Finance Monthly - April 2023

occurring. Criminals never rest, and new schemes are being introduced frequently; therefore, keeping current on the latest red flags, suspicious activities, and schemes is essential. Ensure these typologies are also incorporated into your processes and procedures and addressed by your technology operations. In addition to watchdogs at the financial institution, can more be done to target human trafficking at the governmental level? From a US perspective, FinCEN modified the Suspicious Activity Report (SAR) form to include a checkbox for human trafficking. That simple step facilitates the ability of law enforcement to more easily identify criminal activity related to human trafficking. Previously this check box was just included in the narrative of the form, which made this activity much harder to identify. But FinCEN then declared Human Trafficking a top priority in the AML Act of 2020 which brought some improvements. In December last year, the European Commission proposed further strengthening of the rules that prevent and combat human trafficking. Under the proposal, changes will be made to include forced marriage and illegal adoption as criminal offences of human trafficking. It also proposes to make it a criminal offence for people who knowingly use services provided by victims of human trafficking. It also provides for imposing mandatory sanctions for persons held accountable for trafficking offences. Industry Joins Together The increased attention and strengthened regulations look to be a good sign of change in the fight against human trafficking; however, fears remain in the industry. Many institutions have programs in place to combat human trafficking; however, the concern is that with increased regulations, the focus may shift to just “checking the box” to ensure they are meeting the regulatory requirements, which may take focus away from their current efforts to detect patterns and greater activity levels. Human trafficking continues to be a significant problem, and current efforts are not enough. We must join forces, and everyone needs to take an active role. No one can do this alone, and there is strength in collective intelligence. Fortunately, the financial services industry is seeing unity around this issue. A number of nonprofit organisations have teamed up to fight the fight, leveraging strength in numbers to capture traffickers and their activities. The Knoble, which describes itself as a network of financial crime experts passionately fighting human crime, is one of these organisations which is working hard to pull together financial institutions and technology leaders to focus their talents on human trafficking. Many financial institutions and financial crime technology vendors such as NICE Actimize have joined with The Knoble in a variety of research and outreach activities which target a range of crimes ranging from human trafficking to elder and child abuse and more. As stated by Ian Mitchell, founder and board chair of The Knoble, “The financial industry is well positioned to have material positive impact in the fight against Human Crimes like scams and human trafficking. But to accomplish this, it is going to take bold leadership, development of intentional programs and banking with heart.” “FinCEN declared Human Trafficking a top priority in the AML Act of 2020 which brought some improvements.” Bank i ng & F i nanc i a l Se r v i ce s 22 Finance Monthly.

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