If modern slavery and human trafficking occupy grim corners of the dark economy, they are also more connected to everyday life than many realise. More than 50 million people are estimated to live in slavery worldwide and UK consultancy VinciWorks says that ‘a great proportion work in the supply chains of large multinational companies’.
The EU and countries worldwide are bringing in new regulations and disclosure requirements to strengthen action globally, seeking to ensure that imports for the domestic market are not the products of modern slavery in the overseas supply chain.
Closer to home, research by the UK’s National Crime Agency has identified modern slavery in areas like agriculture, beauty services, construction, the food industry and car-wash services.
‘Our aim is to encourage people to stop, think and act when something looks or feels wrong’
In a 2023 report, Walk Free, an organisation dedicated to eliminating modern slavery, found that 5,000 people in Ireland have experienced forced labour. While ranking the country way down the global scale of offenders (153rd) and scoring the government’s response a respectable 63 out of 100, it also pointed to available data likely underreporting the reality.
Spot the signs
Indications that someone may be a victim of human trafficking include:
- they have no access to personal legal documents or bank accounts
- they work unusually long hours
- they live in unsafe or overcrowded housing
- they are always accompanied by someone else
- they are under the watch of an adult who seems protective or controlling
- they show signs of physical or psychological abuse such as anxiety, bruising or untreated medical conditions
- they are fearful and distrustful of authorities, even though they need help
- they have little to no contact with family or loved ones.
Source: Banking & Payments Federation Ireland
At the same time a report by the Irish Human Rights and Equality Commission identified trafficking for sexual exploitation as the most common form of exploitation in Ireland (55%), followed by labour exploitation (38%) and criminal activities (6%). The report calls for a ‘mandatory requirement for human rights due diligence for all businesses, which includes a focus on preventing and combating domestic, sexual and gender-based violence, including human trafficking’.
Evolving response
Ireland’s legal response is undoubtedly evolving, notably in the introduction of the 2024 Criminal Law (Sexual Offences and Human Trafficking) Act. Minister for Justice Jim O’Callaghan says the government’s recently launched Third National Action Plan to Prevent and Combat Human Trafficking is further evidence it is ‘taking decisive action on this issue to pursue traffickers and to identify potential victims’. Critics, however, can point to shortfalls; there is no direct equivalent to the UK’s Modern Slavery Act here and no specific statutory duty for professionals such as accountants to report trafficking suspicions.
‘The hidden nature of this crime and resource constraints remain significant challenges’
Recognising the importance of disrupting the financial infrastructure that enables human trafficking, the Harcourt Programme, an initiative bringing together EY, Banking & Payments Federation Ireland, An Garda Síochána and the human rights organisation STOP THE TRAFFIK, was set up in 2023.
The programme is acknowledgement of ‘the harsh reality that trafficking is happening right now here in Ireland, in both urban and rural communities across the country,’ says Jenny Pattwell, partner, EY Ireland Financial Services. The programme’s explicit goal is to ‘disrupt trafficking-linked financial flows through improved monitoring, typology sharing, high-quality suspicious activity reports (SARs), and collaboration with An Garda Síochána and NGOs,’ she explains.
Tools in the armoury
November 2025 saw the launch of Project Aware, a national campaign designed to alert the public to signs of exploitation and encourage victims to seek help. (See ‘Spot the signs’.)
Pattwell says that financial services providers are in focus in the information campaign, noting that anti-money laundering (AML) rules on the reporting of suspicious transactions provide a significant tool in their armoury: ‘By shining a light on the connections between everyday financial transactions and human trafficking, our aim is to encourage people to stop, think and act when something looks or feels wrong,’ she says.
Accounting red flags
Accountants should be aware of the following activities that may point towards human trafficking:
- inconsistent and unexplained cashflows, frequent small deposits or structured payments
- transactions to multiple unrelated beneficiaries
- unusual use of intermediaries or shell entities
- clients who are reluctant to provide documentation or appear to be under observable control
- mismatched business activity versus financial footprint
- cash-intensive operations with limited invoices
- rapid movement of funds between accounts.
Source: EY
While much centres on the observation of unusual financial patterns, an element of interpersonal judgment and a willingness to act are also significant. Patwell recommends the ‘pairing of financial red flags with behavioural cues, such as lack of autonomy and coached responses. Escalating concerns via existing AML/SAR channels is crucial.’
‘It is hard to count something if we do not know what we are counting’
Public and institutional response to the ongoing work of the Harcourt Programme leads Patwell to be ‘cautiously optimistic about 2026’ in terms of improved detection rates. ‘Cross-sector collaboration has deepened, awareness is increasing and financial services institutions are recognising their role,’ she says. Nevertheless, ‘The hidden nature of this crime and resource constraints remain significant challenges.’
Clarity needed
If the government’s current legislative direction is positive, calls for clarity are also growing. Writing for RTE News in 2025, James Windle, lecturer in criminology at University College Cork, noted that ‘available data on all forms of exploitation in Ireland is currently poor’, while a lack of definition around the issues can hamper action being taken.
Windle points to trafficking for criminal activity, which, while legislated for, ‘remains one of the least researched or understood forms of human trafficking’. The government’s delay in creating ‘a standardised and unambiguous definition of trafficking for criminal activities’ is a concern, he says. Accountants will concur with the view that ‘it is hard to count something if we do not know what we are counting’.
More information
This AB article explains the changes in financial reporting that mean Accountants can help smash modern slavery
Read a report on The Role of Financial Investigation in Combatting Modern Slavery
