Launch: Financial Investigation of Modern Slavery 


The Independent Anti-Slavery Commissioner, Dame Sara Thornton, has today published a new paper urging police practitioners to prioritise financial investigation of modern slavery and human trafficking crimes.

Financial investigation of modern slavery offending has the potential to increase prosecutions and maximise the chance of victims receiving reparations.

In dealing with serious organised exploitation where victim evidence is often unavailable, the truth of a case can be illuminated by financial evidence, alongside other techniques such as communications data and digital forensics.

The paper focuses on two key aims for a financial investigation in modern slavery – proving the criminal offence has taken place, and compensating victims and survivors.


The paper outlines 10 recommendations: 

  1.  Senior investigating officers should include a financial strategy in their early policy decisions for modern slavery and human trafficking cases.

  2. Embed financial intelligence officers in investigative teams with responsibility for modern slavery and human trafficking.

  3. Modern slavery organised criminal groups should be mapped and scored at the earliest opportunity to support tasking processes and give appropriate weight to bids for resources and capabilities.

  4. This mapping and scoring process should lead to the allocation of financial investigation resources to modern slavery investigations commensurate with the identified risk and opportunities.

  5. Senior investigating officers should utilise the Joint Money Laundering Intelligence Taskforce in their financial strategy.

  6. The Modern Slavery and Organised Immigration Crime Unit and the National Crime Agency should undertake monitoring of threats and opportunities in emerging financial sectors and keep investigators updated.

  7. Modern slavery investigators should set an objective to obtain Slavery and Trafficking Reparation Orders for victims, and structure their financial investigation towards this.

  8. Compensation for victims, and reparation orders in particular, should be added to the learning descriptors of the College of Policing Modern Slavery Investigator course.

  9. Investigators should establish ongoing contact arrangements with victims to facilitate later compensation.

  10. The Victim Care Contract under the National Referral Mechanism should require that victims are informed about routes to compensation.


Read: Financial Investigation of Modern Slavery


Dame Sara Thornton, Independent Anti-Slavery Commissioner, said:

“Modern slavery is a trade in human beings and it generates $150bn in profits a year. In my first strategic plan I expressed concern at the very low level of compensation orders made and committed to encouraging much greater use of financial investigation with a view to identifying assets and compensating victims.

“As I have listened to investigators and researched good practice it has also become apparent that there is so much more potential to exploit financial data to build the evidence case against traffickers and abusers. I therefore asked Detective Inspector Richard Marsh who was seconded to my team to work with law enforcement to identify the barriers to effective financial investigation and to seek out good practice. This report draws his findings together and is a valuable resource for police leaders.”




Notes to editors

  • Part 4 of the Modern Slavery Act 2015 created the role of the Independent Anti-Slavery Commissioner. The Commissioner has a UK-wide remit to encourage good practice in the prevention, detection, investigation and prosecution of slavery and human trafficking offences and the identification of victims.
  • The Commissioner is given an annual budget with which to appoint staff and carry out her duties. She is accountable through her strategic plan and annual reports, which the Secretary of State lays before Parliament, setting out the extent to which objectives and priorities are achieved. 
  • The Commissioner's Strategic Plan 2019 – 2021 was launched in October 2019 and her Annual Report 2019 – 2020 was launched in September 2020.
  • Dame Sara Thornton was appointed as the Independent Anti-Slavery Commissioner by the Secretary of State following consultation with the Scottish Ministers and the Department of Justice in Northern Ireland. She took up post at the beginning of May 2019 and her appointment is for three years.