FinCEN Supplements Guidance On Human Trafficking

FinCEN supplemented its 2014 guidance with additional financial and behavioral indicators for identifying suspicious activity potentially associated with human smuggling and trafficking.

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;