FIs can detect and report human smuggling if red flags are identified
AFC CHALLENGES
southwest border , FIN-2023- Alert001 . 10 The alert emphasizes the seriousness of the crime , which can endanger lives because criminal organizations value profits over human souls . The southwest border is a hotbed for this crime , where over 2.3 million encounters occurred in 2022 , up from 1.7 million in 2021 and growing . 11 According to the Homeland Security Operational Analysis Center , criminals on the southwest border conducting human smuggling generate an estimated revenue of $ 2 billion to $ 6 billion annually . 12
FIs can detect and report human smuggling if red flags are identified . In addition to the two FinCEN advisories released in 2014 13 and 2020 , 14 the 2023 alert gives several red flags specific to threats along the southwest border , such as frequent cross-border wire transfers , rapid movement of funds and deposits followed by immediate withdrawals ( funnel accounts ).
Illegal arms trade : The U . S . has long been a source of military-grade firearms smuggled into Mexico that end up in drug cartels ’ hands . As reported by CBS News , 15 this illegal arms trade has fueled violence in Mexico , which has spilled into the U . S . border cities at an alarming rate . Cartel gunrunning networks operate like terrorist cells and pay Americans to buy weapons from gun stores and online dealers nationwide .
In a press release , 16 the U . S . Department of the Treasury announced the sanctioning of a well-known Mexican arms trafficker in September 2023 for supporting the CJNG , among other violations . “ CJNG relies on high-powered weapons primarily obtained from the U . S . to protect its territory while intimidating rivals and governmental authorities ,” said Under Secretary of the Department of the Treasury Brian E . Nelson . 17 “ CJNG ’ s access to these weapons contributes to its ability to flood the United States with fentanyl and other deadly drugs . Treasury is working with U . S . and Mexican partners to expose , isolate , and disrupt those who facilitate CJNG ’ s lethal activities .” 18 The Department of the Treasury ’ s action is part of a government effort to stop arms and drug trafficking across the U . S . southwest border .
Potential terrorist entry : One of the most pressing threats to the U . S . is the movement of potential terrorists or extremist elements . Intelligence agencies have raised alarms about extremist individuals exploiting the vastness of this border to enter the U . S . The confluence of these terrorism threats underscores the critical importance of a comprehensive approach to monitoring activity at the southwest border . While the numbers are debated and may be low compared to other threats , there is concern about the potential for extremist individuals or groups to exploit vulnerabilities at the border to enter the U . S . 19 According to NBC News , this year , U . S . border agents have encountered a “ growing number of individuals ” 20 on the Federal Bureau of Investigation ’ s terrorist watchlist , including U . S . citizens , 21 stopped at the southern border . The most significant threat of terrorist activity is from immigrants from the Eastern Hemisphere , including Africa and the Middle East , which has more than doubled in 2023 to 228,000 from 110,000 in 2022 . 22
FIs can detect and report human smuggling if red flags are identified
Conclusion
The U . S . -Mexico border is a focal point of numerous illicit activities that require vigilant oversight by LE and FIs . Recognizing the signs of illicit financial activity and acting on them is crucial in combating the broader issues plaguing the border . FIs , equipped with FinCEN guidance and a deeper understanding of border-related risks , can become formidable partners in the fight against border-related financial crimes . If there is a hint of suspicion , FIs should dive deeper . In our world of financial crime detection , suspicion might be the thread that unravels a more significant , darker scenario . FIs should tailor their oversight based on varying risk profiles . In the AML arena , knowledge is power . Reporting suspicious activities via suspicious activity reports ensures institutions remain ahead of the curve .
Terri Luttrell , CAMS-Audit , board member , ACAMS Central Texas Chapter , compliance and engagement director , Abrigo , Terri . luttrell @ abrigo . com , 1
“ FIN-2019-A006 : Advisory to Financial Institutions on Illicit Financial Schemes and Methods Related to the Trafficking of Fentanyl and Other Synthetic Opioids ,” Financial Crimes Enforcement Network , August 21 , 2019 , https :// www . fincen . gov / sites / default / files / advisory / 2019-08-21 / Fentanyl Advisory FINAL 508 . pdf
36 acamstoday . org