FinCEN recently issued a Financial Trend Analysis (Analysis) on human smuggling that focused on threat patterns and trends identified within Bank Secrecy Act data from 2023 to 2025.
The Analysis is based on FinCEN’s review of 67,540 BSA-related reports tied to suspected human smuggling, which involved more than $4.9 billion in suspicious activity. The Analysis identified several trends, including:
- BSA reports linked to suspected human smuggling peaked in 2024 but then declined significantly (by 62%) in 2025.
- Approximately 97% of the BSA reports were filed by money service business (MSBs) and the subjects of the reports were located primarily in the United States and Latin America.
- While depository institutions filed only about 3% of the total number of BSA reports reviewed, those reports accounted for roughly 61% ($3 billion) of the total dollar amount involved.
We encourage you to review this Analysis and determine how you might be able to incorporate the information into your AML/CFT Program (risk assessment, training, etc.). Keep in mind, human smuggling is one of the current AML/CFT Priorities identified by FinCEN and its detection is vitally important.
We plan to take a closer look at this Analysis in the upcoming September issue of our magazine, Banking on BCC, so be sure to check it out! We also have webinars available now OnDemand for related topics including, the “AML/CFT National Priorities” and “BSA: Trafficking.”
Published 2026/08/26
