CUNA
  • Advocacy
    • Priorities we’re fighting for
    • Actions you can take
  • News
  • Learn
  • Compliance
  • Shop
  • Topics
    • Community Service
    • Compliance
    • Credit Union Hero
    • Credit Union Rock Star
    • Credit Union System
    • Directors
    • Human Resources
    • Leadership
    • Lending
    • Marketing
    • Operations
    • Policy & Issues
    • Sales & Service
    • Technology
  • Credit Union Magazine
    • Buyers' Guide
    • COVID-19
    • Digital Edition
    • Credit Union Hero
    • Credit Union Rock Star
    • Subscribe
    • Advertise
    • Contact
  • COVID-19
  • Advertise
  • Awards
    • Nominate Credit Union Hero
    • Nominate Credit Union Rock Star
  • Podcasts
  • Videos
  • Contact
Learn More about Member Value

News

Member Benefits
Learn more
Learn more about the benefits of membership.
Home » ‘Go after the money’ to stop human trafficking
Compliance

‘Go after the money’ to stop human trafficking

Credit unions can be key players in identifying suspected trafficking and aiding survivors.

November 7, 2018
Ron Jooss
No Comments
Emily Borowski

Credit unions don’t want to believe their members are involved in illegal activities such as human trafficking, but that’s sometimes the case, according to panelists at the 2018 CUNA Bank Secrecy Act Certification Conference, presented with NASCUS, Tuesday in Louisville, Ky.

Due to the diversity of products and services they offer, financial institutions have as many touchpoints with would-be traffickers as any other business, says Sara Crowe, data analysis program director at Polaris.

“Trafficking is motivated by greed and profits,” she says, advising credit unions to “go after the money” to thwart this crime.

Even if criminals can’t be apprehended for trafficking crimes, Crowe adds, they often can be cited for financial crimes.

She says the term “human trafficking” often is misunderstood. Essentially, it’s slavery, and involves everything from child prostitution to forced agricultural labor. Crowe identified 25 types of human trafficking in her presentation.

Credit unions should take these steps in the event of suspected human trafficking, according to Emily Borowski, compliance manager at San Francisco Fire Credit Union:

  • Prepare a suspicious activity report (SAR), and include receipts, copies of checks, wires, and other evidence.
  • Contact law enforcement prior to filing the SAR, and include the contact information section on the SAR.
  • Reference the court case by name and case number in the narrative.

After filing the SAR, be prepared to respond quickly to law enforcement’s request for supporting information from the SAR filing.

Borowski says credit unions can train staff formally through conferences and workshops, and informally through alerts and news reports. “In the end you have to trust yourself and your instincts.”

Credit unions can also help victims recover from human trafficking situations, Crowe says. “It’s hard for many trafficking survivors to get access to legitimate financial services.  That’s where credit unions are essential.”

Colleen Kelly, CUNA’s senior federal compliance counsel, suggests joining local networks of anti-trafficking stakeholders. “Having a financial institution at the table can help them know what you’re seeing and what type of help you can provide,” she says.

For more information:

  • Polaris Project
  • Financial Crimes Enforcement Network guidance

KEYWORDS credit union FinCEN trafficking

Post a comment to this article

Report Abusive Comment

Credit Union Magazine - Spring 2021

Spring 2021

Credit Union Magazine’s Spring 2021 edition features CUNA's 2021 advocacy agenda, strategic planning guidance, and labor market insights.
Digital Edition •  Subscribe

Trending

  • Federal, state regulators release updates to BSA/AML Examination Manual

  • FHFA Extends forbearance, foreclosure and REO eviction moratoriums

  • PODCAST: GAC preview, part 1

Tweets by CUNA_News

Polls

Who should be the 2021 Credit Union Hero of the Year?

View Results
More

Champion of America’s Credit Unions

Credit Union National Association is the only national association that advocates on behalf of all of America’s credit unions. We work tirelessly to protect your best interests in Washington and all 50 states. We fuel your professional growth at every level and champion the credit union story at every turn.

More CUNA

  • About
  • Careers
  • Contact Us
  • Recommended Websites
  • Privacy Policy

Resources for

  • CUNA Board Members
  • Credit Union Advocates
  • Leagues
  • Press
  • Vendors