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Financial Services Law Insights and Observations

FinCEN offers suspicious activity reporting guidance for human smuggling along U.S.- Mexico border

Financial Crimes Of Interest to Non-US Persons FinCEN Bank Secrecy Act SARs

Financial Crimes

On January 13, the Financial Crimes Enforcement Network (FinCEN) issued an alert advising financial institutions on how to detect and report suspicious financial activity that may be related to human smuggling along the southwest border of the United States. Highlighting that human smuggling is one of the eight Anti-Money Laundering and Countering the Financing of Terrorism National Priorities identified by FinCEN, the agency pointed out that human smuggling along the southwest border generates an estimated $2 billion to $6 billion in yearly revenue for illicit actors. The alert, which builds on FinCEN’s 2020 and 2014 human smuggling and human trafficking advisories (covered by InfoBytes here and here), provides trends, typologies, and red flag indicators to help financial institutions better identify and file suspicious activity reports potentially related to such activity. “Financial institutions need to know that their vigilance and prompt Bank Secrecy Act reporting matters—it aids investigations tied to human smuggling and transnational organized crime, and can ultimately save lives,” FinCEN Acting Director Himamauli Das said in the announcement.

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