FinCEN Calls Attention to Online Child Sexual Exploitation Crimes

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FIN-2021-NTC3 September 16, 2021
FinCEN Calls Attention to Online Child Sexual
Exploitation Crimes
The Financial Crimes Enforcement Network (FinCEN) is issuing this Notice to call attention to an increase in online child sexual exploitation (OCSE). This Notice provides financial institutions with specific suspicious activity report (SAR) filing instructions, and highlights some financial trends related to OCSE. Crimes related to OCSE, including the funding, production, and distribution of child sexual abuse materials (CSAM), have increased during the COVID-19 pandemic, according to multiple law enforcement authorities. This increase in activity is likely due to a confluence of factors, including: (1) increased internet usage by children who are spending more time online, both unsupervised and during traditional school hours; (2) restricted travel during the COVID-19 pandemic resulting in more sex offenders being online; and (3) increased access to and use of technology, including encrypted communications, bulk data transfer, cloud storage, live￾streaming, and anonymized transactions.1 Another trend is the rise in sextortion of minors, who are coerced or exploited into exchanging sexual images via the internet, mobile devices, and social media platforms.2 OCSE offenders often groom3 minors to share or post self-generated content online in exchange for money. FinCEN performed a review of OCSE-related SARs and observed the following trends. Between 2017 and 2020, there was a 147 percent increase in OCSE-related SAR filings, including a 17 percent year-over-year increase in 2020. FinCEN also observed that OCSE offenders are increasingly

1. See Federal Bureau of Investigation (FBI) Press Release, “School Closings due to COVID-19 Present Potential for
   Increased Risk of Child Exploitation,” (March 23, 2020), and U.S. Department of Justice, “Keeping Children Safe Online,” (Updated, August 3, 2021). See also Europol, “Exploiting Isolation: Offenders and Victims of Online Child Sexual Abuse during the COVID-19 Pandemic,” (June 13, 2020); Interpol, “Child Sexual Exploitation and Abuse – Threats and Trends,” (September 20, 2020); and European Parliament, “Curbing the Surge in Online Child Abuse: The Dual Role of Digital Technology in Fighting and Facilitating its Proliferation,” (November 2020).
2. Sextortion is an “online exploitation crime directed towards children in which non-physical forms of coercion are
   used, such as blackmail, to acquire sexual content from the child, engage in sex with the child, or obtain money from the child.” See The National Center for Missing and Exploited Children (NCMEC), “Sextortion,” (Accessed September 16, 2021).
3. According to the Department of Justice’s (DOJ) Child Exploitation and Obscenity Section (CEOS), it is common for
   producers of child pornography to groom victims, or cultivate a relationship with a child and gradually sexualize the contact over time. The grooming process fosters a false sense of trust and authority over a child in order to desensitize or break down a child´s resistance to sexual abuse. See DOJ CEOS, “Child Pornography,” (Updated May 28, 2020). NCMEC has received reports that include instances of a child being groomed to sell or trade the child’s sexual images or accept other incentives, such as gift cards. See NCMEC, “Online Enticement,” (Accessed September 16, 2021).