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The Super Bowl and human trafficking: How financial institutions can help

Kate Randazzo

January 24, 2025

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Large sporting events like the Super Bowl exacerbate human trafficking

The upcoming Super Bowl usually brings to mind rivalry and camaraderie. But for financial institutions and law enforcement, large sports gatherings mean it’s time to go on high alert for human trafficking.

What is human trafficking?

Financial institutions of all sizes play a pivotal role in detecting and reporting suspicious activity related to human smuggling and human trafficking. Human trafficking is a crime in which force, fraud, or coercion is used to compel a person to perform labor, services or commercial sex. Sadly, there can be an uptick in this practice in areas where large events take place. Any influx of people from all over the world—including the FIFA World Cup, the Olympics, and various other sporting events—requires hiring hundreds of temporary workers for building and staffing events. The increased labor opportunity can open the door for human trafficking.

According to the Alliance to End Human Trafficking, large sporting events like the Super Bowl can be accompanied by an increased demand for commercial sex services. The U.S. Institute Against Human Trafficking reported that the 2021 Super Bowl in Tampa saw 146 arrests made, six victims recovered, and 18 missing children identified. Now, human trafficking is a focus of the upcoming Super Bowl in New Orleans, Louisiana.

With increased demand for manual labor, sex for hire and other services around major sporting events, the Super Bowl should put financial institutions on high alert. Aristides Jimenez, retired Deputy Agent in Charge at DHS, reported that “stables,” groups of trafficked victims who are under the control of a single pimp, travel from all major cities to the host site due to the demand being so high. And while the word "trafficking" implies that victims are being transported from a great distance, some are "stabled" close by in their own neighborhoods, or even enslaved by family members.

FinCEN has issued an updated advisory on identifying and reporting human trafficking, supplementing its 2014 guidance. Together with law enforcement, FinCEN has identified these financial and behavioral red flags of human trafficking.

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Behavioral indicators and transactional red flags

Many behavioral red flags for human trafficking include the presence of a third party, where this person may:

Speak on behalf of the customer
Insist on being present throughout the transaction
Attempt to fill out paperwork without discussing it with the customer first
Keep possession of all of the documents or funds
Claim to be related to the customer (but may lack knowledge of the customer’s important details)
Attempt to open an account for a person not present
Try to open an account for an unqualified minor
Act aggressive or intimidating toward the customer

Additionally, signs that you might be dealing with a human trafficking victim or perpetrator include when the customer may:

Present poor hygiene, malnourishment, or fatigue, or show signs of abuse, physical restraint, or torture
Not know where they are or live, or have inconsistent stories
Exhibit abnormal business payroll expenditures
Have non-existent or meager payroll costs for the size of the customer’s alleged line of business
Deduct large amounts from employees’ wages (e.g., housing, food costs)
Cash payroll checks where most of the funds are kept by the employer or deposited into the employer’s account
Show payments to employment or student recruitment agencies that are not licensed or have labor violations.

Supporting human trafficking victims

According to the National Human Trafficking Hotline, working in the financial industry provides you the opportunity to report suspicious behavior involving 92% of the various types of human trafficking. When you encounter transactions that just don’t feel right, don’t hesitate to file Suspicious Activity Reports (SARs) and call the National Human Trafficking hotline at 888-373-7888.

It's easy to feel overwhelmed by the number of potential human trafficking transactions you find, knowing the abuse that lies behind these transactions. The good news is there are data scientists designing ways to detect these patterns without human intervention. Financial institutions with AML software that incorporates an AML AI solution will be empowered to find data that can free victims faster.

In the meantime, remind front-line staff to trust their gut and be on the lookout for red flags of human trafficking. Banks can help by supporting an organization like Love Never Fails or the Texas Advocacy Project. These organizations support victims of human trafficking by providing housing, counseling, legal help, and professional training.

Learn more human trafficking behavioral indicators with this checklist: "Human Trafficking Red Flags."

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