What could be hidden in plain sight, below the surface?
I’m sure you’ve read stories on human trafficking, depicting (usually) young women forced into underground sex trafficking, kept on drugs and forced to prostitute for money. Have you ever thought this dreadful exploitation might be actually happening where you live, in your own neighborhood?
In 2014, the Financial Crimes Enforcement Network released an Advisory (FIN-2014-A008)* that explains the differences between human trafficking and human smuggling and details behavioral red flags that could indicate one crime or the other if observed as part of account activity.
The U.S. State Department releases an annual Trafficking in Persons Report 2,** which tracks the progress in the fight against human trafficking. The U.S. Department of Homeland Security is responsible for investigating human trafficking, arresting traffickers, and protecting victims. DHS initiates hundreds of investigations and makes numerous arrests every year using a victim-centered approach.
So, why is this important to you? To assist law enforcement in targeting instances of human smuggling and trafficking, FinCEN, in its Advisory, identifies red flags to be considered for SAR filings. As with any other type of red flag, no single transaction or red flag is by itself a clear indicator of human smuggling or human trafficking. But because both crimes are prevalent—and because everyone has a role to play in combating these forms of exploitation—staff training is important to building awareness.
FinCEN’s Advisory represents a good starting point. Other resources, all accessible through a quick internet search, include the Department of Homeland Security; the U.S. Department of State; Immigration and Customs Enforcement; United Nations Office on Drugs and Crime; the Federal Bureau of Investigation; and the Financial Action Task Force.
It’s time to revisit the Advisory and create awareness with your staff through training. I encourage you to add this as a goal for 2018.
*United States Department of the Treasury Financial Crimes Enforcement Network, FIN-2014-A008 Advisory: Guidance on Recognizing Activity that May be Associated with Human Smuggling and Human Trafficking—Financial Red Flags, 11 Sept. 2014, www.fincen.gov/sites/default/files/shared/FIN-2014-A008.pdf.
**U.S. Department of State, Trafficking in Persons Report, June 2017, www.state.gov/documents/organization/271339.pdf.