Youngik Yoon*
This article examines the trafficking of women from one country to another for forced prostitution. Each year, many women are kidnapped, sold to "pimps" in foreign countries, and forced into prostitution. Many others are lured into foreign countries with promises of high paying jobs, but are forced into prostitution once they arrive. These women become virtual sex slaves. Some are even chained to their beds in brothels to prevent their escape. Fn1 Additionally, in most instances, organized crime is heavily involved in the international sex slave business. Fn2
While sexual enslavement may occur domestically, this article focuses on the international aspects of sexual captivity. The international problems tend to be more disturbing to most individuals because these women are powerless to escape and may be forced to endure the slavery until they die. Sexual slavery can be particularly fatal today due to the global epidemic of AIDS, as these enslaved women are forced to have unprotected sex with a large number of men every day. Fn3
While a large portion of these captive women in foreign countries are from poor Third World countries, any woman, regardless of her age, race, or economic class, can be kidnapped and forced into prostitution in another country. Fn4 This article begins with a discussion of the methods of procuring women for use as prostitutes. Second, it examines the reasons why foreign women are selected. Third, the laws of various countries prohibiting the traffic and enslavement of women as prostitutes, including those of China, Brazil and the United States are discussed. Finally, this article focuses on the international prohibitions against trafficking women from one country to another for the purpose of forcing them into prostitution.
While international law provides a sound principle that seems to be universally accepted, it is impossible to enforce because it lacks any mechanism to do so. This article proposes the creation of an international criminal court and law enforcement agency to manage the problems of international sexual slavery. While the creation of a permanent international criminal court has long been suggested by legal scholars, such a court has never been established because of the disagreement between various nations over certain issues. Fn5 After the court's creation, the international community could eventually extend the jurisdiction of the court after it has been successful in handling the international sexual slavery cases. Finally, this article proposes harsh penalties seizure of property and stiff jail sentences for procurers and violators.
Women who become the victims of international sexual slavery are procured by kidnapping, purchase, or with fraudulent inducements for jobs and a better life.
One popular way to procure women for international prostitution is to simply kidnap them in one country and bring them to another. While many incidents of kidnapping and forced prostitution are reported, there is a far larger number of unreported cases because the women who are kidnapped have great difficulty in escaping and reporting the crime. In fact, French police report that every year at least several thousand teenage girls are reported missing from Paris. The police believe that these girls have been abducted into Arab countries for prostitution, but they have no evidence to prove it. Fn6 Also, people have claimed to have actually seen auctions in Africa, where abducted white women from Europe were being sold to Arab customers. Fn7 This section details some of the incidents of kidnapped women who were able to escape and report their abuse.
The following is the reported experience of one French woman who had been held as a prostitute slave for several years in Africa:
Veronique had been a prostitute for several years when her pimp kidnapped her four children, held them hostage, and threatened to kill them if she did not obey him and follow the arrangements he made for her to go to Dakar [Senegal]. Fearing for her children's safety, she went. There, she was enslaved in a brothel for two years, during which time there was no opportunity to leave the premises, let alone escape. When the ships came in, she was forced to take on up to 100 men a day. After two years of brutal beatings and the horrific demands made on her body, she became seriously ill and was taken to a hospital. There, she confided her story to a doctor, who took pity on her. He contacted the police and helped to arrange for her escape. Upon returning to France, she sought refuge with Le Nid, a French refuge for prostitutes. She contacted the authorities and testified against her pimp. He was found guilty and imprisoned, and Veronique's children were returned to her. Fn8
In Asia, much of the prostitution business is run by gangs, who kidnap women from Burma, Laos, Vietnam, and China. These gangs export the kidnapped women to Thailand, and force them into prostitution at massage parlors, go-go clubs, hotels and shacks. Fn9 It is estimated that more than forty-thousand women and girls from Burma alone have been kidnapped and shipped to Thailand. Fn10
When twenty-five Burmese women were kidnapped by gangs in Burma and forced to work in Thailand as prostitutes, Thai police raided the sex den and rescued these women. Subsequently, the women were deported to Burma after they all tested HIV-positive. Upon their return to Burma, Burmese health officials injected the women with cyanide to "prevent the spread of the [HIV] virus." Fn11 In fact, according to a social worker in Burma, the Burmese government routinely executed women who return from Thailand with the AIDS virus. Fn12
The problem of international sexual captivity is not primarily Asian. In Brussels, the daughter of a Dutch count was kidnapped, along with other European girls, and taken to Zaire to work as a prostitute. Fn13
In the United States, federal officials state that women are systematically transported to the United States, and "forced to serve as labor camp prostitutes in return for food." Fn14 U.S. officials further report that organized crime syndicates are behind this international trafficking of women. Fn15
Kidnapped women generally suffer terrible abuses. They are most often under-fed and denied medical care. Those who become sick are often killed by the brothel owners. Fn16 Recently, a number of captives burned to death when a fire broke out in their brothel, and they could not escape because they were chained to their beds. Fn17 One kidnapped woman was lucky enough to escape to the local city hall, but she was found and murdered by brothel thugs. Fn18
In addition to kidnapping, women are also sold into sexual bondage by their families. This happens most frequently in poor Third World countries. In most cases, those who are sold are young girls. Fn19 For example, some Indian parents sell their daughters to Arab men for less than three hundred dollars because they receive cash and no longer have to provide their daughter with an expensive dowry. Fn20 In Thailand, some parents sell their daughters when they are mere babies, and the buyers raise them like livestock. Fn21 Many of the buyers have sold their own daughters. Fn22 When the girls reach a certain age, they are then re-sold into the prostitution circuit to serve foreign tourists. Fn23 A Thai woman, who founded a school for these types of girls, said, "It happens quite often. The kids know that they have to go to Bangkok at a certain age. They know that these people are not their real parents." This woman is working to find these children foster homes, despite continuous threats from gang members. Fn24
The Dallas Morning News published a story of Thai girls who were kidnapped and sold. Fn25 While this story involves the domestic sale of a girl, it gives an idea of how insensitive authorities in Third World countries are to the plight of escaped sex slaves, even when the victims are their own citizens:
In the remote hilltop villages of the Akha, pigs and poverty share the narrow dirt lands with bamboo and thatch homes. Dau came from one such village, from the rice fields, a poor family, and an opium-addicted father. The offer came when she was 12 or 13 - a job in a restaurant that turned out to be a brothel. When her resistance was beaten out of her, the customers were brought to her, five to seven of them on the first night. Her fee was six dollars. She got none of it. The first time Dau escaped from the brothels, she and two other girls from her village climbed through a bathroom window and went to the police. "They tried to convince us to return to the brothel", she says. When the girls refused, the police delivered them to their original kidnapper, who promptly sold them to another brothel. The second time, Dau and her friends made it home. But the brothel agent brought police to threaten their families with arrest unless they repaid him for the girls' value. The girls continued to run until they found a village whose leader took them to the New Life Center in Chianing Mai. The Center, supported by American Baptist and Swedish churches, operates three homes for girls who have survived prostitution, or who are at risk of being sold into it. Fn26
In these poor Third World countries, some parents say they sell their children because they think prostitution is better than starvation. Fn27
Another method of procuring women for forced prostitution in a foreign country is by false promises of work. Many foreign prostitutes in Japan seem to have been brought to Japan by this method. Yeko Takeoka, a Japanese lawyer, and Sister Naoka Iyri, a nun, testified before the Human Rights Commission of the United Nations in 1989 that, among the approximately three -hundred thousand women working in Japan, ninety-three percent had been promised jobs as entertainers, but ended up being used as prostitutes. Fn28
White American women are among the foreign women forced into prostitution in Japan. Fn29 One Japanese organized crime syndicate uses West Coast talent agencies to place advertisements to lure these women to Japan. The agencies advertise jobs of seemingly legitimate productions and shows in Japan. Some of the women who respond to the advertisement are selected, and they are contacted by an "agent". They are promised a specific salary, told where and when they will be performing in Japan, and given pre-paid plane tickets. However, upon arrival, the women are met by a different agent, who informs them that he has bought their contracts from their former "agent". The women's passports and other identification documents are taken away, and they are forced to work as prostitutes. Fn30 Unfortunately many Americans are unaware of this growing problem.
To increase their legitimacy, Japanese gangsters, called Yakuza, have made inroads into the lawful business world. Fn31 This tends to increase their power and ability to participate in the international prostitution business. Japanese gangs may even have some link to American organized crime. Fn32 The collaboration between Japanese and American organized crime "families" makes it difficult to stop the Yakuza's traffic of women without some type of cooperation between the countries.
Even Mexican women are lured into the United States with the promise of employment, but upon arrival in the U.S. they are forced to work as prostitutes. Fn33 Most of them were promised jobs as barmaids, but ended up as sex slaves for Mexican migrant workers. Fn34
The Dallas Morning News reported one Chinese woman's terrifying experience of being kidnapped to Burma under the false pretenses of employment:
When she [Fong] was 16, a monk visited her village in southern China. He said she could make two hundred dollars a month as a sales clerk in a Burmese border town - a huge sum of for a girl who sometimes went hungry. Instead of the wonderful new life, after a three day trip to the Thai-Burma border, she was sold to a brothel agent for six hundred dollars. When she saw the money change hands, Fong said she was terrified. But she didn't know where she was, she had no money and she did not even speak Thai. Fong was taken to a Bangkok teahouse where a Thai man paid her owner two hundred and eighty dollars for the privilege of taking away her virginity. "I almost fainted. I almost killed myself," she says. Her value as a virgin spent, Fong was shifted to a massage parlor at the beach resort of Pattay. There, she joined 30 to 40 other girls in a glass room wearing numbers, so that customers could choose among them. The brothel owner bought her clothes. The other women "trained her," she says, how to dress, how to give a man a bath, how to do the required things, step by step, so that her skills became her job. Like most women in locked brothels, Fong received no money, except tips. Pimps guarded the doors. If she refused to have sex with drunken customers, she was beaten . . . . One of the few excepted excuses for refusing sex was that a woman was having her menstrual period. But when Fong tried to stretch that excuse for more than a few days, she says, the massage parlor owner would make her take off her underwear so he could see if she was telling the truth. Fong managed to escape after six months. By bus, she made it back across the country to Mae Sai. But, before she could cross into Burma, one of the army of procurers found her and sold her to another brothel. "Being recaptured was almost as terrifying as her first customer," she said. Eventually, a Taiwanese customer paid the owner of the second brothel four hundred dollars to free her, and sent her to the Chinese embassy in Bangkok." Fn35
Filipino women are also enslaved as prostitutes in other countries. Aurora Javante de Dios, an expert on the slavery of Filipino women, said, "Slavery now is more sophisticated, more globalized, and more technical than ever. Women can be recruited for domestic jobs, and end up as prostitutes in Japan and the Middle East. Slavery is now integrated into our countries' economies." Fn36
Why are foreign women sought as sex slaves when it may be more difficult to obtain them than the country's own women? First, the demand for prostitution within a country may be greater than the number of domestic women who are willing to be prostitutes. While Thailand has one of the largest number of prostitutes in the world, the demand is disproportionately high because a large number of foreign men from affluent countries, like Japan, South Korea, Australia and the United States, actually come to Thailand on organized sex tours. Fn37 This may explain why gangs kidnap women from Burma and China, and take them to Thailand, even though Thailand already has one of the largest prostitute populations.
Another reason for using foreign women as prostitutes is that it is much more difficult for enslaved women to escape from a foreign country rather than their own country. Women brought into the country, more than likely than not, do not know the language and are very unfamiliar with their surroundings.
Foreign women are also more attractive targets because the kidnapping gangs usually know the local authorities and can easily bribe the local police and judiciary. Fn38 Local police are also far less sympathetic to foreign women.
Furthermore, prostitution clients seem to prefer foreign women. In Japan, men are obsessed with having sex with Caucasian women, especially blondes. Fn39 Therefore, blonde women are the most sought-after prostitutes in Tokyo. Fn40 There is great financial incentive for the Japanese crime syndicates to deliver Caucasian women to the prostitution market. Fn41
This section examines how different nations treat the subject of trafficking women for prostitution. Specifically, the laws of Brazil, China, and the United States are reviewed.
Brazilian law forbids the trafficking of women, which is defined as "the importation of women into Brazilian territory for the purpose of engaging in prostitution, or the assisting of their departure from Brazil, for the purpose of engaging in prostitution abroad." Fn42 Additionally, Brazilian law provides harsh penalties for this crime and even harsher if convicted of selling minor women. Fn43 Those convicted of trafficking women who are over eighteen of age are sentenced to jail for a minimum of three years to a maximum of eight years. Fn44 Those convicted of trafficking minor females under the age of eighteen can be sentenced for a minimum of four years to a maximum of ten years. Fn45 Also, if threat, violence or fraud was used, the perpetrator can be sentenced for up to twelve years. Fn46
While Chinese law does not specifically address the issue of trafficking women abroad, there are provisions which prohibit the kidnapping and sale of women domestically, which can be applied to the international trade of women for prostitution. Fn47 Relevant provisions provide as follows:
Article 36. It is prohibited to abduct and sell or kidnap women. It is prohibited to buy abducted or kidnapped women. The People's Governments and Departments concerned must adopt prompt measures to rescue abducted, sold or kidnapped women. After abducted, sold or kidnapped women are returned to their hometown, no one shall discriminate against them, and local governments and departments concerned should do a good job in helping them to be restored to normal lives.
Article 37. Both working as a prostitute or visiting prostitutes are prohibited. It is prohibited to organize, coerce, lure, keep or introduce women to work as prostitutes . . . . Fn48
Unlike the laws of other countries, Chinese law also specifically prohibits the discrimination against women who have been victims of sexual slavery and returned home. Fn49 The Chinese Communist government takes a very harsh stance against individuals convicted of kidnapping and selling women. Fn50 For instance, when four individuals were convicted of leading a gang that had kidnapped seventy-four Chinese women, the Chinese government sentenced the criminals to death. Fn51 In a country where the average wage is only about thirty dollars per month, the gang reportedly made twenty-five thousand dollars just from the trade of human flesh. Fn52
American law also prohibits kidnapping a person for the purposes of prostitution, but does not specifically address the problem of international sexual slavery. Fn53 The U.S. Constitution and various federal and state statutes specifically prohibit slavery. Fn54 The Thirteenth Amendment to the U.S. Constitution absolutely bars slavery and involuntary servitude. Fn55 The United States Code, sections 1583 and 1584, forbids kidnapping and slavery:
Section 1583. Whoever kidnaps or carries away any other person, with the intent that such other person be sold into involuntary servitude, or held as a slave; or whoever entices, persuades, or induces any other person to go on board any vessel or to any other place with the intent that he may be made or held as a slave, or sent out of the country to be so made or held, shall be fined not more than five-thousand dollars, or imprisoned not more that five years, or both. Fn56
Section 1584. Whoever knowingly and willfully holds to involuntary servitude, or sells or brings within the United States any person so held, shall be fined not more than five-thousand dollars or imprisoned not more than five years, or both. Fn57
While the American laws seem to be more lenient to criminals who are convicted of enslaving women than the laws of either China or Brazil, the various states have criminal statutes which can be harsher than the federal statutes. Fn58 Additionally, the federal government can charge the kidnappers with additional crimes, such as rape, which can result in a more severe punishment. Fn59
International law also addresses the issue of forced prostitution. Various treaties and conventions absolutely forbid the kidnapping of women for the purposed of forcing them into prostitution, whether the women were kidnapped internationally or domestically. Fn60 In fact, the prohibition against prostitutional slavery has long been a part of traditional international law, even before any formal agreements were made between nations. Fn61
Additionally, there have been a number of international treaties specifically addressing this international problem. The first such agreement was the International Convention for the Suppression of the White Slave Traffic of May 18, 1904. Fn62 Signed in Paris on May 4, 1910, and going into effect on August 8, 1912, the Convention forbids the traffic of women for an immoral purpose. Fn63 Initial signatories of the Convention included Austria-Hungary, Belgium, Brazil, Denmark, France, German, Great Britain, Italy, the Netherlands, Portugal, Russia, Spain, and Sweden. Fn64 Later, the Convention was accepted by many other countries, including China, Japan, and Turkey. Fn65
The second international agreement to treat the subject was the International Convention for the Suppression of the Traffic of Women and Children. Fn66 Signed by approximately sixty countries in 1921, the treaty prohibited people from procuring, enticing or leading away a woman, or girl of full age, for immoral purposes, to be carried out in another country. Fn67
The next multilateral treaty was the International Convention for the Suppression of the Traffic in Women of Full Age, which was signed in Geneva on October 11, 1933. Fn68 This convention imposed a duty on the signing countries to prohibit, prevent, prosecute and/or punish those engaged in such practices. Fn69 Twenty-six countries, mostly European, signed this agreement. Fn70
In 1950, the Convention for the Suppression of the Traffic in Persons and the Exploitation of the Prostitution of Others was signed by more than sixty countries, including Japan, Iran, Iraq, and Kuwait. Fn71 The most comprehensive and detailed convention to that date, this treaty consolidated the ideas expressed in the prior three conventions. It prohibits individuals, or countries, from procuring, enticing or leading away, another person for the purposes of prostitution. Fn72 It even prohibits the prostitution of a person with the consent of that person. Fn73 The convention also requires countries to punish any person who keeps, manages, or knowingly finances, or takes part in the financing, of a brothel. Fn74 Additionally, it requires the signing countries to punish people who knowingly lease or rent a building or other facility for the purpose of prostitution. Fn75
On a different level, the convention also provides that aliens shall have the same rights and privileges as citizens, in cases where injured persons are entitled under domestic law to be parties to proceedings regarding any of the offenses referred to in the treaty. Fn76 Accordingly, a woman who was kidnapped and forced into prostitution in a foreign land would be able to bring suit against her capturer and pimp in that country, if the same kind of action could be brought by a citizen of that country.
The signing countries also agreed to make it an extraditable offense to kidnap or entice someone out of his or her own country for the purposes of prostitution. Fn77 This means that when a woman of country "A" is kidnapped by nationals of country "B" to be used as a prostitute in country "B", country "A" can ask country "B" to extradite the kidnappers to be prosecuted in country "A".
The agreement also requires countries to take necessary measures for the supervision of employment agencies, in order to prevent women and girls seeking employment abroad from being exposed to the danger of forced prostitution. Fn78
While the various international conventions provide an elaborate framework aimed at the prevention of the traffic in women for forced prostitution, these agreements are not well adhered to by those countries who endorsed them. Corruption in law enforcement groups and the lack of governmental interest in the plight of these enslaved women make it almost impossible to enforce the treaty.
In Thailand, for example, police corruption is the toughest obstacle in solving the problem of forced prostitution, regardless of whether the women are citizens or foreigners. Fn79 Not only are the police paid to ignore and protect the brothels, but often, some of the police officials own their own houses of prostitution. Fn80 Dr. Saisuree Chitikul, a former Cabinet member who is now a government consultant on women's and children's issues, said "The lower ranks collect [bribe money], divide it up, put it in envelopes, and give it to the higher ups. Its's a feeding system, from the roots up . . . [The police] can't do anything about it because they are part of it." Fn81
Similarly, while the traffic of women to Japan for prostitution purposes is a significant problem in the United Sates, American law enforcement agencies have made little effort to solve the problem. A policeman, assigned to investigate the traffic of women to Japan, said, "After seven years, I'm frustrated. I can't do anything to stop it, the Feds can't do anything, and the State Department doesn't want to do anything." Fn82 Women continue to be victims of forced prostitution in foreign lands, and the criminals go unpunished.
While there are already world-wide agreements that ban the traffic of women from one country to another, these prohibitions have little effect. Fn83 The reason for such non-compliance with fundamental international law is that there is no international enforcement agency or organization to carry out the prohibitions. Creating an international law enforcement agency to deal with this international problem, and an international criminal court system to try those engaged in such crimes, is one solution. Further, the international law should require the seizure of property of the violators, and specify and apply harsh penalties upon them.
The creation of an international criminal court system has long been suggested by legal scholars as a way to deal with such international problems, such as the trafficking of women abroad for prostitution. Fn84 However, since the countries could not agree on certain major issues, such as jurisdiction, the definition of terrorism, funding, etc., such a court has never been created. The international community must set aside their differences and agree that the court will take jurisdiction over the most important problems in the international arena which the countries can agree upon. Since most countries are in agreement that the kidnapping and sale of women and forced prostitution are violative of international law, the proposed international criminal court should have jurisdiction to enforce the conventions and punish the violators. Then, when the court has been more widely accepted, and the problems have been ironed out, the court's jurisdiction can be extended to other criminal matters. The details as to the selection of judges, the court structure, and the funding of the system, can be negotiated between the countries. For example, countries can select judges for the international court from current or former judges of their country.
An international law enforcement agency must also be created to enforce the decisions of the international criminal court. Since international sexual slavery involves the trans-national traffic of women, law enforcement from one single country cannot effectively deal with organized crime that is linked internationally. Instead of enforcing international law, the current international police organization ineffectively gathers crime statistics from the international community. Fn85
Under the proposed system, nations contributing to the agency could select from their own enforcement agencies candidates to compete for a position in the new agency. This proposal may be easy to implement because it does not involve a large world organization that would select international police members, producing excess costs for each country involved. Participating members can cooperate with each other by exchanging information and conducting investigations within their countries, if requested to do so by another country. For example, in cases where American women are trafficked to Japan under false promises of employment, international police in America can investigate who is involved in such crimes in the U.S., and then furnish the information to the international police in Japan. Those officers would have the authority to be able to continue the investigation in Japan. Also, the American police can request that the police in Japan look for missing American women suspected of being kidnapped by Japanese gangs.
The international criminal court should be authorized to be able to seize the property of criminals who are convicted of trafficking in women internationally, or of forcing women into prostitution. The seized property should be sold and the monies used for the benefit of the rehabilitation of the victims of international sexual slavery.
Such seizures and sales can generate a large amount of revenue. For example, Japanese organized crime, which is largely responsible for the enslavement of foreign women as prostitutes in Japan, has enormous assets. In fact, it is estimated that in 1989 alone, the crime syndicates in Japan were valued at over ten billion dollars. Fn86 If some of these assets can be seized, forfeited, and sold, the revenue may be used for the rehabilitation of their victims, many of whom are from poor Third World countries, such as the Philippines and Thailand.
Another international convention should be created to specify the exact penalties to be imposed on those who are convicted of international kidnapping and sex slavery. While the "Convention for the Suppression of the Traffic in Persons and the Exploitation for the Prostitution of Others" prohibits anyone from trafficking women for prostitution, it does not require countries to impose a set punishment. Fn87 The new Convention must require the international criminal court, and the courts of each country, to mandate a strict penalty for those convicted of trafficking and forcing women into prostitution. The new Convention should require countries to impose a very harsh punishment, such as twenty years in jail for kidnapping women from foreign countries, and fifteen years for luring them into the country under false pretenses. It should also require countries to impose life imprisonment on pimps and owners of brothels who chain foreign women to their beds or in their rooms so that they cannot escape.
International law must constantly adjust to new developments in the world to be effective. International sexual slavery is a growing problem, particularly in Third World countries where women and children are exploited tremendously. Organized crime will continue to profit from their exploitation if they are able to avoid prosecution. Only a uniform international agreement and enforcement can curb this disturbing trend in the world, and prevent the misery for countless victims of the sex trade.
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* Youngik Yoon is an attorney at law in Elmhurst, NY. He received his J.D. degree (Cum Laude) from Albany Law School of Union University.
Fn1 . Uli Schmetzer, Slave Trade Survives, Prospers Across Asia, CHI. TRIB., Nov. 17, 1991, at C1.
Fn2 . Lan Cao, Illegal Traffic in Women: A Civil RICO Proposal, 96 YALE L.J. 1297, 1298 (1987).
Fn3 . Gayle Reaves, Trading Away Youth; Impoverished Thai Parents Sell into Prostitution, DALLAS MORNING NEWS, Mar. 21, 1993, at 1A.
Fn4 . KATHLEEN BARRY, FEMALE SEXUAL SLAVERY 121 (1979).
Fn5 . See generally William N. Gianaris, The New World Order and the Need for an International Criminal Court, 16 FORDHAM INT'L L.J. 88 (1992) (stating the case for an international criminal court and reviewing efforts at its establishment).
Fn6 . BARRY, supra note 4, at 5.
Fn7 . Id.
Fn8 . Id. at 78.
Fn9 . Reaves, supra note 3.
Fn10 . Id. See also Gayle Reaves, Group Accuses Thai Officials of Perpetuating the Sex Trade: Government Says Supervision of Local Officers to Improve, DALLAS MORNING NEWS, Jan. 31, 1994, at 10A. The Thai government's crackdown on forced prostitution, rather than helping solve the problem, has resulted in only the arrests of "rescued" Burmese women and girls, reports the New York based Human Rights Watch. Frequently, as reasearchers have found, the women are returned to brothel agents who pay money to police.
Fn11 . Uli Schmetzer, Seventeen Countries Meet to Combat Sex Slavery, CHI. TRIB., Apr. 5, 1993, at N2.
Fn12 . Id.
Fn13 . BARRY, supra, note 4, at 121.
Fn14 . Lan Cao, supra note 2, at 1299.
Fn15 . Id. at 1301.
Fn16 . Reaves, supra note 3.
Fn17 . Id.
Fn18 . Id.
Fn19 . Schmetzer, supra note 1.
Fn20 . Id.
Fn21 . Reaves, supra note 3.
Fn22 . Id.
Fn23 . Id.
Fn24 . Id.
Fn25 . Id.
Fn26 . Id.
Fn27 . Reaves, supra note 10. See also Reaves, supra note 3.
Fn28 . Schmetzer, supra note 1.
Fn29 . Oppenheim, Japanese Mafia's Recruiting of American Women Probed, CHI. TRIB., Mar. 14, 1982, Sec. 1 at 6, cited in Lan Cao, supra note 2, at 1300 n.17, 18.
Fn30 . Id.
Fn31 . Robert Thomson, Japan's Cops Going After Organized Crime Tolerance Ended By Public Anger Over Property, Stock Speculations, S.F. EXAMINER, Aug. 23, 1990, at A17.
Fn32 . Id.
Fn33 . BARRY, supra note 4.
Fn34 . Id.
Fn35 . Reaves, supra note 3.
Fn36 . Schmetzer, supra note 1.
Fn37 . See Ron Moreau, Sex and Death in Thailand, NEWSWEEK, July 20, 1992 at 50.
Fn38 . Reaves, supra note 3.
Fn39 . John Leo, Waterbeds and Willow Worlds: Japan is a Strange Mixture of Open Sex and Silent Frustration, TIME, Aug. 1, 1983, at 71. See also Dennis Kucherawy, The Metamorphosis of Madame Butterfly, TORONTO STAR, Sept. 15, 1990, at M1.
Fn40 . Leo, supra note 40.
Fn41 . Id.
Fn42 . Code Penal., Art. 231, cited in Joao Marcello De Araujo, International Crimes in Brazilian Domestic Law, 1 TOURO J. TRANSNAT'L L., 353, 368 (1990).
Fn43 . Id.
Fn44 . Id.
Fn45 . Id.
Fn46 . Id.
Fn47 . Law Protecting Women, BBC Apr. 16, 1992, available in LEXIS, Nexis Library, BBC file.
Fn48 . Id.
Fn49 . Id.
Fn50 . World Briefs, HOUS. CHRON. Dec. 8, 1991 at A31.
Fn51 . Id.
Fn52 . Id.
Fn53 . See, e.g., 18 U.S.C.A. § 2421 (West 1994).
Fn54 . U.S. CONST. amend. XIII, § 1. See also, 18 U.S.C.A. §§ 1583, 1584, (West 1994). See also, e.g. CAL. PENAL CODE § 181 (West 1994).
Fn55 . U.S. CONST. amend. XIII, § 1.
Fn56 . 18 U.S.C.A. § 1583 (West 1994).
Fn57 . 18 U.S.C.A. § 1584 (West 1994).
Fn58 . See, e.g., CAL. PENAL CODE § 181 (West 1994).
Fn59 . 18 U.S.C.A. § 2421 (West 1994).
Fn60 . The Convention for the Suppression of the Traffic in Persons and of the Exploitation of the Prostitution of Others, Mar. 21, 1950, 96 U.N.T.S. 271.
Fn61 . M. Cherif Bassiouni, Enslavement as an International Crtime, 23 N.Y.U. J. INT'L L. & POL. 445, 445 (1991).
Fn62 . The International Convention for the Suppression of the White Slave Traffic, 7 Martens Nouveau Recueil (ser. 3) 252.
Fn63 . Id.
Fn64 . Bassiouni, supra note 62, at 464.
Fn65 . Id.
Fn66 . International Convention for the Suppression of the Traffic in Women and Children, Sept. 20, 1921, 9 L.N.T.S. 415.
Fn67 . NATALIE KAUFMAN HEVENER, INTERNATIONAL LAW AND THE STATUS OF WOMEN 101 (1983). See International Convention for the Suppression of the Traffic in Women and Children, supra note 67, at art. 2.
Fn68 . International Convention for the Suppression of the Traffic in Women of Full Age, Oct. 11, 1933, 150 L.N.T.S. 431.
Fn69 . Id. art. 1.
Fn70 . Bassiouni, supra note 62, at 471-72.
Fn71 . The Convention for the Suppression of the Traffic in Persons and of the Exploitation of the Prostitution of Others, supra note 61.
Fn72 . See HEVENER, supra note 68, at 78, 90. See also The Convention for the Suppression of the Traffic in Persons and of the Exploitation of the Prostitution of Others, supra note 61, at art. 1, § 1.
Fn73 . The Convention for the Suppression of the Traffic in Persons and of the Exploitation of the Prostitution of Others, supra note 61, at § 2.
Fn74 . Id. art. 2.
Fn75 . Id.
Fn76 . Id. art. 5.
Fn77 . Id. art. 8.
Fn78 . Id. art. 20.
Fn79 . Reaves, supra note 3.
Fn80 . Id.
Fn81 . Id.
Fn82 . Horton & Coll, White Slaves, PLAYGIRL, Nov. 1982, at 48, cited in Lan Cao, supra note 2, at 1304 n.36 (1987).
Fn83 . The International Convention for the Suppression of the Traffic in Women and Children, The International Convention for the Suppression of the White Slave Traffic, The International Convention for the Suppression of the Traffic in Women of Full Age, The Convention for the Suppression of the Traffic in Persons and of the Exploitation of the Prostitution of Others, to name a few.
Fn84 . The Creation of An International Criminal Court, 1991 N.Y. ST. B. ASS'N. COM. & FED. LIT. SEC. REP.
Fn85 . BARRY, supra note 4, at 58.
Fn86 . Thomson, supra note 32.
Fn87 . The Convention for the Suppression of the Traffic in Persons and of the Exploitation of the Prostitution of Others, supra note 61.