1. LYON COUNTY SHERIFF’S OFFICE
INTERNAL AUDIT REPORT on Brothel Compliance Requirements

2. Lyon County Code mandates the Sheriff’s Office to:
Approve, issue and audit work cards for all brothel employees and prostitutes in Lyon County. Implied requirement to conduct regular and periodic compliance checks of all licensed brothels

3. What Generated this Audit?
The Sheriff's Office received 8 total
public records requests for brothel & prostitute records, some requesting ten years of records. The first one was received on December 6, 2017.

4. We Wanted to:
Evaluate our internal support services, functions, and processes to identify weaknesses and gaps
Develop opportunities to streamline, share service, reorganize, consolidate, and/or improve collaboration to ensure consistency and efficiency

5. Audit Steps:
Pulled 342 prostitute and 79 brothel employee applications from 2017
Reviewed crime self-disclosures
Checked federal crime records
Cross-referenced thru law enforcement CLEAR programs
Compiled data looking at trends
Identified gaps & weakness
Involved multiple Federal agencies for time sensitive issues

6. Non-Prostitute Employees
35 live in Lyon County (most live in Silver Springs and Stagecoach)
42 live in Northern Nevada (non-Lyon County)
2 provided out of state addresses on application
2 Active Criminal Cases
2.51 years is the average employment
¼ of non-prostitute employees work less than 1yr

7. Findings
LCC mandates “each employee…shall register and be issued an employment card by Sheriff” Only 79 of a reported 134 could be identified
No significant public safety concerns with these employees

8. Prostitutes 13 Lyon County 42 Northern Nevada (non Lyon County)
18 Southern Nevada
168 out of state
LCSO issued a total of 342 cards to 241 specific individuals

9. Demographics 1.88 years average length of employment
7 years longest length of employment
147 (61-percent) less than one year of employment
72 years oldest applicant
18y/15days youngest applicant
30.78 years average age
9 have more than three years of employment and live in Lyon County
22 Self-disclosed being foreign born and/or non-us citizens. A quick 2018 search identified an additional 17 approved prostitutes (39 total) who were crossed checked through federal systems due to international human trafficking indicators

10. Crime trends 13 Active criminal cases
Warrants
Possession of controlled substances (Lyon & Las Vegas)
Obstructing a peace officer (Reno)
Battery on a peace officer (Carson City)
Fraud (CA)
Theft (CA)
1 Currently serving a 14-week jail sentence

11. Human Trafficking (HT) Indicators
19 self-disclosed prior prostitution convictions
Could still be controlled by an exploiter
4 self-disclosed active prostitution cases
High probability of being controlled by an exploiter
25 Dual licenses with Nye & Elko counties
(excludes City of Elko)
Movement from one brothel to the next
2 Entry into the US and almost immediately applying for card
1 Entry into the US, marriage, and then applying for card
Possible identity theft
1 self-disclosed out-of-state HT arrest

12. Federal Law 1 subject to arrest/deportation when located
1 self-disclosed immigration deportation proceedings
14 federal review for immigration violations. Will be allowed to continue working until notified by the appropriate agency.
1 Active duty military member moonlighting

13. Findings
Part-time administrative clerk does not have knowledge and skills
Temporary work cards being issued contrary to LCC
No equipment to validate out-of-state and passports used to establish identity (possible to have issued a minor a card)
Majority of prostitutes report home instability and criminal histories, indicators of HT.
During audit, received information on labor and civil disputes between prostitutes and brothels.
Our records management systems are not compatible with Storey and City of Elko. We are compatible with Nye and Elko Counties.
83 prostitutes (30% of all applicants) should have been interviewed by a detective

14. Moving Ahead Human Trafficking Resources
UN Office of Drugs & Crime 36 general indicators 12 sexual exploitation indicators
Nevada AG’s Office HT screening tool

15. Lyon County Code Revisions Included but no limited to:
Word card requirements for employees & prostitutes
Temporary work card issues
Minimum age raised to 21 (prostitute, employee, and customer)
Medical Advisor and health requirements from designated medical facility
Prostitute Rights and reporting mechanism
Brothel staff training on HT awareness and reporting
Periodic licensee reviews (every 5 years)
NRS 125B Child Support

16. Corrective Actions
Establish clearly defined roles, functions, and missions to improve efficiency and effectiveness as it relates to brothels.
Enhance informational technologies, training, and equipment to readily detect indicators of HT.
Improve LCC, working with our DA and brothel industry leaders.
Implement best practices strategies to connect supportive services to identified HT survivors.
Visually promote a comprehensive program message to foreign and domestic criminal enterprises that HT has zero tolerance in Lyon County and into its legal system.

17. RESOURCES REQUIRED TO REGULATE PROSTITUTION
Increased administrative clerk staffing at the Dayton substation
Acquisition of ID validation equipment
Increased involvement with regional local and federal law enforcement agencies to combat HT in Northern Nevada
Increased detective staffing to meet the demand of LCC and the recommendations of this audit.
Projected Cost is $150,000

18. Summary This Audit has exposed real weaknesses and gaps in the Sheriff’s Office ability to detect and deter foreign and domestic Human Trafficking into licensed brothels in Lyon County. The LCSO will no longer stand idly by, but will take a proactive public safety stance against any form of Human Trafficking in Lyon County