As a few have previously posted, among the more recent Department of the Treasury (see Combating Human Trafficking webpage), Financial Crimes Enforcement Network (FinCEN) human trafficking advisories, is FIN-2020-A008, October 15, 2020. This advisory supplements the 2014 FinCEN Guidance on Recognizing Activity that May be Associated with Human Smuggling and Human Trafficking – Financial Red Flags (FIN-2014-A008), which remains relevant and provides information related to human smuggling, in addition to human trafficking.
FIN-2020-A008 identifies 20 new financial and behavioral indicators of labor and sex trafficking, four additional typologies (Front Companies, Exploitative Employment Practices, Funnel Accounts, Alternative Payment Methods), and two case studies (Funnel Accounts Facilitate International Thai Sex Trafficking Ring; Trafficking Involving Prepaid Cards and Bitcoin). This advisory also contains a section on Guidance to U.S. Financial Institutions, including:
· Customer Due Diligence and Identification of Beneficial Owners of New Legal Entity Accounts
· Information Sharing
· Suspicious Activity Reporting (SAR) (FinCEN Report 111) – SAR Field 38(h), Code 927 - human trafficking
When reporting suspicious activity related to this advisory, FinCEN requests that financial institutions include the key term “HUMAN TRAFFICKING FIN-2020-A008” in SAR field 2 (Filing Institution Note to FinCEN) to indicate a connection between the suspicious activity being reported and the activities highlighted in the advisory.
Some other sources of indicators of human trafficking include:
· Department of Homeland Security: https://www.dhs.gov/blue-campaign/indicators-human-trafficking
· Department of State (also includes questions to ask victims): https://www.state.gov/identify-and-assist-a-trafficking-victim/
· United Nations Office on Drugs and Crime: https://www.unodc.org/pdf/HT_indicators_E_LOWRES.pdf