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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.
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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
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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.
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How to raise this in your complaint
If coercion, exploitation, or trafficking was a factor in your situation, this should be raised explicitly in your complaint. The institution is required to consider vulnerability factors under FCA vulnerability guidance and under CIFAS filing standards. Failing to do so is a procedural breach that supports the challenge.
Supporting evidence for a Modern Slavery Act argument includes records of the relationship or contact through which you were recruited, communications showing the instructions you were given, any contemporaneous evidence of pressure or control, and if available a police or referral authority report confirming your status as a potential victim.