Project: Prevention, Protection and Integration of the Human Trafficking Victims in Serbia15Sep2014
FinCEN advisory: Financial red flags for human smuggling and human trafficking
The Treasury Department's Financial Crimes Enforcement Network (FinCEN) issued an advisory Thursday to help financial institutions detect and report suspicious activity that could be related to human smuggling or human trafficking.
"Financial institutions, large and small, can play a critical role in identifying and reporting transactions related to these unlawful activities based on their observations when interacting with customers and their monitoring processes," FinCEN said.
And a few of FinCEN's red flags for human trafficking:
Transactions conducted by individuals, escorted by a third party (e.g., under the pretext of requiring an interpreter), to transfer funds (that may seem to be their salaries) to other countries.
Frequent payments to online escort services for advertising, including small posting fees to companies of online classifieds as well as more expensive, higher-end advertising and website hosting companies.
Frequent transactions, inconsistent with expected activity and/or line of business, carried out by a business customer in apparent efforts to provide sustenance to individuals (e.g., payment for housing, lodging, regular vehicle rentals, purchases of large amounts of food).
Payments to employment or student recruitment agencies that are not licensed/registered or that have labor violations.
FinCEN Advisory FIN-2014-A008 dated September 11, 2014 "Guidance on Recognizing Activity that May be Associated with Human Smuggling and Human Trafficking – Financial Red Flags" is here (pdf).
FPCA Blog, Richard L. Cassin