The Financial Crimes Enforcement Network (FinCEN) issued on January 13, 2023 an alert (the “Alert”) to financial institutions regarding the detection of financial activity related to human smuggling along the U.S. southwest border (“SW border”). The Alert builds upon FinCEN’s prior 2020 and 2014 human smuggling and human trafficking advisories in order to provide trends and typologies specifically related to human smuggling along the SW border. It also provides red flag indicators regarding transactions potentially related to human smuggling.
The Alert effectively lays out the breadth of the problem. Effectively detecting and reporting human smuggling and trafficking, however, can be difficult, given the extensive use of cash.