Alert provides banks with ‘red flag’ indicators of human smuggling on southwest border

Financial activity related to human smuggling along the southwest border of the U.S. is the subject of an alert including ‘red flag’ indicators on human smuggling issued Friday by the Treasury’s financial crimes enforcement arm.

According to the Financial Crimes Enforcement Network (FinCEN), the alert provides trends, typologies, and red flag indicators to help financial institutions “better identify and report suspicious transactions potentially related to such activity.”

Among the “red flag” indicators are:

  • Transactions involving multiple wire transfers, cash deposits, or P2P payments from multiple originators from different geographic locations either across (1) the United States, or (2) Mexico and Central America, to one beneficiary located on or around the SW border, with no apparent business purpose.
  • Deposits made by multiple individuals in multiple locations into a single account, not affiliated with the account holder’s area of residence or work, with no apparent business purpose.
  • Currency deposits into U.S. accounts without explanation, followed by rapid wire transfers to countries with high migrant flows (e.g., Mexico, Central America), in a manner that is inconsistent with expected customer activity.
  • Frequent exchange of small-denomination for larger-denomination bills by a customer who is not in a cash-intensive industry. Multiple customers sending wire transfers to the same beneficiary (who is not a relative, and may be located in the sender’s home country), inconsistent with the customer’s usual business activity and reported occupation.
  • A customer making significantly greater deposits—including cash deposits—than those of peers in similar professions or lines of business.
  • A customer making cash deposits that are inconsistent with the customer’s line of business.
  • Extensive use of cash to purchase assets, such as real estate, and to conduct transactions.

FinCEN said illicit actors seeking to make a profit by smuggling migrants across the southwest border have exploited the increasing volume of migration activity. “Recent events involving the death of migrants attempting to cross into the United States illustrate the dangers associated with human smuggling and how smuggling networks exploit human beings for profit,” the agency said.

FinCEN said human smuggling along the U.S. southwest border generates an estimated $2 billion to $6 billion in yearly revenue for the illicit actors. “In support of ongoing initiatives by the U.S. Government to combat human smuggling, today’s alert builds upon FinCEN’s 2020 and 2014 human smuggling and human trafficking advisories, while providing information specifically related to human smuggling occurring along the southwest border of the United States,” the agency said.

FinCEN Issues Alert on Human Smuggling along the Southwest Border of the United States

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