BSA Compliance – Human Trafficking

BSA Compliance: Human Trafficking

If you haven’t already seen the October 2020 FinCEN Advisory on Human Trafficking and Related Activity, this will give you a general overview of what that advisory covered. The advisory was issued in response to the COVID-19 pandemic. And you’re probably wondering, “What does COVID-19 have to do with human trafficking?” Well, the pandemic can exacerbate the conditions that contribute to human trafficking. So as support structures for potential victims collapse, human traffickers take advantage of those that are vulnerable.

This Advisory provides additional human trafficking red flags and is designed to supplement, not replace, FinCEN’s 2014 Advisory on Human Trafficking. Specifically, it provides 20 new red flags for financial and behavioral indications of human trafficking, and it provides for new typologies or methods that human traffickers are using to launder those ill-gotten funds. Then it gives you new information in identifying and reporting this type of activity.

Deb Irving explains more:

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