Financial institutions flagged more than $4.9 billion in suspicious activity linked to suspected human smuggling between 2023 and 2025, according to a Financial Trend Analysis that FinCEN, the US Treasury’s financial intelligence unit, published on August 13, 2026. The study covers 67,540 reports filed under the Bank Secrecy Act (BSA). Its most useful finding for payments professionals is how unevenly those reports split by type of institution: money transmitters filed nearly all of them, while banks reported most of the money.
“Many human smuggling networks generate profit for larger transnational criminal organizations, including Mexico-based drug cartels,” FinCEN Director Andrea Gacki said. “Suspicious activity flagged by financial institutions provides critical information, and we will continue to work closely with both the private sector and law enforcement to dismantle human smuggling networks and protect our borders.”
Banks file 3% of the reports but flag 61% of the money
Money services businesses (MSBs), the US regulatory category that covers money transmitters and remittance companies, filed about 97% of the reports. Depository institutions, meaning banks and credit unions, filed only 3%. On amounts, the split flips: that 3% of filings accounts for about 61% of the money flagged, close to $3 billion.
| Type of institution | Share of reports | Share of amounts |
|---|---|---|
| Money transmitters (MSBs) | ≈97% | ≈11% |
| Depository institutions | ≈3% | ≈61% |
Per filing, the gap is wide. FinCEN puts the average MSB report at $7,961, for about $519 million in all, against roughly $1.5 million for a bank report. The remaining 227 reports came from other filers, such as insurers, casinos, and securities firms. The two groups see different things. Money transmitters see individual remittances as they go out; banks see the pooling accounts where those remittances collect before the money moves on.
The red flags FinCEN highlights
- No verifiable family relationship between sender and recipient, cited in about 59% of the reports filed by money transmitters.
- Cash transactions split up to stay below reporting thresholds, a practice known as structuring.
- Funnel accounts that receive deposits from many different people and are then drained in another region.
- Transfers that follow known migration routes, notably toward Central America.
- Unusually heavy cash activity along the US southwest border.
- Travel agencies used to arrange migrants’ journeys, from sham operations to legitimate businesses that may be unwitting participants.
The United States ranks first among the locations of people named in the reports, followed by Mexico, Guatemala, Honduras, and Colombia. Filings peaked in 2024 at 29,266, then fell 62% in 2025 to 11,018. The published data cannot tell whether that drop reflects less criminal activity or a change in reporting practices.
The figures measure detection, not smuggling itself
A BSA report is a suspicious activity filing that a financial institution sends to the government. It records a suspicion, not a proven offense, and carries no legal finding. The analysis therefore measures detection as it happens inside regulated institutions, not the true scale of human smuggling. Every figure in it should be read that way.
For the remittance industry, the analysis confirms an awkward position. Money transmitters act as front-line sensors: they produce almost all the reports, but without the overall picture that the bank accounts further downstream provide.