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What You Need to Know
Key takeaway #1: On August 13, 2026, FinCEN issued a Financial Trend Analysis showing 67,540 Bank Secrecy Act (BSA) reports filed between 2023 and 2025 involved more than $4.9 billion in reported suspicious activity potentially related to human smuggling.
Key takeaway #2: Money services businesses (MSBs) filed approximately 97% of the reports, while depository institutions filed only approximately 3% but accounted for nearly 61% of the total reported suspicious activity.
Key takeaway #3: Financial institutions should consider whether the red flags and typologies highlighted in the FTA are appropriately incorporated into their automated transaction-monitoring scenarios for detecting potentially suspicious human smuggling-related activity.
Background
On August 13, 2026, the Financial Crimes Enforcement Network (FinCEN) issued a Financial Trend Analysis (FTA) examining patterns and trends in BSA data associated with suspected human smuggling (i.e., the transportation of persons into or within the U.S. that are not authorized to be there). The analysis is based on 67,540 BSA reports filed between January 1, 2023, and December 31, 2025. The analysis sample comes from reports that included a code from a 2023 alert that FinCEN asked financial institutions to include in suspicious activity reports (“SARs”) and other reporting mentioning suspicious activity relating to human smuggling. Although the reports were filed between 2023 and 2025, they may describe activity before this period.
The reports show a total of $4.9 billion in potential human smuggling activity, which may include both attempted and completed transactions. One notable feature of the reporting is that although MSBs filed approximately 96.6% of the reports, they accounted for only approximately $519 million in reported suspicious transactions (10.6% of the total value of reported activity). By contrast, depository institutions filed only 3% of the reports, but those filings accounted for approximately $3 billion, or 61% of the total value of the reported suspicious activity. FinCEN says that BSA reports filed by depository institutions were less likely than those filed by MSBs to involve an international transfer, and that the amounts involved in individual reports were typically far higher, with several single reports noting transactions of more than $100 million.
The bulk of the reports concerned suspects with addresses in the U.S. (especially Texas, California, New York, Florida, and New Jersey) followed by Mexico, and distantly by Guatemala, Honduras, Colombia, and other countries.
The FTA comes against a background of previous FinCEN guidance regarding human smuggling (including alerts on January 13, 2023 and September 11, 2014) and recent efforts to target the activity of cartels and transnational criminal organizations. Most recently, Executive Order 14406, Restoring Integrity to America’s Financial System, highlighted the use of cross-border funds transfers to facilitate human trafficking and directed Treasury to issue guidance to financial institutions identifying related red flags and suspicious-activity typologies. Other recent efforts include a major MSB enforcement initiative along the southwest U.S. border, a southwest border geographic targeting order (GTO), and the State Department’s designation of various Central and South American cartels as foreign terrorist organizations (FTOs).
Key Indicators Identified by FinCEN
FinCEN quantified several recurring typologies that MSB filers noted as indicators of suspicious activity in their BSA reports:
| Indicator | Percentage |
| No verifiable familial connection between originator and beneficiary | 57% |
| Money flows outside typical transaction patterns | 39% |
| Geographic activity outside the customer’s usual pattern | 23% |
| Money sent to high-risk jurisdictions | 20% |
| Money sent to different unrelated receivers | 17% |
| Money sent along known migration routes | 13% |
| Structuring to avoid recordkeeping requirements | 11% |
| One originator sent money to many beneficiaries | 5% |
| Many originators sent money to one beneficiary | 1% |
Source: FinCEN, Human Smuggling: 2023-2025 Threat Pattern & Trend Information, Figure 6. FinCEN Financial Trend Analysis
FinCEN notes that a single BSA report may contain multiple indicators. Depository institution filings tended to highlight frequent cash deposits, peer-to-peer (P2P) payments and wire transfers among persons and businesses with no apparent relationship, and excessive cash deposits and withdrawals at ATMs along the U.S.-Mexico border, often by persons not employed by cash-intensive businesses.
FinCEN noted that many of these typologies are consistent with human smuggling “red flags” the agency has published in previous alerts and guidance.
One institution, for example, identified a potential funnel account that received numerous small-dollar P2P transfers from more than 30 senders. The customer moved incoming funds between checking and savings accounts before making structured cash withdrawals below currency transaction reporting thresholds at multiple branches and ATMs. FinCEN also highlighted suspicious activity involving travel agencies, including excessive cash and third-party deposits, P2P payments for purported visa services, airline refunds, bulk airline-ticket purchases, and charter flights. FinCEN noted that such activity may involve sham travel agencies as well as legitimate businesses that may be unwittingly facilitating human smuggling.
Implications for Financial Institutions
FinCEN’s analysis provides financial institutions with additional data and context about potential human smuggling, including the potential weighting of different red flags. Financial institutions may wish to consider whether the red flags and typologies highlighted in the FTA are appropriately reflected in their automated transaction-monitoring scenarios, including scenarios involving combinations of customer, counterparty, geographic, and transactional indicators.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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