On May 11, 2026, FinCEN issued a Notice to urge financial institutions to be vigilant in detecting, identifying, and reporting suspicious activity connected to human trafficking associated with the 2026 Fédération Internationale de Football Association (FIFA) World Cup.
The United States, together with Canada and Mexico, will host the 2026 FIFA World Cup from June 11 to July 19, 2026, in Atlanta, Boston, Dallas, Houston, Kansas City, Los Angeles, Miami, New York/New Jersey, Philadelphia, the San Francisco Bay Area, and Seattle. FinCEN’s Notice urges increased vigilance by financial institutions located in and around host city locations associated with the 2026 FIFA World Cup. FinCEN also said that customer-facing financial institution staff should recognize behavioral indicators of human trafficking, as victims may have little contact outside their traffickers besides financial institution visits.
FinCEN has identified the following red flag indicators to help financial institutions detect, prevent, and report potentially suspicious activity related to human trafficking, including trafficking associated with major events:
A customer in or around a city hosting a major event has unusually large local travel expenses (e.g., multiple hotel rooms, taxi or ridesharing fares, train tickets) in a relatively short period of time, especially expenses occurring during late night and early morning hours, for no business or apparent lawful purpose.
A customer’s account has few or no transactions indicative of obtaining or maintaining essential needs (e.g., housing, personal products and nourishment, travel) and may only receive credits from multiple third parties or a direct deposit or paycheck that is immediately transferred to a singular individual or business account.
A customer’s account has an unusually high number of transactions involving essential needs (e.g., multiple payments for housing or lodging, bulk purchases of personal products and goods for nourishment, travel-related expenses) or bulk purchases of prepaid access cards for no business or apparent lawful purpose.
A customer’s business account does not exhibit normal or expected payroll expenditures for any readily discernible reason. For example, the customer’s business transactions indicate that payroll is nonexistent or extremely low compared to businesses in the same industry with similar profiles.
A customer deposits funds into an account at a location other than where the customer resides and the funds are quickly withdrawn, typically in a separate location from the deposits, for no business or apparent lawful purpose.
A customer frequently deposits or withdraws cash at ATMs, especially ATMs located at gas stations, particularly if the transactions occur between 10:00pm and 5:00am. The customer may quickly transfer deposited funds via P2P transfers to a separate account for no business or apparent lawful purpose.
A customer regularly receives multiple P2P transfers from accounts with which the customer has no previous transactional relationships and for which there is no business or apparent lawful purpose. Payment memos may indicate or contain vague references disguising payment for commercial sex (e.g., “link,” “services,” “donation,” “personal care,” “wellness,” “advertisements,” etc.).25 These funds are then further sent via P2P, in whole or in part, to another account.
A customer receives frequent P2P transfers from multiple accounts and seems to be consolidating funds received by others via P2P transfers for no business or apparent lawful purpose. This activity may be indicative of the movement of funds related to sex trafficking.
A customer sends three rapid, sequential P2P transfers to three separate accounts for no business or apparent lawful purpose. Such payments may indicate illicit massage business payments, where a customer is expected to make three payments, specifically a door fee, a service fee, and a tip for services provided.
The phone number associated with a customer’s account is listed as a contact method in online commercial sex advertisements. This could be potentially indicative of either a victim’s or a trafficker’s account.
The full Notice can be found here.