● Member Perspective

The ROI of redemption: HT prevention

January 30, 2026

For many years, the financial sector’s response to human trafficking (HT) has been shaped by the “detect and report” obligations of know your customer (KYC) and anti-money laundering (AML) regulation.¹ These tools remain essential, but they operate largely after harm has occurred.² As a result, they do little on their own to address the economic conditions that make individuals vulnerable to exploitation in the first place.³

The “ROI of redemption” framework—which redefines the role of banking institutions not merely as gatekeepers of capital but as active participants in the eradication of modern slavery—argues for a complementary shift in focus toward protecting the customer in a more substantive sense.⁴ That means paying closer attention to whether vulnerable individuals and survivors can regain financial stability, rebuild credit and participate safely in the formal economy.⁵ For a small but growing group of institutions, this has prompted a reassessment of how success is measured. Rather than relying solely on compliance outputs such as the number of SARs filed, these institutions are beginning to consider indicators related to financial inclusion, credit repair and longer-term economic resilience.⁶

The barriers survivors face are significant. Traffickers frequently exploit or hijack victims’ financial identities, leaving lasting damage to credit histories that can prevent access to housing, employment or even basic banking services.⁷ In response, initiatives such as the Survivor Inclusion Initiative (SII) have focused on restoring access to foundational financial products.⁸ Through partnerships with major banks, SII has helped thousands of survivors open accounts and reestablish basic financial services.⁹ While access alone is not sufficient, these programs aim to reduce the financial exclusion that often increases the risk of revictimization.¹⁰

Alongside product design, survivor-lived experience is increasingly recognized as a governance and risk-management asset.¹¹ Survivors are often able to identify weaknesses in recruitment practices, subcontracting arrangements and financial flows that are difficult to detect through transactional data alone.¹² When integrated responsibly, these insights can complement traditional compliance systems and improve the identification of material human-rights risks within complex supply chains and environmental, social and governance (ESG) frameworks.¹³

The calculation of ROI in this context must expand to include both financial and social outcomes. Traditional ROI is calculated as:¹⁴

ROI Financial Benefits-Transformation Costs/Transformation Costs x 100

However, in “ROI of redemption,” the "benefits” term includes the reduction in operational losses from fraud, the decrease in cost-of-capital through improved ESG ratings, and the long-term value of a loyal, rehabilitated customer base. Programs such as Scotiabank’s StartRight illustrate how this logic operates in practice.¹⁵ By offering newcomers—a group that can face heightened exploitation risk due to unfamiliarity with local financial systems—access to credit products without prior domestic credit history, the bank supports early financial stability while building long-term customer relationships.¹⁶

While such initiatives are not a substitute for enforcement, they demonstrate how inclusive financial design can reinforce both customer protection and institutional resilience.

Proactive tools and digital interventions

Efforts to weaken the economics of modern slavery increasingly focused on a dual objective: raising the operational cost and risk for traffickers, while reducing the financial barriers that leave survivors vulnerable to additional exploitation.¹⁷ In practice, this means combining more effective detection of illicit activity with safeguards that allow individuals to reenter the formal economy without exposing them to further harm.¹⁸

Technology plays a growing—though not standalone—role in this approach.¹⁹ Advanced analytics, including artificial intelligence (AI)-assisted transaction monitoring and blockchain analysis are being used by FIs to better understand criminal networks and identify patterns associated with trafficking-related activity.²⁰ At the same time, these tools are also exploited by traffickers themselves, particularly for encrypted communication and the movement of funds across digital channels.²¹The value of technology, therefore, lies not in eliminating risk, but in improving the speed and quality of detection when combined with human judgment and institutional controls.²² The European Commission’s strategy to tackle organized crime for 2021-2025 specifically focused on this intersection of HT and financial proceeds, urging institutions to strengthen their AML programs through innovative tech solutions.²³

As monitoring capabilities expand, data protection becomes a central concern. FIs operating in this space increasingly rely on established information security and privacy standards, such as ISO 27001 and ISO 27701, to safeguard sensitive customer data.²⁴ Firms working in digital-asset compliance, including TRM Labs, have pointed to these frameworks and independent audits (such as SOC 2 Type II) as mechanisms for demonstrating control effectiveness.²⁵ For survivors—whose identities may already have been compromised—strong privacy and security practices are not ancillary; they are essential to preventing further harm and maintaining trust.²⁶

Proactive detection and intelligence sharing

Moving from reactive reporting to more proactive risk identification depends less on any single institution and more on shared intelligence. In practice, this means closer collaboration across banks, technology providers, civil society and sector-specific initiatives that focus on trafficking and financial crime typologies.²⁷ Organizations such as the Anti-Human Trafficking Intelligence Initiative and the Cryptocurrency Compliance Cooperative support this approach by facilitating the exchange of anonymized insights on how trafficking networks operate across both traditional and digital financial systems.²⁸

Rather than relying solely on isolated transaction signals, this kind of shared intelligence helps institutions better understand patterns of abuse, refine risk indicators and apply a more genuinely risk-based approach to monitoring and escalation.²⁹

Alongside detection, inclusive financial design can play a preventive role. Early-stage models such as SympliFi’s migrant-backed loan pilots in the EU–Senegal corridor illustrate how formal financial products can begin to replace informal, high-risk lending arrangements.³⁰ These products allow migrants in Europe to place refundable deposits that help guarantee small loans for family members in their countries of origin. While still limited in scale, such models offer a pathway for first-time borrowers to access credit and build financial histories, reducing dependence on informal lenders who often use debt as a mechanism of control.³¹

Global implementation: From Mexico to Peru

In practice, the “ROI of redemption” approach looks different across regions, but it consistently targets the same problem: structural economic vulnerability.³²

In India, where informality remains a major driver of forced labor, efforts have focused on linking microfinance more closely with the formal banking system as a way to reduce dependence on exploitative work.³³

In Peru, partnerships between FIs and civil society—including Scotiabank’s collaboration with CARE Peru—have combined financial literacy with access to small-scale credit to support income-generating activities in agriculture and other local sectors.³⁴

In Mexico, initiatives have emphasized public–private collaboration to expand financial access for survivors, alongside simplified account structures that lower documentation barriers. These approaches reflect a shared recognition that poverty, exclusion and lack of access to justice are key drivers of re-trafficking.³⁵

While outcomes vary by context, research consistently shows that stronger economic opportunities and labor protections are associated with lower trafficking risk.³⁶ Taken together, these cases reinforce a central point: Financial inclusion is not only a social intervention, but a practical tool for reducing vulnerability to modern slavery.³⁷

Overcoming internal obstacles

The shift to a proactive model is not without its challenges. FIs often struggle with “data silos” and inconsistent metrics, which can lead to a fragmented view of risk.³⁸

Furthermore, the complexity of generative AI poses new hurdles for quantifying ROI, as the returns from these advanced systems are often less immediate and harder to measure than traditional machine learning.³⁹ To overcome these issues, banks are encouraged to centralize their data governance and automate data syncing to ensure that all teams are operating from a single, accurate “source of truth” regarding customer behavior and risk indicators.⁴⁰

Effective performance management in this domain requires making roles and responsibilities explicit. A bank teller, for instance, should have different KPIs related to spot-checking behavioral red flags compared to a commercial loan officer who monitors supply chain finance for forced labor risks.⁴¹ Frequent training on potential red flags and behavioral indicators ensures that HT does not go undetected and is appropriately highlighted for investigation.⁴²

Regulatory evolution and the road ahead

The regulatory environment is also evolving to support the “ROI of redemption” framework. The U.K.’s Modern Slavery Act 2015 and the EU’s Artificial Intelligence Act represent critical steps toward holding corporations and financial actors accountable for human rights abuses in their supply chains.⁴³ These laws require transparency and due diligence, encouraging businesses to move beyond a “checkbox” approach to compliance toward meaningful impact reporting.⁴⁴

Furthermore, the 2025 Trafficking in Persons Report highlights the importance of the “non-punishment principle,” which asserts that survivors should not be penalized for crimes they were forced to commit by their traffickers.⁴⁵ For the banking sector, this means ensuring that a criminal record—especially one related to “forced fraud”—does not automatically result in permanent exclusion from financial services.⁴⁶ Instead, institutions should adopt flexible, trust-based funding models and tailored financial products that prioritize accessibility for survivors.⁴⁷

The synthesis of these efforts—technological, cultural and regulatory—creates a comprehensive strategy to “starve” the market for modern slavery. By integrating survivors into the formal economy and providing them with the tools for financial independence, the global banking sector is not only redeeming the lives of individuals but also reinforcing the integrity of the entire financial system.⁴⁸

The strategic importance of Human Trafficking Prevention Month

January’s designation as Human Trafficking Prevention Month offers FIs a practical opportunity to reflect on how effectively their policies translate into protection for vulnerable customers. For banks exploring survivor-centric approaches, this period can serve as a testing ground for partnerships, internal reviews and pilot programs focused on financial inclusion.⁴⁹ As economic volatility increases the risk of exploitation, the ability to provide stable and accessible financial pathways becomes especially important.⁵⁰

Institutions engaged in initiatives such as the UN’s Finance Against Slavery and Trafficking initiative, which mobilizes public and private financial actors to address the systemic vulnerabilities that reinforce slavery, increasingly view anti-trafficking efforts not as stand-alone compliance exercises, but as part of broader human-rights and sustainability strategies.⁵¹Aligning financial inclusion with ESG and the UN’s sustainable development goals objectives allows capital to be directed toward models that support long-term social and economic resilience, rather than short-term risk transfer.⁵²

Integrated financial empowerment and reintegration

Economic empowerment is not a single intervention, but a long-term process that begins when a survivor exits exploitation and continues through recovery.⁵³ Access to stable financial services, financial literacy and employment opportunities are all necessary components.⁵⁴ Programs that focus only on immediate relief, without addressing longer-term economic independence, often leave survivors exposed to renewed exploitation.⁵⁵

Here, the private sector plays a critical role. Beyond banking access, survivor-inclusive hiring and entrepreneurship initiatives help ensure access to fair wages and asset-building opportunities.⁵⁶ When survivors can achieve sustained financial stability, the risk of re-trafficking declines—breaking a cycle that imposes significant social and economic costs.⁵⁷

Conclusion and recommendations

In order to achieve this, FIs should:

Shift the lens from narrow compliance outputs toward customer protection and long-term economic resilience.
Use technology cautiously and purposefully, pairing analytics with governance, privacy and human judgment.
Design inclusive financial products that reduce dependence on informal and exploitative lending.
Treat lived experience as insight, not anecdote, in risk assessment and governance.

Shruti Katiyar, lawyer and researcher (Financial Crime Compliance), Independent, MA, USA, Shrutikatiyar27@gmail.com,