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