BSA: Human Trafficking & Smuggling

You may have heard of a movie called “Sound of Freedom,” which topped the box office earlier this month. Whether you’ve seen it or not, it focuses on the sensitive topic of child sex trafficking. While there has been some controversy surrounding this film, it isn’t the first to touch on this topic. What it has done is shined a little bit more light on the issue of human smuggling/trafficking, in general.

So, what does that have to do with the banking industry? Plenty. Just like the drug trade, human trafficking/smuggling is a big problem, and sadly it’s more common than most people may think. FinCEN has put out a couple of Advisories (the most recent in 2020) on this over the years 1) to alert financial institutions to the issue and 2) to help them identify these types of illegal activity. Since financial institutions are, in many ways, the government’s eyes and ears when it comes to suspicious and/or potentially illegal activity, human trafficking and human smuggling should be factored into your BSA/AML Program.

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Published
2023/07/18

Kevin Edwards

Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them. Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).

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