FinCEN Analysis Flags Nearly $5 Billion in Suspected Human Smuggling-Related Activity
The U.S. Financial Crimes Enforcement Network has published a new Financial Trend Analysis examining Bank Secrecy Act data linked to suspected human smuggling between 2023 and 2025. FinCEN analysed 67,540 BSA reports filed during the three-year review period, covering more than $4.9 billion in reported suspicious activity.
The analysis is based on BSA filings that used FinCEN’s human-smuggling key term or identified human smuggling as a suspicious activity type. FinCEN cautioned that the figures do not represent the total scale of human smuggling and may include attempted transactions, completed transactions, duplicate transactions and activity that occurred before the filing period.
Reporting fell sharply in 2025
Suspected human smuggling-related filings peaked in 2024 at 29,266 reports, compared with 27,256 in 2023. The number then fell to 11,018 reports in 2025, a 62% decline from the 2024 peak. FinCEN noted that the decline coincided with a significant reduction in illegal crossings at the U.S. southwest border.
The United States was the most common subject location in the dataset, followed by Mexico, Guatemala, Honduras and Colombia. Within the United States, Texas, California, New York, Florida and New Jersey were the leading subject locations.
MSBs filed 97% of reports
Money services businesses accounted for approximately 97% of the BSA reports in the dataset, filing 65,238 reports. Those filings covered about $519 million in suspicious human smuggling-related transactions, with an average reported amount of $7,961 and a median of $3,560.
FinCEN identified several recurring indicators in MSB filings. The most common was the absence of a verifiable family relationship between the transaction originator and beneficiary, appearing in 38,683 reports. Other frequent indicators included transactions outside a customer’s normal pattern, money sent to high-risk jurisdictions or known migration routes, transfers to unrelated recipients, and structuring designed to avoid recordkeeping requirements.
Mexico and the United States were the two most common MSB branch locations. Among money orders, high-volume sender locations included Houston, Los Angeles and Dallas, while major receiver locations included Ciudad Juarez, Villahermosa, Tapachula, Monterrey and Guatemala City.
Banks reported fewer cases but much higher values
Depository institutions filed only 2,075 reports, about 3% of the dataset, but those filings accounted for approximately $3 billion, or 61% of the total reported suspicious activity. FinCEN said bank filings highlighted patterns including cash structuring, funnel accounts receiving funds from numerous individuals, and travel agencies that may have been used to arrange migrant travel.
The report also identified more than $32 million in suspicious transactions associated with MSBs in Canada and activity consistent with human smuggling across the U.S.-Canada border. In one example cited by FinCEN, an individual sent more than $250,000 in peer-to-peer transfers to a person who had been indicted on alien-smuggling charges.
For compliance teams, the analysis provides a current BSA-based view of how human smuggling proceeds can appear across MSB and banking channels. The sharp differences between MSB filing volumes and bank-reported transaction values also show why institutions need to assess both transactional behaviour and the broader network context rather than relying on transaction size alone.
