Religious Freedom

A federally-funded framework that cannot distinguish between coercive organizations and minority religious communities.

The Victim-Centered Approach, as applied, targets belief systems rather than conduct. The diagnostic vocabulary it uses — 'undue influence,' BITE, cult dynamics — does not separate trafficking from minority religion. The record below is drawn from federal trainers, DOJ guidance, and the U.S. Commission on International Religious Freedom.

Steven Hassan — FBI training appearance

The BITE Model presented to federal law enforcement as an investigative tool.

Hassan has publicly described presenting the BITE Model — his Behavior, Information, Thought, and Emotion control framework — to FBI audiences as a tool for identifying coercive groups. The model treats strong organizational norms, internal language, and exit costs as evidence of 'undue influence,' applying the same diagnostic vocabulary to mainstream religious communities and to alleged trafficking operations.

Paul Chang — federal anti-trafficking trainer

BITE Model confirmed as part of federal human-trafficking training.

Chang, a longtime federal anti-trafficking official and trainer, has confirmed in public materials that the BITE Model is used in federal human-trafficking training programs. The same framework that USCIRF criticized as 'pseudo-scientific anti-cult ideology' (Commissioners Abraham Cooper & Mohamed Magid, 'Anti-Cult Update: Religious Regulation in Russia,' July 2020 Issue Update) is taught to federal agents and grantees as a method of identifying trafficking risk inside organizations.

U.S. Bureau of Prisons / DOJ — 2023 trends report

Religious organizations named as 'a growing trend' in trafficking identification.

DOJ's 2023 'Recent Labor Trafficking Cases and Trends' report identified 'forced labor perpetrated by religious organizations — or perhaps more accurately, organizations claiming to have a religious mission' as among the most notable trafficking trends in recent years, naming specific religious groups by case. The report was distributed to federal and state partners as guidance.

U.S. Commission on International Religious Freedom (USCIRF)

Anti-cult prosecution frameworks condemned as religious-freedom violations.

USCIRF has condemned the use of 'expert' anti-cult prosecution frameworks abroad as 'pseudo-scientific anti-cult ideology' (July 2020 Issue Update, 'Anti-Cult Update: Religious Regulation in Russia,' Commissioners Cooper & Magid), criticized France's About-Picard law — structurally identical to the OneTaste prosecution theory — as a threat to religious freedom (2023), and in its 2026 Annual Report devoted a 'Weaponization of Legal Frameworks' chapter to laws criminalizing 'psychological influence' in spiritual contexts absent proof of physical harm.

The Supreme Court held in United States v. Ballard (1944) that the government cannot judge the truth of religious beliefs. The VCA, applied to organizational culture through the BITE Model, effectively requires it to.