FinCEN Flags Nearly $5 Billion Linked to Suspected Human Smuggling

Key insights included:

➡️ BSA Reporting Trends: FinCEN analysed 67,540 Bank Secrecy Act (BSA) reports associated with suspected human smuggling, with reporting peaking in 2024 before declining by 62% in 2025;

➡️ Money Services Businesses: (MSBs) filed approximately 97% of reports, with subjects primarily located in the US and Latin America;

➡️ Transaction Indicators: MSBs identified transactions outside customers’ usual patterns, funds sent to locations along common migration routes and suspected structuring to avoid recordkeeping and reporting requirements;

➡️ Originator and Beneficiary Relationships: 59% of MSB reports indicated no verifiable familial connection between the transaction originator and beneficiary as a basis for filing;

➡️ Depository Institutions: Depository institutions accounted for approximately 3% of reports but approximately 61% of the total suspicious activity amount;

➡️ Human Smuggling Typologies: Depository institutions identified suspected structuring of cash transactions, funnel accounts receiving funds from numerous individuals and travel agencies arranging travel for migrants; and

➡️ Geographic Trends: The US ranked first for subject locations, followed by Mexico, Guatemala, Honduras and Colombia.

✅ Financial institutions should assess whether the indicators and typologies identified by FinCEN are appropriately reflected in their financial crime risk assessments, transaction monitoring frameworks and investigative processes.