The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) recently issued a Notice to warn financial institutions of the threat of human trafficking associated with the 2026 Fédération Internationale de Football Association (“FIFA”) World Cup, which will be hosted in cities across the United States, Canada, and Mexico from June 11 to July 19, 2026. According to FinCEN, countering human trafficking in all its forms is one of FinCEN’s Anti-Money Laundering and Countering the Financing of Terrorism (“AML/CFT”) National Priorities, as it is a multi-billion dollar industry that generates illicit proceeds for Transnational Criminal Organizations (“TCOs”) and associated networks. In the Notice, FinCEN urges financial institutions “to be vigilant in detecting, identifying, and reporting suspicious activity connected to human trafficking” as major events such as the World Cup can create a “concentrated demand” for licit and illicit services in host cities. The Notice lists the World Cup host cities in the United States as Atlanta, Boston, Dallas, Houston, Kansas City, Los Angeles, Miami, New York/New Jersey, Philadelphia, the San Francisco Bay area, and Seattle. In Canada, the cities are Toronto and Vancouver, and, in Mexico, they are Guadalajara, Mexico City, and Monterrey.
In response to this increased threat, FinCEN recommends that financial institutions located in and around these host cities, especially their customer-facing staff members, exercise increased vigilance to identify behavioral indicators that might be evidence of human trafficking activity, as many victims have no contact with persons other than their traffickers except when visiting financial institutions. For this reason, the Notice provides several red flag indicators of human trafficking near major events. The Notice also urges financial institutions to report suspected human trafficking to law enforcement via the National Human Trafficking Hotline and file suspicious activity reports (“SARs”) regarding suspected trafficking activity as soon as possible. FinCEN also encourages financial institutions to share information with one another under the safe harbor provisions in the USA PATRIOT Act, that permit the sharing of information regarding individuals, entities, organizations, and countries to enable the identification of and, in some cases, the reporting of possible terrorist activity or money laundering related to human trafficking.