Identifying the Signs and Reporting Human Trafficking

Human Trafficking

Having well over 22 years of experience working in guardianship, asset protection, trusts, and probate law, we have seen several forms of corruption and exploitation. We work honestly and tenaciously for all our clients, and in doing so, we understand the importance of education when it comes to exploitation that may seep into these areas of law--and life--including human trafficking.

Likewise, a part of our responsibility is to keep you informed of financial and behavioral red flags and signs indicative of human trafficking to help stop it and its related activities, not only in our local communities, but world-wide.

The Facts about Human Trafficking

“In addition to the horrific toll on victims and their families, their very lives, dignity, and livelihood, human trafficking is now one of the most profitable and violent forms of international crime, generating an estimated $150 billion worldwide per year.

In the United States, human trafficking now occurs in a broad range of licit and illicit industries (e.g., hospitality, agricultural, janitorial services, construction, restaurants, care for persons with disabilities, salon services, massage parlors, retail, fairs and carnivals, peddling and begging, child care, domestic work, and drug smuggling and distribution).” -

Human trafficking exploits innocent and vulnerable individuals for a financial gain. This may include sex trade, forced labor, and domestic servitude. Oftentimes these activities are commonly found in a Front Company which may be a massage business, escort service, bar, or restaurant. Three additional typologies, identified in Bank Secrecy Act (BSA) data since FinCEN issued the 2014 Advisory, that human traffickers and facilitators have used to launder money, include:

  • Exploitative Employment Practices
  • Funnel Accounts
  • Alternative Payment Methods

10 Human Trafficking Warning Signs


We encourage you to read the complete human trafficking advisory document provided by The Financial Crimes Enforcement Network (FinCEN). The following is a snapshot we have pulled, encompassing some of the behavioral and financial red flags pointing towards human trafficking.

5 Behavioral Indicators of Human Trafficking

Many victims of human trafficking do not have regular contact with anyone other than their traffickers. The only outside contact they may have is when visiting financial institutions such as bank branches, check cashing counters, or money wiring services. Consequently, it is important that customer-facing staff consider the following behavioral indicators when conducting transactions,28particularly those that also present financial indicators of human trafficking schemes discussed below.

  • A third party speaks on behalf of the customer (a third party may insist on being present and/ or translating).
  • A third party insists on being present for every aspect of the transaction.
  • A third party attempts to fill out paperwork without consulting the customer.
  • A third party maintains possession and/or control of all documents or money.
  • A third party claims to be related to the customer, but does not know critical details

5 Financial Indicators of Human Trafficking

The Financial Action Task Force report on the “Financial Flows from Human Trafficking” also provides numerous indicators of money laundering related to human trafficking.

  • An individual frequently purchases and uses prepaid access cards.
  • Frequent transactions with online classified sites that are based in foreign jurisdictions.
  • Frequent transactions using third-party payment processors that conceal the originators and/ or beneficiaries of the transactions.
  • A customer avoids transactions that require identification documents or that trigger reporting requirements.
  • Transactional activity largely occurs outside of normal business operating hours (e.g., an establishment that operates during the day has a large number of transactions at night), is almost always made in cash, and deposits are larger than what is expected for the business and the size of its operations.

If you suspect any form of human trafficking or observe any of the red flags and warning signs of human trafficking contact the appropriate authorities, such as the National Human Trafficking Hotline 1 (888) 373-7888. You can also send an SMS text message to 233733 (Text "HELP" or "INFO").They are available 24 hours, 7 days a week.

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