As the World Cup begins in North America, the Wolfsberg Group wants to bring attention to the critical partnerships that have formed among civil society, financial institutions, and law enforcement. The collaboration among these stakeholders serves as a powerful example of the promise of an increased focus on effective outcomes:

• Specialist NGOs and information service providers are combing through all forms of media to identify likely fronts for sexual exploitation, packaging actionable intelligence leads for their private and public sector partners.
• Financial institutions will be developing these leads, enriching the information with their own data to identify suspicious activity and report it promptly with national financial intelligence units.
• Law enforcement is on their front foot, ready to action the high confidence information they receive and fold it into their own on-going investigations.

The FinCEN Notice released in May provides a clear path for filing suspicious activity with FinCEN while dual reporting suspected human trafficking through the National Human Trafficking Hotline. NGOs will also use the hotline to report their own leads in real time. Leveraging the hotline is vital for ensuring cases are triaged to the appropriate federal, state and local law enforcement agencies.

In line with previous statements from Wolfsberg on the power of private-to-private information sharing, the Wolfsberg Group strongly encourages financial institutions of all sizes to leverage fully the 314b framework to share information and collaborate on cases. Similar to the key term that financial institutions will use with FinCEN in their own filings, the Wolfsberg Group encourages the use of the tag "HTWORLDCUP" by financial institutions as they initiate and respond to 314b requests. Placing this tag in the subject line of a 314b will equally allow 314b administrative teams to route these requests quickly to the appropriate specialist human trafficking investigative unit within each financial institution. For those smaller financial institutions, the receipt of a 314b with the "HTWORLDCUP" tag will make clear the significance and priority of the request.

As financial institutions dual report to FinCEN and the National Human Trafficking Hotline, we encourage references in those filings to the specialist NGOs / information service providers that supplied the initial leads. These organizations, like financial institutions, are dedicated to outcomes, and recognizing their role in supporting the disruption of human trafficking will reaffirm for those actioning the leads of their significance in the fight. This will also help law enforcement officers connect leads received via the hotline to SARs filed in parallel, which likely contain more sensitive (and possibly more actionable) information.

As the World Cup kicks off and we all enjoy the international camaraderie from the competition, the Wolfsberg Group remains grateful to those investigators behind the scenes across civil society and the private and public sectors who remain vigilant to the human trafficking threat that sadly accompanies the games.

J. Edward Conway Executive Secretary The Wolfsberg Group