Modern slavery and human trafficking generate an estimated US$236 billion in illicit profits each year. Much of that money moves through formal financial systems. This means finance is not merely adjacent to exploitation. It is one of the few institutional systems positioned to detect, disrupt and deter it.

At the same time, the financial system shapes the daily realities of those most vulnerable to exploitation. Access to a bank account can determine whether a survivor can receive wages safely, access support services or begin rebuilding financial independence. Financial exclusion, by contrast, can reinforce dependence on informal channels and cash-based transactions, and make abuse harder to trace.

Financial systems include mechanisms to detect suspicious activity and safeguard financial integrity. Yet when compliance frameworks are not calibrated to real-world risk, they can also exclude the people most vulnerable to exploitation. Survivors who cannot open a bank account leave no transaction trail. Migrants without recognized identity documents may struggle to access regulated institutions. People in precarious situations often remain financially invisible, increasing their exposure to abuse and limiting avenues for protection or recovery.

Across many jurisdictions, anti-money laundering and counter-financing of terrorism (AML/CFT) frameworks must navigate this balance between financial integrity and access. Individuals with limited documentation, thin financial histories or non-standard income patterns can face barriers even where strong regulatory systems are in place. Robust standards are essential to safeguarding financial systems. The challenge lies in implementing them in ways that detect traffickers without unintentionally deepening exclusion.

This balance is particularly relevant in the Western Balkans, where migration flows, informal labor markets and cross-border financial activity intersect. In early February 2026, UNDP’s Finance Against Slavery and Trafficking (FAST) Initiative, together with the UNDP Bosnia and Herzegovina Country Office and EU4FAST Western Balkans, convened two roundtables in Sarajevo to examine how Bosnia and Herzegovina can strengthen its financial response to trafficking while expanding safe access to financial services. Financial intelligence officials, banking regulators, law enforcement authorities, prosecutors, financial institutions and civil society representatives worked through practical solutions grounded in the country’s institutional context.

Reducing high- and medium‑threat illicit financial flows has become increasingly urgent for Bosnia and Herzegovina, particularly following the Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism’s latest evaluation and the country’s placement under enhanced monitoring by the Financial Action Task Force (FATF). While Bosnia and Herzegovina has strengthened elements of its AML/CFT framework in recent years, important gaps remain — notably in complex money laundering investigations, asset confiscation, beneficial ownership transparency and targeted financial sanctions. 

These weaknesses allow illicit proceeds linked to corruption, tax offences, and fraud to circulate with limited disruption. Bolstering responses to human trafficking and migrant trafficking risks is therefore not only a matter of crime prevention, but also of protecting financial stability and safeguarding economic credibility. Avoiding potential FATF greylisting is critical, as it would directly affect investment flows, banking relationships and market confidence.

One focus was detection. Trafficking-related financial activity can display identifiable patterns, including cash-intensive flows, multiple linked payees, irregular income structures and rapid account turnover. These signals are not always easy to distinguish from other irregular activity. Without trafficking-specific typologies and indicators, suspicious patterns can be overlooked or misclassified.

Strengthening structured information-sharing between financial intelligence units, banks, law enforcement and prosecutors can significantly improve detection within existing regulatory frameworks. Participants discussed formalized public–private cooperation, shared case-based learning and joint analytical exercises to build capacity to follow financial flows in trafficking investigations. In many instances, improving coordination and technical guidance can deliver measurable gains without requiring new legislation.

The Sarajevo discussions also drew on international experience, including FATF guidance on financial inclusion and recommendations on the type of financial information that can identify human trafficking and related financial risk. They also reflected UNDP's engagement with the European Financial Investigations Public-Private Partnerships platform and the Council of Europe. Translating those frameworks into nationally applicable practice was a central element of the dialogue in Bosnia and Herzegovina. 

Access was the second core priority. Simplified due diligence, including limited-function accounts, digital onboarding and proportionate identity verification, is often viewed solely through a risk lens. The roundtables examined how these measures, when properly designed, can reinforce financial integrity rather than undermine it.

When survivors, undocumented migrants and people in precarious situations gain access to appropriately structured, low-risk financial products, their transactions become visible within the regulated system. Visibility generates a record. That record supports monitoring, preserves evidence and helps identify patterns of exploitation that remain hidden in cash-based environments. Investigators cannot follow financial flows that leave no trace.

International standards already allow for proportionate, risk-based approaches. The task is ensuring consistent implementation across banks, microfinance institutions and regulators, and embedding trafficking risk into routine compliance practice. Financial inclusion and financial integrity should not be treated as competing objectives. When properly aligned, they strengthen each other.

The discussions in Sarajevo aim to inform concrete outputs, including a national typology report for Bosnia and Herzegovina and practical guidance on inclusion-focused compliance approaches. These tools aim to strengthen institutional coordination, enhance detection capacity and improve safe access to financial services for those at risk. They also contribute to a broader effort to align financial sector governance with human rights considerations and responsible business practices.

Modern slavery affects an estimated 50 million people globally. Financial systems alone cannot eliminate exploitation. However, their design choices matter. Decisions about access, documentation and risk assessment shape whether financial architecture acts as a barrier to traffickers or leaves gaps that traffickers can exploit.

Through the FAST Initiative, UNDP works with governments, regulators and financial institutions across regions to strengthen financial systems so they can better detect and prevent exploitation while remaining accessible to those most vulnerable. This approach does not dilute standards. It applies them proportionately so that financial integrity and financial inclusion reinforce one another.

Bosnia and Herzegovina’s engagement demonstrates how national dialogue can translate global standards into practical reform. When integrity and access are aligned, financial systems are better equipped to identify risk and protect those most vulnerable. In the fight against modern slavery, designing finance to include those at risk is not a secondary consideration. It is central to prevention.