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#1904859 - 03/13/14 01:53 PM Reporting Possible Prostituion/Human Trafficking
Kristen C. Offline
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We have a client who we are filing a SAR on for suspected prostituion and possible human trafficking. Once we submit the SAR I would like to contact someone to give them a heads up. Who would I reach out to, Department of Homeland Security, Immigration????

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#1904865 - 03/13/14 01:59 PM Re: Reporting Possible Prostituion/Human Trafficking Kristen C.
ACBbank Offline
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HSI and ICE would be the appropriate contacts in this situation.
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#1904866 - 03/13/14 02:01 PM Re: Reporting Possible Prostituion/Human Trafficking Kristen C.
Xian Ngyuen Offline
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Just to be clear, the 'heads-up' doesn't include saying that you've filed a SAR, does it?

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#1904888 - 03/13/14 02:22 PM Re: Reporting Possible Prostituion/Human Trafficking Xian Ngyuen
Kristen C. Offline
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No I do not plan on sharing that.

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#1904945 - 03/13/14 03:13 PM Re: Reporting Possible Prostituion/Human Trafficking Kristen C.
Xian Ngyuen Offline
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Thanks.

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#1904991 - 03/13/14 03:51 PM Re: Reporting Possible Prostituion/Human Trafficking Kristen C.
Elwood P. Dowd Offline
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After the SAR is filed, it is permissible to say that you have filed it if you are talking to a law enforcement agency. It would be more appropriate for you to just provide the SAR's DCN and the generic content rather than to discuss the details on the phone. Make a note of the name and position of the person you spoke with.
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#1905562 - 03/14/14 05:20 PM Re: Reporting Possible Prostituion/Human Trafficking Kristen C.
NewTooBSA Offline
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I agree with Ken as I have done that several times in the past when filing a SAR and wanted someone in law enforcement to be aware of the filing. They really appreciate the heads up if it is an investigation they are already working on. But again, AFTER the SAR has been filed and the DCN number is available.

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#1905586 - 03/14/14 06:02 PM Re: Reporting Possible Prostituion/Human Trafficking Kristen C.
Tennismom Offline
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Originally Posted By: Kristen C.
We have a client who we are filing a SAR on for suspected prostituion and possible human trafficking. Once we submit the SAR I would like to contact someone to give them a heads up. Who would I reach out to, Department of Homeland Security, Immigration????


Maybe I am missing something here, however your concern is to file a SAR and then contact authorities. Were talking human trafficking, correct? Each hour, each day, each week you remain silent about your concerns could be another life that falls into the hands of traffickers. Report this to National Human Trafficking Resource Center (NHTRC) immediately. They have a hotline staffed 24/7. Im sure you can report your concerns anonymously.

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#1905780 - 03/17/14 12:26 PM Re: Reporting Possible Prostituion/Human Trafficking Kristen C.
joser Offline
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Just curious - how did you pick up the activity? Was it one or more of the red flags?

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#1907787 - 03/21/14 07:59 PM Re: Reporting Possible Prostituion/Human Trafficking Kristen C.
Lilly C Offline
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joser: did you get an answer to your question? I'm curious too.

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#1908349 - 03/25/14 03:19 PM Re: Reporting Possible Prostituion/Human Trafficking joser
Kristen C. Offline
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In response to the question of how we picked up on the activity, we noticed several small checks that were deposited into a personal account were returned "refer to maker", each check was payable to cash. We asked the branch staff to reach out to the customer and inquire about the items and the customer was very cryptic about her answers but ultimatley revealed that she had "girls" who had accepted the checks. We did some internet research and found out that the customer was tied to several properties that were raided for prostituion, etc.

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#1908365 - 03/25/14 03:37 PM Re: Reporting Possible Prostituion/Human Trafficking Kristen C.
Elwood P. Dowd Offline
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A+
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#1908369 - 03/25/14 03:40 PM Re: Reporting Possible Prostituion/Human Trafficking Kristen C.
manimal Offline
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Wow. Great work Kristen!
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#1908398 - 03/25/14 04:21 PM Re: Reporting Possible Prostituion/Human Trafficking Kristen C.
Xian Ngyuen Offline
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Very nice, Kristen.

Another thing that has worked in an investigation I'm familiar with was looking for credit card transactions at nail salons after business hours.

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#1908571 - 03/25/14 08:36 PM Re: Reporting Possible Prostituion/Human Trafficking Kristen C.
Lilly C Offline
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Thank you for sharing Kristen and EdSpenser. Yikes! we really do have to consider everything.....

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#1961872 - 09/14/14 04:50 PM Re: Reporting Possible Prostituion/Human Trafficking Kristen C.
Elwood P. Dowd Offline
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FIN-2014-A008 Guidance on recognizing activity that may be associated with human smuggling and human trafficking - financial red flags, published last week.

Human Trafficking Indicators published by Homeland Security in 2010.
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#1962988 - 09/18/14 07:40 PM Re: Reporting Possible Prostituion/Human Trafficking Kristen C.
CantBeShocked Offline
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Great tips for verbiage in the SAR - and yes, call law enforcement after you file the SAR.

http://www.fincen.gov/statutes_regs/guidance/pdf/FIN-2014-A008.pdf
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