South Asia Scam Centers: When AI and Human Trafficking Expose Gaps in Global Human Rights Law
Authors: Benitez, Marta; Bolivar, Daniela; Gil, Daniela
Can you imagine securing a dream job abroad, only to discover you’ve been trafficked and forced into digital fraud? These apparently legitimate companies, indistinguishable from any other tech firm, are known as scam centers built on human exploitation (UNODC, 2024).
Southeast Asia has become the epicenter of scam centers, where AI and weak content moderation have escalated human trafficking and forced labor for large-scale online fraud (Interpol, 2025; UNODC, 2025; United Nations News, 2025).
Interpol (2025, September 5) revealed the large-scale operations of scam centers in the region, which often follow the same routes as other criminal activities. They identified other emerging hubs in West Africa, the Middle East, and Central America (Interpol, 2025; UNODC, 2025).
The rise of AI after the COVID-19 pandemic has accelerated this trend. Hyper-realistic job advertisements and automated fraud tools have transformed scam centers into full-scale cybercrime service providers, capable of exploiting people and technology at unprecedented speed (Interpol, 2025; UNODC, 2025; ICMPD, 2025).
Who’s Who in a Multi-Layered Problem: When AI Meets Human Exploitation
Behind the operations of every scam center lies a complex web of actors. Understanding who they are is key to uncovering how technology, law, and exploitation intersect in this form of organized crime (Interpol, 2025; UNODC, 2025).
Recruiters use AI-generated job advertisements tailored to users’ online algorithms (ICMPD, 2025; UNODC, 2025). With rapid advances in AI, these scams create hyper-realistic scenarios that are nearly indistinguishable from authentic job opportunities.
Scam centers operate through transnational trafficking networks, involving countries of origin (where people are recruited), transit countries, and final destinations where victims are enslaved in fraudulent operations (UNODC, 2024; Interpol, 2025). Rapid recruitment often leaves trafficked individuals in a precarious migration status and could lose access to their identity once under traffickers control (UNODC, 2024; ASEAN, n.d.).
Ultimately, these scam centers have become hubs of modern slavery, victims are forced to meet daily cyberfraud quotas under constant violence and coercion, a system of digital exploitation sustained by human suffering. Survivors describe the moral conflict of deceiving others online and the punishment they face when they refuse to comply (UNODC, 2024).
This raises a critical question: are existing international and regional frameworks, such as those of the UN and ASEAN, equipped to address the human rights challenges posed by AI-driven trafficking and online fraud?
Artificial intelligence in international law and regional frameworks
Despite rapid advances in AI, international law continues to lag behind, with no convention regulating its use. However, on March 21, 2024, the United Nations General Assembly adopted the first resolution on AI (A/RES/78/265), which refers to artificial intelligence systems in the non-military domain, understood as “human-centric, reliable, explainable, ethical, inclusive, in full respect, promotion and protection of human rights and international law, privacy preserving, sustainable development oriented, and responsible” (United Nations, 2024).
The resolution serves as a basis for future multilateral treaties on the subject. It recognizes the potential of AI to advance the Sustainable Development Goals and digital governance, calling on States and stakeholders to develop and support regulatory frameworks (United Nations, 2024). Yet it is a non-binding document that leaves major blind spots if we dive deep into AI facilitating cybercrime and human trafficking.
Existing UN international instruments, such as the Convention against Transnational Organized Crime (UNTOC) and its supplementary protocols, laid the foundations for defining and prosecuting “human trafficking” (United Nations, n.d.). However, this instrument, adopted in 2000, does not consider how new technologies and AI are transforming criminal activities.
To address the legal loophole, in December 2024, the UN adopted the Convention against Cybercrime (UNCC). The treaty provides States with a framework for combating crimes committed via the internet, including online fraud. It includes procedural tools for investigation and evidence management, as well as mechanisms for international cooperation and legal assistance (United Nations, n.d.). Despite its promising content, the Convention has not entered into force because, although more than 70 countries have signed it, it requires ratification by 40 member states to be legally binding (United Nations, n.d.).
In October 2025, seven of the ten Southeast Asian countries signed the UNCC. This highlights interest in addressing this issue at the international and regional levels within the Association of Southeast Asian Nations (ASEAN).
In 2015, the Association adopted the ASEAN Convention Against Trafficking in Persons, Especially Women and Children (ACTIP), a binding treaty recognizing human trafficking as a violation of human rights and human dignity (ASEAN, n.d.). While narrower in scope than the UNTOC, the ACTIP has a stronger focus on prevention, victim protection, and repatriation, particularly for women and children (ASEAN, n.d.).
Although ACTIP does not have supplementary protocols, its implementation is guided by a Plan of Action and complemented by the ASEAN Multi‐Sectoral Work Plan Against Trafficking in Persons 2023-2028, which considers the best interests of the child, gender equality, and social inclusion (ASEAN, 2023). In addition to these efforts, ASEAN’s 2017 Declaration to Prevent and Combat Cybercrime promotes regional cooperation and collaboration with partners such as INTERPOL and invites member nations to adhere to relevant regional or international instruments to address this issue (ASEAN, 2017).
Beyond anti-trafficking, the Association has advanced efforts in digital governance, including the digital economy and artificial intelligence matters. At the 4th ASEAN Digital Ministers’ Meeting in 2024, member states adopted the “Singapore Declaration” (The Asia Group, n.d.), which introduced the ASEAN Guide on AI Governance and Ethics and outlined principles for the responsible design, development, and implementation of AI systems (ASEAN, n.d.). This was complemented by the 2025 Expanded ASEAN Guide on AI Governance and Ethics – Generative AI, which addresses the risks of Gen AI, such as disinformation and deepfakes (ASEAN, n.d.), intertwined with human trafficking and cybercrimes, typical of online scam centers.
How the Technology Impacts Rights in Practice
Exploitation today can often start with a click. AI and algorithmic systems have reshaped global recruitment, communication, and surveillance dynamics. Yet in the context of online scam centers in Southeast Asia, these same technologies have intensified old patterns of exploitation, giving rise to a new form of digital slavery (UNODC, 2024; Interpol, 2025). What was once designed to facilitate efficiency and connectivity is now being used to deceive and control, undermining fundamental human rights in practice.
AI-powered recruitment mechanisms enable traffickers to create hyper-personalized and persuasive job offers, generated through the analysis of users’ data and behavioral profiles. By exploiting vulnerabilities linked to poverty and digital illiteracy, these systems lead individuals into fraudulent employment into a path to forced labor (ICMPD, 2025; UNODC, 2025). As a result, they directly violate fundamental human rights, like liberty and security of person (Universal Declaration of Human Rights [UDHR], 1948, art. 3), freedom from slavery and forced labor (International Covenant on Civil and Political Rights [ICCPR], 1966, art. 8), and the right to just and favorable work conditions (International Covenant on Economic, Social and Cultural Rights [ICESCR], 1966, art. 7).
Once trafficked, individuals often have their documents confiscated and are forced under coercion to commit online fraud, a digital manifestation of forced criminality (UNODC, 2024). According to the UN Office on Drugs and Crime (2025), the automation of fraudulent activities through AI-based communication tools and chatbots blurs the line between victim and perpetrator, complicating law enforcement and protection responses. From a human rights law perspective, such practices infringe the principle of non-punishment for victims of trafficking, enshrined in Article 26 of the Council of Europe Convention on Action against Trafficking in Human Beings (2005) and recognized in international customary law (Gallagher & Ezeilo, 2019).
Weak regulation and limited accountability from digital platforms further fuel these violations. Many online job portals and social media companies neglect to conduct human rights due diligence, allowing AI-generated scams to spread unchecked. This regulatory gap undermines the corporate responsibility to respect human rights under the UN Guiding Principles on Business and Human Rights (United Nations, 2011). In effect, companies that host and ignore such content become passive enablers of trafficking and fraud, eroding the right to effective remedy and access to justice (UDHR, art. 8).
Technology also affects the right to privacy (ICCPR, art. 17). Victims’ personal data are systematically collected and exploited to manipulate and monitor them, while AI-enhanced surveillance systems in scam centers track their communications and performance quotas (UNODC, 2024). The same AI-driven tools used for targeted advertising are thus repurposed to reinforce control, creating a feedback loop of exploitation sustained by automation.
However, AI is not inherently harmful; its impact depends on its governance and intent. There are notable positive applications where technology strengthens protection. For example, Singapore’s ScamShield app uses machine learning to block scam calls and texts, helping citizens prevent fraud and promoting the right to security and protection from exploitation (GovTech Singapore, n.d.). ASEAN’s regional cybersecurity strategy also promotes cooperation to enhance digital resilience and reduce cross-border trafficking (ASEAN, n.d.). These examples demonstrate that responsible AI governance can support states’ duty to protect individuals from abuse (UN Human Rights Council, 2021).
Nonetheless, these efforts remain fragmented. In the absence of harmonized regional standards on AI and human rights, states continue to rely on uneven domestic legislation. Weak enforcement and jurisdictional gaps enable traffickers to evade accountability by operating across both digital and territorial borders (Interpol, 2025). As the UN Special Rapporteur on Trafficking in Persons noted, the digital transformation of trafficking requires updated frameworks that integrate ethical AI principles with existing human rights norms (UNHRC, 2023).
Ultimately, the dual nature of AI, its potential for both empowerment and exploitation, highlights the urgent need for human rights-based digital governance. The misuse of AI in scam centers shows how technology can deepen inequalities and systemic vulnerabilities when deployed without transparency or oversight. Yet, when guided by accountability, data protection, and human rights due diligence, AI can become a tool for prevention, detection, and redress. Achieving this balance between innovation and protection requires not only technological expertise but also a solid grounding in international human rights law.
Toward Human Rights–Based Digital Governance: Key Recommendations
To move from diagnosis to solution, States and regional frameworks must operationalize the human rights obligations discussed above. The following recommendations propose some practical pathways for integrating due diligence, accountability, and ethical governance into AI and digital regulation.
1. Modernize international frameworks and strengthen regional cooperation
There are valuable international instruments for addressing the problems of human trafficking and cybercrime; however, some of them are outdated and no longer respond to the current threats arising from the rapid expansion of AI. It is necessary to work multilaterally to define agreements in this area that strengthen digital governance, as well as AI protocols that complement existing legislation.
At the regional level, in areas such as the European Union and Southeast Asia, countries have advanced more rapidly in adapting to the new digital landscape; nevertheless, they should focus on implementing their initiatives to keep pace with information and communication technologies and close the digital gaps within their respective regions and nations.
2. Establish cross-border accountability and joint investigations
States and regional bodies should establish cross-border digital accountability mechanisms to investigate and dismantle AI-driven trafficking and scam networks. National responses alone are insufficient; cooperation through regional and international frameworks (e.g., ASEAN, UNODC–INTERPOL) is essential. These initiatives should use AI auditing tools to trace algorithmic fraud patterns while respecting privacy standards, reinforcing States’ duty under the ICCPR and UN Guiding Principles to protect individuals from tech-enabled human rights abuses.
3. Require human rights due diligence from digital platforms
States should require digital platforms and job-advertising intermediaries to conduct human rights due diligence on AI-based recruitment and advertising systems. This process, developed with companies and civil society, should include regular risk assessments, algorithmic transparency reports, and grievance mechanisms for users affected by AI-generated scams or deceptive recruitment practices.
In line with the UN Guiding Principles on Business and Human Rights (United Nations, 2011), companies must cooperate with international regulators and law enforcement agencies to strengthen digital accountability to prevent trafficking or forced labor.
List of references
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Authors’ short bio
Marta Benítez Brañas is a child rights and child protection specialist with an interdisciplinary background spanning psychology, social education, juvenile justice, and advocacy communications. She holds a Bachelor’s degree in Psychology from the Pontifical University of Salamanca (Spain), a Bachelor’s degree in Social Education from the Open University of Catalonia (Spain), a Master’s degree in Child Psychology from the Autonomous University of Barcelona (Spain), and a Master’s degree in Clinical Psychology from the Open University of Catalonia (Spain). Her experience includes engagement with the United Nations Committee on the Rights of the Child in Geneva, as well as key roles within government child protection and juvenile justice services in Spain. She combines direct psychosocial support expertise with research and policy analysis skills. Her current PhD research at the University for Peace (Costa Rica) examines the intersection of children’s rights, ethics, and artificial intelligence in humanitarian and conflict settings
Daniela Gil is a Mexican diplomat with more than 25 years of professional experience. She holds a Bachelor’s Degree in International Relations from the ITESM (Mexico) and a Master’s Degree in Diplomatic Studies from the Diplomatic Academy of Mexico, the Matias Romero Institute. She is now enrolled in the online M. A. in Sustainable Peace in the Contemporary World at the University for Peace (Costa Rica). She currently serves as Deputy Head of Mission at the Embassy of Mexico in the Philippines. She has been Deputy Head of Mission at the Mexican Embassy in New Zealand, Deputy Consul General of Mexico in Toronto, Canada, and Responsible for the Cooperation Section at the Mexican Embassy in Costa Rica. She is a Member of the Mexican Council on Foreign Relations (COMEXI), and the Pacific Economic Cooperation Council-Mexican Chapter (PECC-Mexico). She has published articles in Costa Rica, Philippines, Mexico, and New Zealand.
Daniela Bolívar is a Bolivian creative communication strategist and collective leadership specialist with a background in visual communication and graphic design for impact-driven organizations with over 20 years of experience. For the past 12 years, she has supported programs and organizations that help scale social enterprises across Latin America, Africa, and Europe. Her work centers on translating complex ideas into accessible campaigns and visual narratives, combining graphic design, strategic communication, and instructional design. She has collaborated with organizations such as Roots of Impact, Swiss Agency for Development and Cooperation, Ashoka, Bridge for Billions, Impact-Linked Finance Fund, and multiple ecosystem builders working on innovative finance, sustainability, and social entrepreneurship.
Disclaimer: The authors used OpenAI’s ChatGPT (2025 version) as a support tool for language editing and for suggesting alternative phrasings. All ideas, legal analysis, selection and interpretation of sources, and final wording were developed and verified by the authors. Any remaining errors are the authors’ own responsibility.




