Often, victims of human trafficking do not regularly interact with anyone outside of their traffickers. Therefore, when a victim visits a financial institution, it may be the only outside contact they have, making it critical that frontline staff is properly trained on behavioral indicators when conducting their transactions. When appropriate, this information should also be included in a suspicious activity report (SAR) filings and reported to law enforcement. Be sure to note the specific indicators, as well as the staff that witnessed the behaviors. Many of these behaviors include the presence of a third party, where this person may:
- Speak on behalf of the customer
- Insist on being present throughout the entirety of the transaction
- Attempt to fill out paperwork without discussing it with the customer first
- Keep ahold of all of the documents or funds
- Claim to be related to the customer (but may lack knowledge of the customer’s important details)
- Try to open an account for an unqualified minor
- Act aggressive or intimidating toward the customer
Staff may encounter a prospective customer using – or attempting to use – the identification of another party that isn’t present to open up an account, which is another telling behavioral indicator. FinCEN also notes important physical and visual characteristics that can indicate the customer may be a victim of human trafficking. The customer may show signs of poor hygiene, malnourishment, or signs of physical abuse. Victims could might also display a lack of knowledge about their personal details or provide inconsistent stories when prompted by the staff.
Financial institutions play a large role in identifying and thwarting human trafficking schemes. From frontline staff identifying behavioral indicators to BSA Officers recognizing suspicious red flags in transaction activity, there are many areas within the financial institution that can detect and report suspicious activity to impede human trafficking schemes. If your financial institution suspects a possible human trafficking incident, FinCEN encourages financial institutions to file a SAR, using the term “Human Trafficking FIN-2020-A008,” and check the SAR Field 38(h) on the form.
Kylee Wooten, Content Marketing Manager at Abrigo, also contributed to this article.
