The Financial Crimes Enforcement Network (FinCEN) has issued a new advisory on identifying and reporting human trafficking, supplementing its 2014 guidance. Financial institutions, big and small, play a pivotal role in detecting and reporting suspicious activity related to human smuggling and human trafficking. Together with law enforcement, FinCEN has identified 20 new financial and behavior indicators of human trafficking and four additional typologies since the 2014 advisory.
Unfortunately, among the detriments of COVID-19, the coronavirus pandemic has also worsened conditions that lead to human trafficking. In the latest advisory, FinCEN noted that traffickers often target the most vulnerable and that “support structures for potential victims collapse” amid the pandemic. Furthermore, shelter-in-place orders and other limits placed on travel may have affected typologies and red flag indicators.