BlogHuman Smuggling, Human Trafficking, and Organized CrimeOctober 8, 2026 by Cheryl Friedenbach Human smuggling and human trafficking are distinct crimes. While human smuggling involves the illegal transportation of people across borders, typically with the consent of those being smuggled, human trafficking involves force, fraud, or coercion for purposes of exploitation. But the... |
BlogFollowing the Money Behind Human SmugglingOctober 1, 2026 by Cheryl Friedenbach In August 2026, FinCEN released a Financial Trend Analysis (FTA) on suspected human smuggling activity. The analysis reviewed 67,540 Bank Secrecy Act (BSA) reports filed between 1 January 2023 and 31 December 2025, representing more than $4.9 billion in suspicious... |
BlogMeasuring What MattersJuly 10, 2026 by Cheryl Friedenbach In my previous post, I explored how FinCEN’s Notice of Proposed Rulemaking (NPRM) from April, 2026 signals a shift toward outcome-focused, risk-based AML/CFT program design. The potential for change is significant, but it raises a more important question: what does... |
BlogCombating Human Trafficking in the Shadow of the 2026 FIFA World CupJune 19, 2026 by Cheryl Friedenbach The 2026 FIFA World Cup arrived this summer across 16 host cities in the United States, Canada, and Mexico. While large-scale events such as the World Cup bring significant economic and cultural benefits there is strong evidence that human trafficking... |
BlogDrug Trafficking Detection: Why Complexity is the Financial Sector’s Greatest ChallengeMay 11, 2026 by Cheryl Friedenbach Drug trafficking remains one of the most persistent and damaging forms of financial crime, and for financial institutions, it is also one of the most complex to detect. As drug trafficking organizations (DTOs) evolve their operations, the financial services community is collaborating to advance anti-money laundering (AML)... |
BlogFinCEN’s Proposed Rule to Reform AML/CFT RequirementsApril 30, 2026 by Cheryl Friedenbach In April, the Financial Crimes Enforcement Network (FinCEN) released a Notice of Proposed Rulemaking (NPRM) that signals a consequential shift in U.S. anti-money laundering and countering the financing of terrorism (AML/CFT) regulation. The proposal is explicitly intended to modernize the... |