WASHINGTON — U.S. financial institutions flagged nearly $5 billion in transactions potentially linked to human smuggling from 2023 through 2025, with money services businesses filing the overwhelming majority of reports but banks and other depository institutions accounting for most of the suspicious dollar volume, according to a new analysis by the Financial Crimes Enforcement Network.
FinCEN said its analysis of 67,540 Bank Secrecy Act reports identified recurring signs of suspected human smuggling, including transactions between people with no verifiable relationship, transfers to locations along common migration routes and unusually high levels of cash activity near the U.S.-Mexico border.
“Many human smuggling networks generate profit for larger transnational criminal organizations, including Mexico-based drug cartels,” FinCEN Director Andrea Gacki said in a statement. “Suspicious activity flagged by financial institutions provides critical information, and we will continue to work closely with both the private sector and law enforcement to dismantle human smuggling networks and protect our borders.”
62% Decline
FinCEN said suspected human smuggling-related BSA reports peaked in 2024 before falling 62% in 2025.
The United States was the most frequently identified location for subjects of the reports, followed by Mexico, Guatemala, Honduras and Colombia.
The Findings
Among FinCEN’s findings:
- Money services businesses accounted for about 97% of the BSA reports. The subjects of those reports were primarily located in the United States and Latin America. MSBs cited activity including transactions inconsistent with a customer’s normal behavior, money transfers to locations along common migration routes and suspected structuring designed to avoid recordkeeping or reporting requirements.
- A lack of an apparent relationship between senders and recipients was a frequent red flag. FinCEN said 59% of reports filed by MSBs indicated there was no verifiable family relationship between the person originating a transaction and its beneficiary.
- Depository institutions filed only about 3% of the reports but accounted for about 61% of the suspicious dollar amount. Their filings identified activity including suspected structuring of cash transactions and funnel accounts receiving money from numerous individuals.
- Travel agencies also surfaced in the reports. FinCEN said depository institutions identified travel agencies arranging transportation for migrants, ranging from sham operations to legitimate businesses that may have unknowingly facilitated suspected smuggling activity.
BSA Data Examined
FinCEN’s report examined BSA data to identify financial patterns and trends associated with suspected human smuggling. The agency said the information financial institutions provide through BSA reporting can help law enforcement identify and disrupt smuggling networks.
The analysis is part of a series of FinCEN Financial Trend Analyses that use BSA data to examine emerging and ongoing illicit-finance threats. For additional info, go here: Financial Trend Analyses
