In its new advisory, FinCEN identified the following additional financial indicators of suspicious activity associated with human trafficking:
- frequent geographic movement of a customer, as indicated by the customer's transactions;
- transactions that do not align with a customer's expected activity and appear to cover the costs associated with trafficking victims (i.e., additional living, transportation, medical, clothing or food costs);
- cash transactions or abnormally large deposits by a business that occur outside of its typical operational hours;
- consistent cash deposits that are made without Automated Clearing House payments;
- a customer's frequent purchase and use of prepaid access cards;
- identification information (i.e., telephone numbers, emails, social media handles or physical addresses) in a customer's account that appears to be associated with commercial sex websites or advertisements;
- frequent financial interaction by a customer with online classified sites that are based in foreign jurisdictions;
- frequent receipt or transmission of funds, by means of cryptocurrency, to or from dark web markets or platforms that are associated with illegal activity;
- frequent use of third-party payment processors for transactions that conceal the identity of the originators or beneficiaries of such transactions; and
- avoidance of transactions that (i) require the customer to produce identification documents or (ii) prompt reporting requirements.
FinCEN encouraged financial institutions to share information regarding transactions suspected to involve specified unlawful activities, reminding them of the safe harbor from civil liability available to them under Section 314(b) of the USA PATRIOT Act. Additionally, FinCEN directed institutions to not report potential human trafficking victims as the subject of a suspicious activity report ("SAR"). Rather, FinCEN requested that institutions provide information concerning a victim in the narrative section of a SAR in addition to referencing the key term "HUMAN TRAFFICKING FIN-2020-A008."
- FinCEN Advisory - FIN-2020-A008: Supplemental Advisory on Identifying and Reporting Human Trafficking and Related Activity
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