On May 11, FinCEN issued a notice advising financial institutions to exercise heightened vigilance in detecting and reporting suspicious activity related to human trafficking in connection with the 2026 FIFA World Cup, which the U.S., Canada, and Mexico will host from June 11 to July 19. The notice stated that major events can generate concentrated demand for both licit and illicit services, increasing vulnerability for individuals to be trafficked for the purposes of sex or labor. FinCEN identified red flag indicators for financial institutions, including: (i) customers with unusually large local travel expenses in short timeframes near host cities; (ii) accounts lacking transactions for essential needs; (iii) business accounts with absent or abnormally low payroll expenditures; and (iv) frequent peer-to-peer transfers from unrelated accounts with vague payment descriptions, among others. The notice requests that financial institutions filing Suspicious Activity Reports (SARs) on potential trafficking related to the World Cup include the key term “FIN-2026-HTWORLDCUP” and select “SAR Field 38(h) (human trafficking).”

FinCEN also encouraged financial institutions to share information with one another under the safe harbor provided by Section 314(b) of the USA PATRIOT Act and to engage in voluntary cross-border information sharing to help identify and disrupt trafficking networks. The notice noted that human trafficking and transnational criminal organizations are among FinCEN’s AML/CFT National Priorities, and that Treasury’s 2026 National Money Laundering Risk Assessment (covered by InfoBytes here) identified human trafficking as a multi-billion dollar industry generating substantial illicit proceeds. In addition to filing SARs, FinCEN further urged financial institutions to notify law enforcement of suspected trafficking activity via the National Human Trafficking Hotline.