Your Financial Institution's Role in the Fight Against Human Trafficking

4/24/2018 - By Susann Kunz, CAFP

Human trafficking is much more prevalent than we’d like to believe. With over 600 human trafficking cases reported in 2017, Florida ranked 3rd among all states for reports according to the National Human Trafficking Hotline.  What can you do to combat this crisis?

Financial institutions can play a vital role in the fight against human trafficking.  While some financial institutions’ AML software programs can detect activity that could expose human trafficking, the activity can be detected manually as well.

Red Flags

Account activity red flags that could identify human trafficking:

  • Perpetual low balances – when someone is being used against their will, they’re giving the money they make to the person controlling them.

  • Mainly or all cash deposits and withdrawals.

  • A lot of travel such as hotels, rental cars, Uber, fast food, etc., especially when this travel does not correlate with the occupation listed by the accountholder.

  • No typical transactions in the account such as car payments, rent, cell phone payment, utility bill payment, etc.

Also, by manually researching purchases made from the account, you may be able to identify the purchasing of ads on websites that are known for human trafficking.

Next Steps

When suspicious activity of this nature is identified, the next step is to look at the customer’s profile for age, occupation, and contact information.  In most cases, victims of trafficking are very young.  Investigate what the account holder listed for their occupation at account opening and if the phone number provided is still a working number. 

Filing Your SAR

If evidence has been gathered to support suspect human trafficking, please err on the side of caution and file a Suspicious Activity Report (SAR).  Remember: narrative is key.  Explain your decision to file a SAR by providing dates, activity, places where activity occurred (travel), occupation listed on account profile that doesn’t agree with account activity, and so on.  

Your SAR could literally mean the difference between life and death. For more information on SARs and how your financial institution can combat human trafficking, email me or contact a member of our Financial Institutions team

About the Author | Susann Kunz, CAFP
Susann is a consultant in the Financial Institutions Advisory Group at Saltmarsh, Cleaveland & Gund. Susann joined Saltmarsh in May 2005 after working in the banking industry since 1996 in operations, compliance, lending, and internal auditing. As a result, she brings significant experience to our Financial Institution Advisory Group. 

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