Financial Services Ireland

Modern Slavery: The key role Financial Services play in combatting this

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According to recent figures from the United Nations, there are 50m people globally in modern slavery with 21m people trafficked annually.  And this is not something that’s happening elsewhere or in developing nations; it’s much closer than that.  It’s happening across Ireland also.

At the macro level, certain factors contribute to the rise of modern slavery, for example, global health crises, wars, and natural disasters all of which create mass displacement, resulting in an environment that allows criminals exploit vulnerable people for profit. The financial figures associated with this are sizeable: $150bn aggregated criminal proceeds of human trafficking and $47.9bn annual profits of trafficking in developed nations*

What is the link between human trafficking/slavery and the Financial Services sector?

Simply put, where there is human trafficking, money changes hands.  Human trafficking and modern slavery are predicate offences for money laundering.

The financial services sector can combat this by leveraging effective controls to detect the diverse financial flows associated with these crimes and prevent the onboarding of traffickers.  For example, regulations such as the EU’s upcoming Corporate Sustainability Reporting Directives require the Financial Services sector to incorporate modern slavery into their due diligence controls and report publicly on their effort.

However, it’s not always straightforward for financial services companies to do this.   With the challenge of accessing up-to-date and accurate data, a tendency towards a siloed approach to data sharing, and the increasing reliance on remote or non-face to face business relationships, it can be difficult to detect these crimes.  During 2021, $21bn AML fines were imposed due to failings to detect modern slavery**.

Collaboration will help all parties in terms of working to combat these crimes.  By leveraging an ecosystem of peers, charities, NGOs and law enforcement, the financial services sector -in each country – can really make a difference.  Sharing information and data across these entities will help to identify, at the early stages, where there is a misuse of funds.

Equally, financial services can lessen the burden on victims by providing financial evidence in legal proceedings that supports the prosecutions testimony.

Our collective aim: why we think collaboration is key

EY and Banking & Payments Federation Ireland (BPFI) believe financial institutions are key to decelerating the growth of modern slavery and human trafficking.  Together, we can build and leverage effective controls to detect the diverse financial flows associated with these crimes and prevent the onboarding of traffickers.  With this in mind, we have established a community of individuals, across financial institutions, law enforcement, the CBI, solution vendors and NGOs to start a conversation about how we can collaboratively stem the flow of funds to criminals, while keeping the victim in mind.

This is in the early stages – and we are working out the best way to build on this momentum -but early indications show there is a huge desire and drive to work together on this issue.


EY & BPFI Modern Slavery Hackathon, May 2023

We recently held an in-person event in Dublin with over 50 attendees, representing 25 organisations, across domestic and international banks, the Central Bank of Ireland, NGOs, vendors, Law Enforcement and consultants.

Attendees heard presentations, demonstrations and panel discussions from speakers who provided unique perspectives on modern slavery and how we can combat it.  This included insights from numerous thought leaders and the latest information from those on the front line, namely:


  • Linda Latham, HSE, Director of Nursing Social Inclusion, gave a keynote on the impact modern slavery has on victims
  • Pat Lordan, Detective Chief Superintendent, GNECB, represented the Garda perspective on money laundering and modern slavery
  • Seána Cunningham, CBI, Director of Enforcement and AML, helped us understand the regulators perspective
  • Neil Giles, Traffik Analysis Hub, CEO (Stop the Traffik), demonstrated how NGOs see Financial Services playing a role
  • John McGrath, Leader of IBM Technology for Good, provided an inspiring demonstration of the Infinitech solution developed with Stop the Traffik
  • Daniel Kelly, Detective Inspector Protective Services, helped us understand the intersection between “following the money” and the real-world impact of human trafficking and modern slavery.

What’s next?

EY and the BPFI wanted this event to galvanise and empower attendees to collaboratively play a more instrumental role in combatting modern slavery.

 With such enthusiasm by those who attended our event, it’s clear that there is an appetite to work together -across the Financial Services sector -and by those agents who are dealing with this issue on a daily basis.  More frequent collaboration, greater cross-industry communication and data-sharing will certainly help in this process.

We know there are many challenges, and it’s a long road ahead, but it’s about starting this journey together and committing to continuing the conversation over the months and years ahead.

This article was co-authored by Niamh Davenport, Head of Prevention, Banking & Payments Federation Ireland.

United Nations Statistics: 50 million people in modern slavery: UN report | United Nations
*International Labour Organization
** International Labour Organization

As part of our brand commitment to building a better world, EY globally is…

  • Developing a typology library to assist clients in understanding indicators of modern slavery. This can be used to build a data footprint as a foundation for developing a risk-based and data-driven controls framework.
  • Investing in a dynamic, data-driven tool that leverages an intelligence-ecosystem and machine learning to help FS firms to identify their modern slavery risk. The tool aims to enrich FIs existing financial crime data in collaboration with select vendors that specialize in anti-modern slavery and reference data from law enforcement, NGOs and adverse media.
  • Building a community through industry roundtables, hackathons and our broader network to explore the challenges in combatting modern slavery and collectively define a best practice anti-modern slavery approach.

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