Maha Khan: Find the Influencer and Change Will Happen

ACAMS Today sat down with Maha Khan, Financial Sector lead with the Finance Against Slavery and Trafficking (FAST) initiative, a project based at United Nations University Centre for Policy Research (UNU-CPR), during the ACAMS 2023 Hollywood Assembly, to discuss the newly updated Fighting Modern Slavery and Human Trafficking (FMS and HT) social impact certificate and its importance.

Hailing from Pakistan, Khan has over 15 years-experience spearheading and managing multimillion-dollar research and strategic operations programs in 15 countries across Asia and Africa, focusing on inclusive finance and technology. Prior to joining UNU-CPR, Khan led the Center for Financial Inclusion (CFI) at Accion’s fintech data initiative, that bridges the information gap between financial service providers, investors and donors. Khan is a firm believer in the meaningful use of technology and finance to help produce multiple outcomes for low-income populations.

ACAMS Today (AT): Thank you for taking the time to speak with us today. You just finished a session at the ACAMS Hollywood Assembly discussing the importance of HT awareness and the newly updated FMS and HT certificate. What are the new updates to the FMS and HT social impact certificate?

Maha Khan (MK): The updated certificate is more practical and provides examples demonstrating how some banks are already using indicators, methodologies, and simplified due diligence measures to identify, mitigate risks, and look at preventive measures for modern slavery.

The certificate also includes new research conducted by FAST which suggests that financial exclusion is a risk multiplier for modern slavery, as well as the work we have done to support  the Organization of Security and Cooperation in Europe (OSCE) to develop a range of process and behavioral indicators that banks can use in their transaction monitoring systems, which can identify the patterns of traffickers or the patterns of those being trafficked.

Moreover, we wanted to demonstrate to banks that they should work in partnership with others, such as survivor support organizations, law enforcement and nongovernmental organizations, and provide an updated risk management framework that financial institutions can employ to identify risks. These updates to the course are important because the world has changed since we released the first iteration of the certificate in 2020—with the devastating impacts of climate change, the COVID-19 pandemic, and rising social inequality, which have increased the number of people experiencing modern slavery. Finally, with FAST operating for three years, we have more data and research to share.

Our next step is to update the certificate in French and in Spanish to make it more global and accessible. We hope to accomplish this by the end of this year.

AT: What is the significance of the social impact certificate? Why is the social impact certificate important?

MK: The financial sector is crucial to identifying and addressing HT and modern slavery because of its unparalleled influence as it may own stakes in companies that may rely on forced labor. If the financial sector does not address the issue of human trafficking and modern slavery, then I do not think the issue can be solved holistically. Compliance professionals are at the forefront of addressing HT and modern slavery and there is a direct relationship between compliance officers identifying suspicious activity and taking the necessary actions to reduce the risk of crime and the exploitation of vulnerable groups.

Also, we need to manage risk versus avoiding risk. We are avoiding risk by not allowing people into the banking system and that increases the very crime we are trying to fight.

AT: Who should be taking the social impact certificate?

MK: Anyone in the financial sector can take the impact certificate, including decision-makers, anti-money laundering (AML) officers, compliance officers, environmental, social and governance (ESG) workers, and board members. AML professionals are encouraged to share the impact certificate with their networks. We have already had 20,000 people take the certificate since its inception in 2021.

AT: If I have taken the first version of the FMS and HT social impact certificate, would you recommend that I take version two?

MK: Modern slavery risks are constantly shifting and evolving—and so it’s important that financial sector professionals constantly refresh their knowledge. As already mentioned, the updated certificate provides new practical examples and reflects recent research that can help financial sector professionals enhance their preparedness and capacity to act. This is a continuous process. You must monitor your risks and get ahead of them. It is a cycle. Cycle is what we say in our risk management course; it is not a one-off exercise. You need to keep revisiting risk management frameworks. There are seven stages that have been identified in our course, and we have added one more step to the risk management framework outlined in the updated certificate.

AT: As the world moves toward a cashless society, how is this going to affect marginalized and vulnerable groups?

MK: Cash is still king. Even in the Global North, where we are becoming more of a cashless society, we still risk leaving the unbanked behind who remain vulnerable to experiencing modern slavery. This risk is even more acute in the Global South where the majority of the 1.4 billion people currently unbanked live.

As we move to a cashless society, we need to understand that we could be leaving out the elderly, rural populations, low-literate populations and women. Would someone who is marginalized or a survivor feel comfortable going to a bank? What we have heard from some trafficking survivors is “Why do I need a bank?” Unbanked populations can turn to lenders to take loans at egregious rates or to informal hawalas to send money. They do this by paying exorbitant fees to money remitters.

However, there has been progress we can build upon. Mobile money services in the Global South are helping unbanked populations gain access to financial services and FAST is interested in exploring how we can leverage technology—which is already being used by millions of people—to help low-literate and low-income people.

Financial literacy and financial access go hand in hand, and as we become cashless, we need to ask whether the alternatives we are providing to people meet their needs or simply making them more unbanked and more reliable on informal financial services?

AT: Why is the partnership between FAST and ACAMS important, specifically in creating the social impact certificate?

MK: The partnership between FAST and ACAMS works well because ACAMS’ members already have a buy-in in preventing HT and modern slavery. In addition, the ACAMS’ audience is already working in compliance. They are hungry to learn more, and compliance professionals are the ones who can make the decisions and who can take the required actions. ACAMS is so open to working with FAST on the social impact certificate because ACAMS understands the importance of this certificate. Understanding the huge role that the financial sector plays in identifying instances of trafficking, reporting and dismantling financial networks. This is where ACAMS plays an enormous role.

It is practitioners that will change the space. FAST is here as an educator but practitioners employ the tools. FAST finds the influencer, and in this case ACAMS is the influencer, and through that influencer change can happen.

AT: What suggestions do you have for anti-financial crime professionals looking to get more involved with social impact, specifically HT and modern slavery awareness, in their organizations?

MK: First, raise your own awareness and educate yourself on why the financial sector is so important to tackling modern slavery. Second, educate your senior management on why they should have policies on HT and modern slavery prevention. Once you understand the research, your value proposition, and the why, then you can convince your senior management to join the cause and start taking action. We outline this process in the social impact certificate course. It starts within your own organization. You can begin by asking the following questions: Is your organization open to addressing HT and modern slavery? Does your organization have the systems in place to address HT and modern slavery? Usually, your organization already has the systems in place, you only need to tailor the systems to HT and modern slavery prevention. This all starts with awareness in your organization through the introduction of the educational piece of HT and modern slavery awareness and then the practical piece, which is the implementation of an anti-human trafficking and modern slavery prevention program by your organization. We have developed a self-assessment tool for financial institutions that can help them assess if their existing compliance framework and governance address and mitigate MS/HT risks and help prevent and detect this crime.

Interviewed by: Karla Monterrosa-Yancey, CAMS, editor-in-chief, ACAMS, USA,

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