The bank helps combat human trafficking

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Sad girl sitting on a bridge

Samirah was just fourteen years old when she travelled from Turkey to Italy on a crowded dinghy. From there, she made her way through Germany, finally arriving at the Dutch village of Ter Apel. It was here that she turned fifteen. Where she’ll end up “celebrating” her sixteenth birthday is anyone’s guess – this young girl from Syria has been missing since April. Did she run away and get lost? Perhaps. In all probability, though, she has fallen victim to human traffickers, just like the other 10,000* child refugees who have gone missing upon arriving in Europe.

Unfortunately, dirty money doesn’t leave fingerprints Maria Anne van Dijk Maria Anne van Dijk Head of Environmental Social & Ethical Risk & Policy

Out of the frying pan into the fire

No one knows exactly what’s happening to these children. Maybe they’re disappearing into the criminal underworld, are being sold as cheap labour, or – worse still – ending up in the sex industry. One thing is certain: our society cannot allow children like Samirah** who are fleeing war and violence to then disappear undocumented before our eyes into an invisible world. Attending a 2014 event organised by the UK newspaper The Guardian, I was shocked and amazed to learn how much money is involved in human trafficking. It was then that I resolved to place this issue squarely in the spotlight at ABN AMRO. Through this blog, I’d like to explain to you the role the bank can play in the fight against human trafficking.

Hunting down a ghost

But don’t expect there to be an instant solution to this problem because there simply isn’t one. The invisibility and complexity of human trafficking makes it a very difficult problem to tackle. Even so, the bank is not going to stand idly by, and has opened a dialogue with law enforcement agencies to explore ways in which it can help.

I can appreciate that, at first glance, it may be hard to see the link between human trafficking and the banking world. After all, ABN AMRO certainly isn’t involved in human trafficking, is it? Of course not. The truth of the matter, though, is that human trafficking is all about making lots and lots of money. And that’s where banks come in. Once this money finally filters through into the economy, an opportunity exists to identify the traffickers. Yet there are still three main difficulties to overcome.

  1. The traceability of funds
    Getting to the source of the problem means figuring out exactly where and how money is being made. Dirty money isn’t always distinguishable from licit funds. After all, it’s not as if there are any fingerprints. Plus the volume of transactions on any given day is such that screening every single euro is impossible. Instead, banks are required to report any unusual transactions to the national Financial Intelligence Unit (FIU). Such transactions give reason to believe that money laundering or terrorist financing may be taking place. The FIU then investigates whether there is actual evidence of underhand dealings. Unfortunately, many of the incidents reported turn out to be false alarms.
  2. Online anonymity
    The price our society pays for the conveniences the online world offers is that the people behind the money are becoming less visible and their contact with the bank more anonymous. Naturally, the bank carries out extensive checks before it accepts new clients, but once an individual has been accepted, they are at liberty to make deposits, withdraw cash from ATMs and transfer funds, all without any form of contact with the bank’s staff. However, the Internet may prove to be an important weapon in the fight against human trafficking. But more about that later.
  3. Privacy legislation
    The third obstacle in the fight against human trafficking is the right to privacy, one of our most cherished human rights. The bank can’t just hand over customer data to law enforcement, for example. Nor is the bank allowed to carry out investigations or share customer data with other agencies on its own initiative. Although we do want to play a more investigative role, we’re still bound to uphold the law.

Putting the pieces together

Despite these three barriers, we can still make a difference. In a speech I gave at the European National Rapporteurs meeting in Brussels on 19 May, I compared the fight against human trafficking to a puzzle: it’s only when all the pieces are in place that we can see the bigger picture. That means we have to be willing to keep puzzling away with multiple key stakeholders including the police, the Labour Inspectorate, criminal justice, industry representatives, financial institutions, the Fiscal Intelligence and Investigation Service (FIOD) and the municipal authorities. We, too, hold several pieces of the public–private puzzle, and these relate to customer behaviour (both on- and offline), our systems, risk policy and exchanging knowledge with all the other stakeholders involved.

Suspicious transactions

By working closely with a range of experts, we increase our knowledge in this area, which in turn allows us to focus much more closely on suspicious behaviour. From organisations like the Dutch Border Police and other law enforcement agencies we’re learning which routes are used to reintroduce dirty money into the economy, in which sectors human trafficking is most prevalent and what financial behaviour is commonly associated with it. We then tell them what we know. After all, we share a single aim and can work together to provide the missing links so that investigations can be concluded, and offenders prosecuted, more quickly. It may all sound a bit vague and secretive, but I obviously can’t divulge too much in terms of specifics.

Little by little, our knowledge of human trafficking and labour exploitation is growing. We’re also analysing known cases in order to detect patterns in traffickers’ “revenue models”, allowing us to identify them faster in the future. New insights allow us to fine-tune our flagging systems and add additional stop lights to our processes – by classifying certain countries and sectors as risk factors, for instance. Awareness training teaches bank staff to be alert to possible signs of human trafficking, such as a rapid succession of small cash deposits which add up to a large amount. While there’s nothing unlawful about making the deposits, the pattern itself is unusual.

Cleaning up the sector together

By emphasising the severity and scope of human trafficking, we’re taking a first step towards raising public awareness. As a large organisation, the bank often has more clout than smaller firms do and is better equipped to get a good overall picture of abuses across entire chains. Take the employment agency sector, for instance. Here exploitation is unfortunately very common, as people fleeing poverty are much more inclined than others to believe empty promises. Unscrupulous companies are also rife in this sector and have tarnished its reputation. If we band together, though, we can make life very difficult indeed for human traffickers. After all, this is a joint problem, one for which we have a shared responsibility.

Can big data save the day?

One glimmer of hope in the combat against human trafficking may actually be behind the veil of anonymity under which criminals are currently hiding: big data. Under the umbrella body FinPro, various government agencies have been studying big data to reveal hidden patterns of behaviour. Let’s hope that in five years’ time tracking software will be available to us so that our Samirah can celebrate her twenty-first birthday in real freedom.

* Source Europol: minstens 10.000 vluchtelingenkinderen vermist, published in NRC Handelsblad
** Samirah doesn't exist. Or maybe she does. I brought her to life based on known facts. She is one of many whose lives are shrouded in darkness.


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