FIFA, mega events and anti-trafficking expectations in 2026

March 18, 2026

Human trafficking (HT) is internationally defined in the United Nations (U.N.) Trafficking Protocol as consisting of specific acts, such as recruitment and transportation and carried out through improper means, including coercion or fraud for the purpose of exploitation. Exploitation includes both sexual exploitation and forced labor, slavery or practices similar to slavery.¹ In the U.S., HT is criminalized under state and local laws as well as federally under the Trafficking Victims Protection Act.² World sporting events, including the International Federation Football Association (FIFA) World Cup, have been identified as heightened risk environments because they increase the demand for HT in host cities.³ Historically, FIFA has faced criticism for insufficiently identifying and mitigating identified forced labor exploitation.⁴ Human rights groups have called for stronger implementation mechanisms, including binding host country requirements, independent monitoring, accessible grievance and remedy pathways.⁵ In response to sustained international scrutiny surrounding human rights risks associated with major sporting events, FIFA has undertaken a series of governance reforms.⁶

2026 FIFA World Cup scale and structure

The FIFA World Cup 2026 is projected to be the largest sporting event in history, potentially surpassing the Olympic Games.⁷ The 2026 FIFA World Cup is being hosted across 16 host cities in the U.S., Canada and Mexico. The tournament’s expanded format, extended duration and multinational footprint will generate substantial cross-border travel, temporary labor demand and atypical financial activity across multiple industries, including construction, hospitality, transportation and security.⁸

Meeting demand while creating compliance challenges

From a compliance perspective, the operational demands of large sporting events introduce predictable but often underestimated labor and financial crime risks. Event delivery requires rapid construction, infrastructure upgrades, transportation services, security, food service and cleaning operations often under compressed timelines and through complex, multitiered supply chains. To meet these demands, organizers and contractors frequently rely on temporary workforces, migrant labor and third-party labor brokers.⁹ These conditions increase exposure to labor trafficking risks and exploitative recruitment practices, while simultaneously reducing visibility into working conditions for regulators and private sector actors.¹⁰ For organizations subject to third-party risk management requirements, these dynamics heighten the importance of robust vendor due diligence, contractual controls and ongoing monitoring of labor practices across subcontractors and service providers.¹¹

At the same time, large-scale, time-bound sporting events create temporary, high-velocity economies that amplify existing social and financial vulnerabilities. They are associated with measurable shifts in transaction volumes, customer behavior and labor-sourcing practices. These disruptions complicate baseline risk assessments and transaction monitoring processes and have been identified by law enforcement (LE) as conditions that can be exploited for HT.¹² Collectively, these dynamics create a challenging environment for regulated financial institutions (FIs) and multinational companies subject to anti-money laundering, know your customer, sanctions and third-party risk management obligations.

FI exposure and typologies

Concentrated global travel, short-term labor and elevated commercial activity make anomalous financial behavior related to large-scale sporting events harder to distinguish from legitimate transactions. Front companies―including cleaning services, construction contractors, transportation providers and short-term accommodation operators―may appear legitimate while concealing exploitative activity within lawful revenue streams, particularly amid increased cash usage, elevated transaction volumes and rapidly shifting customer profiles.¹³

Financial authorities have identified recurring HT typologies, including third-party account control, transaction structuring, frequent use of money services businesses and reliance on prepaid or stored value instruments. While not inherently illicit in isolation, these indicators take on heightened significance during mega sporting events and underscore the need for dynamic, risk-based monitoring calibrated to temporary but foreseeable shifts in financial behavior.¹⁴

Cross-border challenges

The cross-border structure of the 2026 FIFA World Cup introduces additional layers of complexity for LE and private sector compliance profiles.¹⁵ Matches will be hosted across three countries with distinct immigration frameworks, legal and financial regulations, and LE authorities. These jurisdictional differences create enforcement asymmetries that transnational criminal networks exploit. HT organizations are highly adaptive and will move victims, facilitators and illicit proceeds across borders to fragment investigative visibility and exploit regulatory gaps.

For FIs and multinational corporations, this environment complicates customer due diligence, beneficial ownership verification and transaction monitoring. Differences in customer identification requirements, reporting thresholds and supervisory expectations can limit the ability to form a consolidated view of risk across jurisdictions. Transaction patterns that appear benign when assessed within a single country can take on elevated risk when viewed across borders, particularly where funds move rapidly between accounts and payment channels that operate under different regulatory standards.¹⁶

"From a compliance perspective, the operational demands of large sporting events introduce predictable but often underestimated labor and financial crime risks"

The cross-border dimension underscores the importance of recognizing HT as part of broader transnational organized crime ecosystems. Trafficking networks frequently intersect with related criminal activities, including document and identity fraud, corruption, drug trafficking and money laundering schemes. These interdependencies increase the sophistication and resilience of trafficking operations and reinforce the need for coordinated, risk-based approaches that integrate financial crime, sanctions, fraud and third-party risk controls across jurisdictions.

FIFA governance response

FIFA itself acknowledges that the scale and complexity of the World Cup create a heightened responsibility to respect human rights. FIFA’s Human Rights Policy affirms a commitment to “respecting all internationally recognized human rights,” operationalized through due diligence and the integration of human rights requirements into bidding, hosting and ongoing operational activity. As part of the 2026 World Cup bidding and hosting process, FIFA incorporated human rights criteria into its evaluation and selection framework and required host cities to develop human rights risk assessments and action plans. FIFA introduced significant changes during the 2026 bid cycle. They adopted a human rights policy aligned with the U.N.’s Guiding Principles on Business and Human Rights and established formal advisory and committee structures.¹⁷

LE coordination

LE at state, local and federal levels have been preparing for the World Cup 2026 for years.¹⁸ Coordination with LE partners aid in the implementation of unique red flag indicators that may be present during the games. Public-private partnerships and information sharing mechanisms play a central role in identifying and disrupting HT networks.¹⁹ Against this backdrop, FIs and other types of businesses should prepare for the World Cup, both externally and internally.²⁰ Externally, many anti-HT initiatives have been launched in host cities across the country.²¹ These efforts include multistakeholder partnerships that collaborate with local LE to ensure that training and operational efforts are coordinated.

Corporate risk management

Corporations engaged directly or indirectly in World Cup-related activities face exposure through third-party labor providers, subcontractors and service vendors. International frameworks outline expectations for risk-based due diligence, contractual safeguards and grievance mechanisms.²² In addition to LE coordination, businesses should evaluate their exposure through a risk-based lens. This would include assessing geographic exposure to host cities, customer and vendor profiles tied to event-related industries and any increased reliance on temporary labor or third-party service providers.²³ Enhanced due diligence on high-risk customers and counterparties―particularly those operating cash-intensive businesses or relying heavily on intermediaries―can strengthen preparedness without disrupting legitimate commerce.

Conclusion

The 2026 FIFA World Cup presents a unique environment characterized by intensified labor demand, atypical payment flows and heightened multijurisdictional financial activity. FIFA’s governance structures and committee-led initiatives demonstrate formal institutional recognition that HT and labor exploitation risks are inherent to mega sporting events and must be addressed proactively. Existing financial crime, sanctions and third-party risk management frameworks already provide FIs and corporations with the tools necessary to identify, assess and mitigate these risks when applied in a targeted, risk-based manner. Importantly, FIFA’s explicit acknowledgment that trafficking risks associated with large-scale sporting events are foreseeable and mitigable establishes a durable compliance precedent that strengthens coordination among regulators, LE, FIs and private sector actors, while contributing to more effective prevention, detection and accountability well beyond the 2026 tournament.

Anne Marie Lacourse, global compliance industry advisor, Sayari Labs Inc., Washington, D.C., USA, annemarie@sayari.com,