BSA/AML/CFT: Human Trafficking

FinCEN defines human trafficking as the act of recruiting, harboring, transporting, providing, or obtaining a person for forced labor or commercial sex acts through the use of force, fraud, or coercion. This can include online child sexual exploitation. (OSCE).  The Financial Action Task Force, or FATF, issued a report on Detecting, Disrupting and Investigating Online Child Sexual Exploitation. It states that OSCE crimes…include sexual exploitation of children and can also in some cases involve participation in an organized criminal group, fraud, human trafficking and extortion.  It details two specific types of OSCE, Live-streamed Sexual Abuse of Children (LSAC) and Financial Sexual Extortion of Children (FSEC).

The Report gives some General Indicators of Transactions for both LSAC and FSEC activity as well as examples of transactions conducted by consumers and facilitators/abusers that may be indicative of online child sexual exploitation.  We would encourage you to give the Report a look and pass it along to those in your institution who may be in a position to detect such activity.  It’s estimated that 300 million children, or one out of every eight, are impacted by online sexual abuse and exploitation each year.  While these heinous crimes can be difficult to detect, keeping them top of mind and training your employees can help.

Kevin explains more about human trafficking in the video.

 

Published
2025/08/11

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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