Resource: FINTRAC’s human trafficking page

Included on FINTRAC’s human trafficking web page are the following lists of red flags:

Types of financial transactions

  • Online advertising and promotional services (e.g. escort services, massage services, relationship services, related peer-to-peer online booking services): frequent payments in multiples of small amounts (e.g. $3, $12, $24) in relatively short timelines and inconsistent with expected activity;
  • Accommodations (e.g. hotels, motels, peer-to-peer online booking services for private and commercial lodgings): payments for short stays and/or stays in multiple cities in a relatively short time period;
  • Distance transportation: frequent purchases for airline, train, and/or bus tickets, possibly for multiple individuals, in relatively short timelines and inconsistent with expected activity;
  • Local transportation: purchases for taxi, limousine, vehicle rentals, and ride sharing services in relatively short timelines and inconsistent with expected activity;
  • Fast food restaurants: frequent low value purchases in relatively short timelines and inconsistent with expected activity;
  • Drug stores, clothing stores, beauty stores (e.g. lingerie, make-up): frequent purchases in relatively short timelines and inconsistent with expected activity;
  • Strip clubs, massage parlors, beauty salons and modelling agencies: credit card payments for purchases made after the establishments’ normal hours of business;
  • Bitcoins or other virtual currencies: frequent purchases in multiples of small amounts (e.g. $3, $12, $24), directly by the client or through exchanges;
  • Online payment services companies: personal account activity inconsistent with expectations involving frequent deposits and payments through an online payment service in small amounts typically under $100. Account funds may then be used for virtual currency deposits/redemptions, or payment of bills, such as personal or third party credit cards;
  • Rent payments: for addresses where prostitution is reported to occur by media, law enforcement, or classified ads; and,
  • Credit card purchases: for online purchases which provide relative anonymity.

Patterns of financial transactions and account activity

  • Cash deposits/withdrawals between the hours of 10 p.m. and 6 a.m.;
  • Multiple cash deposits conducted at different bank branches/ATMs, possibly across different cities and provinces;
  • Frequent transactions (e.g. purchases, payments, account debits/credits, electronic transfers) across different cities and provinces within short timelines;
  • Multiple deposits and/or incoming email money transfers or other forms of electronic transfers, possibly using a temporary address (e.g. hotel), from unrelated third parties with little or no explanation;
  • Account funded primarily via third party cash transactions;
  • Deposits (e.g. via ABM, in-branch, email money transfers, other forms of electronic transfers) followed rapidly by cash withdrawals, bill payments, and/or electronic transfers;
  • Personal account receives frequent deposits but is typically kept depleted, showing no purchases or transactions that would indicate normal activity;
  • Account appears to function as a funnel account; deposits occur in locations where the client does not reside or conduct business;
  • Deposits (e.g. via ABM, in-branch) conducted in one city followed by same day or next day withdrawal and/or purchase conducted in another city;
  • Unrelated third parties sending email money transfers or other forms of electronic transfers to the same beneficiary with no apparent relation to the recipient or no stated purpose for the transfers;
  • Email money transfers to third parties with alternate names provided in brackets [e.g. (Bambi)];
  • Large and frequent electronic transfers between senders and receivers with no apparent relationship;
  • Common address provided by different people undertaking domestic/international funds transfers;
  • Rounded sum hotel transactions;
  • Hotel transactions by the same individual for two separate rooms for the same dates;
  • Hotel transactions followed by a refund for the same amount; and,
  • Pre-authorized hotel by credit card, but accommodations are actually paid for using cash.

Contextual indicators

  • Media or other reliable sources suggest that a client may be linked to criminal activity which could generate proceeds of crime;
  • Media coverage of account holder’s activities relating to human trafficking in the sex trade and/or prostitution rings;
  • Use of addresses where prostitution is reported to occur by media, law enforcement, or classified ads;
  • Phone number provided on online advertising and promotional services is used in different cities and provinces in a short period of time;
  • Use of a third party to execute transactions (for example, under the pretext of requiring an interpreter); and,
  • Client makes deposits accompanied or watched by a third party who may, on separate occasions, accompany or watch clients who are making deposits. The third party may be handing over to the client what is subsequently confirmed to be the client’s identification.

Know your client

  • Financial activity is inconsistent with that expected based on one or more of the following: the client’s financial status, stated occupation, type of account or stated business activity;
  • Clients give contact/identifying information that is traceable through open sources to advertising related to escort services;
  • Use of someone else’s identification, or opening an account in the name of an unqualified minor;
  • Use of aliases for the purpose of opening multiple accounts in different banks, or in different branches of the same bank; and,
  • Addition of an unusual number of individuals as joint account holders, or authorized users to products such as credit cards.


FINTRAC Human Trafficking Page

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