Key points include:
➡️ Heightened Event Risk: Major events can create concentrated demand for licit and illicit services, increasing exposure to sex and labour trafficking risks in and around host cities;
➡️ Suspicious Activity Reporting: FinCEN strongly encourages firms to file Suspicious Activity Reports (SARs) on potential human trafficking linked to the FIFA World Cup as soon as possible, regardless of threshold;
➡️ Law Enforcement Notification: Firms should also notify suspected human trafficking-related activity through the National Human Trafficking Hotline;
➡️ Information Sharing: FinCEN encourages voluntary domestic and cross-border information sharing between financial institutions to identify, report and prevent money laundering linked to human trafficking; and
➡️ Red Flag Awareness: Customer-facing staff should understand transactional and behavioural indicators, including unusual travel-related activity, cash deposits, peer-to-peer transfers, prepaid cards, withheld wages and limited spending on essential needs.
✅ Firms operating in or around World Cup host cities should refresh human trafficking typologies, front-line escalation procedures, SAR filing protocols and information-sharing arrangements ahead of the event.