Modern Slavery: A Hidden Crime and Our Shared Responsibility to Disrupt It

As we mark Anti-Slavery Week 2025, we reflect on the ongoing and devastating reality of modern slavery, a global issue affecting an estimated 50 million people through forced labor, human trafficking, debt bondage, and other forms of exploitation. It’s a crime that thrives in the shadows, often concealed within legitimate systems, including financial networks.

What Is Modern Slavery?  

Modern slavery encompasses situations where individuals are coerced, deceived, or forced into work or exploitation under conditions that violate their freedom and dignity. From sexual exploitation and child sexual exploitation to labor exploitation, human trafficking, and forced marriage. Behind each statistic is a person robbed of choice, dignity, and safety. 

It spans industries and borders, affecting vulnerable individuals in agriculture, hospitality, construction, domestic work, and increasingly, digital environments. It also includes criminal exploitation, where individuals are coerced into illegal activity such as drug trafficking, theft, or fraud. Bonded labour — where people are forced to work to repay a debt under threat — is another common form, alongside sexual exploitation and servitude. These abuses are often hidden in plain sight, making detection and disruption especially challenging for financial institutions. 

According to  Stop the Traffik, who believe 49.6 million people worldwide are trapped in modern slavery. Of these, 27.6 million are exploited for labor, 17.3 million are in forced marriage, and 12% of those in forced labor are children. These numbers are not abstract. They represent lives in danger. 

The Challenge for Financial Institutions 

Financial institutions are not facilitators of modern slavery, but they can be unknowing channels. 

The sheer scale of global transactions makes detecting exploitation difficult. Indicators may appear insignificant in isolation, but when viewed collectively, they tell a powerful story. 

Common patterns include: 

• Frequent cash deposits at unrelated locations 
• High volumes of third-party credits at irregular hours 
• Rapid movement of funds to unconnected parties 
• Debit card activity linked to travel, accommodation, or adult services sites 

These signals, when analyzed contextually, can point toward exploitation networks and/or trafficking activity. 

Modern Slavery in the UK: A Missed Opportunity for Prioritization

The UK’s 2025 National Risk Assessment (NRA) recognizes modern slavery and human trafficking as predicate offenses that generate illicit funds requiring laundering through the financial system. 

However, it stops short of classifying them as economic crimes  in their own right, a distinction some say undermines prioritization for regulation and enforcement. 

Despite its inclusion in the UK’s 2025 National Risk Assessment (NRA), modern slavery is not classified as an economic crime. While the NRA acknowledges it as a predicate offense linked to illicit financial flows, experts argue this framing fails to reflect the reality of trafficking and exploitation as structured business models within organized crime. The limited references and lack of prioritization in regulatory guidance risk deprioritizing modern slavery in financial crime strategies. 

Critics, including anti-slavery campaigners, argue that this framing is a missed opportunity. There isn’t a great deal of information about modern slavery in the money laundering regulations, especially in the UK. The regulations do not explicitly specify what is expected of financial institutions. By treating modern slavery purely as a by-product of other crimes, rather than as a core economic crime, it risks being deprioritized in policy, supervision, and industry response. 

As one expert put it: 

“Waiting for the criminality to take place and then addressing the money laundered is counterintuitive… Modern slavery and human trafficking are human rights issues, but they are also a key aspect of organized crime gangs. 

The numbers underscore the urgency: in 2024, over 9,000 modern slavery offenses were recorded in the UK, with more than 19,000 potential victims referred to authorities, a staggering 80% increase from 2020. 

AML and Compliance: A Critical Line of Defense

AML and compliance professionals play a vital role in disrupting the financial flows that enable exploitation. 
Their work includes: 

• Monitoring for typologies and behavioral red flags
• Filing comprehensive SARs that help law enforcement trace exploitation proceeds
• Partnering with law enforcement and lobbying regulators to enhance intelligence-sharing 

A single indicator doesn’t necessarily mean exploitation is occurring. But a combination of behavioral patterns may warrant further investigation.  It's not a straightforward conclusion. 

At AML RightSource, our SMEs have extensive experience in proactively identifying, detecting, and reporting modern slavery and human trafficking (MSHT) activity within client portfolios. 

We partner with financial institutions to embed typology-driven controls, develop training, and ensure red-flag awareness becomes part of day-to-day monitoring. 

A Shared Responsibility: What Financial Institutions Can Do

Financial institutions can help expose and prevent exploitation by: 

• Strengthening due diligence across supply chains and third-party relationships 
• Training staff to recognize potential indicators of exploitation 
• Engaging with AML and compliance teams to escalate suspicious activity 
• Supporting ethical sourcing and supply-chain transparency 
• Embedding typology-based detection frameworks in financial crime programs 

The Role of AI — and Why Humans Still Matter Most

AI and machine learning are reshaping how data is analyzed, revealing hidden links across vast datasets. 
They can detect anomalies, connect fragmented information, and prioritize alerts for deeper investigation. 

Yet human expertise remains irreplaceable. 

Technology cannot ask questions, interpret cultural or contextual nuance, or apply empathy and ethical judgment. The best outcomes come from AI-enhanced human insight, where data science meets domain expertise and moral purpose. 

Moving from Awareness to Action

The Modern Slavery Act 2015 was a landmark in the UK’s fight against exploitation. It consolidated slavery and trafficking offenses, introduced tougher penalties, and required businesses to report on supply-chain transparency. Yet, a decade later, critics point to weak enforcement and insufficient accountability. 

At AML RightSource, we believe legislation alone is not enough. Shared responsibility, vigilance, and action are what truly drive change. 

Modern slavery is complex, but not invisible. You wouldn't walk past someone on the street and necessarily know that they were a victim of modern slavery or human trafficking… It's not visible. But with the right tools, partnerships, and determination, we can disrupt the financial systems that sustain it. 

That’s why we work alongside clients, regulators, and law enforcement to transform awareness into tangible action, not just this week, but every day.