After years of neglect, it appears that Human Smuggling financing is a priority to government agencies. Human Smuggling Suspicious Activity Reports (SARs) filed by MSBs have skyrocketed since mid-2021 while banks' filings have remained flat. FinCEN issued then deleted a Human Smuggling Alert on 12/16/2022.
Transnational Organized Crime
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Reporting, discovering, and researching drug trafficking SARs is hindered by the lack of a drug trafficking SAR checkbox.
A recent VICE article on human smuggling and migrant kidnapping quotes DSA president, Alison Jimenez.
Several key threats including Drug Trafficking, Organized Crime and Tax Evasion do not have SAR category checkboxes. SAR data is only "useful" to government authorities inasmuch as it is discoverable. Structured data is more easily searchable and will lead to improved AML effectiveness.
There is a complete disjoint between what financial institutions are asked to report, what they do report, and national illicit finance priorities.
Migrant smuggling tragedies underscore the important role of financial institutions in identifying human smuggling