Although it is nearly four years old, the FinCEN Advisory, Guidance on Recognizing Activity that May be Associated with Human Smuggling and Human Trafficking – Financial Red Flags, is still one of the most important tools you can use to enhance and strengthen your BSA and AML training.
Millions of men, women, and children in the United States and around the world are exploited for their bodies and their labor. They are in brothels, factories, mines, farms, and even in your neighborhoods as nannies or domestic servants; enslaved by indentured servitude or blatantly held against their will.
But what can we do? First of all, we need to be aware that the problem exists and is closer than we think. More and more human trafficking victims are being found in the US. Traffickers are counting on smaller communities, smaller banks, and credit unions to be less alert, have fewer resources, and have limited law enforcement who would thwart their illegal activities. Some experts estimate that globally there are 40 million people imprisoned by traffickers. It is a money-driven black-market industry that we can help unveil. Let’s review some of the red flags, you may encounter, that align with possible human trafficking.
Red Flags in Account(s) Transactions:
Financial patterns like structuring, layering, and money laundering will mirror what you would look for in AML (Anti-Money Laundering) compliance, but there are other types of transactions that may shed light on human trafficking such as:
- High volume round dollar deposits
- Excessive interstate or intra state cash deposits
- Debit and credit cards that are used for lots of travel, high end merchants and casinos
- Extensive payments to web advertisers
- Transactions inconsistent with the intended use of the account
- Several individuals with a common address depositing money into the same account, or
- Multiple accounts transferring money to the same beneficiary
Red Flags in Recognizing Human Trafficking Victims:
Transaction history can tell us a lot about who we are dealing with, but there is a very human element that can be employed and should not be ignored. Some of the behaviors victims may display will be similar to what we have been trained to observe in recognizing and reporting Elder Financial Abuse:
- Accompanied by a controlling person
- Will not speak on his or her own behalf
- Appears to lack control over
- Travel Documents
Not all indicators listed are present in every human trafficking situation, and the presence or absence of any of the indicators is not necessarily proof of human trafficking. The takeaway here is to be aware, recognize possible indicators, and report anything you believe to be in relation to human trafficking. It is a very real financial crime that, when unveiled, can help to save a life.
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