Large gatherings of people, like prominent sporting events or major conferences, are a hotbed for Human Trafficking (HT) activity. The size and prominence of the Super Bowl has historically driven a spike in trafficking in the host city but many other events also yield a spike in criminality. This week fans will start to arrive in Miami for the latest round of Formula One racing. Even in the absence of these types of events, Miami is an area that has higher than usual Human Trafficking activity. The race and the parties and travel and events surrounding it only increase the chances that this type of activity will happen. Compliance analysts that work on these types of cases will have to keep an eye out for red flags in Miami at this time. If we pay attention to particular overlaps in risk, we can more effectively identify and report traffickers to our external partners.

To better identify these criminals it is important that analysts think about the activities that are integral to moving and trafficking people, and figure out how to pair those activities with financial cues. Traffickers need to keep victims entertained and fed, while also keeping their expenses and traceability low. Digital footprints for streaming services could reveal critical information such as IP locations, and device identification to investigators. Renting a DVD from a self-service kiosk costs just a couple of dollars and does not expose this kind of information. One of the more unique red flags for HT is an abundance of video rentals, like Redbox, and fast food purchases. Redbox still has more than 40,000 locations in the US and kiosks are generally located in population centers making them a very convenient option.

Traffickers also need to transport their victims throughout the city many times in a single night to maximize their income. Transportation around the city requires multiple vehicles, and the ascendance of ride-share apps has allowed for faster and more timely transport. Despite the loss of anonymity, finding a cab can be difficult and may result in lost income. Many people use ride-share services during conferences or other events but are more likely to call an uber a few times each night, not dozens of times. That type of activity is more indicative of the movement of victims. These people coordinate the transportation of their victims throughout the city using multiple ride-share services. Traffickers and customers tend to want privacy and discretion once a victim is delivered, and so they will often use their credit card to book hotel rooms for each encounter. This results in many short-term reservations in a short period of time. Even when they’re not on the road, it is common to see traffickers book many hotel rooms on the same nights in their hometowns. An individual who lives in Miami generally won’t need to make 10 or more bookings in a week less than 30 minutes from their house.

Traffickers who want to remain more anonymous will also use more cash. Cash movements significantly above the expected Know Your Customer profile estimates, structuring, and the general timing of cash deposits and withdrawals can help investigators accurately assess and identify trafficking risk. Newer products in the payments space, like Venmo, allow for fast digital processing of payments; some traffickers have migrated some of their activity away from cash to these platforms and are happy to trade a bit of anonymity for convenience. An account that shows a spike in transfers involving unknown counterparties for similar amounts should raise suspicion with analysts. Spectators could be sending money to their friends for various reasons like food, merchandise, and event experiences, but seeing many transfers of a few hundred dollars each for the duration of the event coming mostly from strangers should be considered a red flag.

When analysts see these types of financial behaviors together, it creates a compelling case for HT. Once the analyst is ready to file a Suspicious Activity Report (SAR) there are a few important tasks that they must perform to do so accurately and well. Field 38(h) for “Human Trafficking” must be selected. Field 2, the institutional note to FinCEN, is also required to include the latest advisory term “HUMAN TRAFFICKING FIN-2020-A008”. There must be a specific description in Part V, the narrative, articulating why this activity has a possibility of being HT.

According to FinCEN’s SAR Stats tool, there have been more than 100,000 SAR filings tagged for Human Trafficking since the option was introduced to the filing form in 2018. During this time, Florida has seen the 4th highest count of SAR filings for HT; the top 5 states for human trafficking are California, Texas, New York, Florida, and Colorado. SAR filings tagged with HT have also increased by double-digit percentages over the last two full years of reporting.

While these behaviors are generally rare, it’s still important that financial institutions, fintechs, and money service businesses take steps to prevent human trafficking from occurring on their platform. For the individuals working on these types of cases, it’s imperative to view these types of economic behaviors within the context of these large events. Marrying the overlapping information will increase accuracy in detecting and reporting this type of illicit activity. For attendees of this weekend’s race, you can help by reporting any human trafficking activity you see. Check out this PSA from Miami-Dade County to find out how.