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Compliance & Risk

Red cards and red flags: What AML professionals need to know during the World Cup’s final weeks

Rabihah Butler  Manager for Enterprise content for Risk, Fraud & Government / Thomson Reuters Institute

· 7 minute read

Rabihah Butler  Manager for Enterprise content for Risk, Fraud & Government / Thomson Reuters Institute

· 7 minute read

The 2026 World Cup isn't just a global spectacle, rather it's a high-risk financial crime event in which banks’ AML teams must act now, using FinCEN's updated guidance and cross-sector tools like The Knoble to detect trafficking that’s hidden in plain sight

Key insights:

      • Financial institutions on the frontlines of trafficking prevention — As the 2026 World Cup continues, it puts financial institutions on the frontlines of detection and prevention of human trafficking, whether they are in a host city or not.

      • US government has offered guidance — FinCEN’s updated Section 314(b) guidance, issued June 12, gives institutions explicit authority to share fraud and trafficking-related information with each other, and strongly encourages them to do so.

      • Cross-sector collaboration is essential — Organizations like The Knoble are building the cross-sector collaboration infrastructure that makes that kind of information sharing operational, not just theoretical.


The 2026 FIFA World Cup is, by every measure, the largest sporting event ever staged on North American soil, drawing 3.6 million spectators through its early weeks and generating billions of dollars in economic activity — that level of transaction volume that would strain any risk & compliance team on its best day.

The World Cup and its millions of international visitors also are creating the very conditions that human traffickers are always eager to exploit.

It is a pattern that researchers, law enforcement, and financial crime professionals have documented around major global events for years. And it is precisely why, as the World Cup enters its most dramatic final weeks, compliance teams at financial institutions of every size are treating this moment as the operational inflection point it is.

The World Cup as a financial ecosystem

Most people associate the World Cup with soccer and international competition; yet for compliance professionals, it also represents a full financial ecosystem of its own that they have to navigate.

Julie Conroy, a leader at The Knoble, a nonprofit founded in 2019 to bring together financial services and law enforcement to combat human trafficking, financial scams, elder financial exploitation, and child sexual exploitation, is direct about threat compliance teams face. “All of these big, massive global events bring together lots of people,” Conroy says. “And that makes it very easy for the criminals… to hide their human trafficking.”

Of course, the financial footprint of that activity runs through the banking system, through peer-to-peer transfers, prepaid card activity, late-night ATM withdrawals, unusual hotel charges, or vague payment memos reading “services” or “personal care.” None of these transactions are inherently suspicious in isolation; yet together, as a pattern layered across time and accounts, they can signal exploitation in real time.

FinCEN’s recent guidance changed the calculus

On June 12, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued updated guidance clarifying how financial institutions can share information with one another about suspected fraud, money laundering, and other financial crimes under Section 314(b) of the USA PATRIOT Act.


The World Cup and its millions of international visitors also are creating the very conditions that human traffickers are always eager to exploit.


The guidance is both a clarification and a signal. It explicitly confirms that institutions may share information about suspected trafficking-related activity with any other financial institution eligible to participate in the 314(b) program. It broadens the categories of shareable information to include video surveillance footage, cyber-related data such as IP addresses, and behavioral fraud indicators such as newly added payees followed by large transfers, multiple accounts with similar identifying information, and login activity from geographically distant locations.

U.S. Treasury Secretary Scott Bessent framed the urgency plainly: “Financial institutions are often the first to see suspicious activity in real time. They need the tools to act quickly and share information that can help stop fraud before it spreads.”

For human trafficking detection specifically, this matters because no single institution sees a complete trafficking network. One bank might observe the late-night ATM pattern, another might flag the prepaid card activity, and a third might notice the unusual payroll behavior of a temporary staffing company supplying event workers. Individually, those fragments are insufficient; however, when shared, they become actionable intelligence.

“Now we can share data among ourselves for fraud prevention purposes — which is amazing,” Conroy notes.

The collaboration infrastructure already exists

The regulatory green light from FinCEN is necessary but not sufficient on its own. Effective information-sharing requires relationships, operational frameworks, and trust that take time to build. That is the gap The Knoble was created to close.

The organization has spent six years building the bridges between financial institutions and law enforcement that make inter-agency collaboration real rather than aspirational. That work is harder than it sounds due to personnel changes and departments that operate in silos. The Knoble’s member network is designed to outlast those structural challenges by creating a durable community of practice around financial crime detection.

“The amazing thing that The Knoble has been able to do is bring together banks and law enforcement, build those bridges between the two of them, and give a guide to banks about what are the red flags,” Conroy explains.

The Knoble’s World Cup-specific detection guide, which was developed in anticipation of the tournament, reinforces what FinCEN’s guidance also makes clear: Trafficking rarely presents itself through a single dramatic transaction. Investigators need to identify clusters of behavior across time, look at shared devices and phone numbers, and track rapid movement of funds across accounts. The behavioral anomaly, not the individual transaction, is the signal.


Every suspicious activity report filed, every bit of information shared, and every frontline employee who escalates an unusual interaction contributes to an intelligence picture that law enforcement can act on immediately, while victims are still at risk.


However, perhaps the most consequential misconception in AML and fraud around the World Cup right now is that human trafficking is a host-city problem.

Trafficking networks are geographically distributed by design. Victims may be recruited in one state, transported to and exploited in a host city, and their proceeds moved through financial institutions located elsewhere. That means that a regional bank in Kansas City or a credit union in a midsize market with no World Cup connection can still observe funnel account activity, unusual prepaid card funding, or suspicious peer-to-peer transfers tied to a network operating hundreds of miles away.

Training is not optional

FinCEN’s guidance also makes clear that transaction monitoring systems cannot address trafficking issues alone — a financial institution’s frontline staff matter.

Tellers, branch employees, and customer service representatives are often in a position to observe indicators that never appear in an alert queue. A customer who appears fearful, cannot speak freely, or gives answers that seem scripted. These behavioral signals and more require trained human observation.

That’s why these frontline professionals are so important. Every suspicious activity report filed, every bit of information shared, and every frontline employee who escalates an unusual interaction contributes to an intelligence picture that law enforcement can act on immediately, while victims are still at risk. This is critical, because human trafficking is happening in real time, and the transactions that compliance teams are observing are occurring while the exploitation is ongoing.

Conroy frames The Knoble’s mission in exactly these terms. The organization exists to take financial professionals who are already passionate about stopping human trafficking and other crimes and mobilize them within their day-to-day work.

Now, as the World Cup enters its final weeks, the question now is whether compliance teams will continue to treat this moment as an operational priority by using the collaboration tools and the regulatory guidance at their disposal to make a crucial difference in the lives of trafficking victims.


For more on this, tune into the Thomson Reuters Institute’s recent “Clarity” podcast to learn about the anti-money laundering challenges posed by the World Cup

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