As Enforcement Funding Increases, Organizations Report Varied Anti-Human Trafficking Programs

Following recently increased funding to U.S. law enforcement for anti-human trafficking efforts and during the second annual U.S. National Slavery and Human Trafficking Prevention Month in January, a poll conducted by Deloitte found that organizations have varying levels of anti-human trafficking program deployment.

When asked about the strength of their anti-human trafficking programs, 28.5% of respondents at organizations with existing programs and just 8% of those at organizations launching such programs in the next 12 months described their programs as “stronger than industry standard.” Of those with programs launching inside the next year, 27% called their anti-trafficking programs “weaker than industry standard.”

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“With law enforcement receiving more funding, now is a smart time for organizations to reassess and possibly reinforce their ongoing efforts to stem illicit acts commonly tied to human trafficking: money laundering, corruption and fraud,’” said Josh Hanna, a Deloitte Risk & Financial Advisory principal specializing in anti-money laundering and economic sanctions compliance, Deloitte Transactions and Business Analytics LLP. “Regulatory requirements around financial crime vary by industry and global geography for instance, while FinCEN regulates U.S. financial institutions related to the prevention and detection of money laundering and other financial crimes, some industries have no such regulatory oversight. However, lack of regulatory accountability shouldn’t deter organizations from doing what they can.”

Don Fancher, Deloitte Risk & Financial Advisory principal, Deloitte Financial Advisory Services LLP, who serves as US and Global leader for Deloitte Forensic, added, “Human trafficking is one of the world’s fastest growing and toughest to detect illicit activities because it happens in the shadows. The good news is that many organizations, including those without standalone anti-trafficking programs, are collecting more and better data than ever before that can help cast a light on these crimes. As technologies improve, the global business community can be invaluable in helping to fight human trafficking by taking a closer look at financial data with more advanced technologies and by conducting deeper due diligence on the third parties with which it transacts globally.”

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Respondents from organizations with existing anti-human trafficking programs already in place were more likely to use advanced technologies like artificial intelligence and cognitive computing to monitor transactions for possible ties to human trafficking (42.3%) and to conduct ongoing due diligence on new and existing third parties for the same (47.1%). Just 26.4% of respondents from organizations launching such programs in the next 12 months leverage advanced technologies for anti-trafficking transaction monitoring and fewer (18.4%) conduct ongoing due diligence on new and existing third parties to prevent engagement with potential human traffickers.

Similarly, the executive most responsible for managing anti-human trafficking programs differed by group as well. Global chief compliance officers or global chief risk officers (41.5%) were most likely to manage efforts at organizations with existing anti-human trafficking programs. For organizations launching anti-human trafficking programs in the year ahead, global chief legal officers or general councils (33.5%) were most likely to take point.

Hanna added, “Leaders running anti-human trafficking programs may want to ask themselves if program awareness is as high as they’d like and if employee training is frequent enough such that the full organization can better share responsibility for detecting and preventing illicit acts.”

Fancher concluded, “Ultimately, companies that lean into technology, prioritize the detection of these crimes enterprise-wide and are diligent in their corporate financial crime fighting efforts can help to move the bar higher on what constitutes a leading anti-trafficking program.”

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