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According to FinCEN, which red flags within a bank account may, taken together, be indications of modern slavery, human trafficking, and exploitation? (Select Two.)
Correct Answer: B,C
Human trafficking and modern slavery involve illicit financial transactions, often conducted through banks, money service businesses (MSBs), or virtual assets. Option B (Correct): Frequent payments for online advertisements can indicate recruitment for illicit labor or trafficking operations. Option C (Correct): Incoming funds from third-party processors with unclear originators suggest concealed financial flows linked to illicit activities. Why Other Options Are Incorrect: Option A (Incorrect): Transactional activity with a virtual currency exchange alone is not a strong human trafficking red flag. Option D (Incorrect): Cash payments to workers could indicate labor law violations but do not necessarily indicate human trafficking. Common Financial Red Flags for Human Trafficking: Unexplained cash deposits and withdrawals from multiple accounts. Frequent wire transfers to high-risk jurisdictions. Use of prepaid cards to move funds anonymously. Best Practices for Detecting & Preventing Human Trafficking-Related Transactions: Train frontline staff to recognize financial indicators of trafficking. Monitor unusual transaction patterns in industries with high labor exploitation risks. File Suspicious Activity Reports (SARs) when trafficking-related transactions are suspected. Reference: FinCEN Human Trafficking Financial Red Flags (2021) FATF Report on Financial Flows Linked to Human Trafficking 6th EU AML Directive (6AMLD) on Human Trafficking & Financial Crime