How you can help modern slaves

Modern slavery is a very real problem in the UK – as one AAT student experienced for herself. Accountants are at the front line for spotting this kind of abuse, so need to be vigilant of the signs. 

One member’s story

Just over six years ago, Deepika AATQB and two of her three children were flown from her home in India to the UK to visit her husband’s relatives. She was told it would be a ‘holiday’. 

But on arrival, they were met by her husband’s uncle and aunt who confiscated their documents, passports and money.

She was forced to work every day from 6:30 in the morning until 11:30 at night, cooking, cleaning, gardening and other domestic tasks. Her children (four and 12 at the time) were sometimes forced to work, too. 

“They told me they had paid my husband and I to serve them for seven years,” Deepika recalls. “My other child had been kept in India to ensure I behaved. My husband used to phone and tell me that if I returned, he would kill me and the children.” 

There was just one mattress for the three of them and they were fed on leftovers. They endured physical and psychological abuse. “They locked my older daughter in a room for a few months with limited food at one point and my son was locked in a store cupboard,” says Deepika. “We were refused medical care and we weren’t allowed to go out, unless I was taking the children to and from school, but I was always watched. It was continuous abuse for two years.”

How one intervention made a difference

Deepika is able to share her story with AAT because she managed to escape after a local resident grew suspicious of her situation and smuggled her a note with contact details of organisations who could help her. 

Six years on and Deepika and her children are safe. Although Deepika is currently unable to work because she is still in the process of seeking asylum, she volunteers at a local foodbank and her son’s school, and she has finished AAT Level 3 with the hope of one day becoming a licensed accountant. 

Deepika’s story serves as a reminder that raising one concern can change a life. 

“While a lot of the time, modern slavery suspicions might be unfounded, it’s important to remember that some of the time those suspicions will be correct,” says Julia Penny, chair of ICAEW Ethics Advisory Committee and principal of JS Penny Ltd, which provides anti-money laundering procedure training. 

Financial exploitation is increasing

Anti-slavery charity Unseen estimates that 122,000 people in the UK are currently in modern slavery. 

According to Justine Carter, Deputy CEO at Unseen, there’s been an ‘uptick’ in financial exploitation where people work for a genuine business, but wages are taken from them once they’ve been paid. 

“These situations are becoming more common,” she says. “There is often an individual on the outside who is commanding control over somebody’s finances, threatening them and having a hold over their life.”

Why you?

AAT members are crucial in identifying modern slavery, although the connection between the role of an accountant and modern slavery might not be obvious to begin with.

By promoting and advocating for an ethical and transparent culture across all your business relationships, and implementing robust due diligence systems and controls, you can identify activities associated with modern slavery and human trafficking. It is extremely important that members stay up to date with global regulations and reporting requirements. 

The signs to watch out for

Accountants should look for:

• Payroll anomalies
• Complex supply chains
• Shell suppliers
• Inconsistent invoices
• Large business operations with significantly low labour costs

In a workplace setting, it can be very difficult to spot the signs of modern slavery, but not impossible. “Some signs might be similar to domestic abuse,” says Julia. “They might be cagey or look like they’re trying to hide bruises. Maybe they are always dropped off and picked up or they’re overly anxious about leaving on time. Maybe they never join after work drinks and seem reluctant to socialise with colleagues. They might keep their head down and say very little at work.” 

As well as being aware of signs of modern slavery, accountants should be on the lookout for issues among their client base, too. Although some sectors are more high risk than others, no sector or business is immune. 

Julia highlights the importance of client due diligence (CDD). “What is the nature of the business? Is it a high-risk business for money laundering?  Is it a business which doesn’t require specific qualifications or where you can interchange people quickly? Ask yourself, ‘could this nature of client be used for modern slavery?’”

Nail bars are well-known money laundering environments for example, as well as some agricultural businesses where workers live in caravans in the fields.

Payroll information can give clues too. It may look legitimate at first glance, set up to look like payroll, but wages may be going back to the perpetrators either by disguised umbrella companies or false agencies.  

If you have staff members, ensure that they are trained in how to spot red flags. The NCA has produced a document on Indicators of Modern Slavery and Human Trafficking in the Accountancy Sector.

What actions you can take

So what’s the advice if you suspect modern slavery? 

If you have knowledge or suspicion of money laundering, you must submit an internal Suspicious Activity Report (SAR) to your Money Laundering Reporting Officer (MLRO). 

The MLRO will then assess whether an external SAR is required to the UKFIU. Failure to submit either an internal or external SAR once you have knowledge or reasonable grounds to know or suspect money laundering, is a criminal offence. 

When submitting a SAR to the UKFIU, use the following glossary code: XXMSHTXX. This PDF from the NCA contains guidance on submitting better quality SARs.  

To report any suspicions about modern slavery, you can also call Unseen’s Modern Slavery Helpline, open 365 days a year:  08000 121 700. 

If you are concerned that victims are at immediate risk of harm, call the police on 999. 

Justine cautions against taking ‘obvious action’ which might compromise a person’s safety but instead, giving someone space and time to talk about what’s happening, without arousing suspicion. 

“There also needs to be clear escalation routes and mechanisms where individuals are given advice, help, support and next steps,” she says. “This ensures the business fulfil their duty of care obligations by providing the individual the opportunity to get help and support.” 

“Modern slavery is a constantly evolving picture, so businesses need to understand that whatever you check today might not necessarily be what you need to check tomorrow,” says Justine. “We just need to make sure that we don’t take our foot off the pedal.”

Positive outcomes

For people like Deepika, the traumatic memories of slavery will stay with her forever. But it took just one person to act carefully on a suspicion to save Deepika and her children. 

“I kept telling myself, they can keep my documents and my freedom, but they can’t keep my knowledge, my identity or my inner fight.”

One result of that inner fight was Deepika’s nomination for an Triumph Award, which is given to members who have overcome challenges and obstacles, at the AAT Impact Awards in November 2024.

Deepika’s daughter (now 18) has got a scholarship in engineering while her son (now 10) wants to be an astronaut when he grows up.

Useful resources 

Some accountants find Anti-Money Laundering (AML) and compliance stressful, or view it as a tickbox exercise. But both are essential because accountants and bookkeepers are in a very powerful position to spot and help survivors of modern slavery and other abuse – money laundering is never a victimless crime. 

AAT has a comprehensive range of resources on Standards and Requirements for you to use, including information on CDD, Suspicious Activity Reporting (SARs) and red flag indicators.

Here is AAT’s ethics page.

Learn how to report AAT’s supervised members here.

AAT Comment also features guidance on AML and compliance. 

The AASG risk outlook (PDF) sets out the key risks and red-flag indicators relevant to the accountancy sector, which covers modern slavery.

THEMIS Knowledge offers free digital learning on the subject, aimed at financial institutions. 

Annie Makoff is a freelance journalist and editor.