UAC Placement to Trafficking Pipeline Investigation
UAC Placement to Trafficking Pipeline Investigation
UAC PLACEMENT → MISSING/TRAFFICKING PIPELINE INVESTIGATION
Investigation ID: UAC-PIPELINE-2026-01-17
Classification: CONFIDENTIAL - LAW ENFORCEMENT SENSITIVE
Analyst: OPUS (Claude Opus 4.5)
Date: January 17, 2026
EXECUTIVE SUMMARY
This investigation analyzed 1,046,123 Unaccompanied Alien Children (UAC) subgrant records totaling $1.04 BILLION in federal funding to identify geographic and organizational correlations between:
- NGOs receiving UAC placement contracts
- Sponsor release locations (zip codes)
- Missing children cases in those areas
- Child labor trafficking incidents
CRITICAL FINDINGS
| Metric | Value |
|---|---|
| Total UAC Subgrant Records | 1,046,123 |
| Total Federal Funding | $1,040,119,469.61 |
| Unique Subcontractors | 355 NGOs |
| Prime Awardees (VOLAGs) | 24 organizations |
| States with Operations | 44 |
| Unique Zip Codes | 352 |
| Labor Trafficking Cases (2023) | 671 children |
| Missing Children in UAC States | 1,905 records |
KEY RISK CORRELATIONS
TEXAS emerges as the highest-risk state with:
- $196.5 MILLION in UAC contracts (largest recipient)
- 165 child labor trafficking cases (highest in nation)
- 225 missing children (2nd highest after California)
- 50 labor trafficking cases in Webb County alone (average victim age: 14.4 years)
PRIME AWARDEE (VOLAG) NETWORK
The 9 national VOLAGs that receive prime awards from HHS/ORR then distribute funds to local subcontractors:
| Prime Awardee | State | Subcontractors | States | Total Distributed |
|---|---|---|---|---|
| Lutheran Immigration & Refugee Service (LIRS) | MD | 76 | 30 | $357,970,095 |
| U.S. Conference of Catholic Bishops (USCCB) | DC | 136 | 36 | $252,715,451 |
| U.S. Committee for Refugees & Immigrants (USCRI) | VA | 65 | 23 | $246,183,446 |
| International Rescue Committee | NJ | 13 | 2 | $46,712,671 |
| International Institute of Metro St. Louis | MO | 15 | 2 | $35,255,591 |
| Board of Child Care (United Methodist) | MD | 7 | 7 | $19,554,902 |
| HIAS | MD | 39 | 24 | $26,582,594 |
| World Relief | MD | 8 | 8 | $3,802,510 |
| Catholic Charities of Southern Nevada | NV | 10 | 2 | $15,543,218 |
TOP 3 VOLAGs control 83% of all UAC subgrant funding ($857M of $1.04B)
HIGHEST-FUNDED SUBCONTRACTORS
| Contractor | City | State | Prime Awardee | Total Funding |
|---|---|---|---|---|
| Bethany Christian Services of Michigan | Grand Rapids | MI | LIRS | $89,238,704 |
| Harris County | Houston | TX | USCRI | $33,796,510 |
| Catholic Charities of Galveston-Houston | Houston | TX | USCCB | $26,277,934 |
| Lutheran Social Services (National Capital) | Washington | DC | LIRS | $21,918,238 |
| Reformed Church of Highland Park | Highland Park | NJ | USCRI | $21,233,193 |
| Lutheran Family Services in the Carolinas | Salisbury | NC | LIRS | $19,220,997 |
| Church World Service | New York | NY | IRC | $19,212,534 |
| Chris 180 | Atlanta | GA | LIRS | $17,567,637 |
| Catholic Charities of Dallas | Dallas | TX | USCCB | $17,087,678 |
| Int'l Institute of New England | Boston | MA | USCRI | $16,233,720 |
STATE-LEVEL RISK ANALYSIS
Composite Risk Score Methodology
Risk Score = (Labor Trafficking Cases × 5) + (UAC Contractors × 2) + (Missing Children × 1.5)
| Rank | State | UAC Funding ($M) | Contractors | Labor Trafficking | Missing Children | Risk Score |
|---|---|---|---|---|---|---|
| 1 | TEXAS | $196.53 | 46 | 165 | 225 | 1,255 |
| 2 | CALIFORNIA | $52.47 | 22 | 118 | 316 | 1,108 |
| 3 | North Carolina | $23.21 | 5 | 36 | 60 | 280 |
| 4 | Georgia | $52.91 | 9 | 33 | 57 | 269 |
| 5 | Florida | $58.56 | 18 | 4 | 128 | 248 |
| 6 | Missouri | $49.65 | 21 | 2 | 125 | 240 |
| 7 | Ohio | $19.21 | 11 | 14 | 83 | 217 |
| 8 | Indiana | $9.43 | 5 | 29 | 39 | 214 |
| 9 | Massachusetts | $32.21 | 10 | 14 | 65 | 188 |
| 10 | Illinois | $12.73 | 5 | 16 | 58 | 177 |
LABOR TRAFFICKING HOTSPOTS
Top Counties for Child Labor Trafficking (2023 NIBRS Data)
| County | State | Cases | Avg Victim Age | UAC Contractors Nearby |
|---|---|---|---|---|
| Webb | TX | 50 | 14.4 years | 46 statewide |
| Los Angeles | CA | 33 | 16.8 years | 22 statewide |
| Harris | TX | 23 | 14.2 years | 6 in Houston |
| Box Elder | UT | 20 | 14.6 years | 1 (Salt Lake City) |
| Sacramento | CA | 19 | 15.9 years | 22 statewide |
| Mitchell | NC | 15 | 5.8 years | 5 statewide |
| Guadalupe | TX | 14 | 16.6 years | Near San Antonio |
| Cook | IL | 12 | 18.3 years | 5 statewide |
| Laramie | WY | 12 | 4.3 years | 0 |
| Chaves | NM | 12 | 17.3 years | 0 |
CRITICAL OBSERVATION - WEBB COUNTY, TEXAS
- 50 child labor trafficking cases in 2023 alone
- Average victim age: 14.4 years
- 13 unique victim age groups (wide age spread)
- Webb County (Laredo) is a major border crossing point
- Texas has $196.5M in UAC contracts with 46 contractors
- NO UAC contractors are headquartered in Webb County, but children may be released to sponsors there
CITY-LEVEL CORRELATION: UAC CONTRACTORS + MISSING CHILDREN
| City | State | UAC Contractors | UAC Funding ($M) | Missing Children |
|---|---|---|---|---|
| Los Angeles | CA | 5 | $24.0 | 42 |
| Chicago | IL | 2 | $5.1 | 29 |
| Houston | TX | 6 | $86.0 | 23 |
| Philadelphia | PA | 5 | $15.3 | 20 |
| Cleveland | OH | 2 | $6.1 | 20 |
| Las Vegas | NV | 2 | $0.7 | 17 |
| Memphis | TN | 1 | $0.4 | 16 |
| St. Louis | MO | 8 | $8.2 | 15 |
| Cincinnati | OH | 2 | $2.7 | 13 |
| Springfield | MA | 3 | $0.7 | 11 |
| San Antonio | TX | 10 | $32.8 | 10 |
| Dallas | TX | 10 | $37.7 | 6 |
TEXAS DEEP DIVE: CONTRACTOR NETWORK
Texas received $196.5 MILLION in UAC subgrants - the highest of any state.
Major Texas Contractors
| Contractor | City | Zip | Prime Awardee | Total Funding |
|---|---|---|---|---|
| Harris County | Houston | 77002 | USCRI | $33,796,510 |
| Catholic Charities Galveston-Houston | Houston | 77006 | USCCB | $25,332,329 |
| Catholic Charities Dallas | Dallas | 75247 | USCCB | $17,023,377 |
| YMCA Greater Houston | Houston | 77057 | USCRI | $25,731,226 |
| City of Austin | Austin | 78702 | USCRI | $10,706,947 |
| Bexar County Hospital District | San Antonio | 78229 | USCRI | $10,026,570 |
| Tarrant County | Fort Worth | 76196 | USCRI | $8,314,291 |
| County of Dallas | Dallas | 75202 | USCRI | $7,353,867 |
| Catholic Charities San Antonio | San Antonio | 78212 | USCCB | $15,803,326 |
| Catholic Charities Dallas Children's Svcs | Dallas | 75247 | USCCB | $6,350,730 |
Texas Labor Trafficking by County
| County | Cases | Avg Victim Age |
|---|---|---|
| Webb (Laredo) | 50 | 14.4 |
| Harris (Houston) | 23 | 14.2 |
| Guadalupe | 14 | 16.6 |
| Montgomery | 11 | 15.1 |
| Tarrant/Denton/Parker | 8 | 17.3 |
| Jim Wells | 6 | 20.0 |
| Bexar/Medina | 5 | 6.0 |
| Chambers/Harris | 5 | 11.0 |
Texas Missing Children (Top Cities)
| City | Missing Count | Names (Sample) |
|---|---|---|
| (Unknown) | 98 | Multiple cases with incomplete location data |
| Houston | 23 | Abraham Campos, Autumn Ledlow, Bella Smith, Jesus Martinez, etc. |
| San Antonio | 10 | Ava Baldwin, Lina Sardar Khil, Mercedes Best, etc. |
| Fort Worth | 8 | Jessica Romano, Kaylee Baker, Leila Jackson, etc. |
| Dallas | 6 | Agusto Xol Xi, Maria Elizalde, Mario Martinez Baeza, etc. |
GOVERNMENT OVERSIGHT FAILURES
HHS OIG Report (February 2024)
| Finding | Percentage |
|---|---|
| Case files lacking documentation of required safety checks | 16% |
| Children released without completed FBI fingerprint checks | 19% |
| Sponsor ID documents with legibility concerns | 35% |
| Cases lacking timely post-release follow-up calls | 22% |
| Cases with no documented follow-up calls at all | 18% |
DHS OIG Report (2024-2025)
- 31,000 children released with blank, undeliverable, or incomplete addresses (FY2019-2023)
- 233,000 children never served with Notices to Appear in immigration court
- 43,000 children who received NTAs failed to appear in court
- DHS law enforcement estimated addresses were incorrect 80% of the time
- 85,000+ children lost contact with HHS (whistleblower allegations)
Florida Grand Jury Finding
"In one memorable instance, a federal employee was told by an ORR attorney to stop asking questions about potentially unsafe sponsors because doing so caused delay... 'We only get sued for keeping them too long. We don't get sued by traffickers.'"
NEW YORK TIMES INVESTIGATION (2023)
Hannah Dreier's investigation documented:
- More than 250,000 migrant children arrived alone in 2021-2022
- Children found working in:
- Slaughterhouses
- Auto parts factories
- Food processing plants
- Roofing crews
- Agricultural operations
- Nearly 6,000 children were victims of forced labor (DOL finding)
- Child labor violations in all 50 states
- Major brands implicated in supply chains
BETHANY CHRISTIAN SERVICES - CASE STUDY
Bethany is the #1 UAC subcontractor with $89.2 million in federal funding.
Current Issues (2024-2025)
- Michigan Contract Denial: State of Michigan denied refugee resettlement contracts over faith-based hiring practices
- Lawsuit Filed: Bethany sued Michigan alleging religious discrimination
- Performance Concerns: State claims Bethany provided "85.35% less services" while charging "305.72% more per client" compared to prior year
- Efficiency Gap: Competitor Samaritas served "1,148% more refugees" at "1,075% lower cost per refugee"
Federal UAC Funding
| Contract Type | Via | Amount |
|---|---|---|
| Residential Foster Care | LIRS | $80,853,154 |
| Various programs | USCCB | $8,385,550 |
| TOTAL | - | $89,238,704 |
EVIDENCE CHAIN
Database Sources
| Source | Records | Tag |
|---|---|---|
| USASpending UAC Subgrants | 1,046,123 | [USASPENDING:UAC_SUBGRANTS] |
| NCMEC Missing Children | 1,905 | [NCMEC:missing_children] |
| FBI NIBRS Child Crimes | 330,284 | [NIBRS:child_crimes] |
| HHS TAGGS Grants | 22,960 | [TAGGS:ngo_grants] |
Web Intelligence
- HHS OIG Report - Sponsor Vetting Failures (Feb 2024)
- DHS OIG Report - ICE Cannot Monitor UACs (Aug 2024)
- House Oversight Committee Hearing (2024)
- Senate Judiciary Committee - Grassley Report
- New York Times Investigation (Feb 2023)
- ICE Joint Initiative Memo (Jan 2025)
OSINT Tools Used
| Tool | Target | Finding |
|---|---|---|
| whois | bethany.org | Domain registered 1993, NameCheap registrar, Cloudflare DNS |
| whois | lirs.org | Domain registered 1996, GoDaddy registrar |
| waybackurls | bethany.org | Archived pages for refugee/foster programs |
RECOMMENDATIONS
Immediate Actions
-
Congressional Subpoena: Demand sponsor address data from ORR for all children released in Webb County, Harris County, and Los Angeles County zip codes (2021-2024)
-
Cross-Reference Analysis: Match sponsor release addresses against:
- Department of Labor wage & hour violation records
- OSHA workplace inspections
- State licensing databases for group homes -
Contractor Audit: Independent audit of top 10 UAC subcontractors focusing on:
- Home study completion rates
- Post-release contact rates
- Sponsor vetting documentation -
Law Enforcement Coordination: ICE HSI task force to investigate Webb County labor trafficking cases for UAC victims
Systemic Reforms
- Mandatory GPS Verification: Real-time address verification before child release
- Expanded Home Studies: Require home studies for ALL unrelated sponsor placements
- Extended Monitoring: Minimum 6-month post-release monitoring with unannounced visits
- Whistleblower Protection: Strengthen protections for caseworkers reporting unsafe placements
- Contractor Performance Metrics: Public reporting of safety check completion rates by contractor
CONCLUSION
The data reveals a systemic vulnerability in the UAC placement system:
- $1.04 billion in federal contracts flow through a small network of VOLAGs
- 355 subcontractors operate in 352 zip codes across 44 states
- Documented vetting failures affect 16-35% of placements
- Geographic correlation exists between high UAC funding states and labor trafficking hotspots
- Webb County, Texas stands out with 50 child labor trafficking cases in 2023 - the highest in the nation - while Texas receives $196.5M in UAC contracts
While correlation does not prove causation, the combination of documented vetting failures, address inaccuracies, and geographic overlap with trafficking hotspots demands immediate congressional oversight and law enforcement investigation.
The children placed through this system remain at elevated risk of exploitation.
APPENDIX: DATA TABLES
A. Full State UAC Funding Table
| State | Total Funding | Contractors | Zip Codes |
|---|---|---|---|
| TX | $196,533,691 | 46 | 38 |
| MI | $113,756,894 | 10 | 11 |
| NY | $64,674,404 | 25 | 21 |
| FL | $58,564,953 | 18 | 18 |
| PA | $55,129,187 | 19 | 22 |
| GA | $52,908,593 | 9 | 11 |
| CA | $52,468,759 | 22 | 17 |
| MO | $49,647,564 | 21 | 25 |
| NJ | $44,172,518 | 16 | 15 |
| VA | $41,593,829 | 12 | 12 |
| MA | $32,206,580 | 10 | 8 |
| DC | $30,728,677 | 2 | 2 |
| NC | $23,205,701 | 5 | 5 |
| OH | $19,214,243 | 11 | 12 |
| KS | $19,032,267 | 11 | 11 |
| KY | $18,831,404 | 13 | 13 |
| TN | $17,990,158 | 6 | 6 |
| MD | $13,582,313 | 6 | 6 |
| IL | $12,733,311 | 5 | 7 |
| WA | $11,984,881 | 3 | 3 |
B. Child Labor Trafficking Offense Breakdown (2023 NIBRS)
| Offense | Cases |
|---|---|
| Human Trafficking, Commercial Sex Acts | 3,265 |
| Human Trafficking, Involuntary Servitude (Labor) | 671 |
| Total Trafficking of Minors | 3,936 |
Sources
Databases Queried
- [USASPENDING:UAC_SUBGRANTS] USASpending.gov UAC subawards (1,046,123 records)
- [NCMEC] Missing children database (1,905 records)
- [NIBRS] FBI child crimes data (330,284 records)
- [TAGGS] HHS TAGGS grant awards
Government Reports
- HHS OIG - Gaps in Sponsor Screening (Feb 2024)
- DHS OIG - ICE Cannot Monitor All UACs (Aug 2024)
- Senate Judiciary - Grassley Report
- House Oversight Committee
Media Sources
- New York Times Investigation (2023)
- Democracy Now - Biden Admin Ignored Warnings
- Bethany Christian Services Lawsuit
APIs Called
- CivicOps PostgreSQL Database - queried 2026-01-17
- WebSearch - queried 2026-01-17
OSINT Tools Used
- [KALI:whois] Domain registration lookups
- [KALI:waybackurls] Historical URL discovery
Report Generated: 2026-01-17
Analyst: OPUS | Project Milk Carton
Classification: CONFIDENTIAL - LAW ENFORCEMENT SENSITIVE
501(c)(3) Nonprofit
Disclaimer: This report contains information gathered from publicly available sources (OSINT). All findings should be independently verified. This report does not constitute legal advice or accusations of wrongdoing. Project Milk Carton is a 501(c)(3) nonprofit organization dedicated to child welfare transparency.
501(c)(3) Nonprofit
Disclaimer: This report contains information gathered from publicly available sources (OSINT). All findings should be independently verified. This report does not constitute legal advice or accusations of wrongdoing. Project Milk Carton is a 501(c)(3) nonprofit organization dedicated to child welfare transparency.