How can banks work with others to help end this insidious crime?
Nick Lewis | Group Head, Integrated Intelligence and Investigations, Standard Chartered
Julia Makra | Head, Outreach, Integrated Intelligence & Investigations (i3), Financial Crime Compliance, Standard Chartered
‘If you look back to where we were just 5 years ago, we’ve made huge progress on modern slavery and human trafficking.’
That was the verdict of Andrew Wallis, CEO of Unseen, one of the leading NGO voices at a recent event we convened at Standard Chartered in London.
His reason for optimism was the political will demonstrated by the UK’s Modern Slavery Act, and an emerging global commitment coming through in policies and laws being enacted around the world. He was also pointing at the growing emphasis being placed on the issue by businesses in how they operate and in their supply chains, and the increasing focus on the issue by academics and NGOs. ‘We can end it in 40 years,’ he concluded – sending a signal of the need for determination, and endurance.
Modern slavery and human trafficking are a priority for the Bank and one of ways in which we have been tackling the challenge has been through our membership of the Joint Money Laundering Intelligence Taskforce (JMLIT) – the UK’s model for a collaborative approach to tackling money laundering. We chair the Expert Working Group on human trafficking and organised immigration crime, convening members of the financial sector with subject matter experts from UK law enforcement and intelligence agencies. The objective of this JMLIT expert working group is to increase the financial sector’s ability to identify and report financial flows linked with these crimes, and thereby respond to the financial crime threat posed by them.
In July, we extended the scope of the JMLIT expert working group to convene an industry ‘outreach’ event, which brought a wider range of key actors from the public and private sectors and civil society together with the core JMLIT expert group. The aim of this event was to share experiences and approaches, and to establish new opportunities to work together on this shared challenge.
So, what will it take to end this insidious crime in the next 40 years? Participants at our July event agreed on three key principles:
1. Getting closer to the victims, and how modern slavery shows up locally around the world…
‘We’re still at a stage where we know about the issue in generalisation,’ said one NGO voice in the conversation. ‘And victims are our best source of intelligence.’ New approaches are making it possible to understand more deeply the experience of the victims of modern slavery, the typologies that characterise the activity of the perpetrators, and through that tackle the issue on a specific, and local level.
The UK Modern Slavery Helpline and Resource Centre, set up by NGO Unseen and founding partner BT, has the power to create new data about the challenge in the UK. Allied to this work is a set of questions, developed under the lead of SCB in conjunction with a set of NGOs, that first-line responders can use to understand better the financial, technological and real-world facilitators of modern slavery today. At the same time new, so-called ‘hyper-local’ campaigns are being developed which target interventions within modern slavery hotspots – at the level of boroughs, towns and cities. In such cases, expert NGOs like Stop the Traffik can use banks’ branch networks and targeting through social media to focus attention and amplify impact.
2. …and working to tackle human trafficking ‘upstream’
Human traffickers are characterised as ‘smart, savvy, highly adaptable business people’ said one participant. This is organised crime, and it operates across borders. Key to action on human trafficking will be understanding better the ‘supply chain’ of human trafficking, starting in the countries that are often the source of this trade. St Mary’s University has a programme unearthing the key dynamics in some of these global links, and on specific ties between countries where the challenge is greatest.
With over 60% of modern slavery taking the form of forced labour, global banks have a clear role to play. We operate global businesses, and global supply chains. And as we engage with multinational clients and work with banks in markets across the world we can collectively make a difference. Our key role is to keep the proceeds of this crime out of the financial system, using due diligence to identify and leverage to address it where found in our own operations, sourcing or lending. By doing that, and sharing the information and experience we gain, we can support efforts to detect and disrupt this damaging crime.
3. Building concerted cross-sector collaboration
As emphasis grows on the issue of modern slavery, so businesses and business organisations are putting effort into understanding the impact that they have, the risks that they face and how they can play their part. Shiva Hotel Group for example is working to raise awareness of sexual and labour exploitation among both staff and guests, and their corporate Foundation has led the effort to establish the Stop Slavery Hotel Industry Network.
Participants of the July meeting agreed that there is the opportunity to create greater value by bringing together actions such as these, drawing on shared learning and experience. As banks, we have a money-flow focus. But the victims and the perpetrators will be the same whether you’re running a hotel or providing technology. The more eyes and ears we have out there, the better.
The act of sharing experiences led to immediate actions for many of the banks and other private sector actors present. For example, other sectors wanted to incorporate the ‘red flags’ for human trafficking identified by the financial services sector into their own activities and training for frontline staff. But tackling this challenge also means meeting head-on the demand-side of the equation. Andrew Wallis summarised the challenge for the group: "Increasing political will is a necessary step. But it requires the will of every business and organisation to change the products and services they offer, and what their customers think is acceptable. That’s why this is a cross-sector issue, and one that all businesses must take seriously".
The July meeting was an important contribution, and we hope it is the start of many more.
An example of Standard Chartered taking action against human traffickers
Acting on intelligence received relating to allegations of human trafficking, our Financial Crime Compliance (FCC) team mounted a cross-regional investigation into a Retail client in a country in Asia. This investigation led to the discovery of a network of linked clients in the country, across Asia Pacific and the Middle East. Using data gathered by our Cyber Intelligence team in conjunction with closed source research, we were able to discover a link between the client and an escort agency website, which gave rise to suspicions that the broader network was involved in human trafficking activities for the sex industry. We immediately took action to address the risk to the Bank, and are also reaching out to NGOs and the relevant authorities with the intention of growing our understanding of what is likely to be a large, pervasive and pernicious network, and to support any investigation they may undertake. Work of this nature underpins our aspiration to be on the front line of the fight against financial crime.