Clifford Chance

Biden administration Ratchets Up Pressure on Financial Institutions to Help Combat Human Trafficking and Forced Labor

August 12, 2021

The US government is sending clear signals that financial institutions need to increase their focus on detecting and preventing the use of the US financial system in support of human trafficking as a prioritized part of their anti-money laundering program. The Financial Crimes Enforcement Network has long warned financial institutions regarding the risks of their services being misused in support of human trafficking and related crimes, which could constitute specified unlawful activities under the Money Laundering Control Act of 1986. FinCEN issued its first comprehensive guidance on recognizing activity associated with human trafficking in September 2014. Last year, FinCEN issued a supplementary advisory highlighting 20 additional potential behavioral indicators of forced labor and sex trafficking, and four additional typologies. In May 2021, prompted by the Biden Administration, the G7 reaffirmed its members' commitment to protect individuals from forced labor, specifically referencing the risks of forced labor in global supply chains.

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