ACAMS TODAY
By Freddy Massimi III, CFCI, CHTI

When the FIFA World Cup starts, the world comes together in celebration. However, while fans are focused on the games, criminal networks see an opportunity. Human traffickers, fraudsters, money launderers, and even terrorist financiers are aware that major events like this create an ideal environment for their activities: millions of visitors, billions of dollars in transactions, and infrastructure that is often stretched to its limits.

This is not speculation. History has demonstrated that global sporting events often attract a significant amount of illicit activity. For financial institutions, law enforcement, and businesses, the World Cup represents more than just a tournament; it serves as a real-time stress test of your defenses. The question is not if risks will arise, but rather whether you are prepared to confront them directly.

Why the World Cup is a Magnet for Crime

Global events concentrate vulnerabilities in ways criminals are quick to exploit.
• Massive inflows of money: cross-border transactions, remittances, betting, and ticketing
• Sudden surges in mobility: millions of travelers creating unprecedented demand for accommodation, transport, and entertainment
• Informal shadow markets: pop-up vendors, unregulated services, and cash-heavy economies
• Digital anonymity: prepaid cards, wallets, and rapid remittances masking illicit finance

Flags that Can’t Be Ignored

It’s important to stay vigilant. If you see something – say something. During a recent FIFA Club World Cup event in Miami, authorities reported 9 arrests, and 3 survivors rescued from trafficking situations. Source: Miami-Dade State Attorney’s Office, 2025.

Here are some not-so-obvious red flags to look for:

Human Trafficking and Exploitation

• Large hotel or short-term rental blocks paid in cash or prepaid instruments
• Payments spiking at escort services or “temporary entertainment” businesses
• Structured small-value remittances flowing out of host cities to high-risk corridors
• Young or vulnerable account holders under obvious third-party control

CHECKLIST: Human Trafficking Red Flags 

• Unexplained third-party control over documents or accounts

• Multiple accounts linked to the same device or contact information

• Rapid movement of funds inconsistent with client profile
  
  
  

Fraud and Financial Crime

• Fake ticketing websites that look indistinguishable from official FIFA portals
• Sharp increases in account takeover attempts and ATM fraud around host cities
• Charities with emotional appeals but no credible verification
• Business email compromise schemes spoofing sponsors, vendors, and logistics partners

Terrorism and Security Financing

• Rapid cross-border transfers funneled into shell accounts near event venues
• Online crowdfunding campaigns that obscure extremist beneficiaries

Every one of these is a red flag that should trigger scrutiny. For the well-prepared, they are opportunities to intervene. For the unprepared, they are openings criminals will exploit.

Training Your Teams: Moving Beyond Awareness

Training staff for the World Cup cannot be a “check-the-box” exercise. Criminal networks are sophisticated and adaptive, and know how to exploit the weakest link in an institution’s defenses. To be effective, training must be targeted, scenario-driven, and ongoing.

1. Tailor Content by Role

Frontline tellers and hospitality staff need short, practical red-flag guides. Investigators and compliance officers require in-depth typology sessions and case studies. Executives should receive briefings focused on reputational and regulatory impact.

2. Use Real Case Simulations

Generic slide decks are not enough. Walk teams through scenarios based on prior World Cups and Olympics: fake ticketing portals, bulk suspicious travel bookings, or an account controlled by a trafficker. Interactive training helps staff to recognize subtle patterns under pressure.

3. Prioritize a “See Something, Say Something” Culture

Staff must know not only what to look for, but also how to escalate concerns without fear of repercussion. Institutions should establish clear, fast escalation paths—whether to compliance units, fraud teams, or designated liaisons.

4. Refresh and Reinforce

Criminal tactics evolve rapidly. Training should not be a one-off event in the months before kickoff. Instead, deliver micro-trainings, alerts, and typology updates throughout the tournament to keep red flags fresh in staff minds.

5. Measure Effectiveness

Track suspicious activity reports (SARs), staff escalations, and feedback post-training. Use these metrics to refine programs in real time, closing gaps before criminals exploit them.

Callout Box: Training Essentials for World Cup Readiness

• Scenario-driven exercises based on past mega-event cases

• Role-specific guides for frontline staff, investigators, and executives

• Clear escalation protocols reinforced through practice

• Ongoing “micro-trainings” and typology alerts during the event

• Feedback loops and metrics to measure effectiveness

Partnerships: The Difference Between Success and Failure

The World Cup is too big for any one institution to fight alone. Preparation must happen now. Academic research estimates the global sports industry may facilitate up to USD 140 billion annually in money laundering, given its large cash flows and opaque financial structures. Source: European Journal of Sport, 2023

Financial institutions need to establish direct intelligence-sharing frameworks with law enforcement. They should also update transaction monitoring rules to reflect event-specific typologies and conduct regular training for their teams on recognizing red flags. Law enforcement must embed liaisons into institutions, coordinate with foreign counterparts, and shift from conducting investigations after the fact to implementing real-time interdictions.. Additionally, businesses—particularly in the hospitality, travel, and gig economy sectors—should train their staff to identify signs of exploitation and establish clear escalation pathways, including options for anonymous reporting.

Events of this scale demand collective defense. Without it, the criminals win.

QUICK WINS Before the Event

• Update monitoring parameters for high-risk transactions
• Create a 24/7 escalation channel with local law enforcement (Investigations@ccht.dhs.gov)
• Issue sector-wide alerts on ticketing fraud and trafficking typologies
• Deliver refresher training to frontline teams

Bringing Business Leaders to the Table

Compliance teams often know the risks, but struggle to secure buy-in from executives. The World Cup provides a clear platform to change that narrative.

This is not just a compliance issue. It’s a reputational and commercial issue. No brand wants to be associated with trafficking or fraud on the world stage. Regulators are increasingly holding businesses accountable for failing to identify and mitigate risks of exploitation. Investors are watching closely, aligning Environmental, Social, and Governance (ESG) expectations with human rights safeguards. And history has already shown that businesses tied, even indirectly, to exploitation at major events can face years of reputational damage.

Leaders respond when risks are framed in business terms. Use the World Cup to make that case.

Human Trafficking Does Not Stand Alone

Human trafficking is rarely an isolated issue; it is closely connected to other criminal markets. Cartels often use the same routes for transporting drugs and people. Victims are forced into fraud schemes including romance scams, call center operations, and synthetic identity creation. Additionally, terrorist groups exploit both the financial gains and the people involved in trafficking. Money laundering plays a crucial role in this network, utilizing casinos, betting operations, shell entities, and trade to obscure illicit funds.

For investigators, this means that the signs of trafficking are often indicative of a larger, multi-crime ecosystem. Targeting this interconnected network is where true disruption can occur.

Conclusion: The Call to Action

The World Cup is not only a celebration of sport, but also a battleground for those fighting against fraud. Criminals are already planning their schemes, and it is essential for financial institutions, law enforcement agencies, and businesses to be equally prepared. 

 Strengthen your monitoring systems. Build strong partnerships. Train your teams effectively. Engage your leadership. 

 When the matches begin, criminals will already be at work. The key difference will be our level of preparedness. Let’s work together to make a difference and save lives!