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BSA/AML Hot topics: Reviewing the ways to identify Human Trafficking

By Kristina Davis, CAMS, BSA/AML Investigator

Although slavery was officially abolished in 1865, here we are in 2018, and slavery still exists. According to, “slavery is the state of being under the control of someone where a person is forced to work for another.” This is also the definition of human trafficking, which is forcing someone against their will to perform an act that they would not perform if not under duress. FinCEN advisory FIN-2014-A008, defines human trafficking as “the act of recruiting, harboring, transporting, providing or obtaining a person for forced labor or commercial sex acts through the use of force, fraud or coercion.”

Human trafficking, a multi-billion-dollar criminal industry, is no longer believed to be only in third-world countries. Human trafficking is right here in the United States, in our backyard and our communities. Make no mistake about it, human trafficking is modern-day slavery, and as professionals in the financial industry, it is our duty to do our part to help combat and report human trafficking.

Types of human trafficking

When we hear the term “human trafficking,” we tend to think only of forced sexual acts, but human trafficking is more than that. Sex trafficking is only one form of human trafficking, and there are various ways someone could be coerced into it. For example, it could start off as an innocent romantic relationship and then evolves into one of the partners compelling the other into committing unwanted acts. Sex trafficking may also derive from a situation where someone living a transient lifestyle may be forced into this existence based off the promise of drugs, shelter, and/or protection.

Labor trafficking is another form of human trafficking. While labor trafficking may not be as widely known in the United States, it does happen here. Labor trafficking consists of the promise or guarantee of a job that pays top dollar but results in a situation with atrocious working conditions.

In both types of trafficking, the trafficker can use manipulation, physical, and/or mental abuse as a form of control so that the victim is fearful of leaving and/or fears for their family’s safety, which compels them to continue to endure the situation.

Spotting the signs of human trafficking

In the financial industry, it is important to be able to spot the signs of human trafficking through face-to- face contact and transactional review. Training front-line staff, especially those who have face-to-face interactions, on what to look for is vital.

Here are a few ways to identify possible human trafficking during front-line interfacing:

  • When someone enters the facility and does not make eye contact with you or seems visibly shaken.
  • When the victim does not ask/answer questions. The victim may be in the presence of someone else who is taking complete control of the situation with little to no input from the possible victim. The victim may look to the accompanying person for approval to answer any questions that are personally directed to them.
  • When bruises or marks are visible on an individual.

In some cases, a potential victim of human trafficking may not come into the facility at all, and in this instance, the transactional review is most important. Some suspicious transactional signs are:

  • Very late night and/or early morning transactions at ATMs.
  • Transactions that are for low-dollar motels or recurring transactions for motel/hotel purchases.
  • Deposits made through the ATM late at night (for those who have this capability).
  • Transactions that do not appear to be in the neighborhood listed on the account as an address.
  • Unusual wire activity (multiple incoming wires) with no apparent relation to the possible victim.

Some suspicious transactional signs for possible labor trafficking are:

  • If the expenses of an employer do not appear reasonable for the industry, company size and employee count. For example, if expenses seem relatively low dollar for the nature of business they are in, high-dollar expenses may be a sign of possible labor trafficking.
  • If an individual’s payroll appears to be much less given the nature of business they’re working for.
  • If a customer enters the financial institution and is always in the presence of another individual who may claim to be their interpreter.

It’s vital to remember that individuals in human trafficking are victims of a crime, so it’s our job as credit-union professional to file a SAR (Suspicious Activity Report) in the event we suspect human trafficking. But it’s also important not to victimize the potential victim any further, so make sure to never include them as a suspect on the SAR. Spotting possible human trafficking activity is every BSA/AML professional’s responsibility, and we must do our part to help stop and report these terrible crimes.