Financial crime compliance to fight modern slavery and human trafficking
This blueprint urges financial institutions to tackle human trafficking and modern slavery, suggesting that both are a financial crime and compliance risk, and warns against wholesale de-risking. This report outlines strategies for detecting financing of such illegal activities, reducing risk, and government action towards AML/CFT risk assessments, ahead of regulatory fines and sanctions in jurisdictions worldwide.
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OVERVIEW
This blueprint is urging financial institutions to address human trafficking and modern slavery, emphasising both as compliance risks and financial crimes. Financial institutions are advised to adopt more effective typologies, to increase and improve their reporting processes and to actively integrate the feedback of survivors and NPOs into their understanding of modern slavery. The report highlights the significant financial loss caused by human trafficking and modern slavery and warns against wholesale de-risking by financial institutions which could drive vulnerable groups into the informal financial sector.
The report outlines current practices for detecting modern slavery and human trafficking financing in the financial services industry. There is considerable work being done by financial institutions and regulators on typologies, risk indicators, and red flags to help identify signs of human trafficking. JPMorgan Chase, Amex, Citi, US Bank, HSBC, IBM and StopTheTraffik have combined network analysis, transactions data, and open-source materials to identify transactions that indicate modern slavery. The TraffikAnalysis Hub and Traffic Jam also mine data to identify modern slavery risks. Further, financial institutions in the Netherlands are using artificial intelligence (AI) and machine learning to identify labour trafficking in transaction patterns.
The report warns against practises of wholesale de-risking, which increases the financial exposure of financial institutions. Project Protect in Canada is an example of a partnership between regulators, financial institutions, law enforcement, and survivors to increase understanding of modern slavery and human trafficking. The FAST Survivor Inclusion Initiative supports efforts by banks to include survivors to prevent their risk of returning to exploitation.
The report emphasises the need for governments to update their AML/CFT risk assessments, incorporate modern slavery and human trafficking threats into them, and encourage reporting entities to vigilantly trace and freeze the proceeds of modern slavery financing. The AML/CFT risk assessments should also request obliged entities to identify the financing of modern slavery and human trafficking.
Financial institutions are encouraged to employ strategies that are no longer reactive, but proactive, to address the compliance and financial crime risks that modern slavery and human trafficking pose.