Please feel free to send your questions and comments 

to the editors of the Cornerstone Report at: cornerstone@ice.dhs.gov

For Project Stamp and case studies: www.ice.gov/stamp

H V O L U M E X I I I : N O . 1 — S U M M E R 2 0 1 7

uman trafficking and human 

smuggling are often confused. 

The two crimes are very different and

it is critical to understand the 

difference between the two.

Human trafficking involves 

exploiting men, women, or children

for the purposes of forced labor or

commercial sexual exploitation.

Human smuggling involves the 

provision of a service—typically,

transportation or fraudulent

documents—to an individual who 

voluntarily seeks to gain illegal entry

into a foreign country.

It is possible the crime may start out 

as human smuggling but quickly turn 

into human trafficking. U.S. 

Immigrations and Customs 

Enforcement (ICE) Homeland 

Security Investigations (HSI) is the 

lead agency countering both issues. 

HSI exploits the financial 

vulnerabilities of smuggling and 

trafficking organizations to stop their 

illegal activities.

If you think you have witnessed 

trafficking and/or smuggling activity, 

please call HSI at:

1-202-312-9746 

Or

1-800-BE-ALERT

Volume XIII No. 1 Summer 2017

Inside This Issue

Human Trafficking vs 

Human Smuggling.....................1

Red Flags.....................................2

Cornerstone is U.S. 

Immigration and Customs 

Enforcement’s (ICE) 

comprehensive investigative 

initiative for fighting financial 

crime.

The Cornerstone Report is a 

quarterly bulletin 

highlighting key issues related 

to ICE Homeland Security 

Investigations’ (HSI) financial, 

narcotics and special 

operations investigations.

Toll Free Tip Line:

1-866-DHS-2-ICE

www.ice.gov/cornerstone

Human Trafficking vs 

Human Smuggling
 Common Human Trafficking business 

fronts: Modeling and travel agencies, 

employment companies, “au pair” 

babysitting and international 

matchmaking services (mail order bride), 

massage parlors

 Transactions conducted by individuals, escorted by a 

third party (under the pretext of requiring an 

interpreter), to transfer funds to other countries

 Frequent transactions, inconsistent with expected 

activity or line of business, carried out by a business 

customer in apparent efforts to provide sustenance to 

individuals such as: payment for housing/lodging, 

regular vehicle rentals, purchases of large amounts of 

food, frequents purchases at pharmacies (e.g. medicine/

condoms for victims)

 Payment to employment or student recruitment agencies 

that are not licensed/registered or that have labor 

violations

 Frequent payments to online escort services for 

advertising, including small posting fees to companies of 

online classifieds as well as more expensive high-end 

advertising and website hosting companies

 Accounts of foreign workers or students where the 

employer or employment agency serves as a custodian

 Business owner does not exhibit normal payroll 

expenditures such as wages, payroll taxes, social security 

contributions. Payroll costs can be non-existent or 

extremely low for the size of the customer’s alleged 

operations, workforce or business model.

 Multiple accounts established for different businesses or 

persons with the same signatory powers on each account

 Frequent outbound wire transfers with no business or 

apparent lawful purpose, directed to countries at higher 

risk for human trafficking or to countries that are 

inconsistent with the customers expected activity

 Business bank accounts that lack typical business 

expenses or account activity does not relate to the 

business

 Credit or debit processing for even dollar amounts, or 

transactions at time when atypical for business type (e.g.

2 am transactions)

 Leasing of high-end luxury vehicles and extravagant trips 

paid by electronic funds transfers from business bank 

accounts

 Receipt of numerous incoming wire transfers or personal 

checks inconsistent with account type

 Wire transfers from one business account to another 

business account that has no apparent ties

 Checks deposited from a possible funnel account appear 

to be pre-signed, bearing different handwriting in the 

signature and payee fields

 Frequent exchange of small denomination bills for larger 

denomination bills by a customer who is not in a cash 

intensive industry

 Sudden increases in cash deposits, rapid turnover of 

funds and large volumes of cash deposits from unknown 

sources

 Money flows that do not fit common remittance patterns 

such as wire transfers that originate from countries with 

high migrant populations (Mexico, El Salvador, 

Honduras, Guatemala) directed to beneficiaries location 

in US or Mexican cities along the border

 Beneficiaries receiving wire transfers from countries with 

high migrant populations who are not nationals of those 

countries

 Inflows are largely received in cash where substantial 

cash receipts are inconsistent with the customers line of 

business

 Wire senders may use similar transactional information, 

including commons accounts, addresses, phone numbers 

and IP addresses

 Multiple wire transfers to the same beneficiary who may 

be located in the US or Mexican city along the SW border

 When questioned, the senders have no explanation for 

the purpose of the wire transfer and have no relation to 

the recipient of the funds

 New accounts that often reflect similar activity of that of 

the closed account

Page 2 of 2

Volume XIII No 1

HS/HT Red Flag Indicators

HSI – A Diverse, Global Force

HSI is a critical investigative arm of the Department of 

Homeland Security and is a vital U.S. asset in combating 

criminal organizations illegally exploiting America's 

travel, trade, financial and immigration systems.

DHS/ ICE

Homeland Security Investigations

500 12th Street, SW

Washington, DC 20536

E-mail: cornerstone@ice.dhs.gov

Web: www.ice.gov