A report published by the Independent Anti-Slavery Commissioner says financial services sector firms have low awareness of the risks of modern slavery within their businesses. It found a general low awareness of the risks and many board level managers believed that modern slavery was not something that occurs in the UK. There was also low awareness of the existence, or otherwise, of a firm policy. Nearly half of all financial services employees said they would not know who to report a suspicion of modern slavery to, and over 70% had not been trained on the subject, It said most firms focus only on direct impacts but fail properly to consider the risks within their supply chains. The report says firms should improve due diligence and should integrate modern slavery red flags into their money laundering control frameworks.
Every entity with a turnover or budget of over £36m is required to publish a Modern Slavery Statement, and modern slavery is also a predicate crime to money laundering. So the legal and reputational risks to financial institutions are high – as any financial institution found to be holding the proceeds of MSHT will be holding proceeds of crime.
The report calls for greater awareness and support at top level, with MHST elements incorporated into existing risk assessments and due diligence processes, and considered alongside other critical factors.
The report specifically calls on retail bank staff to look for wider patterns of suspicious activity and facilitate access to bank accounts and ongoing support services to survivors of modern slavery.