Human Trafficking—Exotic Dancers

A Lithuanian man living in the Chicago area has pleaded guilty to conspiracy charges related to the trafficking of Eastern European women.^[1] Michail Aronov and another man, Aleksander Maksimenko, were arrested in February after two Ukrainian women fled from his control and told federal agents that the men had enslaved the women, forcing them to work as topless dancers in Detroit.^[2] Mr. Aronov pleaded guilty to conspiracy to commit forced labor, immigration violations, and money laundering.^[3] As part of his agreement, he admitted that he confiscated the women’s passports, threatened to report them for immigration violations, forced them into indebtedness, and threatened them with physical violence.^[4] US Attorney Stephen J. Murphy has announced that Mr. Aronov will be cooperating with the government in their case against Mr. Maksimenko, who is awaiting trial.^[5]

When the men were arrested in February, Immigrations & Customs Enforcement [hereinafter ICE] officials announced that the men traveled to the Ukraine, recruiting women to work as waitresses, but when they arrived in the US with their husbands, they were forced to work at “Cheetah’s” a Detroit strip club.^[6] The women were forced to work 12 hours a day, six days a week, to pay off $12,000 in travel expenses, and $10,000 for identification documents.^[7] Mssrs. Aronov and Maksimenko, took all money the women earned, barred them from contacting their husbands, drove them to and from work, and gave them no access to a telephone.^[8] They were also intimidated, battered, and threatened with death.^[9]

Human Trafficking
Human trafficking is a very serious transnational crime. In this case, Mr. Aronov likely pleaded guilty to 18 U.S.C. § 1590, which makes it a crime to recruit, harbor, transport, or obtain by any means, a person for labor or services.

The punishment for violating section 1590 is a fine, imprisonment for up to 20 years, or both.

Mr. Aronov, could also have pleaded guilty to confiscating the women’s passports in violation of 18 U.S.C. § 1592, which carries a punishment of a fine, imprisonment for up to five years or both.

Immigration Violations
There are a host of immigration violations to which Mr. Aronov could have pleaded guilty. Most likely he pleaded guilty to 8 U.S.C. §§ 1324(a)(1) and (a)(2). Under these sections, it is illegal for a person to engage in a conspiracy^[10]

• to knowingly bring an alien into the United States at a place other than an official port of entry, regardless of whether the alien has received prior official authorization;^[11]
• to knowingly transport an illegal alien within the United States;^[12]
• to knowingly harbor and illegal alien in any place;^[13] or
• to encourage an alien to enter the United States, knowing that such entry is illegal.^[14]

The punishment for violating this statute is a fine, the potential for life in prison or both.^[15]

8 U.S.C. § 1324(a)(2) makes it a crime for a person, knowing that an alien has not received prior official authorization to enter the United States, to bring that person into the US for the purpose of financial gain. The punishment for violating this section is a fine, imprisonment for up to 10 years, or both.^[16]

Money Laundering
Money laundering is punished under 18 U.S.C. § 1956. We have recently discussed this crime here.

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[1] Man Pleads Guilty to Trafficking in Exotic Dancers, Associated Press, Sept. 8, 2005, available here.
[2] Id.
[3] Id.
[4] Id.
[5] Id.
[6] ICE, ICE Nabs Two Michigan Men for Human Trafficking Scam, Feb. 2005, available here.
[7] Id.
[8] Id.
[9] Id.
[10] 8 U.S.C. § 1324(a)(1)(A)(v)(I).
[11] Id. § 1324(a)(1)(A)(i).
[12] Id. § 1324(a)(1)(A)(ii).
[13] Id. § 1324(a)(1)(A)(iii).
[14] Id. § 1324(a)(1)(A)(iv).
[15] Id. § 1324(a)(1)(B).
[16] Id. § 1324(a)(2)(B).