to an individual having an increased visibility to potential exploiters and therefore an increased vulnerability to becoming a victim of modern slavery. However, homeless individuals can have a range of complex vulnerabilities beyond their homelessness that may include mental health problems, substance addiction, and physical health problems.

Throughout 2019 there was a marked increase in awareness of homeless individuals being approached at soup kitchens, night shelters, and ‘drop-ins’ where they are deceived with promises of work and income. Specialist Modern Slavery and Homelessness organisations, both governmental and non-governmental, have stated that individuals who are homeless are being specifically targeted for exploitation, which in many cases takes the form of criminal exploitation; where the victims are forced to commit crimes. In the case of victims who are homeless, the modern slavery charity Unseen found that the criminal exploitation is most commonly in the form of forced begging, though their exploitation may also involve being forced to commit theft, deal and/or produce drugs, or a number of other criminal acts. Victims of criminal exploitation may be arrested, charged, and even prosecuted and imprisoned for the crimes they have been forced to commit before being formally identified as victims of modern slavery and/or human trafficking and receiving appropriate support. HTMSE has provided extensive training on this area throughout the UK and world.

Criminal exploitation and forced criminality has been an area that has received substantial attention recently across the counter-trafficking and anti-slavery sectors and mainstream media, most notably in the context of ‘county lines’ drug dealing operations. Increases in awareness and guidance for addressing criminal exploitation across law enforcement, legal and local authority professionals; the prevalence of modern slavery and human trafficking across various industries such as the hospitality industry, and in particular new models in the hospitality sector such as ‘AirBnB’; and the links between homelessness and modern slavery, can all be considered positive shifts towards the development of effective strategies to combat modern slavery and human trafficking across society. However, in the context of homelessness and modern slavery individuals may swiftly become trapped in cycles of exploitation. As discussed in HTMSE’s previous analysis of homelessness and modern slavery, victims of modern slavery and human trafficking are at an increased risk of becoming homeless without appropriate long term support in place, and homeless individuals have an increased vulnerability to potential exploiters.

The circularity of this issue remains a clear demonstration that a comprehensive multi-sector response is needed to effectively tackle these issues.

 

Doorstep Scams, Rogue Traders, Travelling Sales and Modern Slavery

Human Trafficking and Doorstep Scams

Door to door scams and rogue traders have been points of focus recently for their links with modern slavery and human trafficking. However, the links between door to door scams and modern slavery and human trafficking are not new issues. In July 2015 the Polaris Project published a report entitled ‘knocking at your door: Labor Trafficking on Sales Crews‘, exploring the major issues of modern slavery, human trafficking and forced labour in the travelling sales industry. The Polaris Project’s report focused specifically on the US context, but awareness of door to door scams and rogue trader’s links with modern slavery and human trafficking has risen in the United Kingdom too.

 

What are Door to Door Scams and Rogue Traders?

The Neighbour Hood Watch provide a general overview of doorstep scams, including who is likely to be targeted by doorstep scammers and what sort of scams might be involved. They identify typical doorstep scams involving ‘home improvements’, where an individual will knock on the door of their victim, without warning, and explain that their home is in need of improvement works, such as gardening, re-wiring, re-roofing etc, and that this work is extremely urgent. However, more recent incarnations of these traditional scams include installing solar panels, exploitation of internet connections, and the creation of false technical service provider adverts on search engines. Aside from these typical doorstep scams, the Neighbourhood Watch also links apparent doorstep sales pitches with distraction burglary and identity theft.

 

Links to Modern Slavery

Door to door scams of the kind noted above are being increasingly identified as being undertaken by victims of modern slavery. Criminal gangs will target vulnerable individuals who are held by the gang and forced to work for little or no pay, with one reported instance stating that a victim had been forced to work long hours 7 days a week for food and tobacco.  These patterns broadly mirror the findings of the Polaris Project’s 2015 report, which found vulnerable young people in need of employment would be offered the chance to work for a travelling sales company. Once in the ’employ’ of the company the victim would be moved around the country, often under threat of violence and/or abandonment, and forced to work for no wages.

Debt bondage can be a common feature of modern slavery and human trafficking involving doorstep sales, scams and rogue traders. Vulnerable victims are initially offered shelter, food, support, and transport, which gets tallied against them as a debt. Continued reliance on the traffickers for these provisions adds to the debt, as well as failures to meet randomly assigned sales quotas.

The noted increase in victims of modern slavery being used to carry out door to door sales and scams has led to authorities calling for greater vigilance from consumers, both to be careful of new incarnations of old scams, but also of who is the individual apparently carrying them out.