On August 13, FinCEN published a Financial Trend Analysis examining patterns in BSA/AML data linked to suspected human smuggling activity. The report found that financial institutions flagged nearly $4.9 billion in suspicious activity across 67,540 BSA reports filed between January 1, 2023, and December 31, 2025, linked to such activity. Suspected human smuggling-related filings peaked in 2024 with 29,266 reports before declining 62 percent to 11,018 reports in 2025, a decrease the report said coincided with a significant decline in “illegal crossings at the southwest border.” According to the analysis, money services businesses (MSBs) filed approximately 97 percent of reports in the dataset, totaling roughly $519 million in suspicious transactions. By contrast, depository institutions filed approximately 3 percent of the reports but accounted for 61 percent of the total suspicious activity dollar volume, or approximately $3 billion.

The analysis identified several common indicators of suspected human smuggling, including unverifiable relationships between transaction originators and beneficiaries, which were cited in 59 percent of MSB-filed reports as a basis for filing; fund transfers along known migration routes; and excessive cash activity along the southwest border. The states with the highest number of subject locations were Texas, California, New York, Florida and New Jersey, while Mexico, Guatemala, Honduras and Colombia were the leading subject countries outside the United States. FinCEN also noted that depository institutions identified typologies including suspected structuring of cash transactions, funnel accounts receiving funds from numerous individuals, and travel agencies — both sham operations and potentially unwitting legitimate businesses — arranging travel for migrants. The report was issued pursuant to Section 6206 of the AML Act of 2020, which requires FinCEN to periodically publish threat pattern and trend information derived from BSA data.