Assessment of Exploitation
0070-535.10 | Revision Date: 7/31/2026

Overview

This policy guide provides staff with an overview of how CSWs are to identify, assess, and document the exploitation of a child.

Table of Contents

Version Summary

This policy guide was updated from the 12/18/24 version, to incorporate a change requested by the Board of Supervisors’ Five-Year Strategic Plan to Prevent and Address Human Trafficking.  The revisions broaden definitions of child trafficking, labor trafficking, and forced criminality, replacing older CSEC‑specific language with more comprehensive, trauma‑informed terminology. It adds expanded indicators of exploitation, including detailed behavioral, environmental, and coercion‑related red flags. New guidance strengthens procedures for CSWs, covering safety planning, interviews, law‑enforcement coordination, medical exams, and services for LGBTQ+ and immigrant youth. The revision also introduces new Special Project Codes with clearer documentation requirements. Several outdated sections were removed or rewritten to align with the County’s strategic plan and current best practices.

POLICY

Human Trafficking

Overview

Children and young people may experience sex trafficking, labor trafficking or both, which can occur in formal or informal settings. Federal law defines human trafficking as the use of force, fraud or coercion to compel a person to engage in commercial sex or labor against their will.

Child trafficking is the human trafficking of minors, specifically. Child trafficking is also known as the Commercial Exploitation of Children (CEC).

Definitions

Commercial Exploitation of Children or Child Trafficking

The Commercial Exploitation of Children (CEC), or Child Trafficking, includes sex trafficking, labor trafficking, and labor trafficking by forced criminality, which are defined below.

The commercial aspect (financial gain) present in human trafficking is critical in distinguishing it from other crimes like sexual assault, molestation, rape, labor violations, or other forms of abuse.

Human trafficking often overlaps with other crimes, as individuals frequently experience other forms of abuse while being trafficked. The Trafficking Victims Protection Act (TVPA) of 2000 (22 U.S.C. 7102) defines " trafficking in persons" as follows:

Sex Trafficking or Commercial Sexual Exploitation of Children

Sex trafficking, also referred to as Commercial Sexual Exploitation (CSE) is the recruitment, harboring, transportation, provision, obtaining, patronizing, or soliciting of a person for the purposes of a commercial sex act, in which the commercial sex act is induced by force, fraud, or coercion, or in which the person induced to perform such an act has not attained 18 years of age (22 USC ? 7102).  This means that any child under the age of 18 who is induced to perform a commercial sex act is considered a victim regardless of the presence of force, fraud, or coercion.

In order to open cases involving trafficking of minors with out-of-home perpetrators, a new Welfare and Institutions Code (WIC) 300 count was created.  WIC 300(b)(4) describes Commercially Sexually Exploited Children as a child who is sexually trafficked or who receives food or shelter in exchange for, or who is paid to perform, sexual acts, and whose parent or guardian failed to, or was unable to protect the child. Although WIC 300(b) counts must meet a threshold finding of negligence (often, an inability to protect), the focus and intent of WIC 300 (b)(4) is not to find wrongdoing on the part of the parent in order to sustain the petition. Parents often do not have control or are unable to stop the victimization of their child, despite their efforts to protect their child from the exploitive situation. WIC 300 (b)(4)’s core element is its requirement that the court find the child has been or is being sexually trafficked.

*A sustained b-4 allegation does not result in a CACI hit for the parent.

Labor Trafficking:

Labor trafficking is the recruitment, harboring, transportation, provision, or obtaining of a person for labor or services, through the use of force, fraud, or coercion for the purposes of subjection to involuntary servitude, peonage, debt bondage, or slavery, (22 USC § 7102)

  • Labor or services can be any type of work, including employment in any legal industry (e.g. restaurant, bars/clubs, agriculture, construction, factories/manufacturing, construction, hotels), informal services (e.g. babysitting, elder care and housekeeping) or even illegal acts (e.g., drug cultivation or drug sales).

Child labor trafficking may involve serious physical harm or a substantial risk of serious physical harm to a child resulting from the failure or inability of the parent or guardian to adequately supervise or protect the child, which may be grounds for the child to be removed from the home and/or come under the jurisdiction of the juvenile court (Welfare and Institutions Code section 300(b)(1)) California Code, WIC 300. This may include children who were labor trafficked by a parent or guardian.

  • Not all child labor constitutes labor exploitation or trafficking. The California Department of Labor Relations Division of Labor Standards Enforcement has published California Labor Laws (2013), which provides additional information about the State’s child labor protections and what can constitute legal work for a minor under the age of 18 years.

 

Examples of Sex Trafficking/Sexual Exploitation:

  • Street exploitation
  • Arranging exchange of sex acts on the internet/social media
  • Production and/or sales and/or trade of sexually explicit images or videos
  • Advertising a minor for sexual purposes

Indicators Associated with Child Sex Trafficking

Identifying the signs or indicators that a child may be a victim of sex trafficking is crucial for intervention and support.  While not all children who exhibit certain behaviors or indicators are trafficking victims, there are indicators that may suggest a potential risk or involvement in sex trafficking.  An analysis of the investigative findings, collateral information, and identification of indicators often associated with child sex trafficking should be included when determining whether or not sex trafficking has more than likely occurred.  Indicators associated with child sex trafficking include:

  • Running away from home; leaving care
  • Spends time in areas associated with commercial sexual exploitation
  • Tattoos or branding (i.e., diamonds, money signs, crowns, rose, moniker of exploiter)
  • Romantic/inappropriate relationships with adults or older adults
  • Evidence of controlling or dominating relationships
  • Secrecy regarding intimate partners, friends, and associates
  • Protective of suspected exploiter
  • Homelessness, couch surfing
  • Exchanging sex for anything of value (i.e., food, clothing, shelter, drugs)
  • Truant from school
  • Unexplained travel; non-consensual travel
  • Unexplained shopping trips, hair/nail salon services, or possession of expensive clothing, jewelry, items that the child could not normally afford
  • Clothing inappropriate for age, weather, or context
  • Unaccounted for time, vagueness concerning whereabouts, and/or defensiveness
  • Possession of multiple cell phones
  • Visible signs of abuse, such as unexplained bruises, black eyes, cuts or marks
  • Exhibit “hyper-vigilance” or paranoid behavior, especially when it comes to access of their phones
  • Someone else controls their money or collects their earnings
  • Use of lingo or slang referencing exploitation (i.e., “the life”, “renegade”, the “track/blade” (streets where exploitation occurs), “out of pocket”, “trick”, referring to a boyfriend as “Daddy”)
  • Ties to gangs, drugs, or criminal activities (especially at younger ages)
  • Sudden onset or increase in substance use
  • Personal information such as age, name, and/or date of birth might change with each telling of his or her story, or the information given might contradict itself
  • Secrecy about whereabouts
  • Recurring health issues, including Sexually Transmitted Infections (STIs), Urinary Tract Infections (UTIs), and/or other urologic/reproductive diseases
  • Multiple pregnancies or abortions
  • May be advertised or monitored by traffickers online
  • Sexually explicit images, videos, or text posted online or exchanged via messaging apps
  • Media posts including references to “daddy” or “king” or “trident emoji”, “304”
  • If youth frequently mentions posting online (youth often use websites such as, Backpage Pro, Only Fans, Mega Personals, or the youth is featured on a Soft White Underbelly video

Labor Trafficking by Forced Criminality

Involving a child in criminal behavior, whereby the third-party profits from the child’s involvement in performing an illegal act on the third party’s behalf. The child who is forced to commit crimes in the course of their trafficking may be forced to commit crimes including, but not limited to, theft, terrorism, murder, illicit drug production, drug sales, drug transport, fraud/scams, or other activities required by a gang, criminal organization, parent or guardian or other third party. In CWS/CMS, (under a subcategory under the allegation of Exploitation) this is called “Involving Child in Criminal Behavior”. A victim of Labor Trafficking by Forced Criminality may be forced to recruit, advertise, monitor, or coach another individual to engage in commercial sex acts. In instances of forced criminality, the child is a victim of a crime, rather than a perpetrator of the crime, since they are under the coercion or control of a trafficker.

Child labor trafficking by forced criminality may involve serious physical harm or a substantial risk of serious physical harm to a child resulting from the failure or inability of the parent or guardian to adequately supervise or protect the child, which may be grounds for the child to be removed from the home and/or come under the jurisdiction of the juvenile court (Welfare and Institutions Code section 300(b)(1)) California Code, WIC 300. This may include children who were labor trafficked by forced criminality by a parent or guardian.

Indicators Associated with Child Labor Trafficking/Labor Trafficking by Forced Criminality

  • Cannot move freely, not allowed to come and go at will.
  • Living with or accompanied by people who are not their parents or guardians or whom their relationship is unclear.
  • Someone else speaks for them.
  • Not permitted to use phone or other communications, especially if restricted from contacting family.
  • Someone may control their transportation.
  • Unsure of day, date, month or year as developmentally appropriate.
  • Frequent moves or uncertainty of address.
  • Unusual living/workspace (i.e. tinted windows, security cameras, barbed wire, sleeping/living at worksite).
  • Wears the same clothes daily or routinely wears clothes inappropriate for the weather conditions.
  • Not in control of personal identification
  • Someone else controls their money or collects their earnings from work
  • Explanation of work situation doesn’t make sense; seems scripted
  • Fearful of employer (may be formal employer or family member, boyfriend/girlfriend)
  • Long work hours; exhausted; hungry
  • Missing school because they have to “work”
  • Owes a debt to employer (may be family member)
  • Shows other signs of abuse or neglect
  • Arrested or criminal history for crimes such as stealing or drug sales
  • Money goes to third party
  • Unattended at night
  • Ties to gangs, drugs or previous criminal activity
  • Multiple cell phones and/or social media accounts under different names
  • Unexplained cash, gifts, or virtual payments

Co-occurrence of Both Sex and Labor Trafficking

Sex trafficking (CSE) and labor trafficking can also occur at the same time. A child may be forced to provide commercial sexual services while also being made to do other tasks, such as working as a masseuse, performing domestic chores, or engaging in illegal activities like growing, selling, or transporting drugs.

Commonly understood rules of consent do not always apply in this context. For example, if the youth is asked whether anyone forced them to engage in sexual activity or perform a labor/service for someone else's profit (particularly if it was illegal), they may say no, because the youth felt like an active participant in the exchange or they state they consented to their participation, even though youth under 18 are not able to legally consent to commercial sex. Trafficked youth may say that they consented due to fear of getting in trouble with the law, with the trafficker, or because they believed they “did what they had to do” to survive. Instead, it may be more informative to ask about the facts of the labor or service performed and make an independent assessment of whether force, fraud, or coercion was used. The following questions could help determine if consent was violated: 1) What happens if the youth ever refused or was unable to work? 2) Has anyone ever threatened or implied consequences of their refusal/ failure to work? 3) How much are they paid/ promised for their work?

  • Due to poverty or financial strain, some youth have no other option than to work to support their basic needs and/or support family members and feel the only way to support themselves or their families is to work, even if they can only do so illegally. Families may be struggling to survive and struggle with meeting the basic needs due to living in poverty; however, poverty alone cannot be the basis for a finding of neglect (WIC 300(b)(2)(C). To address needs related to poverty, link to concrete services (i.e., housing/shelter, food sources, work opportunities) and community-based supports to address the needs and services that should be provided.

At Risk Youth

  • Early identification of at-risk youth is important so that early interventions can be provided to divert youth from becoming a victim of child trafficking. If a youth has been identified as “at-risk”, consider referring the child/youth to Advocacy Services for Youth Impacted by Commercial Exploitation (enter link here to FYI: Advocacy Services), along with other prevention efforts (i.e., education and awareness on Child Trafficking, relational health, healthy boundaries, sexual health, self-worth/self-advocacy, mental health and well-being, and building protective factors that mitigate risk factors associated with human trafficking). Victims of one form of trafficking (sex or labor) are, by definition, at risk of the other form of trafficking since they are under the control of a trafficker.

At-Risk for Commercial Sexual Exploitation

Per Social Security Act § 471(a)(9)(C)(i)(I), WIC § 16501.35, & WIC § 16501.45s: County child welfare agencies are responsible for identifying youth who may be at risk of exploitation. The indicators listed below are intended to serve as a guide to support the identification of at-risk youth and should be considered alongside professional judgement and individual assessment.

The child/youth displays at least one of the following indicators:

  1. Exhibits behaviors or otherwise indicates that they are being controlled or groomed by another person.
  2. Spends time with people known to be involved in commercial sex.
  3. Use of internet, cell phone, or social media involves social or sexual behavior that is atypical for their age.

Or

The child/youth displays a minimum of two of the following indicators:

  1. Has a history of running away, unstable housing, including multiple foster care placements, or periods of homelessness including couch surfing.
  2. Has had prior involvement with law enforcement or the juvenile justice system.
  3. Is frequently truant.
  4. Has relationships that are concerning (controlling, older adult), placing them at risk or in danger of exploitation.
  5. Has a history of substance abuse, specifically narcotics, opiates, crack/cocaine and amphetamines.

Youth At-Risk of Child Labor Trafficking

While there is not a legal definition for a youth that is defined as "at risk" for child labor trafficking, similar criteria listed in the above definition could be applied. Specific factors may include vulnerabilities such as poverty, homelessness, criminal record, young age, disabilities, and an unstable family environment, history of Adverse Childhood Experiences (ACES), immigration status, chemical dependency, sexual orientation, gender identity, gender expression and racial or ethnic marginalization. If a child or youth is at risk for CSEC they have an increased risk of experiencing child labor trafficking.

Exploiters/Traffickers

Exploiters/traffickers may be family members, parents, caregivers, intimate partners, gang members, drug dealers, smugglers, a criminal organization, landlords, employers, or third parties, not known at the time of the investigation.    

Victims and traffickers can come from any background, race, gender, gender expression, sexual orientation, or economic status. Traffickers target individuals who are vulnerable, such as those living in poverty, runaway or homeless youth, those with criminal records, young people, individuals with disabilities, those from unstable family situations, immigrants, people struggling with substance use, or those who face discrimination based on race, ethnicity, gender identity, gender expression, sexual orientation, or other aspects of identity.  A child or youth can be a primary victim or a secondary victim. For example, if they are in the care of a parent or guardian who is being trafficked, the child/youth can be a secondary victim. 

Types of practices exploiters/traffickers use to victimize:

  • Force: involves physically restraining or harming a victim (assault, beatings, confinement).
  • Fraud: deceives victims about aspects of their lives, education, or employment including job duties, work conditions, and payment. Fraud includes promises of a good job, shelter, and a better life. For example, youth may be promised the ability to enroll in or attend school but then are never enrolled. Fraud may also include promises of love or companionship.
  • Coercion: may include threats of violence to the victim or loved ones; psychological abuse, real or threatened abuse of the legal system (i.e., threatening youth with deportation, falsely offering legal status or threatening to call immigration, child welfare, or the police), withholding pay or necessities, or any plan or scheme that causes someone to continue working for their trafficker. California law specifically includes holding someone’s identification/ legal documents or facilitating drug use or drug dependency as a means of coercion.

Interviewing a victim of child trafficking requires sensitivity, care, and techniques to ensure the safety and comfort of the youth being interviewed. Building rapport and trust, asking questions to identify their needs, and understanding trauma’s impact on children are all key to engaging youth during conversation.

Please refer to the following link for guidance regarding Recommended Interviewing Techniques and Interview Questions for Youth.

Interviewing Questions for Parents and Caregivers

Begin the conversation regarding Commercial Exploitation (CE) with parents/ caregivers in broad terms in order to ease into the questions. Share with parents/caregivers that CE, or child trafficking, is unfortunately a problem in Los Angeles County and that in fact, L.A. County is deemed one of the areas in our nation with the highest levels of CE. Explain the definition of sex and labor trafficking and provide examples to the parent/caregiver. Offer empathy and support, letting them know that parents/caregivers who have children that are being trafficked may experience a range of emotions--denial, anger, depression, hopelessness, shame, confusion, etc. Share with the parent(s)/caregivers that there is support available to parents/caregivers and youth impacted by Commercial Exploitation to assist them. Explain that you would like to ask them some questions to assess whether or not their child may be a victim of CE. Let them know that answering the questions may be difficult, but to please try and provide as much information as possible to help with the assessment in order for their child to receive the support that is needed. Be mindful and respectful of familial customs and demonstrate cultural humility.

Please refer to the following link for guidance regarding Recommended Interviewing Techniques and Interview Questions for Parents/caregivers.

Collateral Contacts

CSWs are to make necessary collateral contact with people having knowledge of the condition of the children that will help in understanding the nature and extent of the exploitation and in the ongoing assessment of the risk to, and safety of, the child. Residents within the family home should be interviewed, (but are not to be solely considered as collaterals) in the disposition of a referral or to assess for safety as part of ongoing case management.  Collateral contacts include:

  • Law Enforcement from specialized Vice and Human Trafficking units should be consulted to determine whether the crime of trafficking has occurred
  • Placement Providers
  • School
  • Medical Professional
  • Transitional Shelter Care staff
  • Prior CSWs
  • Service providers that have served the youth/family, including the LGBTQ+ Program
  • DREAM Unit (Specialized unit that provides services to child trafficking victims)
  • Runaway Outreach Unit (ROU) Unit
  • Immigration Unit

Investigative Areas to Address

  • Is there a known or suspected trafficker/exploiter?
  • Where has the exploitation occurred?
  • Is the suspected perpetrator a parent, relative, or non-relative?
  • Has the youth presented with any mental health symptoms, gang affiliation or dangerous behavior?
  • Does the child have any outstanding warrants? Warrants in other jurisdictions?
  • Are they entered into the National Crime Information Center (NCIC) and the National Center for Missing and Exploited Children (NCMEC)?
  • Does the child have any AKAs or monikers?
  • Are the parent(s) identities and whereabouts known?
  • Do the parents have knowledge of the exploitation?
  • What have the parents done to prevent or stop exploitation?
  • Was the youth observed with any unusual clothing items or visible tattoos?
  • Has the child experienced any other form(s) of maltreatment? (Sexual Abuse; Physical Abuse; General Neglect; Emotional Abuse; Severe Neglect)
  • Exploitation is constantly evolving, and exploiters are regularly changing tactics to avoid detection, so it is important that workers receive regular training and seek out updated information.

Determining Disposition

Determining Disposition--Commercial Sexual Exploitation

If investigative findings and collateral information indicate that an allegation of commercial exploitation likely occurred (prima facie), it can be substantiated, regardless of the following:

  • The youth denied any involvement of a trafficker/exploiter.
  • The youth denied that exploitation occurred.
  • The youth does not disclose identification or the name of perpetrator.
  • The parent or legal guardian made reasonable efforts to protect the child and/or prevent the exploitation.
  • The family does not require additional DCFS or dependency court intervention.

Determining Disposition – Labor Trafficking/Labor Trafficking by Forced Criminality

If investigative findings and collateral information indicate that an allegation of labor trafficking (Exploiting a Child’s Labor) or an allegation of labor trafficking by forced criminality (Involving a Child in Criminal Behavior) likely occurred (prima facie), it can be substantiated if the following has occurred:

There is serious physical harm or a substantial risk of serious physical harm to a child resulting from at least one of the following:
  1. The parent/caregiver is the perpetrator of labor trafficking/labor trafficking by forced criminality, or
  2. The child involved in labor trafficking/labor trafficking by forced criminality has no parent or caregiver willing or able to provide care (caretaker absence), or
  3. The parent has knowledge or reasonable knowledge of the trafficking and has failed to protect.

Meeting the Needs of Children and Youth Impacted by Commercial Exploitation

To be effective, interventions and services must be trauma-informed, victim-centered, strengths-based, culturally responsive, inclusive, and developmentally appropriate, while recognizing and respecting diverse identities, backgrounds and lived experiences.

It is important to recognize that most children will not follow a linear path from initial identification to leaving their exploitative relationship or situation. Children who experience commercial exploitation will often cycle through the stages of exploitation many times before they are able to maintain a life outside of exploitation. Each child's needs will differ depending on a variety of factors, including, but not limited to:

  • Prior abuse and/or neglect
  • Mode of exploitation
  • Stage of exploitation
  • Stage of change (based on the Stages of Change Model)
  • Developmental age
  • Chronological age
  • Learning differences or cognitive abilities
  • Relationship with exploiter(s)
  • Attachments and community support system
  • Familial connections
  • Pregnancy or parenting status
  • Housing status
  • Immigration status
  • Alcohol/drug abuse or other types of addiction
  • Sexual orientation, gender identity, and gender expression (SOGIE)
  • Socioeconomic status

A wide array of services and flexible and intensive case management services should be provided as needed, including:

  • Emergency Crisis Response and Safety Planning
  • Food, clothing, shelter
  • CSEC Medical Clearance and CSEC Initial Medical Examination by Medical HUB provider
  • Multi-Disciplinary Approach to assessment, planning, and intervention
  • Advocacy Services
  • Safe means of transportation
  • Dental care, medical care, and/or medication regimen and follow up care
  • Tattoo removal
  • Therapeutic support by a trauma-informed therapist and/or other mental health professionals with understanding of CSEC and/or child labor trafficking
  • Intensive mental health services
  • Psychiatric Services
  • Sexual and Reproductive Health Assessment and Counseling
  • Substance abuse assessment, intervention and treatment
  • Physical therapy
  • Occupational therapy
  • LGBTQ+ affirming medical and mental health services
  • Screening/intervention for eating disorders
  • Screening/intervention for self-harming behaviors
  • CSEC and/or trauma-informed foster care placement providers that receive support in caring for the critical needs of the trafficked youth
  • Transitional housing and services
  • Vocational and Life Skills
  • Victims of Crime
  • Restoration Funds (only if they are in Dream court) (add link to Restoration Funds forms)
  • General education advocacy
  • Special Education assessment and advocacy
  • Empowerment events and activities
  • Additional extra-curricular activities to assist in building self-esteem and stress relief
  • Referral to the Special Immigration Status Unit

Required Documentation of Commercial Exploitation in CWS/CMS

Commercial Sexual Exploitation of Children (CSEC) is documented in unique places within CWS-CMS. The following document provides screenshots and step-by-step recommendations for completing CSEC documentation within CWS/CMS.

Documentation of Sexual Exploitation of Children/Youth in SDM

Sexual exploitation would fall under SDM Safety Threat #2:

  1. Child sexual abuse or sexual exploitation is suspected, AND circumstances suggest that the child's safety may be of immediate concern. The child’s safety may be of immediate concern if:
    • There is no non-offending caregiver, or the non-offending caregiver is not protective (blaming the child for sexual abuse or the investigation or denying that the sexual abuse occurred) or is otherwise influencing or coercing the child victim regarding disclosure; or
    • Continued access to a child by a confirmed sexual abuse perpetrator or trafficker, especially with known restrictions regarding any child under age 18, exists.

Sexual Abuse

Suspicion of sexual abuse may be based on indicators such as:

  • The child discloses sexual abuse verbally.
  • The child displays behaviors that strongly indicate sexual abuse (e.g., excessive, age-inappropriate sexualized behavior toward self or others).
  • Medical findings consistent with sexual abuse or molestation.
  • The caregiver or others in the household have been convicted, investigated, or accused of rape or sodomy, or have had other sexual contact with the child.

CSWs can refer to the online Safety Assessment definitions.

Children Who May Disproportionately Experience Trafficking

Although trafficking can affect any child, those who have endured historical trauma, experienced a history of abuse or neglect, lack stable support networks, or belong to economically and socially marginalized communities may face an elevated risk. Children in out-of-home care, those grappling with housing instability or poverty, those who have experienced injustices and systemic inequalities, and newcomers to the United States (including unaccompanied children) may also have additional needs to address. Traffickers focusing on children are keenly aware of and capitalize on children’s unmet basic physical and emotional needs. Children who may be disproportionately impacted by trafficking include children in or aging out of foster care, children experiencing homelessness or missing from foster care, American Indian, Alaska Native, and Indigenous Children, and lesbian, gay, bisexual, transgender, queer, or questioning (LGBTQ+) youth.

LGBTQ+ youth face higher rates of family rejection, discrimination, violence, and economic instability than their non-LGBTQ+ peers. Without adequate support, LGBTQ+ youth are at particular risk for sex trafficking. When faced with fewer resources, employment opportunities, and social supports, LGBTQ+ youth may engage in survival sex to meet their basic needs. Traffickers may seek to exploit their vulnerabilities and compel them into commercial sex by offering them a sense of family, protection, and belonging. This bond may complicate the youth's understanding of their victimization and prevent them from speaking out against their trafficker.”

LGBTQ+ youth may have additional fears or barriers to accessing anti-trafficking services because they are unaware of services in their area, the community lacks affirming resources (e.g. bed space, funding), or they are concerned that providers are not LGBTQ+ friendly.

Special Considerations for Immigrant Children and Youth

Contact the DCFS Special Immigrant Status Unit at sisuib@dcfs.lacounty.gov and confer with county counsel when working with trafficking identified youth/ families in order to assist with all legal standing issues.

If you are working with a foreign national minor (non-US citizen/ legal permanent resident and currently under 18 years old) and have concerns that they may have experienced CSEC and/or labor trafficking at any point in their life, be aware they are eligible for additional benefits and services under the Trafficking Victims Protection Act.  Make sure to assess if:

  1. Fleeing trafficking from their country of origin
  2. If trafficking happened in route to the United States and
  3. If trafficking occurred at any point they were in the United Sates.

Federal, state, and local officials are required to notify the Office on Trafficking in Persons (OTIP) within 24 hours of a suspected trafficking case to facilitate local assistance. The following steps must be completed to make a mandated report in compliance with 22 USC 7105.  This should be done upon "suspicion," you should not wait until the case is confirmed.  The CSW should submit a Request for Assistance (RFA) through the Shepherd Case Management System at https://www.acf.hhs.gov/otip/victim-assistance/shepherd.   

It is the policy of the Office on Trafficking in Persons (OTIP), as a federal agency providing access to direct services for immigrant victims of trafficking, not to share information with other federal departments, including immigration authorities. However, Los Angeles County maintains that only the minimal information necessary should be included in reporting—particularly when disclosing a youth’s criminal activity, such as gang affiliation or involvement in drug sales or cultivation. This approach is intended to ensure that such unnecessary details do not create adverse consequences for a youth’s immigration case.

CSWs shall confer with County Counsel and the DCFS Special Immigrant Status Unit to address barriers and challenges that arise when children lack legal status, ensuring their rights and well-being are protected. CSW should also review with the child their right to safety and discuss safety planning to educate and empower the child to seek help in unsafe situations.

If you want to discuss the case with the OTIP Child Protection Specialists before submitting the RFA, after conferring with County Counsel, you can call them during normal business hours (9:00 am to 5:00 pm ET) at (202) 205-4582 to make the initial report. They will respond within one business day. You can also reach them at ChildTrafficking@acf.hhs.gov.  The worker should save a copy of any RFA submitted to OTIP, so that the information can later be provided to the youth’s immigration attorney.    

It is important to follow all policy and procedure when working with clients who do not speak English as their native language.

Resources:

DCFS Child Trafficking Resource Guide – List of local providers in L.A. County who provide services to victims of human trafficking

National Human Trafficking Hotlines’ Referral Directory

NCMEC’s Resources for Parents, Educators, and Communities

Preventing and Addressing Child Trafficking (PACT) Resources

Coalition to Abolish Slavery and Trafficking Human Trafficking Training Opportunities

PROCEDURE

Assessing Alleged Commercial Sexual Exploitation

CPH CSW Responsibilities

  1. Conduct an initial assessment of the reported concerns to determine whether or not the details provided by the reporter constitute a report of alleged child abuse or neglect.
    • If the details require a report of alleged child abuse or neglect, conduct an initial assessment of the allegations and complete the ER Protocol.
    • Elicit all pertinent information known to the reporter that would enable you to accurately answer the questions contained in the SDM Hotline Tool screening criteria and arrive at a response decision.
    • When the indicated response decision is for an in-person investigation, ensure that you have asked the caller sufficient questions that allow you to accurately answer questions contained in the SDM Hotline Tool response priority decision trees and arrive at an appropriate response determination.
    • If upon completion of the ER protocol, it is determined that an in-person investigation is not required, evaluate out the referral with or without a referral to another community agency, as appropriate. 
    • If the allegations are cross-reportable:
      • Determine which law enforcement agency has jurisdiction over the child abuse incident.
      • Create a SCAR and cross-report to that agency per existing procedures.

ER/Continuing Services CSW Responsibilities

  1. Assess for potential indicators associated with the Commercial Sexual Exploitation through interviews, observations, collateral contacts, review of referral/case documentation and other pertinent sources of information.
  2. Conduct social media and the internet searches through designated staff for online accounts, if known.
    • Web-based search engines and social media platforms can be searched with the child/youth's name, nicknames, and phone numbers to identify additional accounts and evidence of exploitation.
  3. Call the Child Protection Hotline if you suspect that a child is a victim of Commercial Sexual Exploitation. All new and repeated incidents of CSE must be reported to the CPHL.
  4. Refer youth as needed for a CSEC Medical Clearance and a CSEC Initial Medical Examination per policy.
  5. If there is no information regarding law enforcement being involved with the allegations, contact law enforcement as soon as possible. Law enforcement partners from specialized Vice or Human Trafficking units should be consulted when trying to determine whether an incident of commercial sexual exploitation occurred. Determine if a Detective is assigned or will be assigned to investigate. Document the Detective’s name and contact information in CWS/CMS in Contacts and in the Case Alerts field on the Case ID Page
  6. If minor consents, refer youth and non-minor dependents who are victims of commercial sexual exploitation to Advocacy Services for Youth Impacted by Commercial Exploitation. Advocacy Services includes parent/caregiver support through the Parent Empowerment Program (a (10) ten-week psycho-education and support group).
  7. Determine if the following situation exists:
    • The child is determined to fall under WIC 300 (b)(4) and exhibits a combination of potential indicators that the child may be a victim of sex trafficking.
    • If investigative findings and collateral information indicate that an allegation of commercial exploitation likely occurred (prima facie), it can be substantiated, regardless of the following: 1) The youth denied any involvement of a trafficker/exploiter; 2) The youth denied that exploitation occurred; 3) The name/identification of the perpetrator is unknown; 4) The parent or legal guardian made reasonable efforts to protect the child and/or prevent the exploitation; and 5) The family does not require additional DCFS or dependency court intervention.
    • If the youth denies being exploited, the youth and family should still be offered Advocacy Services agencies who understand the Stages of Change Model, are CSEC and trauma-informed, and able to apply a Harm Reduction Approach
  8. Enter required documentation on CWS/CMS: Disposition of Exploitation Allegation, General Neglect (Failure/Unable to protect child from commercial sexual exploitation, if applicable) and document children/youth who are at-risk or victims of CSEC on the CSEC Data Grid.
  9. As the CSW is working to assess a youth for trafficking it is important to ensure that they are referred to appropriate services once concerns for trafficking have been identified.  The following are steps to follow:
    1. Refer youth for CSEC Medical/forensic Examination per policy. The Hubs are equipped to provide gender affirming medical care for LGBTQ+ children.
    2. Ensure communication between Emergency Response and the Continuing Services CSW (if there is one assigned) during a new investigation to develop a safety plan and stabilize youth.
    3. Develop a safety plan with the child with ways to seek safety if they leave care and phone numbers that they can call if in danger
    4. Submit a new Child and Adolescent Needs and Strengths (CANS) Assessment as needed, per the Screening and Assessing Children for Mental Health Services and Referring to the Coordinated Services Action Team (CSAT)
    5. Schedule a Multidisciplinary Team Meeting or CFT; include DMH, DPH, Probation and Substance Abuse provider as required, per SB 855 mandate
    6. Refer youth as appropriate to LGBTQIA+ Advocacy Services if the minor consents to receiving services
    7. Determine if the case should be transferred to DREAM Court. Note: youth who are at risk may also qualify for cases to be transferred to Dream Court.
    8. Per the Missing or Absent from Care Children/Nonminor Dependents policy: If child is missing from home or absent from care, direct the caregiver to make a Missing Person Report to law enforcement. Under no circumstance should contact with law enforcement be delayed more than twenty-four (24) hours. Direct the caregiver to obtain the report number and name of the Law Enforcement Agency that took the report. If the caregiver refuses to complete a report, it is the responsibility of the worker to ensure one is completed. If the youth is a NMD and the circumstances of their disappearance warrant such action, the CSW is to file a Missing Person Report with law enforcement, obtain the report number and document the information in the Contact Notebook. Circumstances warrant this action if the NMD has been reasonably determined to be in fact missing from care, there are competency issues, or there is a reasonable suspicion that the NMD is a victim of harm or foul play.
    9. If the youth is undocumented, contact the DCFS Special Immigrant Status Unit sisuib@dcfs.lacounty.gov to discuss services and a referral to OTIP for assessment within 24 hours.
    10. Document all contacts and observations.

Assessing Allegation of ‘Exploiting a Child’s Labor’

ER/Continuing Services CSW Responsibilities

  1. Assess for the presence of potential indicators associated with Child Labor Trafficking through interviews, observations, collateral contacts, review of referral/case documentation and other pertinent sources of information.
  2. Conduct social media and the internet searches through designated staff for online accounts.
    • Web-based search engines and social media platforms can be searched with the child/youth's name, nicknames, and phone numbers to identify additional accounts and evidence of exploitation.
  3. Call the Child Protection Hotline if you suspect that a child is a victim of Child Labor Trafficking.  All new and repeated incidents of Child Labor Trafficking should be reported to the CPH.
  4. Refer youth as needed for a Medical Examination to address any illness or injuries sustained as a result of Child Labor Trafficking and other forms of abuse. If there is a nexus with commercial sexual exploitation or sexual abuse is used as a method of control, refer youth for a CSEC Medical Examination.
  5. If there is no law enforcement involved with the investigation, contact law enforcement if there are concerns that a child is a victim of Child Labor Trafficking. Law enforcement partners from specialized Vice and Human Trafficking should be consulted when trying to determine whether an incident of labor trafficking occurred.
  6. If minor consents, refer youth and non-minor dependents who are victims of Child Labor Trafficking to Advocacy Services for Youth Impacted by Commercial Exploitation.
  7. Determine if the following situation exists:
    1. Potential indicators for Child Labor Trafficking are present and the child falls under WIC 300 (b)(1) due to serious physical harm or a substantial risk of serious physical harm to a child resulting from the failure or inability of the parent or guardian to adequately supervise or protect the child. This may include children who are labor trafficked by a parent or guardian.
    2. It is important to always assess for the risk and safety of the child.  Even if labor trafficking is not able to be determined, the child may still be at risk for abuse or neglect.
    3. At this time there is no specific WIC 300 code for Labor Trafficking, in order to assess a child/ youth’s safety if they are being trafficked; utilize the following in your assessment and be sure to consult with your supervisor and county counsel if the situation rises to the level of a Court petition.
      • If the child is being induced to work through force, fraud, and/or coercion.
      • How the child's education is affected by working.
      • Whether the conditions of employment are detrimental to the child's mental health, physical health and safety.
      • Whether the working conditions have led to injuries, chronic health issues, and/or malnutrition.
      • Whether the working conditions have led to mental health issues such as depression, anxiety, PTSD, and/or other emotional disturbances.
      • Whether other forms of abuse by the exploiter(s) against the child are present
      • The legality of the specific job as it applies to the child's age, abilities and certified training.
      • If a debt exists that the child or family feel they must repay.
      • If a third party receives the money earned.
      • Regarding a child who is working in a home or a domestic situation (performing duties such as cleaning, childcare/elder care, laundry) determine:
        • Whether the assigned tasks are safe and developmentally appropriate.
        • If the tasks are equally divided among all the children in the household in accordance with each child's age and developmental ability.
      • If suitable parental supervision is provided.
      • If the parent is the primary person who sustains the household.
      • The number of hours spent working in the home each day.
      • If the household work interferes with school or age-appropriate outside activities.
      • If the youth has experienced any actual or threatened physical harm for failing to perform or complete the work or for failing to complete the work to a certain standard.
      • If the youth has been threatened with significant negative consequences (e.g. report to immigration or law enforcement, being kicked out of the home) if they fail to perform the work.
      • If investigative findings and collateral information indicate that  Child Labor Trafficking likely occurred and there is serious physical harm or a substantial risk of serious physical harm to the child because the parent or guardian is unable to adequately supervise or protect the child, the child falls under WIC 300 (b)(1) and may be grounds for the child to be removed from the home and/or come under the jurisdiction of the juvenile court.  This may include children who were labor trafficked by a parent or guardian
  8. Enter required documentation on CWS/CMS: Disposition of Exploitation Allegation, Sub-category: Exploiting a Child’s Labor; Disposition of General Neglect; and select Special Project Code “S-Labor Traf Expl Child Labor” in case notebook to indicate child is a victim of Child Labor Trafficking or select Special Project Code “S-Labor Traf EL / IC Concern” in case notebook to identify a child who is at-risk for labor trafficking.
  9. As the CSW is working to assess a youth for trafficking it is important to ensure that they are referred to appropriate services once concerns for trafficking have been identified.  The following are steps to follow:
    1. Ensure communication between Emergency Response and the Continuing Services CSW (if there is one assigned) during a new investigation to develop a safety plan and stabilize youth.
    2. Develop a safety plan with the child with ways to seek safety, mitigate the risk of harm, and phone numbers that they can call if in danger.
    3. Submit a new Mental Health Screening Tool as needed, per the Screening and Assessing Children for Mental Health Services and Referring to the Coordinated Services Action Team (CSAT).
    4. Coordinate a Child and Family Team Meeting to address the safety and well-being of the child and discuss the services and support needed to address the needs of the child and family.
    5. Refer youth as appropriate to the Office of Equity’s LGBTQ+ Program and any other available LGBTQIA+ Advocacy Services if the minor consents to receiving services.
    6. If the youth is also a victim of Commercial Sexual Exploitation, determine if the case should be transferred to DREAM Court.
    7. Determine if the youth should be assessed for transfer to the DREAM Unit. There must be a nexus with substantiated Commercial Sexual Exploitation to request a transfer to the DREAM unit.
  10. Per the Missing or Absent from Care Children/Nonminor Dependents policy: If child is missing from home or absent from care, direct the caregiver to make a Missing Person Report to law enforcement.  Under no circumstance should contact with law enforcement be delayed more than twenty-four (24) hours. Direct the caregiver to obtain the report number and name of the Law Enforcement Agency that took the report. If the caregiver refuses to complete a report, it is the responsibility of the worker to ensure one is completed. If the youth is a NMD and the circumstances of their disappearance warrant such action, the CSW is to file a Missing Person Report with law enforcement, obtain the report number and document the information in the Contact Notebook. Circumstances warrant this action if the NMD has been reasonably determined to be in fact missing from care, there are competency issues, or there is a reasonable suspicion that the NMD is a victim of harm or foul play.
  11. If the youth is undocumented, contact the DCFS Special Immigrant Status Unit sisuib@dcfs.lacounty.gov and confer with County Counsel to discuss services and a referral to OTIP for assessment within 24 hours.
  12. Document all contacts and observations.

Assessing Child Exploitation Involving a Child in Criminal Activities

ER/Continuing Services CSW Responsibilities

  1. To assess if a child has been induced through force, fraud, and/or coercion to engage in criminal activities for profit, consider whether the exploiter could be a family/caregiver or third-party exploiter: 
    • Induces the child to engage in violent behavior and/or criminal activities (activities may include, but are not limited to, drug or arms sales or human/drug smuggling, drug cultivation, fraud/scams, shoplifting or theft, peer recruitment, gang affiliated crimes, domestic terrorism)
    • Receives monetary or non-monetary benefits as a result of the criminal activities of the child
    • Allows the child access to or provides drugs/alcohol
    • Encourages the child to use drugs/alcohol, including with the family and/or other children.
    • Uses the child to sell drugs (may be prescription drugs) or receive money from a drug dealer.
    • Uses the child to assist in the production of drugs.
    • Trains or encourages the child to post other youth online for the purpose of commercial sexual exploitation.
    • Threatens the youth with significant negative consequences (e.g. report to immigration or law enforcement, being kicked out of the home, serious physical harm or death) if they fail to perform the work.
  2. Conduct social media and the internet searches through designated staff for online accounts.
    • Web-based search engines and social media platforms can be searched with the child/youth's name, nicknames, and phone numbers to identify additional accounts and evidence of exploitation.
  3. Call the Child Protection Hotline if you suspect that a child is a victim of Labor Trafficking by Forced Criminality
  4. Refer youth as needed for a Medical Examination per policy. If there is a nexus with Commercial Sexual Exploitation or if sexual abuse is used as a method of control, refer child for a CSEC Medical Examination.
  5. For children who are victims of forced criminality and have been charged with a crime, it is important to team with those involved in the investigation and to contact law enforcement, district attorney, and Public Defender to advocate on child’s behalf to avoid the criminalization of the child.  Be mindful to be in contact with the county counsel on the case when contacting outside agencies.
  6. If minor consents, refer youth and non-minor dependents who are victims of Child Labor Trafficking by Forced Criminality to Advocacy Services for Youth Impacted by Commercial Exploitation.
  7. At this time there is no specific WIC 300 code for Labor Trafficking, in order to assess a child/ youth’s safety if they are being trafficked; utilize the following in your assessment and be sure to consult with your supervisor and county counsel if the situation rises to the level of a Court petition:
    • Potential indicators for Child Labor Trafficking by Forced Criminality are present and the child falls under WIC 300 (b)(1) due to serious physical harm or a substantial risk of serious physical harm to a child resulting from the failure or inability of the parent or guardian to adequately supervise or protect the child. This may include children who are experiencing forced criminality by a parent or guardian.
    • To assess safety and impact to the child, weigh the following factors:
    • The violence and exploitation associated with forced criminality led the child to be impacted by trauma, PTSD, anxiety, and/or depression
    • Child is forced to work in dangerous environments, leading to injuries, chronic illnesses, and long-term health issues.
    • Child is impacted by lack of school attendance, thereby limiting their cognitive development and future career prospects.
    • Child experiences stress and trauma that hinders their ability to concentrate and learn effectively
    • Child has been arrested and prosecuted for crimes they did not willingly commit, leading to criminal records that can affect their future.
  8. If investigative findings and collateral information indicate that Child Labor Trafficking by Forced Criminality occurred and there is serious physical harm or a substantial risk of serious physical harm to the child because the parent or guardian is unable to adequately supervise or protect the child, the child falls under WIC 300 (b)(1) and may be grounds for the child to be removed from the home and/or come under the jurisdiction of the juvenile court.  This may include children who were labor trafficked by forced criminality by a parent or guardian.
  9. Enter required documentation on CWS/CMS:
    • Disposition of Exploitation Allegation, Sub-category: Involving a Child in Criminal Behavior; Disposition of General Neglect; and select Special Project Code “S-Labor Traf In Child Crim Beh” in case notebook if child is a victim of Labor Trafficking by Forced Criminality/Involving a Child in Criminal Behavior.
  10. As the CSW is working to assess a youth for trafficking it is important to ensure that youth are referred to appropriate services once concerns for trafficking have been identified.  The following are steps to follow:
    1. Refer youth for appropriate Medical Examination per policy. The Hubs are equipped to provide gender affirming medical care for LGBTQ+ children.
    2. Ensure communication between Emergency Response and the Continuing Services CSW (if there is one assigned) during a new investigation to develop a safety plan and stabilize youth.
    3. Develop a safety plan with the child to identify ways to mitigate safety concerns and reduce risk of harm to the child. Include in the plan ways for child to seek safety, including phone number(s) to contact when in distress
    4. Submit a new Mental Health Screening Tool as needed, per the Screening and Assessing Children for Mental Health Services and Referring to the Coordinated Services Action Team (CSAT)
    5. Coordinate a Child and Family Team Meeting to address the safety and well-being of the child, and discuss the services and support needed to address the needs of the child and family
    6. Refer youth as appropriate to the Office of Equity’s LGBTQ+ Program and any other available LGBTQIA+ Advocacy Services if the minor consents to receiving services
    7. Determine if the youth should be assessed for transfer to the DREAM Unit. There must be a nexus with substantiated Commercial Sexual Exploitation to request a transfer to the DREAM unit.
  11. Per the Missing or Absent from Care Children/Nonminor Dependents policy: If child is missing from home or absent from care, direct the caregiver to make a Missing Person Report to law enforcement.  Under no circumstance should contact with law enforcement be delayed more than twenty-four (24) hours. Direct the caregiver to obtain the report number and name of the Law Enforcement Agency that took the report. If the caregiver refuses to complete a report, it is the responsibility of the worker to ensure one is completed. If the youth is a NMD and the circumstances of their disappearance warrant such action, the CSW is to file a Missing Person Report with law enforcement, obtain the report number and document the information in the Contact Notebook. Circumstances warrant this action if the NMD has been reasonably determined to be in fact missing from care, there are competency issues, or there is a reasonable suspicion that the NMD is a victim of harm or foul play.
  12. If the youth is undocumented, contact the DCFS Special Immigrant Status Unit sisuib@dcfs.lacounty.gov and confer with County Counsel to discuss services and a referral to OTIP for assessment within 24 hours.
  13. Document all contacts and observations.
APPROVALS
None
HELPFUL LINKS
REFERENCED POLICY GUIDES

0050-501.10, Child Abuse and Neglect Reporting Act (CANRA): Who Must Report

0070-532.10, Assessing Allegations of Child Sexual Abuse

0070-548.10, Investigation, Disposition and Closure of Emergency Response Referrals

0070-548.24, Structural Decision Making (SDM)

0070-548.25, Completing the Structured Decision Making (SDM) Safety Plans

0400-503.10, Contact Requirements and Exceptions

STATUTES AND OTHER MANDATES

All County Information Notice (ACIN) I-16-24 - Documentation of Labor Trafficking of Children in the Child Welfare Services/Case Management System.

ACIN I-32-21 - Recommended Practices Regarding Youth Who Have Experienced Commercial Sexual Exploitation and Their Usage of Cell Phones

All County Letter 16-85 - Statewide Policies and Procedures to Prevent Child Sex Trafficking

Labor Code Sections 1285-1312 – Sets forth guidelines as it relates to work rules regarding children.

Penal Code Section 11165.1 (c) – Defines “sexual exploitation” as any conduct involving matter depicting a minor engaged in obscene acts or the encouraged/coerced prostitution, modeling, or other pictorial depiction of a child, involving obscene sexual conduct.

Welfare and Institutions Code 300(b)(4) - Does not require the court to find negligence or wrongdoing on the part of the parent.  Instead, it only requires that the court find the child has been or is being sexually trafficked as described in Section 236.1 of the Penal Code or has or is receiving food or shelter in exchange for, or who has been or is being paid to perform sexual acts described in Section 236.1 or 11165.1 of the Penal Code.