The upcoming Super Bowl usually brings to mind rivalry and camaraderie. But for financial institutions and law enforcement, large sports gatherings mean it’s time to go on high alert for human trafficking. Financial institutions of all sizes play a pivotal role in detecting and reporting suspicious activity related to human smuggling and human trafficking.
The Super Bowl and human trafficking: How financial institutions can help
February 6, 2024
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Large sporting events like the Super Bowl exacerbate human trafficking
Financial institutions may see increased signs of human trafficking during the upcoming Super Bowl. Know the red flags to watch for.
You might like this podcast, Ahead of the curve: A banker’s podcast – Unveiling human trafficking.
Takeaway 1
A consistent spike in reported incidents around January and February points to the Super Bowl as a hot spot for human trafficking
Takeaway 2
Front-line staff should get familiar with behavioral red flags for human trafficking, which often include the presence of a third party.
Takeaway 3
Financial institutions with a suspected human trafficking transaction should not hestiate to file a Suspicious Activity Report.
Exploitative practices
What is human trafficking?
Human trafficking is a crime in which force, fraud, or coercion is used to compel a person to perform labor, services or commercial sex. Sadly, there can be an uptick in this practice in areas where large events take place. Any influx of people from all over the world—including the FIFA World Cup, the Olympics, and various other sporting events—requires hiring hundreds of temporary workers for building and staffing events. The increased labor opportunity can open the door for human trafficking.
According to data compiled by the Institute for Sport and Social Justice's "Shut Out Trafficking" program, there's consistently a spike in reported incidents in the U.S. around January and February (when the Super Bowl occurs). In January 2019, there were approximately 450 reported incidents, with a jump to about 540 in February. It dropped down to 140 incidents in March 2019.
The U.S. Institute Against Human Trafficking reported that the 2020 Super Bowl in Miami saw a 163% increase in human trafficking reports to the national hotline over the course of the event. The good news is that 47 traffickers were arrested, and 22 victims were found and assisted. The 2021 Super Bowl in Tampa saw 146 arrests made, six victims recovered, and 18 missing children identified. Now, human trafficking is a focus of the upcoming Super Bowl in Las Vegas, Nevada.
With increased demand for manual labor, sex for hire and other services around major sporting events, the Super Bowl should put financial institutions on high alert. Aristides Jimenez, retired Deputy Agent in Charge at DHS, reported that “stables,” groups of trafficked victims who are under the control of a single pimp, travel from all major cities to the host site due to the demand being so high. And while the word "trafficking" implies that victims are being transported from a great distance, some are "stabled" close by in their own neighborhoods, or even enslaved by family members.
FinCEN has issued an updated advisory on identifying and reporting human trafficking, supplementing its 2014 guidance. Together with law enforcement, FinCEN has identified these financial and behavioral red flags of human trafficking.
Warning signs
Behavioral indicators and transactional red flags
Many behavioral red flags for human trafficking include the presence of a third party, where this person may:
- Speak on behalf of the customer
- Insist on being present throughout the transaction
- Attempt to fill out paperwork without discussing it with the customer first
- Keep possession of all of the documents or funds
- Claim to be related to the customer (but may lack knowledge of the customer’s important details)
- Attempt to open an account for a person not present
- Try to open an account for an unqualified minor
- Act aggressive or intimidating toward the customer
Additionally, signs that you might be dealing with a human trafficking victim or perpetrator include when the customer may:
- Present poor hygiene, malnourishment, or fatigue, or show signs of abuse, physical restraint, or torture
- Not know where they are or live, or have inconsistent stories
- Exhibit abnormal business payroll expenditures
- Have non-existent or meager payroll costs for the size of the customer’s alleged line of business
- Deduct large amounts from employees’ wages (e.g., housing, food costs)
- Cash payroll checks where most of the funds are kept by the employer or deposited into the employer’s account
- Show payments to employment or student recruitment agencies that are not licensed or have labor violations.
Report and assist
Supporting human trafficking victims
According to the National Human Trafficking Hotline, working in the financial industry provides you the opportunity to report suspicious behavior involving 92% of the various types of human trafficking. When you encounter transactions that just don’t feel right, don’t hesitate to file Suspicious Activity Reports (SARs) and call the National Human Trafficking hotline at 888-373-7888.
It's easy to feel overwhelmed by the number of potential human trafficking transactions you find, knowing the abuse that lies behind these transactions. The good news is there are data scientists designing ways to detect these patterns without human intervention. Financial institutions with AML software that incorporates an AML AI solution will be empowered to find data that can free victims faster.
In the meantime, remind front-line staff to trust their gut and be on the lookout for red flags of human trafficking. Banks can help by supporting an organization like Love Never Fails or the Texas Advocacy Project. These organizations support victims of human trafficking by providing housing, counseling, legal help, and professional training.
Learn more human trafficking behavioral indicators with this checklist: "Human Trafficking Red Flags."
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