Overview
On May 11, the US Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued a notice to financial institutions, titled "FinCEN Notice on the Threat of Human Trafficking During the 2026 FIFA World Cup" (Notice).[1] The Notice is intended to "support Federal and state law enforcement agencies in protecting victims and identifying suspicious activity potentially indicative of human trafficking around the 2026 FIFA World Cup."[2] Specifically, the Notice provides a list of financial "red flag" indicators of human trafficking and encourages "increased vigilance" by financial institutions in or near host cities.[3] The Notice outlines other factors to consider in conjunction with red flags to determine whether illegal or suspicious activity may have occurred.[4] The Notice also asks financial institutions to report suspected trafficking by filing a Suspicious Activity Report (SAR) with FinCEN and notifying law enforcement via the National Human Trafficking Hotline.[5]
Human trafficking is an ever-present threat that may be exacerbated by international sporting events like the World Cup. Financial institutions and companies in other industries that may be impacted, including hospitality and transportation, should take note of red flags applicable to their respective industries in preparation for such events.
Red Flag Indicators of Human Trafficking
The Notice identifies ten specific red flag indicators of human trafficking that financial institutions should be aware of as they monitor for possible suspicious activity. These are:
- Large local travel expenses, especially in late night or early morning hours (e.g., multiple hotel rooms, rideshare fares).
- A customer's account has few or no transactions for essential needs (e.g., housing, personal products) and may only receive credits or funds from third parties that are immediately transferred to another account.
- An unusually high number of transactions involving essential needs or bulk purchases of prepaid access cards with no apparent lawful purpose.
- A business account without expected payroll expenditures.
- A customer deposits funds in an account at a location where the customer does not reside, and the funds are quickly withdrawn in a separate location for no apparent lawful purpose.
- Frequent deposits or withdrawals of cash at gas station ATMs, particularly between 10:00pm and 5:00am.
- Multiple peer-to-peer (P2P) transfers from accounts with no previous transactional relationships, particularly with vague payment descriptions and particularly if the funds are then sent to another account via P2P methods.
- A customer receiving frequent P2P transfers and seemingly consolidating those funds for no apparent lawful purpose.
- Three rapid, sequential P2P transfers to separate accounts for no apparent lawful purpose.
- A customer's phone number is listed online in commercial sex advertisements.[6]
These red flag indicators, as well as others included in prior FinCEN advisories, should guide anti-trafficking financial measures during international sporting events including the 2026 FIFA World Cup and the 2028 Summer Olympics.
Potential Uses of FinCEN Notices in Investigations or Litigation
Federal and/or state authorities may rely on notices like this to argue companies were "on notice" that trafficking could occur around the World Cup. Such arguments could arise in the context of investigations or litigation. For instance, the Federal Financial Institutions Executive Council (FIFEC), a US interagency body which seeks to standardize principles and forms used in federal examination of financial institutions, has referenced FinCEN guidance in its Bank Secrecy Act/Anti-Money Laundering Examination Manual.[7] Additionally, parties have referenced FinCEN guidance in litigation. For instance, in 2022, a special agent for the Federal Bureau of Investigation referenced FinCEN guidance "to U.S. financial institutions related to reporting of suspicious activity related to Russia" in an affidavit in support of an application for a seizure warrant.[8] Going forward, this Notice may be similarly used by entities governing compliance with reporting requirements or by litigants to demonstrate that financial institutions should have been aware of these human trafficking indicators.
Steps Companies Can Take
The FinCEN notice was directed at financial institutions, but companies in other industries likely to see surges in trafficking-related activity around mega-sporting events—including hospitality and transportation—should also take heed of the red flags that FinCEN outlined and other red flags applicable to their respective industries. We recommend that companies across potentially impacted industries do the following:
- Develop event-specific red flags. FinCEN's notice shows how indicators of trafficking risk evolve in tandem with technology and reveal increased regulatory scrutiny in periods of heightened risk. Many companies have invested in developing trafficking compliance programs, but if those programs are not regularly reviewed and adapted to context, they may only provide paper shields. With the LA Olympics around the corner, it is critical for programs in exposed industries to keep pressure-testing red flags for efficient resilience.
- Create multi-tiered training. For hospitality and related sectors, mega-sporting events can drive substantial increases in company personnel and contractors. These groups will have different exposure to and responsibility for distinct red flags. They may also be vulnerable themselves. Exposed companies should consider distinct training modules tailored to function to ensure they are equipped to identify and respond to red flags.
- Invest in trusted and safe complaints mechanisms. Trafficking risks frequently intersect with other markers of vulnerability—notably, immigration status—which can discourage reporting of harm. These risks are all heightened during mega-sporting events like the World Cup and the Olympics. Effective complaints mechanisms should enable anonymized reporting, trust that the complaint will be taken seriously, and confidence that reporting will not lead to a worse outcome than silence, which may require more context-specific measures than compliance hotlines alone.
Steptoe's Sports Integrity Team advises clients across the sports landscape in due diligence and compliance matters, as well as investigations and litigation. Visit our website for continued alerts about this and related developments. If you have any questions, please contact the authors.
[1] FinCEN Notice on the Threat of Human Trafficking During the 2026 FIFA World Cup. US Dep't of the Treasury Financial Crimes Enforcement Network (May 11, 2026) [hereinafter "FinCEN Notice"], https://www.fincen.gov/system/files/2026-05/FinCEN-WCHT-Notice.pdf.
[2] Id. at 2.
[3] Ibid.
[4] Id. at 4.
[5] Id. at 2, 6.
[6] Id. at 5, 6.
[7] Mission. Federal Financial Institutions Examination Council, https://www.ffiec.gov/about/mission; FIFEC Bank Secrecy Act/Anti-Money Laundering Examination Manual, Appendix F, https://bsaaml.ffiec.gov/manual/Appendices/07.
[8] Matter of Seizure & Search of Motor Yacht Tango, 597 F. Supp. 3d 149, 162 (D.D.C. 2022).
