ACAMS FinCEN Targets Human Smuggling Across Southwest Border

January 13, 2023

The Treasury Department’s Financial Crimes Enforcement Network, or FinCEN, recommended that financial institutions should monitor for irregular cash deposits, multiple, inexplicable wire transfers, and other red flags that may be related to human smugglers along the US-Mexico border. FinCEN advised financial institutions to use the term “FIN-2023-HUMANSMUGGLING” when filing suspicious activity reports (SAR). AnnaLou Tirol, a partner at O’Melveny & Myers LLP and former FinCEN deputy director, noted that the code is used to expedite reporting to investigators. “Any time FinCEN provides financial institutions with a specific code such as this one, it’s a flag that there is law enforcement interest in receiving this specific information,” Tirol said.

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