Despite the pandemic and economic crises of the last year, financial institutions continue to recognize their unique role in responding to human trafficking. However, the challenge remains with how to tactically build that response in a survivor-centered way, especially in the wake of a global pandemic.
A robust response to human trafficking for financial institutions necessarily includes:
- providing enterprise-wide training to arm personnel with the skills needed to identify exploitation both within the company and in external relationships;
- enacting and enforcing human rights policies;
- establishing enhanced due diligence in anti-money laundering (AML) and know-your-customer (KYC) procedures;
- paying attention to supply chain risks at both the company- and customer-level; and
- creating survivor support programs that increase access to financial services and employment opportunities.
A survivor-focused and survivor-informed approach
An anti-human trafficking program is only effective if it is shaped by the victim experience and includes a remedial goal. This involves assisting law enforcement with seizure of account funds which will be subject to forfeiture for future restitution orders paid to victims, updating typologies to reflect real-life victim and perpetrator behaviors, and eliminating obstacles to access to financial services including penalties for low- or no-balance accounts, overdrafts, and delinquent credit histories. Mostly, this means listening and learning from the victim experience. A recent survey of survivor advocates performed by the Moore & Van Allen Human Trafficking Pro Bono Project led to the following recommendations for banks, specifically:
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