- Key insight: Banks and credit unions filed about 3% of the suspected human smuggling reports Fincen counted but accounted for about 61% of the suspicious dollars.
- What's at stake: The typologies Fincen describes are ordinary retail banking activity, including funnel accounts, structured cash withdrawals and border ATM traffic, which puts them inside the monitoring perimeter of banks that may not think of themselves as exposed to smuggling.
- Supporting data: Banks and credit unions sent the Treasury Department 6.19 million suspicious activity reports from 2023 through 2025, making the 2,075 human smuggling reports they filed roughly one in every 3,000.
Overview bullets generated by AI with editorial review.
Money used for human smuggling moves through U.S. banks disguised as everyday activity, just as it does with scams, fraud, money laundering and other financial crimes. Banks rarely flag it, but when they do, they flag large sums.
Banks and credit unions filed just 3% of the suspected human smuggling reports the Financial Crimes Enforcement Network, or Fincen, counted in
The analysis shows what it looks like when humans smuggling money surfaces inside a bank: accounts collecting deposits from dozens of strangers, cash withdrawn in amounts small enough to avoid automatically triggering a report and ATM traffic along the southwest border.
The dataset Fincen analyzed covers 2023 through 2025 and shows filings falling as illegal border crossings also decrease; 2025 saw 62% fewer filings about human smuggling compared to 2024.
Human smuggling is the act of illicitly moving a person — chiefly, moving them into the United States. Migrants typically choose to make the journey and pay for it, often through relatives already in the country, according to
Human trafficking is a different crime. It involves moving or holding a person for forced labor or commercial sex through force, fraud or coercion, according to the same Fincen advisory. A trafficking victim does not consent; a smuggled person typically does.
The filings are suspicious activity reports, or SARs. Financial services companies send these reports to Fincen when a transaction or attempted transaction appears to be related to money laundering, fraud, human smuggling and a wide range of other crimes.
What a human smuggling transaction looks like
Banks and credit unions sent the Treasury Department 6.19 million SARs from January 2023 to December 2025, according to Fincen's published
Very few reports referenced an international money transfer at all. Nearly all of them (98%) named a subject in the United States, according to the analysis. Mexico, the next most common country, appeared in only 2%. (A single report can name subjects in more than one country.)
That does not mean the smuggling stayed domestic. Smugglers collect their fees inside the United States, often from relatives of the person being moved, according to the 2014 advisory. The transactions a bank sees can cross no border even when the crime does.
Many filings flagged activity such as "excessive travel purchases or negative news on subjects of the filings," according to the analysis. Negative news refers literally to negative press coverage — banks looking for customers who have already drawn public attention.
In terms of how this activity actually manifests at a bank, one financial institution reported a funnel account (one that gathers deposits from many unrelated senders) taking in more than 500 transactions from more than 30 people from March to July 2023. The transactions totaled $68,000.
The account holder moved that money into savings, then cashed it out from various branches and ATMs, all in amounts below the $10,000 threshold that triggers an automatic currency report. This evasive practice is called structuring.
Another institution found more than $195,000 in unusual cash deposits paying for debit card purchases at a tactical thermal equipment supplier. The two customers (a student and a produce company owner) also pulled cash repeatedly from ATMs in Arizona.
The two bought nearly $30,000 worth of merchandise from a company that sells thermal binoculars and night vision attachments, goods that "could aid in human smuggling operations," according to the analysis.
Travel agencies recur in the report, ranging "from sham operations to legitimate businesses that may be unwittingly facilitating" human smuggling, according to the analysis.
One filer flagged a travel agency in Juarez, Mexico, whose account drew nearly all its funding from cash deposited along the southwest border. The supposed agency had no payroll activity at all.
Catching this kind of activity after the fact is how bank monitoring normally works, not a sign it failed, according to Daniel Stipano, a partner at the law firm Davis Polk and a former deputy chief counsel at the Office of the Comptroller of the Currency.
"Potential suspicious activity is almost always identified after the fact by transaction monitoring systems because they are more of a detective, as opposed to a preventative control," Stipano told American Banker.
Banks typically escalate those alerts for investigation, which "usually includes a consideration of negative news," Stipano said.
Filings fell 62%, likely from less illegal immigration
Suspected human smuggling reports peaked in 2024 around 29,000, then dropped to roughly 11,000 in 2025, a decrease of 62%.
Fincen counted these reports by the date someone filed them, not the date of the activity they describe. The reports "may refer to incidents that occurred in previous months and years," the analysis said, and filers often described activity stretching back before 2023.
The decrease in human smuggling SARs correlates with a decrease in apprehensions at the southwest border.
Arrests fell below 240,000 in fiscal 2025, which was about 87% below the average of the previous four years and the lowest total in 55 years, according to an
CBP's apprehension figures follow the federal fiscal year, which runs from October through September. Fincen's filing counts follow the calendar year.
There "can be a number of reasons for the decline in filings," Stipano said, "but the sharp drop in illegal border crossings in 2025 likely accounts for the bulk of the decrease."
