FinCEN Issues First National AML/CFT Priorities and Accompanying Statement

Updated: Mar 25


U. S. Treasury Financial Crimes Enforcement

There have been several posts on subject but what I want to flag are the two paragraphs for the priority for Human Trafficking and Human Smuggling (IIG, page 11):

“Financial activity from human trafficking and human smuggling activities can intersect with the formal financial system at any point during the trafficking or smuggling process. FinCEN, in collaboration with law enforcement agencies, nonprofit organizations, and members of the financial industry, issued two advisories identifying financial and behavioral red flags of human trafficking, as well as financial red flags associated with human smuggling.

As described in these advisories and other U.S. government reports, human trafficking and human smuggling networks use a variety of mechanisms to move illicit proceeds, ranging from cash smuggling by individual victims to sophisticated cash smuggling operations through professional money laundering networks and criminal organizations. The illicit proceeds from human trafficking can include income associated with logistics, such as housing and transportation of victims, as well as earnings from the exploitation of victims. Human traffickers and smugglers have established shell companies to hide the true nature of a business. Human traffickers and human smugglers receive payments in a variety of ways, such as funnel accounts and TBML schemes.”

My article,“Identifying and Reporting Human Trafficking and Related Activity,” 3 February 2021, discussed Financial Crimes Enforcement Network (FinCEN) human trafficking advisories FIN-2014-A008, “Guidance on Recognizing Activity that May be Associated with Human Smuggling and Human Trafficking – Financial Red Flags,” 11 September 2014, and FIN-2020-A008, “Supplemental Advisory on Identifying and Reporting Human Trafficking and Related Activity,” 15 October 2020.

I would also like to point out that human trafficking is linked with all the other AML/CFT priorities to some extent.

AML/CFT Priorities (30 Jun 2021)

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