Reported by Transform Finance

Common Labor Trafficking Red Flags:

• Feel pressured by their employer to stay in a job or situation they want to leave

• Owe money to an employer or recruiter and/or not being paid what they were promised or are owed

• Do not have control of their passport or other identity documents

• Are living and working in isolated conditions, largely cut off from interaction with others or support systems

• Appear to be monitored by another person when talking or interacting with others

• Are living in dangerous, overcrowded, or inhumane conditions provided by an employer

• Are being threatened by their boss with deportation or other harm

• Are working in dangerous conditions, without proper safety gear, training, adequate breaks, and other protections

Source: Recognizing Labor Trafficking – Polaris (polarisproject.org)

Transactional Red Flags:

• A business customer does not exhibit normal payroll expenditures (e.g., wages, payroll tax, unemployment, etc.)

• Multiple transactions outside of business hours

• Unusual expenses for business, such as paying for hotels, cars services, drug stores, etc.

• Transactions lack a business or apparent lawful purpose

• Cash deposits or wire transfers below reporting thresholds

• Frequent wire transfers to high-risk jurisdictions for known human trafficking or forced labor

Additional Indicators:

• Account appears to function as a funnel account where cash deposits occur in cities or states where the customer does not reside and funds are quickly withdrawn within the same day – after deposit

• Multiple, apparently unrelated, customers sending wires to the same beneficiaries. The sender may use the same addresses and phone numbers

• An individual conducting transactions at a branch is escorted by a third party

• Frequent payments to online escort services for advertising or online classified, website hosting companies

Source: FINCEN Advisory FIN-2020-A008 | FinCEN.gov