FinCEN Notice - Summarized by the NJCAHT Bank Awareness Committee
FinCEN is the U.S. Department of the Treasury’s Financial Crimes Enforcement Network
World Cup, Human Trafficking, and Money Laundering
On its face it might not be obvious how the World Cup, human trafficking, and money laundering are connected — however, they are interrelated. Large sporting events are known to present great opportunities for traffickers and the people who exploit men and woman for sex and forced labor. The World Cup is no different and if anything, the event will perpetuate human trafficking for weeks, unlike other sporting events which typically last only one or two days.
Human trafficking is a crime that involves force, fraud, or coercion to compel a person to provide commercial sex acts or forced labor or services. Traffickers take advantage of vulnerable people, and the victims do not fit any one profile.
The demand for human trafficking in the U.S. is high all year. Yet, human trafficking is more prevalent at sporting events because there is a huge influx of people who attend sporting events in a concentrated area that are willing to pay for commercial sex or use forced labor. Human trafficking can happen at any venue, including hotels and spas or other businesses that provides goods and services to attendees.
Traffickers operate no different from legitimate businesses. They collect revenue and must pay expenses. However, their payroll might be non-existent because they rarely pay the victims or if they do, their pay is well below market. The traffickers will have revenue in the form of illicit proceeds that they will need to deposit at banks to pay for expenses or items for themselves. Traffickers employ different schemes to lauder their illicit proceeds and avoid detection by banks and law enforcement. For example, a trafficker might co-mingle their trafficking proceeds with proceeds from a legitimate business to make the illicit proceeds appear that it is coming from a legal business.
On May 11, 2026, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Notice (FIN-2026-NTC1) to urge banks and other financial institutions to be vigilant in detecting, identifying, and reporting suspicious activity associated with the World Cup. This Notice and prior FinCEN notices* provide behavioral indicators (behavior of people who conduct transactions) and financial/transaction indicators (money movement) red flag indicators of human trafficking to help banks detect, prevent and report human trafficking activity. Below is an overview of the red flag indicators from the Notice:
1. Behavioral Indicators (Victims or Traffickers) - These are signs frontline staff, community members, or service providers may observe.
Possible Victim Indicators
- Appears fearful, anxious, submissive, or coached when speaking.
- Someone else controls their ID, money, or documents.
- Avoids eye contact or lets another person speak for them.
- Shows signs of physical abuse, malnourishment, or exhaustion.
- Has restricted freedom of movement or is constantly monitored.
- Cannot explain where they live or where they are traveling.
- Works excessively long hours with no breaks or days off.
- Expresses confusion about their location, job, or the people around them.
Possible Trafficker Indicators
- Controls another person’s transportation, documents, or communication.
- Insists on being present for all conversations.
- Pays for others’ lodging, travel, or services in unusual patterns.
- Moves individuals frequently between hotels, cities, or worksites.
2. Financial Indicators -These are especially relevant for banks, credit unions, fintechs, and payment platforms.
Unusual Travel & Lodging Patterns
- Multiple hotel rooms, rideshares, or travel expenses in a short period.
- Late-night or early-morning travel activity with no clear business purpose.
Suspicious Cash or ATM Activity
- Frequent ATM deposits/withdrawals at gas stations between 10pm–5am.
- Cash deposits in one location followed by rapid withdrawals elsewhere.
Peer-to-Peer (P2P) Transfer Red Flags
- Numerous P2P payments from unrelated individuals.
- Payment memos with vague or coded terms such as:
- “services,” “link,” “donation,” “wellness,” “personal care,” “advertising.”
- Rapid onward transfers of received funds to other accounts.
- Three quick sequential P2P payments (door fee, service fee, tip) — a pattern seen in illicit massage businesses.
Payroll or Business Irregularities
- Business accounts with no payroll or unusually low payroll for the industry.
- Wages deposited into a worker’s account and immediately transferred to another person.
Essential Needs Patterns
- Victim accounts with no spending on food, housing, or personal items.
- Or the opposite: bulk purchases of essentials or prepaid cards with no business explanation.
Online Commercial Sex Indicators
- A phone number linked to an account appears in online sex ads.
3. Labor Trafficking Indicators
Often seen in hospitality, construction, agriculture, domestic work, and event-related temporary labor.
- Workers transported to and from job sites in groups, with no control over their schedule.
- Withheld wages, debt bondage, or unexplained deductions.
- Workers living and working in the same location under surveillance.
- No access to personal documents or employment contracts.
- Signs of isolation — not allowed to speak to others freely.
4. Sex Trafficking Indicators
- Frequent movement between cities or hotels.
- Someone else holding the victim’s earnings.
- Advertisements posted online by a third party.
- Victims required to meet high daily quotas.
- Payments made in cash, prepaid cards, P2P apps, or digital assets.
*FinCEN prior notices on human trafficking:
- FinCEN, FIN-2014-A008, “Guidance on Recognizing Activity that May be Associated with Human Smuggling and Human Trafficking – Financial Red Flags” (Sept. 11, 2014)
- FinCEN, FIN 2020-A008, “Supplemental Advisory on Identifying and Reporting Human Trafficking and Related Activity” (Oct. 15, 2020);
- FinCEN, FIN-2023-Alert001, “FinCEN Alert on Human Smuggling Along the Southwest Border of the United States” (Jan. 13, 2023);
You do not need to work at a bank or another financial institution to identify these risk indicators. If you observe any of the red flag indicators you can report them to the National Human Trafficking Hotline toll-free at 1-888-373-7888; text 233733; chat the hotline via humantraffickinghotline.org/chat; or submit an anonymous tip online: Report Trafficking | National Human Trafficking Hotline. However, if the situation is urgent or occurred within the last 24 the hotline encourages you to call, text, or chat.
