UK’s Largest Anti-slavery Prosecution ‘Operation Fort’ Provides Lessons for Business and a Framework to Analyse Compliance to the Modern Slavery Act, June 2020

Operation Fort is the UK’s largest anti-slavery prosecution, with eight members of a Polish criminal gang convicted of slavery, trafficking and money laundering offences on 5th July 2019.

The Independent Anti-Slavery Commissioner report highlights “Operation Fort is important not only because of the number of victims, but also the length of time the criminal gang was able to operate without disruption.” The gang’s activities were traced back to 2012 and continued four years after the Modern Slavery Act was passed in 2015.

The case involved 92 victims aged between 17- 60 who spoke minimal or no English, who were forced to work on farms, in factories, waste recycling plants, warehouses and live in dire conditions in the Birmingham area, although West Midlands PD estimated 400 Polish nationals may have been subject to this exploitation. Operation Fort was a complex case of modern slavery involving many criminal elements, including labour exploitation, human trafficking, fraud, deception, theft and physical abuse.

A key lesson from this case lends to employers and businesses being educated and proactive in spotting the signs of slavery and exploitation, and having effective measures in place to report concerns. There must be particular safeguards in place for temporary workers. Lessons to banks suggest they must proactively look for the signs of slavery within their branches, and also by analysing financial data. Furthermore, recruitment agencies can learn lessons from this case. They have an important role in identifying victims during interview or inductions, carrying out effective checks to detect anomalies, and an ongoing responsibility to check on worker welfare.

“Operation Fort sends a clear warning that no supply chain is safe from worker exploitation. Modern slavery and human trafficking gangs are highly adaptable; organisations must continually evolve to keep pace with entrepreneurial criminality.”

The Independent Anti-Slavery Commissioner provides a maturity framework for business’ compliance to the Modern Slavery Act:


  • Superficial modern slavery statement – policy but no action
  • Little or no mapping of supply chains
  • Minimal awareness of modern slavery amongst staff
  • Sole reliance on audits
  • No protocol for dealing with labour abuse 



  • Evidence of activity or improvement in modern slavery statement
  • Identifying areas of high-risk in the business and supply chains
  • Educating suppliers on policy and setting expectations
  • Regular staff training and awareness-raising exercises
  • Basic protocols for dealing with labour exploitation cases
  • Installing whistleblowing hotlines



  • External challenge or working groups informing strategy
  • Going beyond auditing – deep dives and unannounced visits
  • Cascading ethical standards throughout supply chains
  • In-depth training for staff in key roles, such as procurement
  • Commitment to worker engagement
  • Implementing the Employer Pays principle



  • Board leading on human rights strategy
  • Using data analytics to identify risk
  • Local, national, international intelligence gathering
  • Supporting suppliers to develop ethical competencies
  • Pioneering new ways of worker engagement, using technology
  • Factoring in the true cost of labour


Find the full Independent Anti-Slavery Commissioner report here.

Analysis of Global Revenue Produced by Human Trafficking

The International Labour Organisation estimates human trafficking derives USD 150.2 billion per year, making it one of the most profitable criminal ventures worldwide
The International Labour Organisation estimates human trafficking derives USD 150.2 billion per year, making it one of the most profitable criminal ventures worldwide

In parallel to the transatlantic slave trade as one of the most profitable business ventures in global history, modern slavery in the form of human trafficking follows suit. The International Labour Organisation estimates human trafficking derives USD 150.2 billion per year, making it still one of the most profitable criminal ventures worldwide. Furthermore, in an environment of globalisation it is rapidly increasing in numbers and in typologies. The rise in displacement and movement of people, whether in refuge from conflict zones, economic or environmental migration means there is increased vulnerability to trafficking, and in turn, more revenue produced by trafficking rings.

The Financial Action Task Force (FATF) and the Asia/Pacific Group on Money Laundering (APG) compiled a study Financial Flows From Human Trafficking to address the use of human trafficking as a source of money laundering and terrorist funding. Modern terror networks have indeed taken advantage of this profitable business venture, which creates a complex nexus between trafficking, money laundering and terror financing.

The report divides human trafficking into three categories in which revenue is produced through very unique money laundering systems. Firstly, trafficking for forced labour produces USD 51.2 billion per year, of which USD 43.40 billion is generated by hard labour exploitation, and USD 7.9 billion produced through domestic servitude. Second, trafficking for forced sexual exploitation produces USD 99 billion. Third, organ removal produces between USD 600 million – 1.2 billion, however the report refrains from providing a defined figure because the crime is rarely done in isolation, and therefore overlaps with other crimes which clouds the figures.

The aim of the FATF report is to provide “tangible indicators and best practices for national authorities to improve their effectiveness in combatting money laundering and terrorist financing from human trafficking”. In order to understand these systems appropriately, they provide a set of ‘money laundering indicators’ to be adopted by specialists and authorities working in the human trafficking sector,  to create a systematic form of recording and analysing financial flows from trafficking. The report finds major issues that international actors have in disrupting the nexus between human trafficking, money laundering and terror financing, and outlines resolutions including the need to:

On analysis, the conclusions of this report put significant weight on the need for cooperation between international, state and regional authorities to work together in combatting financial flows from human trafficking. However, there are many challenges and complexities including the corruption of state actors that contribute to the global trafficking systems and obscure the financial figures recorded, including which revenue streams are being used for terror funding. The international institutions such as FATF need to work closely with governments to systematically identify and analyse this. By nature of the black market, accurate figures are impossible to find which inhibits the capacity of national authorities, financial institutions, NGOs and actors to prioritise responses to human trafficking in its various forms. Yet as we further understand the finances of the crime, we are able to respond with effective measures of prevention and resolution.

For the full FAFT report, Financial Flows From Human Trafficking read here.