ACAMS Today had the opportunity to speak with Jennifer Fiddian-Green, CAMS, partner with Grant Thornton (GT) LLP, about the current human trafficking landscape and her work with Project Protect, an initiative launched to disrupt human trafficking by breaking financial chains.
Fiddian-Green is GT’s national practice leader for forensics and anti-money laundering (AML) services and the financial services sector across Canada. In addition, she is a qualified investigation and forensic accountant and an AML specialist.
Fiddian-Green’s practice regularly provides AML compliance program reviews for the financial sector and the practice provides remediation, consulting, risk assessment facilitation, internal audit co-sourcing and training to reporting entities, sectors, industry associations and regulators within and outside of Canada. Fiddian-Green has 20 years of AML/counter-terrorist financing-experience in Canada and now works with entities that have multijurisdictional requirements across the globe.
Today, Fiddian-Green works with clients to understand fraud and money laundering risks as well as the evolving regulatory landscape to implement strategies to prevent and detect fraud, mitigate risk and meet regulation requirements. Her current focus includes working with entities in the emerging cryptocurrency space.
ACAMS Today: How has your background and experience helped you in the fight against human trafficking?
Jennifer Fiddian-Green: Throughout my career, I have had the opportunity to focus significantly on projects involving forensic accounting of money flows related to both criminal and civil allegations and the evidential burdens of proof required. I have an in-depth understanding of AML compliance regime requirements and frustrations of regulated entities.
The fight against human trafficking has been an opportunity like no other. It has helped me connect the dots between all parties involved and to clarify the reasons why we all need to do the work of risk identification, detection and reporting. Over the past 20 years, there has been so much talk and training on illegal profits or proceeds of crime from sources that are often quite far removed from the individuals and entities tasked with meeting detailed and burdensome requirements. As a result, they become more conceptual than real when you are trying to train or help others to understand. I have often been asked or challenged to defend the whole existence of AML and to prove in a very detailed way why a small bank, credit union or securities dealer, for example, has anything to do with AML.
The fight against human trafficking has made this communication and the very real human connection much more impactful. Over the past 18 months, when I have told the story of a victim, trafficker, use of the financial system, money flows and shared local newspaper headlines, there is a level of understanding and acceptance like none I have experienced before. The response is beyond compliance—it is individual people deciding that they won’t let this happen on their watch.
AT: Can you tell us about your involvement and work with Project Protect?
JFG: Once my GT team and I became aware of the issues and Project Protect, we put our heads together to think about what we could do. Due to the significant involvement of our largest Canadian banks, the Financial Transactions and Reports Analysis Center (FINTRAC) and the government, I was not quite sure at first what we could do. It then became clear that we could be a conduit for sharing the message and connecting other groups. In the fall of 2016, we researched and pulled together an awareness brochure1 to help explain the issues and what people and entities could do to respond. The initial piece focused on the financial sector; we then followed this up with a second publication based on further research that our team conducted. We had important input and feedback from a number of members in law enforcement and Project Protect. The input received from human trafficking investigators was valuable and our team learned a lot as we wrote on the whiteboard what we understood collectively about the money flows from the perspective of each of the different roles in the crime—including victim, trafficker, financial service provider, ad agency, etc. There is more to do!
Recently, I had the chance to be a part of some developing conversations with those in the hotel industry in Toronto, Ontario. These groups want to do more and no longer allow this activity on their premises. We have distributed the awareness brochures2 primarily through a number of educational/training sessions that we organized and hosted with different parts of the financial services community, including credit unions, money services businesses and specific banks. Some of these sessions ran locally and involved members of local law enforcement (this is really impactful) and some ran as national webinars working with industry association groups.
A big shoutout to FINTRAC for their participation in these events and also to the members of law enforcement and Project Protect who stepped up to help. We also ran a national internal session for GT staff, connecting the dots with Project Protect (Peter Warrack was one of our guest speakers and we also had a guest from the Canadian Centre to End Human Trafficking). Over this last holiday season, our team at GT decided to donate funds we would normally use for client gifts to organizations supporting the cause and victims of human trafficking, including Timea’s Cause.
On January 31, 2018, we will be a part of a learning event organized by people in the AML community that simply have been/are inspired by Project Protect. There is a cost to attend the event and all proceeds will be donated.
There are a couple of things that have made this very real for me:
- It helps me connect with people in a real way. This is very important to me. I am at a point in my life and career where I am able to influence and connect with people and make a difference.
- Many people on our team here at GT they feel as I do; we have always cared about our work and are proud of it. This in some ways takes it to a whole new level.
- Many of my clients and professional contacts have responded in a positive way and want to help.
AT: In what way does Project Protect help validate human trafficking victim stories?
JFG: It connects the dots for people. A victim’s story is no longer isolated—all of us in the business now know or have the ability to know. Some would say we have the human obligation to know that the victim’s story is connected to work that we might have touched. We have to take notice and do our part to end this horrific crime.
AT: How has Project Protect helped in leading to arrests, charges or convictions?
JFG: I have been in the room during awareness sessions when the dots connect for people inside financial services and they leave knowing what they want to do to support a suspicious transaction report to the regulator; the regulator then receives the report, completes the analysis and pulls together a report for law enforcement. I have had firsthand accounts from law enforcement members regarding how detailed reporting is helping them with their cases. Initially the reports were targeted to help more ongoing cases already known to law enforcement. Now I understand that the reports are opening more cases for law enforcement. This evidences the proactive effort of Project Protect.
AT: What does the current human trafficking landscape look like for regulators, law enforcement and financial institutions?
JFG: We have to keep at this. We need to use this collective effort and experience to improve the broader AML regime and effort. There has been significant learning, time and cost expended over the last 20 years by so many different parties and individuals in AML. In my experience, if we can start to work together and collaborate in the same ways as demonstrated through Project Protect we will achieve much more. I think for me this really speaks to the need for us to work together as a community and not in individual silos.
- “Preventing Human Trafficking: Global Issue, Calling Canada,” Grant Thornton, 2016, http://insights.grantthornton.ca/i/735894-human-trafficking-2016/0?m4=
- “How the Financial Services Sector Can Help Tackle Human Trafficking,” Grant Thornton, May 9, 2017, https://www.grantthornton.global/en/insights/articles/financial-services-helping-tackle-human-trafficking/