In 2024, financial control was the second most reported method of control reported to the UK Modern Slavery & Exploitation Helpline. This shows just how central money can be in systems of abuse and exploitation.
At Unseen, we work directly with survivors and support businesses to understand and address their exposure to modern slavery risks, as well as increasing the positive impact they can have on worker and customer wellbeing. This article explores how modern slavery intersects with fintech, what the law says, and what companies can do to stop exploitation before it starts.
What is modern slavery?
Modern slavery is about control. It happens when someone uses force, threats, deception, or abuse of power to exploit another person and take away their freedom for the purposes of personal or commercial gain . It includes human trafficking, forced labour, child exploitation, domestic servitude, and forced marriage.
These abuses can be found in any industry, including finance, and in the value chains behind everyday goods and services. Victims may be forced to work or live in poor conditions, with their control maintained through digital tools (see below) like apps and online platforms, making the abuse harder to detect.
Find out more about modern slavery and the financial industry .
What is fintech and why does it matter?
Fintech (short for financial technology) refers to the digital tools that are changing how we manage money. This includes mobile banking apps, Buy Now Pay Later services, cryptocurrency platforms, and gig economy payment systems like Just Eat, DoorDash and Uber Eats. These tools are designed to make financial services faster, more flexible, and more accessible.
For many people, fintech is a lifeline, helping them send money to family, access credit, or get paid instantly. But for those being exploited, these same tools can be used to control income, hide abuse, or move money without detection.
Because fintech often operates with little face-to-face contact and at high speed, it can be difficult to spot when something’s wrong. Independent perpetrators and organised crime groups are increasingly using digital finance to exploit victims and launder profits.
As the sector grows, so does its influence. With the right tools, awareness, and partnerships, fintech companies can help spot the signs early and build platforms that protect people.
How modern slavery shows up in fintech
Modern slavery doesn’t always present the way people expect. It’s not just physical control, it can also be financial. And as fintech platforms become more common, they’re increasingly being used by traffickers and exploiters to move money, hide abuse, and control victims.
At Unseen, we’ve seen how financial exploitation can be a key part of someone’s experience of exploitation. Through our Modern Slavery & Exploitation Helpline, we’ve received reports of individuals being forced to open bank accounts by family, friends or partners, hand over control of digital wallets, or take out loans they never benefit from. The Unseen Annual Assessment offers key insights into reported cases, trends, and types of exploitation in the UK.
Some of the most common ways exploitation shows up in fintech include:
- Coerced financial control: victims are made to open digital wallets or prepaid cards, which are then accessed and used by their exploiters.
- Loan fraud: Individuals are forced to take out credit or loans in their name, often under threat or manipulation.
- Gig economy abuse: workers are recruited into jobs where their wages are skimmed, withheld, or paid into accounts they can’t access.
- Crypto laundering: criminals are increasingly using cryptocurrency platforms to move and disguise the profits of exploitation. INTERPOL has warned that cryptocurrencies are “changing the landscape of the criminal underworld,” and that without coordinated global action, they risk becoming safe havens for illegal financial transactions.
Relevant legislation for financial institutions
Modern slavery is not just a moral issue, it’s a legal and economic crime. In the UK, businesses have a clear responsibility to identify and address exploitation risks, including those linked to financial systems and digital platforms.
UK Modern Slavery Act 2015
The Modern Slavery Act requires large organisations (with a turnover of £36m or more) to publish an annual Modern Slavery Statement. This statement must outline the steps they are taking to prevent slavery in their operations and supply chains.
The 2025 update to the UK Home Office’s Transparency in Supply Chains guidance (TICS) places stronger emphasis on risk identification, victim-centred remediation, and transparent reporting. The guidance highlights that financial institutions may face risks in their investments or how they manage the flow of finances for traffickers*, reinforcing the sector’s role in identifying and disrupting exploitation-related financial activity.
For Fintechs and financial institutions, this means recognising modern slavery not only as a legal and moral obligation, but also as an economic crime with direct relevance to financial systems. Exploitation risks may be embedded in digital platforms, third-party relationships, and transactional flows, making proactive due diligence and ethical governance essential to compliance and risk management.
These legal obligations are not optional. They reflect a growing recognition that financial systems can either enable exploitation or help stop it. Fintech firms have a legal and ethical duty to choose the latter. Proactive due diligence and clear disclosures are increasingly seen as benchmarks of good governance and ethical risk management.
*Home Office transparency in supply chains guidelines – page 32
**Section 75 of POCA defines criminal lifestyle offences, which includes human trafficking; Citation: Proceeds of Crime Act 2002, Section 75 – Criminal lifestyle
Proceeds of Crime Act 2002 (POCA)
This Act is key in disrupting exploitation by targeting the profits behind it. It gives authorities the power to recover assets gained through criminal activity, including modern slavery. While the Modern Slavery Act 2015 defines offences and victim protections, POCA focuses on asset recovery and criminal profits.
POCA places clear responsibilities on financial organisations, especially around anti-money laundering (AML) and reporting obligations. Fintechs aren’t just passive observers, they’re active players in identifying and disrupting financial flows linked to exploitation.
POCA underpins the Suspicious Activity Reporting (SAR) framework*, which requires financial institutions to report transactions that may involve criminal property to the National Crime Agency (NCA). Once a SAR is submitted, it becomes a criminal offence to inform the person involved – a practice known as “tipping off”, designed to prevent suspects from hiding or moving assets.**
Financial institutions are also required to seek consent for risky transactions from the NCA before proceeding as part of the Defence Against Money Laundering (DAML) process***.
Part 7 of POCA is the legal backbone of the UK’s fight against money laundering. It sets out the duty to report, criminalises handling dirty money, and makes it an offence to look the other way. These rules help financial institutions cut off cash that fuels exploitation. While POCA lays the groundwork, the Money Laundering Regulations 2017 demands action. Financial organisations must train staff, assess risks, and spot suspicious activity fast. These checks are vital for catching exploitation before it takes hold.
Fintechs are uniquely placed within the financial sector to support POCA’s aims—using agile platforms and data-driven tools to strengthen AML controls, report suspicious activity, and help disrupt the financial flows that enable exploitation.
*Part 7 of POCA covers Money Laundering, including the duty to report suspicious activity; Citation: Proceeds of Crime Act 2002, Part 7 – Money Laundering
**Proceeds of Crime Act 2002, Section 333A – Disclosures prejudicing investigations
***Proceeds of Crime Act 2002, Section 327 – Concealing criminal property
How can fintechs respond to the increased modern slavery risk?
Financial technology has the power to disrupt exploitation but only if it’s used responsibly. Here’s how fintech companies can take meaningful action:
- Build awareness from the inside out
- Equip fraud and compliance teams with training to spot signs of modern slavery.
- Strengthen onboarding and know your customer (KYC) frameworks
- Follow TISC guidance by embedding lived experience into due diligence processes. Work with NGOs like Unseen to develop KYC frameworks and onboarding processes shaped by real-world insights, helping to identify coercion, third-party control, and vulnerability during onboarding.
- Understand and look out for Fintech specific red flags, such as unusual account activity, inconsistent or suspicious personal data, and third-party control indicators.
- Monitor for exploitation patterns
- Strengthen pattern recognition by embedding modern slavery indicators into automated transaction monitoring and Suspicious Activity Report (SAR) processes.
What to look out for:
- Irregular payment patterns in gig economy platforms, which may suggest exploitation or financial control.
- Cryptocurrency transactions with no clear origin or purpose, potentially masking illegal activity.
- Accounts accessed from multiple devices or locations, indicating possible third-party control or account misuse.
- Embed Ethics into Governance
- Integrate modern slavery risks into your Environmental, Social and Governance (ESG) strategy, vendor due diligence, and risk frameworks.
- Ensure a top-down commitment by embedding modern slavery considerations into governance structures, such as board-level oversight, steering committees, and cross-functional working groups.
- Align your technology and product design with ethical values, ensuring systems are designed to detect and prevent exploitation.
- As highlighted by government guidance, collaborate with frontline expert organisations like Unseen to access survivor-informed training, risk indicators, practical risk indicators, and ethical best practices.
- Work with experts to better understand your organisation’s risk profile, identify gaps in current processes, and develop clear reporting and escalation mechanisms that support safe and ethical responses to exploitation.
What to do if you identify a sign of modern slavery
If you see something that doesn’t seem right act safely and responsibly. Here’s what to do:
Prioritise safety and confidentiality
- Do not approach the person you’re concerned about or anyone you suspect may be exploiting them.
- Avoid taking any action that could put someone at further risk.
Escalate responsibly and survivor focused
- Follow your internal escalation processes, such as whistleblowing policy or speak up line
- If someone is in immediate danger, call 999.
- For advice or to report concerns confidentially, contact the Modern Slavery & Exploitation Helpline: 08000 121 700
Preserve Evidence
- Keep a clear and accurate record of any suspicious account activity, transactions, or communications that may indicate exploitation.
- Do not delete, edit, or overwrite any data. Preserving original evidence is essential and may support safeguarding efforts or future investigations.
Seek expert support
- Follow expert guidance when engaging with individuals who may have experienced exploitation. As highlighted in TISC guidance, organisations are strongly advised to consult with NGOs such as Unseen before engaging directly. Modern slavery experts can provide trauma-informed advice on ethical processes including confidentiality, anonymity, safeguarding and compensation.
Review and strengthen systems
- Reassess your onboarding, KYC, and fraud detection systems to better identify and prevent exploitation, ensuring they remain responsive to evolving risks.
- Review internal systems, such as escalation and remediation routes, work with modern slavery experts to strengthen your approach.
- Upskill teams using resources like free government training or bespoke sessions from specialist organisations.
Removing financial barriers for survivors
While much of the focus in financial services has been on identifying and managing the risks linked to modern slavery, fintech has the potential to do far more. It can be a powerful tool for rebuilding lives.
Across the UK and beyond, we’re seeing examples of fintech innovation that go beyond compliance, offering survivors practical, dignified ways to access money, build independence, and move forward.
Some companies are developing survivor bank accounts that don’t require conventional ID or proof of address, removing a major barrier to access. Other Fintechs are partnering with frontline organisations to offer prepaid cards that allow survivors to receive emergency funds safely and discreetly.
Digital wallets and flexible onboarding processes are helping people manage their finances without putting themselves at risk. These are not just technical solutions, they’re often lifelines.
Fintechs are in a unique position to lead with empathy and practical innovation, offering survivors meaningful ways to access financial services and take steps toward long-term recovery.
Ready to be part of the change?
Fintech companies have tools, data, and reach to make a real difference. If you’re a business looking to strengthen your response to modern slavery, our team is here to help.
From survivor-informed training to risk assessments tailored to your sector, we’ll work with you to build safer systems and stronger safeguards.
Get in touch now: [email protected]