Law enforcement (LE) suspects human trafficking to occur during a major spotting event. LE officers asked several financial institutions (FIs) to monitor financial transactions occurring before, during, and after the event.

Law enforcement (LE) suspects human trafficking to occur during a major spotting event. LE officers asked several financial institutions (FIs) to monitor financial transactions occurring before, during, and after the event.

An investigator identified a pattern linked to a business. The business* account received multiple even dollar deposits between midnight and 4:00 AM. They occurred each day for several days prior to the date of the sporting event. Also, large cash deposits, typically between 2,000 USD and 3.000 USD. made by a person to the business’ account occurred in many branches in the days after the sports event

There was little information about the company. The company did not have any history of employee payroll expenses or paying taxes. Expenses from the business account included air travel and hotel expenses. Searches about the person making cash deposits showed little. An online social media platform webpage with the individual’s name showed ads for dates" and "companionship."

If the investigator uncovers evidence that foreign nationals are involved in this activity, they should also note the possible presence of:
A . tax fraud.
B . black market peso exchange.
C . trade-based laundering.
D . human smuggling.

View Answer

Answer: D

Explanation:

If the investigator uncovers evidence that foreign nationals are involved in this activity, they should also note the possible presence of human smuggling (D). This is because human smuggling is the illegal movement of people across borders, often facilitated by criminal networks that exploit vulnerable migrants. According to the FATF and Egmont Group report on Financial Flows from Human Trafficking2, “human smuggling can be closely linked to human trafficking, as smuggled migrants may become victims of trafficking along their journey or at their destination” (p. 9).

The report also states that some indicators of human smuggling are similar to those of human trafficking, such as:

Frequent cash deposits or withdrawals in different locations

Use of false or fraudulent identification documents

Expenses related to travel and accommodation

Involvement in online platforms that advertise sexual services

The other options are not as relevant or specific as option D. Tax fraud (A) is the evasion of taxes by individuals or businesses, which may or may not be related to human trafficking or smuggling. Black market peso exchange (B) is a money laundering scheme that involves exchanging illicit proceeds in one currency for another currency at a discounted rate, which is more commonly associated with drug trafficking or trade-based laundering. Trade-based laundering © is the manipulation of trade transactions to disguise the origin and ownership of illicit funds, which is also more likely to be linked to drug trafficking or other types of fraud.

Reference: 1: ACAMS Advanced Financial Crimes Investigations Certification Study Guide, available at ACAMS 2: FATF and Egmont Group, Financial Flows from Human Trafficking, July 2018, available at FATF