CUNA’s latest Compliance Blog provides an overview of available resources to help credit unions combat human trafficking in their communities. Human trafficking happens 365 days a year in cities and towns across the country. Credit unions must remain diligent on this issue to create awareness and be part of the solution.

The full text of the post, 40 Sex Traffickers Arrested At The Super Bowl – Homeland Security Offers Posters For Your Credit Union, is below:

As I walked through the Atlanta airport yesterday, while the Super Bowl festivities were winding down, I was not surprised to see human trafficking notices streaming on the baggage claim monitors.  This was a stark reminder that not only did a million football fans pour into the city to watch the Big Game – but human sex traffickers also poured into the city to take advantage of the increased demand for young women.

According to reports, in preparation for the Super Bowl, the city of Atlanta had gathered many of their non-profits, faith-based organizations, elected officials, government agencies, and law enforcement departments to boost awareness and attack this horrific crime that, year after year, plagues the Super Bowl activities.

But, as we well know, human trafficking happens 365 days a year and in most cities across the country.  Cities that have the highest rate of human trafficking usually have a convention center, an international airport, and multiple interstate highways.

At last year’s Regulatory Compliance School, several credit unions shared ideas of how they are working to combat Human Trafficking in their credit unions through training and posting the National Human Trafficking Hotline number (1-(888) 373-7888) in their lobbies and restrooms.  You can order posters from Homeland Security’s Blue Campaign, which was created to protect the basic right of freedom and to bring those who exploit human lives to justice.

Additionally, FinCEN’s Advisory FIN-2014-A008 offers a number a human trafficking red flags for you to incorporate into your training, such as:

  • Substantial deductions to wages, where the employee only receives a small fraction of their wages;
  • Transactions are conducted by individuals escorted by a third party, sometimes under the pretext of requiring an interpreter, to transfer funds to other countries;
  • Frequent transaction that are inconsistent with the expected activity and which appear to provide sustenance for many individuals (ie: payment for housing, lodging, regular vehicle rentals, purchases for large amounts of fast food).
  • Payments to employment or student recruitment agencies that are not licensed / registered or that have labor violations;
  • Address of a business is an apartment complex;
  • Multiple unrelated people living at the same address;
  • Rent payments for multiple locations within apartment complexes.

Whether your credit union is in a major metropolitan area or a small town, your community is not immune from this fast-growing industry. The FBI estimates that 300,000 American children are lured each year into sex trafficking by being stalked on FaceBook, at movie theaters, parks, bowling alleys and even at after school activities. Credit unions have a great opportunity to create awareness around this issue and to be part of the solution.