MVA White Collar Defense, Investigations, and Regulatory Advice Blog

Last week, the House Financial Services Committee Subcommittee on National Security, International Development and Monetary Policy held a hearing on transnational trafficking networks and illicit finances.  Titled “The Traffickers’ Roadmap: How Bad Actors Exploit Financial Systems to Facilitate the Illicit Trade in People, Animals, Drugs, and Weapons,” the hearing was billed as the beginning of a bi-partisan counter-trafficking initiative to explore legislation to improve (i) the financial sector’s role in identifying trafficking; and (ii) communication among law enforcement, financial institutions and NGOs.   An AML specialist testified that “with better information, financial institutions can integrate (1) trafficking-specific factors or lists into already existing risk assessments and/or screening processes, (2) incorporate specific typology-driven criteria into their transaction monitoring rule program, and (3) provide more effective and targeted information to law enforcement through established channels of communication such as suspicious activity reports.”  In addition to the hearing, several related bills are before congressional committees including the CONFRONT ACT, H.R. 1387, 116th Congress (2019-2020), which would mandate the development of a national strategy to combat the financial sector facilitation of organized crime and money laundering involved in all forms of trafficking.  The hearing and proposed bills indicate increased legislator interest in preventing trafficking, including human trafficking.  Similarly, we would expect regulators to increase their scrutiny, supervision and enforcement of existing trafficking related laws and regulations. 

Click here for more about what financial institutions can do to combat human trafficking.