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More Than Foot Traffic: Why Anti-Trafficking Efforts Must Take Precedence Among 2026 FIFA World Cup Preparations

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Photo Source: James, One Shot for Glory, Flickr (Jan. 27, 2010) (CC BY 2.0)

By: Skylar Glass*                                                                               Posted: 10/17/2025

 

In mid-summer 2026, the United States, Mexico, and Canada will co-host the FIFA World Cup, where an estimated six and a half million people are expected to attend the tournament.[1]  To prepare for the influx of fans, large-scale preparations are required of each host country and city, including stadium upgrades, creating environmental and sustainability plans, and ensuring lodging and transportation services are able to accommodate fans and locals alike.[2]  In addition to these oft-cited preparations, another area that deserves substantial public attention is the efforts required to successfully combat human trafficking.[3]  Although trafficking exists year-round and does not merely emerge when there is a major sporting event, these events increase the potential for trafficking because traffickers identify the large crowds as an opportunity for profit.[4]  However, despite the importance of anti-trafficking efforts, the Department of Health and Human Services (“HHS”) awarded the 2026 FIFA World Cup anti-trafficking grant to Compass Connections, a company currently under investigation for improper sponsorship of migrant children at locations potentially associated with child-trafficking rings.[5]  At the time this decision was made, advocates had already raised concerns about the heightened risk of trafficking in certain U.S. host cities for the 2026 World Cup[6]

 

Brief Background of Trafficking in the United States

Human trafficking is a crime where traffickers use force, fraud, or coercion to exploit a person into committing acts against their will.[7]  The two main types of trafficking are sex trafficking and labor trafficking.[8]  Sex trafficking occurs where the trafficker’s ultimate purpose is to obtain a commercial sex act from the victim, whereas labor trafficking happens where traffickers exploit an individual for involuntary labor.[9]  In both scenarios, traffickers often exercise physical and emotional control, including victim isolation, which makes it hard for the victim to exit the cycle of exploitation or seek help from others.[10]

Due to the nature of the crime, gathering concrete data that reflects the extent of trafficking in the United States is difficult; however, it has been noted that more than ten thousand instances of human trafficking were reported to the National Human Trafficking Hotline in 2021 alone.[11]  That large number is fueled by systemic inequalities that repeatedly cause certain groups to be more vulnerable than others, and traffickers rely on exploiting this vulnerability to enable their criminal operations.[12]  Various government agencies are responsible for conducting efforts to combat human trafficking and exploitation in the United States, largely due to the implementation of the Trafficking Victims Protection Act of 2000 (“TVPA”).[13]

 

Approaches to Combat Trafficking During the FIFA World Cup

Some previous World Cup host countries conducted mass public awareness campaigns to educate their citizens and attempt to clarify certain identifiers of trafficking.[14]  Contrarily, when Russia hosted the World Cup in 2018, it failed to conduct any major anti-trafficking efforts and was also criticized for failing to implement their trafficking laws leading up to and during the event.[15]  As a result, women have come forward detailing how they were trafficked for sexual exploitation.[16]  Similarly, Qatar failed to conduct any serious anti-trafficking efforts prior to it hosting the 2022 World Cup, which caused it to face mass scrutiny, especially after Russia’s recent failure only a few years prior.[17]  In fact, reports revealed that Qatar exploited migrant workers when assisting in the construction of the stadiums and facilities used for the 2022 World Cup in the years leading up to the event and also underreported worker deaths that occurred while working on these facilities.[18]

In response to these failures and the ensuing public scrutiny, FIFA began implementing human rights initiatives as part of their preparation for the 2026 World Cup.[19]  FIFA required all host committees to develop human rights action plans to address potential human rights violations during the Cup, including human trafficking.[20]  Despite these well-intentioned efforts, FIFA lacks the enforcement power necessary to ensure that host countries actually follow through with their commitments, meaning the agreements and action plans are not legally binding.[21]  In addition, FIFA faces scrutiny from many human rights organizations who claim that the organization is failing to take a clear stance against human rights violations, despite its newfound commitment to human rights issues.[22]  For example, FIFA has a complaint mechanism which provides a platform for victims to report human rights abuses in connection with FIFA.[23]  However, FIFA’s limited release of information about its functionality makes it unclear what the mechanism actually accomplishes, casting doubt as to whether it addresses such complaints sufficiently.[24]  Advocates suggest that to actually enforce human rights, FIFA must move beyond releasing “policy statements” for the media and instead work towards the creation of legally binding human rights plans with future host countries.[25]

 

Concerns About the Recent Grant Transfer to Compass Connections

Recently, the HHS awarded the anti-trafficking grant to Compass Connections.[26]  By receiving the grant, Compass Connections must operate the National Human Trafficking hotline, which is the primary hotline to report trafficking nationwide.[27]  Historically, the grant was given to Polaris, an organization with a specific mission to end trafficking using survivor-centered and trauma-informed tools.[28]  In contrast, while Compass Connections does have experience managing complex hotline systems, its mission does not specifically center on providing assistance to trafficking survivors.[29]  This, coupled with the fact that Compass Connections is under investigation for mishandling a hotline for migrant children, has caused concern about the company’s ability to effectively respond to survivor concerns.[30]

The transfer of the anti-trafficking hotline grant to Compass Connections directly intersects with the operational needs of the 2026 World Cup.[31]  During large-scale international events, hotline systems often serve as one of the few real-time tools available for identifying and responding to trafficking incidents.[32]  Because the World Cup will involve dozens of host cities across the United States, a centralized and reliable hotline becomes even more critical.[33]  Yet, rather than signaling a strengthened national commitment to anti-trafficking ahead of the tournament, the grant transfer to Compass introduced ambiguity around federal decision-making regarding trafficking.[34]  Although Compass is expected to fulfill its duties, the timing and nature of the change in spite of allegations against the company have created a perception that efforts to combat trafficking are unsubstantiated and made without genuine consideration for survivors.[35]  As a result, it is important for FIFA and local host committees to demonstrate that trafficking prevention remains an active part of World Cup planning and is not merely performative.[36]

The effectiveness of anti-trafficking systems during the World Cup will depend on a complex, concerted effort of behalf of FIFA, anti-trafficking organizations, and newly appointed Compass Connections.[37]  Evidently, these efforts warrant the same level of attention as the infrastructure projects that so often dominate World Cup planning.[38]  Those overseeing World Cup preparations should take advocates’ recommendations seriously and prioritize the fight against human trafficking.[39]

*Staff Writer, Jeffrey S. Moorad Sports Law Journal, J.D. Candidate, May 2027, Villanova University Charles Widger School of Law.

 

[1] See FIFA World Cup 26: Host Countries, Cities, Dates, Teams, Tickets, Qualifying and More, FIFA (Oct. 7, 2025), https://www.fifa.com/en/tournaments/mens/worldcup/canadamexicousa2026/articles/fifa-world-cup-2026-hosts-cities-dates-usa-mexico-canada (detailing logistics of World Cup 2026, including host cities); see also Safid Deen, FIFA Says World Cup, Club World Cup Could Bring $47B in Economic Impact to US, USA Today (Apr. 8, 2025, at 09:26 ET), https://www.usatoday.com/story/sports/soccer/2025/04/08/fifa-world-cup-2026-economic-impact-us/82988176007/ (explaining World Cup expected to have tremendous impact on U.S. economy due to bringing in large crowds).

[2] See, e.g., Dominic Anthony Wash, Houston’s NRG Stadium to Receive Upgrades Ahead of 2026 FIFA World Cup, Hou. Pub. Media (Jan 28, 2025, at 13:39 CT), https://www.houstonpublicmedia.org/articles/news/sports/world-cup/2025/01/27/511988/houstons-nrg-stadium-to-receive-upgrades-ahead-of-2026-fifa-world-cup (noting Houston stadium to receive $15 million in upgrades before 2026 World Cup); see also Planning for the 2026 FIFA World Cup, Fed. Highway Admin., https://ops.fhwa.dot.gov/pse/spotlight/2026worldcup.htm (last visited Sep. 27, 2025) (listing host cities and citing specific engagement efforts required of transportation services).

[3] See World Cup 2026: An Opportunity to Lead on Human Trafficking, Polaris: Blog (June 23, 2022), https://polarisproject.org/blog/2022/06/world-cup-2026-an-opportunity-to-lead-on-human-trafficking/ (asserting anti-trafficking efforts requires systemic and infrastructural approach, not merely awareness campaigns aimed at public).

[4] See The Super Bowl Myth, Polaris: Blog (Feb. 5, 2016), https://polarisproject.org/blog/2016/02/the-super-bowl-myth/ (“Sporting and other major venue events . . . are a magnet for business of all kinds, including human trafficking.  While traffickers are savvy businessmen and go where the demand is, they also know where law enforcement is focusing their efforts and are constantly changing their tactics.”).

[5] See Letter from Charles E. Grassley, Sen., Iowa, to Sonya Thompson, Exec. Dir., Compass Connections, at 1 (Feb. 21, 2024), https://www.grassley.senate.gov/imo/media/doc/grassley_to_compass_connections_-_hhs_contractors_and_grantees.pdf (stating whistleblowers notified Committee on the Budget of potential improper care and vetting of migrant children).

[6] See, e.g., Katie Sobko, How NJ Is Seeking to Prevent ‘Abuse and Exploitation’ Ahead of FIFA World Cup 2026, North Jersey (June 10, 2024, at 11:17 ET), https://www.northjersey.com/story/sports/mls/worldcup/2024/06/10/fifa-world-cup-2026-nj-human-trafficking-concerns/74015922007/ (documenting two New Jersey advocates’ concerns about potential for trafficking in state because it is “major transportation center”).

[7]  See Human Trafficking, U.S. Dep’t of Just., https://www.justice.gov/humantrafficking (last visited Sep 28, 2025) (noting elements of trafficking crime).

[8] See id. (acknowledging two primary forms that trafficking may take).

[9] See Sex Trafficking, Nat’l Hum. Trafficking Hotline, https://humantraffickinghotline.org/en/human-trafficking/sex-trafficking (last visited Sep. 28, 2025) (describing crime of sex trafficking); see also Labor Trafficking, Nat’l Hum. Trafficking Hotline, https://humantraffickinghotline.org/en/human-trafficking/sex-trafficking (last visited Sep. 28, 2025) (describing crime of labor trafficking).

[10] See Human Trafficking Facts, Polaris: Myths, Facts, and Statistics, https://polarisproject.org/myths-facts-and-statistics/ (last visited Sep. 28, 2025) (discussing tactics employed by traffickers to exploit victims).

[11] See id. (documenting 10,359 reports of human trafficking in 2021); see also Gaps in Reporting Human Trafficking Incidents Result in Significant Undercounting, Nat’l Inst. of Just. (Aug. 4, 2020), https://nij.ojp.gov/topics/articles/gaps-reporting-human-trafficking-incidents-result-significant-undercounting (recognizing not all trafficking incidents will be reported and trafficking is difficult for law enforcement to identify).

[12] See Social Justice and Human Trafficking Are Intrinsically Interconnected, Survive & Thrive Advoc. Ctr., https://surviveandthriveadvocacy.org/social-justice/ (last visited Sep. 28, 2025) (“In almost every instance, human trafficking victims are victims of institutional oppression and systemic racism, classism, sexism, agism, ableism, and heterosexism before they become exploited by a trafficker.”).

[13] See Federal Government Efforts to Combat Human Trafficking Fact Sheet, Off. on Trafficking in Persons, https://acf.gov/archive/otip/fact-sheet/federal-government-efforts-combat-human-trafficking (last visited Sep. 29, 2025) (listing government agencies responsible for combatting trafficking as result of TVPA).

[14] See Richard Lapchick, The State of Human Trafficking and Sports, ESPN (Jan. 29, 2019, at 12:57 ET), https://www.espn.com/espn/story/_/id/25876477/the-rise-exposure-human-trafficking-sports-world (highlighting fact that Germany, Brazil, and South Africa had public awareness campaigns prior to hosting World Cup).

[15] See Laura Dean, A Stage for Human Trafficking: The World Cup in Russia, Wilson Ctr. (June 18, 2018), https://www.wilsoncenter.org/blog-post/stage-for-human-trafficking-the-world-cup-russia (discussing lack of human trafficking campaign in Russia coupled with lax law enforcement policies when trafficking incident is identified).

[16] See How Nigerians Were Trafficked at Russia’s 2018 World Cup, Freedom United (Mar. 7, 2019), https://www.freedomunited.org/news/how-nigerians-were-trafficked-at-russias-2018-world-cup/ (documenting survivors’ stories after being trafficked during Russia World Cup).

[17] See Minky Worden, The World Cup is Exciting, Lucrative, and Deadly, Hum. Rts. Watch (Aug. 23, 2022, at 17:00 EDT), https://www.hrw.org/news/2022/08/23/world-cup-exciting-lucrative-and-deadly (explaining Qatar faced major criticism from human rights organizations for violating workers’ rights and FIFA faced criticism for failing to address such allegations).

[18] See id. (stating Qatar failed to reach out to several countries to confirm deaths of migrant workers and thus skewed death count); see also Reality Check: Migrant Workers Rights with Four Years to Qatar 2022 World Cup, Amnesty Int’l (Feb. 5, 2019), https://www.amnesty.org/en/latest/campaigns/2019/02/reality-check-migrant-workers-rights-with-four-years-to-qatar-2022-world-cup/ (identifying Qatar’s lack of care for workers’ rights was in “spotlight” leading up to 2022 World Cup).

[19] See Charlotte Kramon, FIFA Tests New Human Rights Strategy for World Cup Games, and Advocates Are Skeptical, PBS (Aug. 12, 2025, at 18:16 EDT), https://www.pbs.org/newshour/world/fifa-tests-new-human-rights-strategy-for-world-cup-games-and-advocates-are-skeptical (acknowledging FIFA’s new human rights strategy but noting critics describe approach as “watered down”).

[20] See id. (describing FIFA’s human rights strategy).

[21] See Andrew Moore, FIFA World Cup: Can It Leave Behind a Positive and Lasting Human Rights Legacy?, NC State Univ. (July 29, 2025), https://cnr.ncsu.edu/news/2025/07/fifa-world-cup-human-rights-legacy/ (noting concerns that nature of FIFA’s human rights approach is “voluntary” and relies largely on host countries, not on enforcement by FIFA).

[22] See Ninety U.S. Civil Society Groups Express “Deep Concern” to FIFA About Immigration Policies Ahead of 2026 World Cup, Robert F. Kennedy Hum. Rts. (July 2, 2025), https://rfkhumanrights.org/press/ninety-u-s-civil-society-groups-express-deep-concern-to-fifa-about-immigration-policies-ahead-of-2026-world-cup/ (summarizing civil rights groups’ concerns regarding FIFA, particularly its reluctance to address state of human rights in polarized political climate of U.S.).

[23] See Human Rights and Anti-Discrimination Grievance Mechanism, FIFA, https://inside.fifa.com/human-rights/fifa-grievance-mechanism (last visited Oct. 5, 2025) (detailing grievances that should be reported and how to report them).

[24] See Anna van der Veen, FIFA’s Self-Constitutionalisation and Its Impact on Access to Effective Remedy, Tilburg L. Sch., at 29 (Aug. 2022) (J.D. thesis, Tilburg Law School), https://arno.uvt.nl/show.cgi?fid=159716 (arguing FIFA’s complaint mechanism has several negative attributes that can prevent it from being effective).

[25] See Playing a Dangerous Game?, Amnesty Int’l (June 6, 2024), https://www.amnesty.org/en/latest/news/2024/06/global-fifa-must-protect-human-rights-by-securing-binding-safeguards-from-2030-and-2034-world-cup-bidders-new-report/ (asserting FIFA must prioritize human rights issues, particularly during bid process before selecting host countries).

[26] See Press Release, Admin. for Child. & Fams. HHS Invests $35 Million to Bolster National Human Trafficking Hotline and Protect Survivors, (Sep. 22, 2025), https://acf.gov/media/press/2025/hhs-invests-35-million-human-trafficking (announcing HHS award of grant).

[27] See id. (explaining Hotline responds to calls, texts, and chats by survivors and is available 24/7).

[28] See Our Work, Polaris, https://polarisproject.org/our-work/ (last visited Sep. 28, 2025) (noting Polaris was founded specifically to combat trafficking).

[29] See About Us, Compass Connections, https://compassconnections.org/landing/ (last visited Sep. 28, 2025) (declaring their mission to promote child welfare and connect families worldwide).

[30] See Letter from Charles E. Grassley to Sonya Thompson, supra note 5, at 1 (detailing mishandling incident and noting importance of determining severity of problem through investigation).

[31] See The National Human Trafficking Hotline, Polaris, https://polarisproject.org/national-human-trafficking-hotline/ (last visited Sep. 28, 2025) (identifying trafficking hotline and noting it is available in more than 200 languages). The Hotline will remain the primary hotline for human trafficking concerns during the 2026 World Cup. See Report Human Trafficking, Nat’l Hum. Trafficking Hotline, https://humantraffickinghotline.org/en/report-trafficking (last visited Oct. 10, 2025) (encouraging trafficking victims to report all instances, except immediate emergencies, to hotline).

[32] See Human Trafficking Hotlines, U.S. Dep’t of State, https://www.state.gov/human-trafficking-hotlines (last visited Sep. 28, 2025) ([National human trafficking hotlines] also often serve as the first point of contact for the public on human trafficking concerns.”).

[33] See FIFA World Cup 26: Host Countries, Cities, Dates, Teams, Tickets, Qualifying and More, supra note 1 (listing host cities across U.S.).

[34]  See Letter from Charles E. Grassley to Sonya Thompson, supra note 5, at 1 (revealing concerns about Compass Connections company’s operations).  The grant-transfer decision follows other federal action around human trafficking, including the Trump administration’s cut of certain funding.  See Mel Leonor Barclay, Marissa Martinez, & Jennifer Gerson, Trump Administration Pulls back on Work Combatting Human Trafficking, Long a Top GOP Priority, 19th (July 18, 2025, at 15:46 ET), https://19thnews.org/2025/07/trump-administration-human-trafficking/ (observing Trump administration made cuts to funding previously used to combat human trafficking).

[35] See Jennifer Suchland, What’s Wrong with the US Federal Response to “Sex Trafficking”?, Univ. of Minn. (Jan. 11, 2023), https://genderpolicyreport.umn.edu/whats-wrong-with-the-us-federal-response-to-sex-trafficking/ (“There is a profound human rights deficit at the core of US federal anti-trafficking policy.”).

[36] See World Cup 2026: An Opportunity to Lead on Human Trafficking, supra note 3 (urging structural, systemic approach to combat human trafficking prior to 2026 event).

[37] See, e.g., Nick Webster, SeattleFWC26 Teams Up with BEST to Battle Trafficking and Slavery, Inside World Football (Sep. 30, 2025), https://www.insideworldfootball.com/2025/09/30/seattlefwc26-teams-best-battle-trafficking-slavery (highlighting Seattle’s effort to go beyond minimum standards and educate local businesses about human trafficking for free in preparation for World Cup).  For further discussion of the approach suggested by advocates, and FIFA’s partial adoption of such suggestions, see supra notes 20– 25 and accompanying text.

[38] See World Cup 2026: An Opportunity to Lead on Human Trafficking, supra note 3 (arguing awareness campaigns will not themselves prevent trafficking and thus prevention requires organized, informed approach).

[39] See, e.g., Joyce Chu, Santa Clara County Braces for Trafficking Risks Ahead of Super Bowl, World Cup, Loc. News Matters (Oct. 10, 2025), https://localnewsmatters.org/2025/10/10/santa-clara-county-braces-for-trafficking-risks-ahead-of-super-bowl-world-cup/ (adopting survivor- and advocate-centered approach to combat trafficking in preparation for 2026 Super Bowl and World Cup).