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Online Child Sexual Exploitation Crimes

Financial Crimes Enforcement Network - Child Trafficking

Financial Crimes Enforcement Network (FinCEN) notice, “FinCEN Calls Attention to Online Child Sexual Exploitation Crimes,” FIN-2021-NTC3, 16 Sep 2021:

  • Calls attention to an increase in online child sexual exploitation (OCSE)

  • Provides financial institutions with specific suspicious activity report (SAR) filing instructions

  • Highlights some financial trends related to OCSE

Crimes related to OCSE, including the funding, production, and distribution of child sexual abuse materials (CSAM), have increased during the COVID-19 pandemic, according to multiple law enforcement authorities. This increase in activity is likely due to a confluence of factors, including:

  • Increased internet usage by children who are spending more time online, both unsupervised and during traditional school hours

  • Restricted travel during the COVID-19 pandemic resulting in more sex offenders being online

  • Increased access to and use of technology, including encrypted communications, bulk data transfer, cloud storage, livestreaming, and anonymized transactions

Another trend is the rise in sextortion of minors, who are coerced or exploited into exchanging sexual images via the internet, mobile devices, and social media platforms. OCSE offenders often groom minors to share or post self-generated content online in exchange for money.

FinCEN performed a review of OCSE-related SARs and observed the following trends:

  • Between 2017 and 2020, there was a 147 percent increase in OCSE-related SAR filings, including a 17 percent year-over-year increase in 2020

  • OCSE offenders are increasingly using convertible virtual currency (CVC) (some of which provide anonymity), peer-to-peer mobile applications, the darknet, and anonymization and encryption services to try to avoid detection. CVC in particular is increasingly the payment method of choice for OCSE offenders who make payments to websites that host CSAM

  • OCSE facilitators attempt to conceal their illicit file sharing and streaming activities by transferring funds via third-party payment processors

SAR Filing Instructions

FinCEN requests that financial institutions should:

  • Reference only this notice in SAR field 2 (Filing Institution Note to FinCEN) using the keyword “OCSE-FIN-2021-NTC3”; this keyword should also be referenced in the narrative to indicate a connection between the suspicious activity being reported and the activities highlighted in this notice

  • Select SAR Field 38(z) (Other) as the associated suspicious activity type to indicate a connection between the suspicious activity reported and OCSE activity and include the term “OCSE” in the text box. If known, enter the subject’s internet-based contact with the financial institution in SAR Field 43 (IP Address and Date)

  • If human trafficking or human smuggling are suspected in addition to OCSE activity, select SAR Field 38(h) (Human Trafficking) or SAR Field 38(g) (Human Smuggling), respectively

The notice provides Child Sexual Exploitation (CSE) terms and definitions in an appendix to use to describe suspicious activity and several useful references.

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