The Vulnerable: Targets and Tools of Financial Crime

What FinTechs can do to fight financial crime & exclusion

Lured by the opportunity for employment, housing and travel, a Latvian Organised Crime Group facilitated the movement of people from Latvia to the UK. For those hoping to create a better life for their families, these were immediately crushed as once they arrived in the UK, they were told they were "in debt" to the gang. The gang forced the victims to open bank accounts in their own names, then hand over their bank accounts and bank cards to the group before being sent to work in various locations across the UK. The gang retained control over their earnings and any refusal to cooperate was met with threats of violence and assault (1). Unfortunately this is not an isolated incident with a global figure of 40.3 million vulnerable individuals estimated to be victims of modern slavery (2).

In the UK, serious and organised crime is the most deadly national security threat (3). It affects more UK citizens, more than any other national security threat and leads to more deaths in the UK each year than all other national security threats combined. Organised crime groups sexually exploit children and ruthlessly target the most vulnerable, ruining lives and blighting communities. The predicate offences that drive financial crime often generate illicit funds off the back of the hopes and fears of desperate individuals. Crimes like the one highlighted cost us in the UK at least £37 billion each year (4). Criminals are able to reap the benefits of their crimes and to fund lavish lifestyles while their victims are left to suffer the consequences.

The rise of new technology and financial innovation, often leads criminals to seek creative ways to exploit evolving financial developments to their advantage. This makes FinTechs and their customers a particular focus for the criminals, a problem which is heightened further when one considers that two of the largest under-banked groups, the young and migrant communities, are at a higher risk of vulnerability.

What can we do?

One of the simplest ways to identify and understand a customers potential vulnerability is through ‘face-to-face’ interaction. This is much harder for FinTechs to do; most interactions involve online onboarding, with little dialogue apart from email and instant messaging between the client and a customer service representative. Indeed, much of this kind of interaction is increasingly automated, which is part of the inherent attraction of the sector.

The best time for FinTechs to identify and protect a vulnerable individual is during the onboarding process, through Identification and Verification (IDV). One of the most concerning situations we have come across through our involvement with the FinTech FinCrime Exchange (FFE) have been reports of FinTech client applicants providing IDV selfies or undergoing an onboarding interview online who appear to be in the presence or possibly even under the control of another individual. Instances such as these need to be taken very seriously, and simply rejecting the new customer is not enough. Where suspicious activity of any kind is in evidence, FinTechs have a clear moral responsibility to report it (5).

FINTRAIL believes that all companies, should have the opportunity to thrive, free from the threat of financial crime and in doing so reduces the opportunities for exploitation of the most vulnerable.

If you would like to discuss the issues in this post, or wider anti-financial crime topics in an increasingly digital FinTech world, please feel free to get in touch with one of our team or at



(2) International Labour Organization and Walk Free Foundation - Global Estimates of Modern Slavery - 2017

(3) Home Office - Serious and Organised Crime Strategy- November 2018

(4) Home Office - Serious and Organised Crime Strategy- November 2018

(5) NCA - Guidance on reporting routes relating to vulnerable persons - November 2016