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Modern slavery rarely looks like the headlines suggest. More often, it’s a small, unremarkable transaction that never gets a second look. This month, we unpack what modern slavery covers and how transaction monitoring can help compliance teams detect it.
Why this matters now
Modern slavery is topical right now. New Zealand’s Modern Slavery Bill is in the select committee phase, while Australia has had dedicated legislation for several years. But the proposed New Zealand bill is largely about identifying modern slavery in supply chains, not about new transaction monitoring requirements.
That doesn’t take transaction monitoring off the hook. Modern slavery is already a predicate offence under existing AML laws, so the obligation to detect it is already there — the bill simply raises the profile of the issue, making it harder for institutions to justify not looking for it.
What we mean by modern slavery
Modern slavery isn’t a single crime — it’s an umbrella term covering human trafficking, forced labour, debt bondage, enforced prostitution and other forms of sexual exploitation, affecting adults and children alike. The common thread: people exploited and controlled for someone else’s gain, often unable to extricate themselves from their situation.
The scale in Australia and New Zealand
Australia and New Zealand have among the lowest rates of modern slavery in the world — but it does happen here, and the true numbers are almost certainly higher than reported. The best available estimates come from the Walk Free Global Slavery Index, which puts the number affected at 41,000 in Australia and 8,000 in New Zealand.
Debt bondage in practice
One recent case involved Moeaia Tuai, a Samoan national sentenced to 16 years in New Zealand for numerous charges relating to slavery, rape and indecent assault of Samoans moving to New Zealand.
The pattern is worth knowing: a facilitator arranges travel and a work visa for someone moving from a less well-off country, plus a loan to be repaid from their New Zealand wages. On arrival, the facilitator takes their passport, puts them to work for low wages, and charges high rent and interest on the loan. Unable to pay it off and often undocumented or threatened, the victim is stuck. In the Tuai case, Immigration New Zealand notes that victims did come forward, helping lead to his conviction.
Child exploitation and the Westpac lesson
In a separate Australian case, Willie Mareko was sentenced to 13 years for child sexual exploitation offences, after paying or coercing someone in the Philippines to facilitate the live-streamed sexual abuse of children, viewed by people in Australia and elsewhere.
This is the same pattern the financial sector failed to catch in the well-known Westpac case, where AUSTRAC found the bank had failed to adequately monitor transactions linked to child exploitation risks, resulting in a record penalty. There was no suggestion Westpac was involved in the crimes — the failure was in detection. But the case shifted attitudes across the industry, and institutions now find it far harder to justify not having these controls in place.
Spotting modern slavery in transaction monitoring
Transactions linked to modern slavery are usually small in value, so rules built to catch large-scale money laundering won’t pick them up. It pays to think of modern slavery as a pattern of financial behaviour rather than an isolated transaction — and to know what expected behaviour looks like for a customer before you can spot what’s unusual. Watch for:
- A controller receiving wages on behalf of several people, or several victims sharing the same address, phonenumberor email
- Wages transferred out almostimmediately, to a controller’s account or as cash
- A personal account with regular income from severalapparently unconnectedsources
- A business paying noticeably less in wages than expected for its size
- Frequent, small international payments with noapparentconnection between the customer and the receiving country
None of these are conclusive alone — a student flat sharing an address looks similar on paper. That’s why it matters to know your customer and apply a range of indicators together.
What this means for compliance professionals
Modern slavery is a broad subject covering very different types of crime, and each moves money differently. Understanding how each works, and what expected customer behaviour looks like, is what makes it possible to build transaction monitoring that actually catches it — and, as with any offence, understanding that risk is the starting point for putting the right measures in place.
This blog is based on the July 2026 episode of ThirdEye View, hosted by Jing Zhang, Business Development Manager, and Colin Dixon, CAMS-certified AML Solutions Specialist at ThirdEye. Colin has been with ThirdEye since its inception in 2012 and works closely with clients to help them maximise their platform capabilities.
