Banks filed only 3% of FinCEN's human smuggling reports but spotted 61% of the $4.9 billion in suspicious activity. The data gap shows why AML needs network intelligence, not just more filings.
Financial institutions have spent years trying to see more suspicious activity. New data from the Financial Crimes Enforcement Network suggests the more valuable question is whether they can see enough of the activity together.
FinCEN said in an Aug. 13 press release that financial institutions flagged nearly $5 billion in activity potentially connected to suspected human smuggling between 2023 and 2025. The analysis covered 67,540 Bank Secrecy Act reports and found recurring indicators: unverifiable relationships between senders and beneficiaries, payments moving along common migration routes and excessive cash activity near the southwest border.
The headline number obscures the finding that may matter most to bank compliance executives. Money services businesses filed approximately 97% of the reports. Depository institutions, including banks and credit unions, filed only about 3%. Yet that small share of bank filings represented roughly 61% of the suspicious activity amount identified in the dataset.
The finding maps how different financial institutions see financial crime. MSBs occupy a natural observation point for cross-border money movement. In FinCEN's dataset, they frequently identified transactions outside customers' normal patterns, including money moving through locations associated with migration routes and suspected efforts to structure transactions around reporting or recordkeeping requirements. According to the findings, 59% of MSB reports cited the absence of a verifiable familial relationship between originator and beneficiary.
Banks appear to see another layer of the network. Their filings highlighted funnel accounts receiving money from numerous individuals, suspected cash structuring and travel agencies arranging transportation for migrants. Those agencies ranged from suspected sham businesses to legitimate companies that may have unknowingly facilitated suspicious transactions.
Put differently, an MSB may see the individual payment. A bank may be better positioned to see what happens when dozens of those payments converge.
Conventional AML systems were largely designed to determine whether an individual transaction, customer or account deviates far enough from expected behavior to warrant review. The FinCEN findings illustrated why the harder compliance problem sits one level above the transaction: determining whether otherwise explainable activities become suspicious when connected.
Banks need tools that can join accounts, merchants, cash activity, peer-to-peer payments, travel spending and external intelligence into one picture. Artificial intelligence and graph analytics could help, but only if they improve judgment rather than simply create another pile of alerts. A better system would identify how parties relate to one another, whether the relationship makes sense, where money moves next and whether behavior changes after law enforcement or regulatory scrutiny increases. It would also help compliance officers distinguish between legitimate migrant support payments and activity that may finance criminal smuggling networks.
FinCEN said suspected human smuggling-related BSA reports peaked in 2024 before declining 62% in 2025. The U.S. ranked first for subject locations by country, followed by Mexico, Guatemala, Honduras and Colombia.
For financial institutions, the main lesson is practical. More reports alone will not solve AML. Better connections might. The firms that can turn scattered transactions into usable network intelligence will give law enforcement more useful leads and give banks a better chance of stopping suspicious money before it moves too far.
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