Posted by Brian Monroe - firstname.lastname@example.org 07/30/2021
World Day Against Trafficking in Persons 2021: ACFCS offers key tips, tactics, resources to counter criminals, empower fincrime compliance teams
How to find trafficking transaction trails? Look for spike in CC cancellations, late night payments
Over the last decade, through a bevy of globe-spanning public-private partnerships, law enforcement agencies and banks have shared broad and specific red flags to help uncover businesses taking advantage of slave or sex labor.
One key tactic to uncover potential ties to trafficking groups in your institution is looking for accounts without standard sources of income and in terms of credit card transactions, frequent cancellations, according to several fincrime compliance professionals speaking at a conference for the Association of Certified Financial Crime Specialists.
Some examples include:
- Excessive deposits, particularly in round amounts, like $50, $150 and $200.
- Abnormally timed deposits, such as between 10 p.m. and 6 a.m.
- Large denominations of deposits. If normal cash-intensive business, you will have a mix of denominations. Coins. $5 and $10. If human trafficking, you will largely be taking in $50 bills, $20 and $100 dollar bills.
- Illicit groups think banks don’t look for that, but denominations in deposits are recorded at the branch level.
- Deposits in multiple cities, particularly if they are close to each other, over a period of time. Traffickers will take victims from city to city and rotate throughout the country in urban centers in the country.
- Look for the impossible trip, such as deposits and withdrawals at ATMs in two cities that are hours apart by car. If you see that as an AML analyst, it means multiple people are using the same account as a funnel account.
Peer to peer payments (EMT, Venmo, etc.)
- Payments in round consistent amounts. An account that is taking in a lot of these have some telltale signs as well. The fact that the payments are in some sort of increment. $150, $300 and $50, means someone is buying something in increments of hours.
- Multiple originators with some repetition. Many different parties paying into the same account over time and repeat customers. Look for customer drift in multiple cities. Look for a single email address associated with multiple bank accounts or the opposite, a single bank account associated with multiple email addresses, and those tied to online advertising or escort sites.
- Funnel accounts and Peer to peer transfers. They know that is a vulnerable area, used accounts to collect the P2P transfer, then immediately hit an ATM and withdraw the money.
- They know the behavior to stick out, so when a P2P transfer hits a bank account, they pull it out immediately, sometimes in as little as 30 minutes. It is a smurfed account. If that is caught and shut down, they won’t lose a lot of value. A key red flag is 5 – 10 email money transfers and then 5-10 withdraws done on that periodically.
- Multiple payroll deposits into one account, which could be tied to slave labor. This would look like multiple government benefit checks to the same account. Clearly intended for more than two or three people, meaning the person is in control of the labor and taking the money and paying it out – but much less to those actually doing the work.
- Multiple deposits from processors for online adult content, such as Fenix, Onlyfans and the like.
See What Certified Financial Crime Specialists Are Saying
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