According to a recent change in the FBI’s hiring policy, applicants are no longer barred from employment if they have a history of buying sex unless they have done so “three or more times.” The new policy, which also relaxes restrictions for applicants with histories of bestiality, animal abuse, and stealing from employers, raises broad concerns about the integrity of the FBI – the very agency tasked with dismantling systems of prostitution fueled by the demand for commercial sex. These changes, which took effect in June 2026, may be a response to recruiting issues at the FBI.
Sources briefed on this new policy purport that the FBI is maintaining certain guardrails, such as automatic rejections for applicants who purchased sex while in positions of public trust (educators, social workers, health care providers, lawyers, and public safety officers). However, this carveout notably does not include military personnel, who are ripe for FBI recruitment and have a long, well-documented history of buying sex.
Similarly, the FBI and other U.S. law enforcement agencies have histories of purchasing sex. In 2025, a Justice Department watchdog reported that between 2008 and 2018, FBI employees bought sex in Cambodia, the Philippines, and Thailand – including as they attended trainings about human trafficking. The DOJ later released a report confirming this conduct. In 2012, various members of the Secret Service and Drug Enforcement Agency purchased sex at a hotel in Cartagena, Colombia.
This policy change, in and of itself, signals the FBI’s acceptance of harmful conduct within its agency. When considered alongside the FBI’s heel dragging in investigating Jeffery Epstein’s affiliates and releasing the “Epstein files” pursuant to the Epstein Files Transparency Act, the message is clear: the FBI no longer considers the crime of buying sex sufficiently serious to warrant accountability. While defaulting on a federal student loan still categorically bars an applicant from employment with the FBI, purchasing sex does not. Sitting on the shoulders of familiar cliches that “boys will be boys” and “one mistake shouldn’t ruin a man’s future,” the new policy normalizes buying sex, reflecting an ongoing cultural acquiescence to sexual violence. In stark contrast, people in prostitution continue to face disproportionate criminalization and moral reproach.
The policy change also presents countless ethical, practical, and procedural problems. First, FBI agents often must testifyin court to secure human trafficking convictions. A history of buying sex is likely to impeach their credibility, which could jeopardize critical prosecutions. Next, it presents a serious conflict of interest when an FBI agent tasked with arresting sex buyers and traffickers is (or was) a part of the market fueling demand for commercial sex. New hires are unlikely undergo spontaneous moral reform – rather, they are likely to harbor the same misogyny and biases that made them feel comfortable buying sex in the first place, limiting their objectivity and effectiveness. They may, for instance, be more likely to criminalize a person in prostitution or exercise lenience with a sex buyer. For these reasons, the FBI cannot investigate human trafficking operations with integrity, public trust, or efficacy if it employs sex buyers.
The CSE Institute is disheartened by the FBI’s new hiring policy, which is part of a broader pattern of law enforcement turning a blind eye to sex buyers’ culpability in perpetuating commercial sexual exploitation. Given that the FBI advertises its “trauma-informed, victim centered approach” in investigating human trafficking cases, the CSE Institute contends that the agency must reinstate its moratorium on hiring sex buyers and align itself with the Equality Model to effectively combat human trafficking,. The key tenants of the Equality Model are 1) the decriminalization of people in prostitution, 2) criminalization of sex buyers and facilitators, 3) public education about the harms of prostitution, and 4) well-funded, comprehensive exit services for victims. To successfully combat human trafficking, the FBI must send a strong message to sex buyers that they will be targeted and criminalized – not only by reimposing automatic hiring bans for sex buyers, but also by refocusing investigatory efforts on sex buyers and traffickers rather than people in prostitution.
All views expressed therein are personal to the author and do not necessarily reflect the views of Villanova University Charles Widger School of Law or of Villanova University.