Combating International Trafficking, Money Laundering Strategies

In a recent report, the Government Accountability Office (GAO) examined how transnational organized crime and terrorist networks engage in drug trafficking, human trafficking, and money laundering. Various intricate methods may be employed to engage in such activities, including phony trades, the purchasing and selling of real estate or art, and could potentially involve professional money laundering networks, or financial and legal counsel.

The federal government's efforts to combat trafficking and money laundering utilize a variety of information-sharing and collaboration mechanisms, including fostering intragovernmental communication, and collaboration with industry and foreign partners. This framework addresses some of the challenges, including the increasingly sophisticated strategies used by criminals and terrorists, and the fragmentation of responsibility among federal agencies with respect to money laundering and trafficking.  

In 2021, the Financial Crimes Enforcement Network (FinCEN), a bureau of the Treasury Department, designated terrorism financing, drug trafficking, and human trafficking as national priorities for preventing money laundering and counterterrorism. The Bank Secrecy Act (BSA) requires financial institutions to report information on large cash transactions and suspicious activity by their customers to FinCEN. FinCEN partners with approximately 160 international financial intelligence agencies who subsequently incorporate the bureau’s reports into human trafficking and money laundering investigations.

Suspicious transactions indicating examples of trafficking include:

  • Third parties speaking for the customer, insisting on being present during transactions, or acting aggressively towards the customer;

  • Consistent transactions in a variety of U.S. geographical regions;

  • Inconsistent transactions with customer activity expectations;

  • Customers who use a common telephone number or other identifying information with escort agency websites or commercial sex work; and,

  • The use of cryptocurrency to send or receive funds to or from addresses associated with illicit activity.  

Whether it is human trafficking or the movement of goods, the stages of trafficking usually revolve around the countries of origin, transit, and destination.  

According to United Nations Office on Drugs and Crime (UNODC) research, criminal or terrorist organizations transport heroin from Afghanistan to western Europe via the Balkan route, as well as guns, cigarettes, and victims of human trafficking. Further reports from the UNODC indicate that most drugs travel from northern South America to central America to Mexico before reaching the United States; however, each country's route may differ.

In determining their strategies for trafficking persons or goods, these groups consider a variety of factors, according to federal law enforcement. One of these factors is the degree of control they have over a geographic territory, another is the ability to leverage existing operations to meet their aims, and the third is potential penalties in relation to potential profits.

The examined federal interagency groups included the Organized Crime Drug Enforcement Task Forces, Joint Interagency Task Force-South, El Dorado Task Force, Joint Task Force Alpha, the President’s Interagency Task Force to Monitor and Combat Trafficking in Persons, Presidential Task Force on Wildlife Trafficking, Border Enforcement Security Task Force, and Suspicious Activity Report Review Teams.


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