Banks flagged nearly $5 billion in suspected human trafficking, agency finds in BSA data

“Consistent indicators,” including excessive cash activity conducted along the southwest border of the United States, among other things, are detailed in a report on suspected human smuggling issued Thursday by the Treasury’s financial crimes enforcement arm.

According to the Financial Crimes Enforcement Network (FinCEN), banks and other financial institutions flagged nearly $5 billion linked to suspected human trafficking over the three-year period of 2023-25. The agency used Bank Secrecy Act (BSA) data from 67,540 BSA reports to analyze trends. It said the analysis identified other consistent indicators including unverifiable relationships between originators and beneficiaries and transactions sent along common migration routes.

Other key points reported by FinCEN from the analysis included:

• Money services businesses (MSBs) most (97%) BSA reports potentially related to suspected human smuggling activity. The MSB reports showed, the agency said, similar descriptions of potential connections to human smuggling, such as transactions outside of a customer’s usual pattern, money sent to locations along common migration routes, and suspected structuring of transactions to avoid recordkeeping and reporting requirements. FinCEN said 59% of the MSB reports indicated no verifiable familial connection between the transaction originator and beneficiary as a basis for filing.
• Depository institutions filed fewer BSA Reports related to suspected human smuggling activity but had a higher total suspicious activity amount. FinCEN asserted that although bank filings accounted for only 3% of the reports, the suspicious activity amounts in their reports accounted for approximately 61% of the total amount in reports filed. Among the activities included in the bank filings, FinCEN said, were suspected structuring of cash transactions, funnel accounts receiving funds from numerous individuals, and travel agencies arranging travel for migrants—ranging from sham operations to legitimate businesses that may be unwittingly facilitating such activity.

FinCEN Analysis: Financial Institutions Flagged Nearly $5 Billion Linked to Suspected Human Smuggling