Combating human trafficking in hospitality

What hotel owners need to know

KEY TAKEAWAYS

Human trafficking litigation is a significant and growing liability risk for hotels, even if they aren’t aware of or lack direct involvement in trafficking.

Insurance carriers, cognizant of this risk, are seeking exclusions of sexual assault and battery and human trafficking claims for hotels.

Strong prevention programs and training that help recognize signs of trafficking can mitigate risks and bolster insurance negotiations.

In 2025, a jury in Georgia returned a $40 million verdict against a hotel where a minor said she was repeatedly trafficked for sex.

The verdict set a record and sounded alarm bells for the hospitality industry, increasingly a target of human trafficking and sex trafficking lawsuits.

Plaintiffs filed more sex trafficking cases against hotels in 2025 than in any year before, according to data from the Human Trafficking Legal Center. The hotel industry was by far the most highly targeted sector for sex trafficking lawsuits.

Hotels are a frequent nexus for human trafficking, as they offer physical and fleeting infrastructure to the housing and transport of victims and perpetrators, as well as a location to commit offenses against victims.

It takes clients having strong protocols in place, human trafficking prevention plans and an overall strong safety culture.

Brian Popelmayer Real Estate Hospitality Leader, Lockton

A surge in claims

More than 1,600 lawsuits have been filed under the Trafficking Victims Protection Reauthorization Act (TVPRA) since its passage in 2000, with 371 filings in 2025, the most ever for a single year. The majority of cases involve sex trafficking allegations.

TVPRA allows victims to sue perpetrators of human trafficking for damages. Its 2008 reauthorization expanded TVPRA to allow victims to sue anyone or any entity that benefits from sex trafficking, which can include hotels if plaintiffs can show hotels knew or should have known trafficking took place on their premises. To show that an entity benefited from sex trafficking does not require its direct involvement. For hotels, this can mean they can be held liable if employees miss signs of human trafficking at their locations without knowing it occurred.

The Eliminating Limits to Justice for Child Sex Abuse Victims Act of 2022 raised liability risks for hotels, as it eliminated the statute of limitations for minor victims of human trafficking or federal sex offenses to file civil lawsuits.

According to the Anderson Kill law firm, rulings in two recent federal court cases have held that insurers had to defend hotels facing allegations of violating TVPRA, and the duty to defend was broader than the duty to indemnify.

Insurance implications for the hospitality industry

Insurance carriers have recently sought to exclude coverage for sexual abuse and misconduct, as well as human trafficking, from general liability and excess liability towers.

The London market has developed a stand-alone sexual misconduct policy, but its capacity is limited and typically responds to instances of employees assaulting a guest. Incidents in which guests assault other guests do not usually trigger coverage under these stand-alone policies.

“We have succeeded in negotiations to have those exposures not excluded,” said Brian Popelmayer, Real Estate Hospitality Leader at Lockton. “It takes clients having strong protocols in place, human trafficking prevention plans, and an overall strong safety culture.”

Industry organizations, cognizant of the growing threat human trafficking poses to the hospitality industry, have put together training courses and recommendations to help employees recognize signs of suspicious or troubling behavior.

Mitigating risks

Lockton’s Real Estate team counsels clients to build safety and loss mitigation programs to help prevent cases on their properties. The American Hotel & Lodging Association’s No Room for Trafficking initiative offers training for industry employees.

Tools like security cameras, while helpful for investigating crimes after they have occurred, have limitations for preventing trafficking in hotels — chiefly, hotels cannot place cameras in rooms. Hotel staff, the eyes and ears of the facility, are best positioned to spot signs of suspicious behavior and report it.

Red flags include:

Rooms paid for in cash, with several short-term reservation extensions.

Hotels that accept cash payments for rooms risk attracting traffickers who want to conceal their movements. Hotel staff should also watch for guests who bring little or no possessions or luggage for longer stays. A single person reserving several rooms may be another sign worth noting.

Suspicious guest behavior.

Hotel staff, those tasked with checking visitors into their rooms, should watch for guests who appear to exert controlling behavior over another person who is accompanying them. Watch for guests who exhibit fear and anxiety. Guests who appear reluctant to speak for themselves, who cannot provide identification or basic information about themselves, or who cannot explain why they’re staying at the hotel may warrant closer attention.

Unusual room activity.

Are guests frequently requesting housekeeping services, such as new towels and linens, while also refusing to allow housekeeping staff to enter the room? Are guests in possession of large amounts of cash, several phones, or credit card payment devices? Does it seem like more people are visiting the room all day and night than are listed in the registration?

Hotel owners should always work with an experienced broker who can advise clients on training programs and security measures that can reduce the risk of trafficking at their properties. From there, a broker can help hoteliers design an insurance program that may also mitigate balance sheet risk if trafficking incidents do occur.