The Modern Slavery Act and CIFAS markers

The Modern Slavery Act 2015 provides statutory defences for people who were coerced or trafficked into committing offences. This is directly relevant to CIFAS marker cases where the account holder was exploited, pressured, or controlled by others.

When this defence applies

If you allowed your account to be used for suspicious transactions because you were coerced, threatened, or exploited by others, the Modern Slavery Act defence may apply. This is particularly relevant in money muling cases where young or vulnerable people are recruited by organised criminal groups.

• You were pressured or threatened into allowing account use
• You were recruited through deception about the nature of the activity
• You were in a controlling or exploitative relationship
• You were vulnerable due to age, mental health, or circumstances

How this supports your complaint

If coercion or exploitation was a factor, the complaint should raise this explicitly. The institution is required to consider vulnerability factors under both FCA rules and CIFAS filing standards. A marker placed against someone who was coerced may be disproportionate even if the underlying transactions were suspicious.