FinCEN issues Financial Trend Analysis on Human Smuggling

FinCEN issued a Financial Trend Analysis on 67,540 BSA reports filed between 2023–2025 involving more than $4.9 billion in suspected human smuggling-related activity. While filings declined 62% in 2025, FinCEN identified recurring financial typologies in migration routes across U.S.–Latin America. Key takeaways from the Analysis: 1. MSBs filed 97% of reports, while depository institutions filed only 3% but accounted for 61% ($3 billion) of reported suspicious activity. 2. Key red flags include unverifiable relationships between senders and beneficiaries, unusual transaction patterns, funds sent to migration routes/high-risk jurisdictions, and structuring. 3. Banks identified funnel accounts, frequent P2P payments, excessive cash deposits/withdrawals, and transactions inconsistent with customers’ stated occupations or profiles. 4. Travel agencies can serve as unwitting or intentional facilitators, with suspicious activity including large cash deposits, bulk airline-ticket purchases, charter flights, and visa-related payments. 5. The analysis also highlights emerging activity along the U.S.–Canada border, including P2P transfers, cash/foreign currency exchanges, and geographic activity inconsistent with customer profiles.