UAC Placement System: $1 Billion Flows to 355 Contractors as Children Vanish

Investigation reveals labor trafficking hotspots overlap with states receiving largest UAC contracts

A Project Milk Carton investigation analyzing 1,046,123 federal UAC placement records has uncovered troubling geographic correlations between child labor trafficking cases and the $1.04 billion network of government contractors responsible for releasing unaccompanied migrant children to sponsors.

Texas leads the nation with $196.5 million in UAC contracts—and 165 child labor trafficking cases involving minors in 2023 alone. Webb County, home to the border city of Laredo, reported 50 labor trafficking cases with an average victim age of 14.4 years, the highest concentration in the country.

Why This Matters

Since 2021, more than 250,000 migrant children have arrived at the southern border alone. The federal government places them with sponsors through a network of religious nonprofits called Voluntary Agencies (VOLAGs) and their subcontractors. But government oversight reports show systemic failures: 31,000 children released to blank or undeliverable addresses, 85,000 who lost contact with federal caseworkers, and sponsor vetting gaps affecting up to 35% of placements.

A Florida grand jury heard testimony that an HHS attorney told a federal employee: "We only get sued for keeping them too long. We don't get sued by traffickers."

Meanwhile, investigations from the New York Times to Congress have documented children working in slaughterhouses, auto plants, and roofing crews across all 50 states.

The VOLAG Empire

Nine national VOLAGs control the UAC placement pipeline. The top three receive 83% of all funding:

Lutheran Immigration & Refugee Service (LIRS): $358 million distributed through 76 subcontractors in 30 states

U.S. Conference of Catholic Bishops (USCCB): $252.7 million through 136 subcontractors in 36 states

U.S. Committee for Refugees & Immigrants (USCRI): $246.2 million through 65 subcontractors in 23 states

The single largest subcontractor is Bethany Christian Services of Michigan, which received $89.2 million despite being denied future contracts by the state of Michigan. State officials alleged Bethany provided "85.35% less services" while charging "305.72% more per client" compared to the prior year. Bethany has sued the state alleging religious discrimination.

Geographic Risk Patterns

PMC developed a composite risk score combining labor trafficking cases, UAC contractor presence, and missing children reports. The top five states:

1. Texas - 46 contractors, 165 labor trafficking cases, 225 missing children (risk score: 1,255)
2. California - 22 contractors, 118 labor trafficking cases, 316 missing children (risk score: 1,108)
3. North Carolina - 5 contractors, 36 labor trafficking cases, 60 missing children (risk score: 280)
4. Georgia - 9 contractors, 33 labor trafficking cases, 57 missing children (risk score: 269)
5. Florida - 18 contractors, 4 labor trafficking cases, 128 missing children (risk score: 248)

Major cities show the same pattern. Los Angeles has 5 UAC contractors managing $24 million in contracts—and 42 missing children. Houston has 6 contractors with $86 million in contracts and 23 missing children. Chicago, Philadelphia, and Cleveland round out the top five.

The Texas Pipeline

Texas contractors received more UAC funding than any other state. Harris County itself received $33.8 million as a direct subcontractor. Catholic Charities of Galveston-Houston received $26.3 million. Catholic Charities Dallas received $17 million.

Harris County reported 23 child labor trafficking cases in 2023 with an average victim age of 14.2 years. Houston has 23 missing children in the NCMEC database.

But Webb County stands out. With 50 labor trafficking cases and a victim age average of 14.4 years, it represents the highest concentration of child labor exploitation in the nation. While no UAC contractors are headquartered in Webb County, children may be released to sponsors in the Laredo area under the oversight of Texas's 46-contractor network.

Documented Vetting Failures

Two HHS Office of Inspector General reports and a DHS OIG audit documented systematic breakdowns in sponsor screening:

• 16% of case files lacked required safety check documentation
• 19% of children released without completed FBI fingerprint checks on sponsors
• 35% of sponsor ID documents had legibility concerns
• 22% of cases lacked timely post-release follow-up calls
• 18% of cases had no documented follow-up calls at all

DHS law enforcement estimated sponsor addresses were incorrect 80% of the time. Of 31,000 children released with incomplete addresses, federal authorities have no reliable way to locate them.

The Lost Children

233,000 children were never served with Notices to Appear in immigration court—meaning there is no legal mechanism requiring them to make contact with federal authorities. Of the 43,000 who did receive court notices, they failed to appear.

When HHS caseworkers attempt post-release welfare calls, many numbers are disconnected or answered by people who deny knowledge of the child. Whistleblowers allege 85,000 children have lost contact with the placement system entirely.

The New York Times investigation found nearly 6,000 children working in violations of federal child labor law—in slaughterhouses, factories, agricultural operations, and construction. The investigation documented cases in all 50 states and implicated supply chains for major American brands.

What Happens Next

The investigation recommends immediate congressional action:

Subpoena sponsor address data for all children released in Webb County, Harris County, and Los Angeles County from 2021-2024. Cross-reference those addresses against Department of Labor wage violations, OSHA inspections, and state licensing records.

Independent contractor audits of the top 10 UAC subcontractors focusing on home study completion rates, post-release contact rates, and sponsor vetting documentation.

ICE task force investigation in Webb County specifically targeting the 50 labor trafficking cases to determine if UAC program children are among the victims.

Systemic reforms should include mandatory GPS verification of sponsor addresses before child release, expanded home studies for all unrelated sponsors, minimum six-month monitoring periods with unannounced visits, and public reporting of contractor performance metrics.

The current system releases children into a network of 355 subcontractors operating in 352 zip codes with documented vetting failures affecting up to 35% of placements. Geographic overlap exists between the highest-funded states and labor trafficking hotspots. While correlation does not prove causation, the combination of oversight failures and trafficking patterns demands immediate investigation.

The children remain at risk.

This investigation drew on 1,046,123 UAC subgrant records from the USASpending.gov database, 1,905 missing children records from NCMEC, 330,284 child crime records from FBI NIBRS data, HHS TAGGS grant records, congressional testimony, HHS and DHS Office of Inspector General reports, and OSINT tools including domain registration and historical web archives. Full source documentation and data tables are available in the original OPUS investigation report.