U.S. Dep't of State, 2024 Trafficking in Persons Report: United Kingdom

UNITED KINGDOM (Tier 1) The Government of the United Kingdom (UK) fully meets the minimum standards for the elimination of trafficking. The government continued to demonstrate serious and sustained efforts during the reporting period; therefore the UK remained on Tier 1. These efforts included convicting more traffickers and referring a significant number of potential trafficking victims to the NRM. Additionally, the UK government continued to devolve the NRM decision process for child victims to the local authorities to ensure better decision making and more timely service delivery to child victims and recruited new decision-making staff to attempt to reduce victims’ wait times for decisions.

The UK government appointed a new Independent Anti-Slavery Commissioner (IASC) and continued to fund research and targeted prevention activities globally, including efforts to incorporate survivor inputs into programming. Although the government meets the minimum standards, the UK government implemented a 2022 law, which brought negative impacts on victim identification, including the referral process, and hindered victim protection measures. As a result of its implementation, UK government data from 2023 showed authorities recognized significantly fewer potential or confirmed victims at both the “reasonable grounds” and “conclusive grounds” stages. Wait times for determining potential victim status increased, which delayed potential victims from accessing support services.

Victims continued to face years-long wait times for final decisions, though slightly reduced from the previous reporting period. Furthermore, there appeared to be inconsistencies in determinations from two distinct decision-making authorities responsible for making victim status determinations for foreign national and UK national potential victims. In 2023, the UK government removed 331 potential victims from the NRM, which removed their access to services. Observers reported the government may have inappropriately penalized potential victims solely for unlawful acts they committed as a direct result of being trafficked.

Protections for unaccompanied minor children, some of whom may be victims of trafficking, and long-term care and reintegration support for victims were inadequate. For the second consecutive year, the UK government did not publish its Modern Slavery Strategy nor its annual report on anti-trafficking efforts. The UK government did not report sentencing data of convicted traffickers; thus, it was unclear if judges consistently treated trafficking as a serious crime. PRIORITIZED RECOMMENDATIONS: Implement reforms to the NRM, to facilitate timely determination of victim status that do not discourage victims to come forward, particularly undocumented migrants. * Ensure all potential victims, including individuals subject to immigration control, are consistently screened for trafficking indicators, and referred to services. * Ensure consistency across NRM decision making for foreign national victims and UK national victims and provide all victims access the same quality of decisions and services. * Ensure victims are not inappropriately penalized solely for unlawful acts, including immigration violations, committed as a direct result of being trafficked. * Train all first responders on the NRM process to increase the proactive identification of trafficking victims among vulnerable populations, including foreign migrants, asylum-seekers, individuals in immigration detention centers, and individuals exploited in forced criminality, and refer all victims to protection services. * Expand the Independent Child Trafficking Guardians (ICTG) program nationwide and train more social workers and care providers to better safeguard child victims. * Expand long-term care and reintegration support and monitor and assess outcomes of post-NRM support. * Vigorously investigate and prosecute trafficking crimes across the UK, particularly in Scotland and Northern Ireland, and seek adequate penalties for convicted traffickers, which should involve significant prison terms. * Increase victim identification training for and the number of first responder organizations to make referrals to the NRM. * Increase proactive victim identification of individuals whose exploitation occurs in Northern Ireland. * Develop and publish a new Modern Slavery Strategy, with updates to the 2014 strategy, and finalize and resource the three-year strategy in Northern Ireland, with robust inputs from civil society and anti-trafficking experts. * Clarify the process for individuals to appeal negative “reasonable grounds” decisions and train officials and first responder organizations on the process. * Improve victims’ ability to access court-ordered restitution in criminal cases and compensation through civil proceedings. * Ensure the statutory definition of trafficking under the Modern Slavery Act (MSA) and similar provisions in Northern Ireland do not require movement of the victim as an element of the crime. * Guarantee a trafficking-specific long-term alternative for foreign victims, including children, at risk if returned to their home country. * Ensure all victims have access to timely legal aid. * Strengthen measures on transparency in supply chains, including holding companies to account for noncompliance. * Strengthen and monitor anti-trafficking efforts in the British Overseas Territories and in Northern Ireland. * Increase survivor engagement, including by establishing accessible mechanisms for receiving and providing compensation for survivor input when forming policies, programs, and trainings.

PROSECUTION

The government slightly increased prosecution efforts. The 2015 MSA, applicable to England and Wales, and similar statutes in Scotland and Northern Ireland, criminalized sex trafficking and labor trafficking and prescribed penalties of up to life imprisonment, which were sufficiently stringent and, with regard to sex trafficking, commensurate with those prescribed for other grave crimes, such as rape. Inconsistent with international law, the laws in England, Wales, and Northern Ireland required the element of movement of a victim in the definition of “trafficking.” However, these jurisdictions criminalized “slavery and servitude, and forced or compulsory labour” in other provisions of their law, which could be utilized to prosecute trafficking crimes that did not involve victim movement. Scotland, by contrast, did not require victim movement in the definition of trafficking.

As of December 2023, the government reported there were at least 3,360 active law enforcement investigations of new and ongoing suspected trafficking crimes, compared with 3,555 in December 2022. The government initiated 2,269 investigations of trafficking crimes in 2023; the government did not report the number of investigations initiated in 2022. The Crown Prosecution Service (CPS) prosecuted 410 defendants on trafficking charges, compared with 405 prosecutions in 2022 and 466 in 2021. Courts convicted 311 traffickers in 2023, compared with 282 convictions in 2022 and 332 in 2021.

CPS data did not differentiate between sex and labor trafficking, nor did the government provide data on the range of sentences of convicted traffickers or percentage of convicted traffickers serving prison time. The Crown Courts continued to experience a backlog of 67,573 cases – including trafficking cases – in England and Wales as of December 2023. In 2023, the Home Affairs Committee, a House of Commons parliamentary body tasked with assessing the work of the Home Office, released a report expressing concern over the inconsistency between the high number of potential victims referred to the NRM and the low number of prosecutions and convictions of traffickers; the report urged CPS to increase the prosecution and conviction of traffickers and urgently accelerate efforts to clear the backlog of human trafficking cases. The UK government noted not all potential victims’ cases met the threshold to initiate a trafficking investigation, and cases where the exploitation occurred outside the UK remained complicated to investigate.

The UK government did not report any investigations, prosecutions, or convictions of government employees complicit in trafficking crimes. Scottish authorities reported 171 trafficking-related investigations initiated in 2023; Scottish authorities did not report the number of investigations initiated in 2022. Scottish authorities referred 72 cases to the Crown Office for suspected trafficking under the Scotland Human Trafficking and Exploitation Act (2015) in 2023. Scottish authorities previously reported prosecuting 13 suspected traffickers, with four traffickers convicted between April 2022 and September 2022.

Scottish authorities did not report convictions related to trafficking cases for the corresponding period in 2023, compared with four traffickers from April through September 2022. Police Scotland maintained a specialized anti-trafficking unit focused on coordination, investigation, and intelligence; this unit also worked with law enforcement agencies across Europe to investigate trafficking cases, including on financial investigations. In 2023, authorities in Northern Ireland reported 129 new trafficking-related investigations, compared with none reported in 2022 and 370 in 2021. Northern Irish authorities prosecuted four suspected traffickers (four in 2022; six in 2021) and convicted one trafficker (three in 2022; one in 2021).

Observers previously noted the greatest impediment to the timely prosecution of alleged traffickers in Northern Ireland remained the inherent delays in the legal system, often taking two or more years from the time of initial arrest to conviction. The Home Office continued funding the Modern Slavery and Organized Immigration Crime Unit with £1.3 million ($1.65 million) to support the police in combating trafficking and organized immigration crime. The government provided a variety of training to police, immigration and border officials, government officials, front-line practitioners, and first responders, including on victim identification and investigative techniques. The National Crime Agency (NCA) continued a project to increase law enforcement cooperation and investigations, participated in an EU program to monitor trafficking trends, and updated its strategic action plan on human trafficking.

In coordination with the interagency and civil society, Police Scotland, including its national human trafficking unit, trained front-line and specialist law enforcement officers and investigators on various anti-trafficking issues and facilitated trainings to partners and stakeholders. Scottish authorities provided an NRM Toolkit to support first responders and enable improved victim engagement and trauma-informed information gathering from victims. The Police Service of Northern Ireland reported some training for police officers on human trafficking; however, observers noted a need for systematic training for police on investigative techniques, including involving technology-facilitated trafficking; and victim identification, including for victims exploited in Northern Ireland and victims of forced criminality. Observers expressed concern the number of NRM referrals, especially of domestic trafficking victims, by police in Northern Ireland was low compared to the rest of the UK.

Observers reported training for criminal justice officials had improved but was still insufficient, particularly training on the non-punishment of victims and a trauma-informed approach. The UK participated in 14 Joint Investigation Teams (JIT) with EU Member States and EUROPOL. The UK cooperated with a range of partners bilaterally and multilaterally on law enforcement activities. In 2023, the UK government signed a Joint Action Plan on human trafficking with the Government of Romania and renewed an MOU on human trafficking with the Government of Vietnam.

Northern Irish authorities cooperated closely with other UK jurisdictions and Irish counterparts on law enforcement efforts across the island of Ireland, and participated in a JIT with Romanian authorities. Police Scotland participated in a JIT with Hungarian law enforcement to investigate sexual exploitation for prostitution, and two JIT requests are under consideration with Romanian authorities for a sex trafficking case. Scottish authorities successfully completed two extraditions and two warrant arrests in relation to human trafficking crimes. The UK government did not provide updates on a 2022 case where the Supreme Court granted the appeal in a 2019 ruling by the Employment Tribunal that diplomatic immunity did not protect against trafficking charges; the Court concluded that if the facts alleged by the complainant are proven, the foreign diplomat will not have immunity from civil jurisdiction in UK courts.

PROTECTION

The government decreased protection efforts. While the government referred a significant number of potential victims to the NRM, it implemented a law that negatively impacted victim identification and protection measures; additionally, it passed a law which experts and NGOs widely assessed would further expand such negative impacts. The percent of negative “reasonable grounds” decisions for potential victim status increased, as did wait times for such determinations; wait times for “conclusive grounds” decisions on official victim status remained excessive averaging 526 days. While victims continued to receive support while “conclusive grounds” decisions were pending, protection gaps existed especially for those pending now further delayed the time it took for authorities to make “reasonable grounds” decisions; gaps also remained for both foreign national and British victims, including those requiring long-term support.

The UK government’s NRM was the framework for identifying and providing care and support for victims. Designated first responders, such as police, border force, local authorities, and NGOs, referred potential victims into the NRM. In 2023, first responders referred 17,004 potential trafficking victims to the NRM nationwide, compared with 16,938 in 2022, and 12,727 in 2021. The Home Office maintained a detailed online database with disaggregated information, including source of referral, nationality, jurisdiction handling the referral, and type of trafficking.

Of the referred potential victims, 76 percent were male and 24 percent were female. Authorities identified 7,432 child potential victims, an increase from 7,019 in 2022; this result followed devolution of the NRM decision process to local authorities for child victims to ensure better decision making and more timely service delivery to child victims. Authorities identified 8,622 adult potential victims, compared with 8,854 from 2022. UK nationals (4,299) made up the majority of potential victims, followed by Albanian nationals (4,052), and Vietnamese nationals (911).

Labor trafficking, including forced criminality, was the most common form of exploitation. Authorities categorized 1,559 referrals as “county lines” cases, a form of forced criminality in which traffickers force victims, often young adults or children, to transport drugs (a decrease from 2,281 in 2022). The 2023 Home Affairs Committee report expressed concern over the increased number of child victims exploited in forced criminality. In Scotland, first responders referred 765 potential victims to the NRM, an increase from 621 in 2022 and 419 in 2021.

In Northern Ireland, officials referred 462 potential victims to the NRM, compared with 547 in 2022 and 363 in 2021. In Wales, first responders referred 559 potential victims to the NRM, compared with 536 in 2022 and 479 in 2021. The “reasonable grounds” threshold, established by the MSA and amended by the 2022 Nationality and Borders Act (NABA), and further amended in July 2023 following a legal challenge from UK courts, functioned as a gateway to support for potential trafficking victims. Once a potential victim was referred to the NRM, the Home Office’s Single Competent Authority (SCA) or Immigration Enforcement Competent Authority (IECA) made a “reasonable grounds” decision on whether the individual may be a trafficking victim.

A positive decision indicated authorities determined an individual was a potential trafficking victim, while a negative decision indicated authorities did not make this determination. The SCA handled NRM referrals for British nationals and ensured victims continued to receive support, and the IECA made “reasonable” and “conclusive grounds” decisions in cases involving adults subject to immigration control, including adults in deportation proceedings and individuals served a notice of intent of potential inadmissibility of an asylum claim. The “conclusive grounds” decision granted a potential victim official victim status. The government reported the SCA or IECA aimed to make a “reasonable grounds” decision within five working days.

If the SCA or IECA made a positive “reasonable grounds” decision, adult victims in England and Wales received support for at least 30 days or up to the point when a “conclusive grounds” decision was made, whichever was longer. In Scotland, unlike in England and Wales, NGOs reported potential victims could access services prior to a positive “reasonable grounds” decision; and potential victims received support for 90 days or until authorities made a “conclusive grounds” decision, whichever came first. In Northern Ireland, potential victims received support for a minimum of 45 days while authorities reviewed their cases. Across the UK, if authorities recognized an individual as a victim per the “conclusive grounds” determination, the victim was not guaranteed additional recovery periods or services, as of January 2023 under NABA, where, previously, victims received a minimum of 45 additional days of support.

NGOs and experts observed the quality or timeliness of protection services for victims decreased across the UK, and government legal officials noted the decreased timeliness of decisions. In 2023, the average “conclusive grounds” decision took 526 days, compared with 544 days in 2022. Of the 17,004 NRM referrals during 2023, 37 percent (6,222) were still awaiting “conclusive grounds” decisions at the end of the year, compared with 76 percent (12,907) in 2022. Although potential victims continued to receive services under the Modern Slavery Victim Care Contract (MSVCC) while waiting final decisions, the high volume of cases and length of a victim’s care affected the quality of care.

Both government and civil society reported the NRM and service provision remained under immense pressure due to the significant number of referrals, and backlogs, over recent years. The Home Office hired approximately 200 new staff and made 9,825 “conclusive grounds” decisions in 2023, an increase from 6,189 in 2022. Observers noted only 66 percent of these decisions were positive, compared with 89 percent in 2022. NGOs reported the long wait times were detrimental to victims’ mental health and, in some cases, resulted in victims choosing not to receive government support, potentially increasing their risk of re-trafficking.

The 2023 Home Affairs Committee inquiry found the wait times “unreasonably long” and recommended the government reduce the number of days for decisions and clear the backlog of cases awaiting decisions. In 2021, the UK government created the IECA with the intent of speeding up the decision-making process for the backlog of “conclusive grounds” decisions. Experts strongly criticized the creation of the IECA and the return to a “dual system” approach for identifying victims – one for UK citizens and another for foreign nationals – noting that many victims who lacked secure immigration status may not be identified or protected and would subsequently fear coming forward to seek support; observers noted the government did not consult with civil society or the survivor community prior to making this change. In April 2022, the British Parliament passed the NABA with anti-trafficking measures with the stated intent of clarifying in law the UK’s international obligations and entitlements for trafficking victims.

NABA required individuals claiming asylum to provide information to authorities related to if they are trafficking victims within a specified time period, although the government made available a “good reasons” ground for providing information outside the specified period; it also increased the “reasonable grounds” threshold of the MSA to require proof of additional “objective factors” beyond a potential victim’s testimony before authorities could issue a reasonable grounds decision. The Home Office reported the changes to the “reasonable grounds” threshold intended to increase the quality of information provided in referrals and improve the speed of decisions. NABA also reduced the minimum recovery period from 45 days to 30 days and limited additional recovery periods; added two disqualification statuses for potential victims on the basis of “bad faith” or “public order” if they were involved in serious criminality or threats to national security or in cases where they claimed to be a victim of human trafficking in bad faith; and specified the criteria and circumstances by which authorities could grant confirmed victims temporary permission to remain in the UK, including where necessary for assisting victims to recover from exploitation, receive compensation, or to cooperate with a criminal investigation. However, following implementation of NABA provisions on January 31, 2023, subsequent legal challenges relating to the requirement to provide objective evidence for a “reasonable grounds” decision and the “public order” disqualification, resulted in the government issuing revised guidance on the implementation of those provisions in July 2023 and January 2024, respectively.

Civil society, international experts, the Home Affairs Committee, and others expressed concern the changes made under NABA undermined effective efforts by the government to combat human trafficking. The 2023 Home Affairs Committee report criticized the de-prioritization of human trafficking in favor of irregular migration, which overlooked that most identified victims in the NRM were UK nationals. The Home Affairs Committee and NGOs urged the government to treat human trafficking as a protection issue, rather than an immigration enforcement issue and recommended a review of the implementation of the modern slavery portions of NABA. Civil society expressed concern the government demonstrated a lack of independent oversight, and lack of consultation with the NGO community.

NGOs said the government did not consult civil society, including on changes to victim identification, before NABA passed. The UK government claimed that undocumented migrants were misusing the NRM system to avoid deportation; however, civil society criticized government statements alleging misuse by economic migrants, and said the government had provided no evidence to support its claims. The government’s data demonstrated nine out of 10 referrals to the NRM in 2021 and 2022 resulted in a positive final decision. Similarly, the Home Affairs Committee found the data of the Home Office alleging abuse of the system “not compelling” and urged the Home Office to submit data to support their assessment.

Experts also criticized that NABA increased the burden of proof for victim identification; created impediments regarding the disclosure of victim status; conflated human trafficking with migrant smuggling; and disqualified certain individuals from the NRM process, including potential victims who committed unlawful acts as a direct result of being trafficked. After these changes under NABA came into effect in January 2023, early data suggested negative impacts to “reasonable grounds” and “conclusive grounds” decisions, including increased lengths of wait times, differences in decisions from the IECA and SCA for foreign national and UK national victims. NRM data in 2023 showed a decline in positive “reasonable grounds” decisions made by UK authorities to 55 percent positive decisions, from what had consistently ranged from approximately 80 to 92 percent positive decisions over the past nine years. Observers noted 2023 had the lowest percentage of positive “reasonable grounds” decisions since the NRM began.

The average wait time for initial “reasonable grounds” decisions increased to 23 days compared to six days in 2022 – and more than four times the average wait time of approximately 5.5 days that had been consistent over the last nine years. Civil society noted this was critically important as potential victims cannot access support services in England or Wales until they have an initial positive “reasonable grounds” decision. Government officials in England and Wales were required to notify the Home Office when they detected potential victims of trafficking; such “duty to notify” referrals increased in 2023. Some NGOs believed this increase of “duty to notify” referrals reflected a growing number of victims who do not wish to enter the NRM due to not understanding it, fear of deportation, or concern it would delay their asylum claims.

Of 9,825 “conclusive grounds” decisions made in 2023, only 66 percent were positive, the lowest percent in five years and decreased from approximately 90 percent consistently over the past three years specifically. NGOs reported the process for referrals was confusing and victim decisions from the authorities were seemingly inconsistent. The number of requests for reconsideration of decisions doubled; and service providers reported working with potential victims to resubmit reconsideration requests to the NRM and significant delays in decision-making timelines. In 2023, authorities issued more positive decisions for UK nationals than foreign nationals referred to the NRM, which observers found concerning.

Approximately eighty percent of all referrals (13,704) were sent to the SCA while twenty percent (3,300) were sent to the IECA. Only 33 percent of “reasonable grounds” decisions made by the IECA were positive, while 61 percent of “reasonable grounds” decisions made by the SCA were positive. Similarly, one third of “conclusive grounds” decisions made by the IECA involving foreign nationals were positive, compared with three quarters of decisions involving British nationals by the SCA. NGOs noted receiving different decisions from the SCA and IECA on referrals submitted with similar information.

The Home Affairs Committee recommended the government reinstate a quality assurance process for decisions to ensure accurate and consistent review of referrals. From January 2023, disqualification requests could be made on the basis of “public order,” after potential victims entered the NRM. However, in response to the legal challenge to this provision, public order disqualifications were paused, from July 2023 to January 2024 while the policy was updated. In 2023, 331 individuals were disqualified from the NRM on the grounds of “public order” (none prior to 2023).

Observers noted with concern this process may have disqualified potential victims from accessing support, especially those who committed unlawful acts as a direct result of being trafficked, including victims exploited in forced criminality. In July 2023, despite concern from civil society, GRETA, and other anti-trafficking experts, Parliament passed the Illegal Migration Act (IMA), which included sections on human trafficking. The IMA’s stated intent is to remove incentives for individuals to enter the UK illegally, including tackling alleged abuse of the UK’s modern slavery system by people seeking to block their removal once their asylum claim has been denied. Although not yet fully implemented, under the IMA, individuals who arrive in the UK irregularly, including potential trafficking victims who already entered the NRM, would not be entitled to protection.

Instead, the IMA creates a duty to remove individuals who enter the UK irregularly, to their home countries or to a third country deemed safe by the Home Office, unless they meet certain exemptions. Civil society and anti-trafficking experts widely criticized IMA, noting it could reduce potential victims’ access to support; result in victims’ inappropriate detention or deportation; disqualify victims from care; hinder identification; and increase potential victims at risk of re-trafficking. Some NGOs reported victims’ removal from the UK may also hinder prosecution and investigation of cases. Civil society and international experts, including GRETA and the Joint Committee on Human Rights, previously said IMA may not comply with the anti-trafficking convention.

Observers in Northern Ireland and NGOs and government officials in Scotland widely criticized the impacts of IMA and NABA, further noted a lack of clarity among first responders on how provisions will come into force. Due to their concerns about NABA and IMA, some NGOs advocated for the creation of a separate NRM in Scotland to avoid the foreseen negative impacts on victim protections. In November 2023, the UK Supreme Court ruled that a government policy removing individuals who enter the UK irregularly to Rwanda was unlawful under current UK law and that such removal of asylum seekers would expose them to risk of ill-treatment. In response to this ruling, in November 2023, the UK government introduced the Safety of Rwanda (Asylum and Immigration) Bill, intended to provide a legal basis to remove individuals who enter the UK irregularly to Rwanda.

Anti-trafficking experts assessed the bill will not protect victims of trafficking and contradicts the UK’s obligation under the anti-trafficking convention to prevent trafficking through safe migration policies. The UK government appointed a Victims Commissioner in October 2023, its first since September 2022, to provide independent oversight of victim screening measures. In 2023, the government reported updating its guidance for screening individuals in commercial sex for trafficking indicators; it also reported immigration officers screened for such indicators. The Home Office maintained e-learning modules for first responders, on indicators of human trafficking to help proactively identify victims, and with instructions of how to make a referral; however, experts noted the training was significantly out of date and did not reflect recent changes to the referral process.

NGOs designated as first responder organizations (FROs) referred five percent of the total referrals to the NRM in 2023. Only 15 NGOs held first responder status and could refer potential victims into the NRM; observers noted not having an adequate number and geographical reach of FROs may have left victims unidentified. FROs were responsible for training first responders in their organization. Civil society urged consistent, mandatory training for FROs, including on the trauma-informed approach.

NGOs noted not all FROs had the same level of understanding of human trafficking, and NGOs urged accredited training, including for law enforcement, on how to make NRM referrals. Observers noted the quality of information provided to victims on their rights varied widely among first responders and interpretation and translation services were not fully available, in practice, at all stages of the victim support process. The UK government continued implementing a five-year MSVCC, for which it allocated more than £379 million ($482 million), with the anti-trafficking NGO sector to coordinate the provision of care for adult victims in England and Wales under the NRM. NGOs stated this contract supported 10,704 potential victims from July 2022 to June 2023, the only period for which data was made available, including those awaiting final decisions and 3,533 new victims.

The MSVCC could provide a range of support services including safehouse accommodation, financial support to meet essential living needs and assist with social, psychological, and physical recovery, access to essential services, and a dedicated support worker to assist victims in accessing support services such as free health care and legal aid. The Home Affairs Committee and anti-trafficking experts noted gaps in British national victims’ access to services in the NRM; for example, British victims faced barriers to accessing shelter. Following the implementation of NABA, NGOs reported a greater workload to refer potential victims into the NRM, including to complete victim referral applications with sufficient objective evidence, and support potential victims to appeal negative decisions. Observers noted access to legal aid remained limited for many trafficking victims.

Moreover, GRETA expressed concern the UK government did not provide potential victims legal aid prior to entering the NRM. Observers claimed accommodation was provided according to availability rather than need and there was limited support available for victims with complex needs. The Scottish government continued to fund the ICTG Service (Guardianship Scotland) to provide legal assistance and basic needs to unaccompanied children and victims of trafficking. In April 2023, the Guardianship Scotland became a statutory service.

The Scottish government allocated more than £9 million ($11.45 million) for victim protection and assistance from 2022-2025. The Scottish government’s Victim Centered Approach Fund continued to provide support to victims of crime, including trafficking victims. Northern Ireland did not report how much funding it allocated to two local NGOs to provide victims services in the 2023-2024 fiscal year, compared with approximately £2 million ($2.54 million) in the 2022-2023 fiscal year. In Northern Ireland, the Sexual Offences and Trafficking Victims Act and Human Trafficking and Exploitation Act 2015 provided for support and assistance for trafficking victims.

Observers noted a limited number of FROs in Northern Ireland may have hindered victim identification, especially of victims exploited in Northern Ireland. In 2023, officials in Northern Ireland appointed one new organization as an FRO. The UK government continued to utilize a recovery needs assessment to tailor ongoing support to victims’ specific needs and determine the point at which a victim would exit the support services under the MSVCC. Observers asserted the recovery needs assessment was too restrictive because it placed the burden on survivors to document their ongoing need, in order to continue receiving support.

After a confirmed victim transitioned out of MSVCC support, they could access assistance through the “reach-in service,” a post-NRM service that offered transitional support, including provision of information and assistance to housing, health care, translation, employment, and support with submitting paperwork. Children received care through children’s services offices in local jurisdictions; social workers worked with potential child victims to assess needs and create a care plan that included health, legal, education, and accommodation support. The government reported children’s care services were under increasing pressure due to the high number of unaccompanied children arriving in small boats crossing the English Channel. The government continued the ICTG program, which covered two thirds of local authorities across England and Wales.

NGOs and the 2023 Home Affairs Committee report recommended the UK government to extend the ICTG scheme across the country and continue support to individuals older than 18 and urged the government to complete the roll out to all local authorities by 2025, especially considering the increase in child trafficking victims. The Home Affairs Committee report found a shortage of housing for victims of human trafficking in the MSVCC, with children particularly vulnerable due to a lack of safe accommodation after they turn 18. NGOs highlighted concerns about the difficulty of safeguarding children whom the government relocated away from their home to parts of the country where services were available; criminal gangs actively targeted vulnerable children who were taken out of their communities and ran away or went missing. Observers also noted unaccompanied migrant children were vulnerable to trafficking and many of these children went missing after their arrival in the UK.

The Home Office continued its pilot program to devolve NRM decision-making for children to local authorities, reaching 20 pilot sites by January 2024. Civil society widely commended this program for producing more reliable decision making and allowing children access to services faster and some NGOs recommended the government adapt a similar devolved decision making for adult victims. In 2023, the average time from referral to a “conclusive grounds” decision for children was between 45-62 days. In 2023, the Scottish government launched the ICTG Service (Guardianship Scotland), which provided support to all unaccompanied children arriving in Scotland, which may have included victims of human trafficking.

Further, the Scottish government updated their guidance for child protection, with an emphasis on screening for indicators of human trafficking and exploitation. Since April 2022, the Scottish government funded two victim navigators to support victims in the criminal justice system process. Scotland and Northern Ireland required the appointment of independent legal guardians for child trafficking victims and trained the guardians on the support services available. In Northern Ireland, the Health and Social Care Trust referred child victims to the NRM.

In Northern Ireland, NGOs raised concern that authorities identify very few domestic child victims compared to the rest of the United Kingdom, with only three domestic child victims out of 462 referrals to the NRM in 2023. Foreign national victims without legal status were unable to work until receiving a temporary residence permit intended to replace “discretionary leave” that survivors – and any dependent children they have – may be considered for if they have a positive conclusive grounds decision. Discretionary leave decisions were not linked to an individual’s status as a confirmed trafficking victim but were judged on individual circumstances. While the UK government provided subsistence payments to victims who entered the NRM, observers noted victims were unable to meet their essential needs with the payments.

As of March 2023, the government provided all potential victims the same level of weekly financial support, regardless of whether they claimed asylum. The government did not automatically grant foreign victims legal status in the UK; authorities reviewed requests for discretionary leave on a case-by-case basis. Under NABA, foreign victims granted a reflection period after a positive ”conclusive grounds” decision could not be removed from the UK during that period; however, foreign victims with a positive “reasonable grounds” decision could be disqualified under ”public order,” so the recovery period was not available, and these individuals could be removed from the UK. Observers noted that a positive “conclusive grounds” decision did not lead to ongoing support, or regularization of immigration status for foreign national victims, something that increased vulnerability to re-trafficking.

To avoid re-traumatization, UK authorities encouraged police to use intelligence-led investigations, pre-recorded cross-examination, and allowed victims to apply for reporting restrictions and other measures to maintain anonymity. In 2023, the Home Office continued to fund four police forces and the Gangmasters and Labour Abuse Authority (GLAA) to improve support measures for victims in the criminal justice system. Additionally, the Home Office commissioned independent research on models of support for victims navigating the criminal justice process; the results have not yet been published. The courts allowed victims to testify by video, behind a screen, or with the public removed from the courtroom during hearings.

Under NABA, “temporary permission to stay” – formerly “leave to remain” – may be granted to victims to assist in their recovery, cooperate with an investigation or criminal proceeding, or seek compensation; the government has not reported how many victims received leave to remain. Civil society said this new guidance is narrower than the previous guidance, including for child victims. Civil society expressed concern this increases the risk of trafficking some victims would face if returned to their home countries. Courts in England and Wales continued use of pre-recorded cross examination and made it available to all Crown courts.

Courts could grant restitution in a criminal case; however, NGOs noted courts infrequently granted restitution. Although victims could apply for compensation through civil suits, this remedy was difficult to access given the small number of legal aid providers available to file such claims and some victims were unaware of their entitlement to compensation. During the 2022-2023 fiscal year, courts granted a total of £1.1 million ($1.4 million); a small part of this was compensation to trafficking victims in England, Wales, and Northern Ireland. Moreover, traffickers could appeal or contest compensation orders; observers noted traffickers often moved assets, meaning that awards were often not paid in practice.

A 2022 policy paper by the previous IASC found courts granted only 41 compensation orders and eight reparation orders to trafficking victims since 2018. The 2023 Home Affairs Committee report recommended the government provide victims with earlier and more comprehensive access to legal aid. GRETA previously noted free legal assistance was not provided in practice to victims seeking compensation under this scheme in England and Wales despite a complex compensation procedure and the requirement that victims prove they have suffered a physical or psychiatric injury as a direct result of a violent crime to receive an award. There is not a specific compensation provision in Scotland’s anti-trafficking act, but under the criminal procedure, courts are required to consider whether compensation is required to the victim and the judge sets the amount to be paid.

The Northern Ireland Criminal Injuries Compensation Authority could withhold or reduce compensation if the victim did not report the circumstances of the injury to the police and could not offer a reasonable explanation for not doing so, did not cooperate with law enforcement, or had a criminal conviction. In Scotland, victims could seek state funded compensation through the Criminal Injuries Compensation Scheme, for victims of violent crime. Neither Scotland nor Northern Ireland reported awarding restitution or compensation to any victims in 2023. Victims had a statutory defense in England and Wales for unlawful acts committed as a direct result of being trafficked; the defense did not apply to the most serious crimes, such as sexual offenses or crimes involving serious violence.

In these cases, the CPS had to consider whether it was in the public interest to prosecute the trafficking victim. NGOs noted victims could only access this defense when the prosecution commenced, and therefore, it did not protect them before this point. In December 2023, CPS issued guidance on how prosecutors should approach such cases. His Majesty’s Prison and Probation Service dedicated three staff as contacts on human trafficking and, in consultation with civil society, updated its operational guidance for prison staff to identify victims in prison, and sought to develop guidance recognizing the barriers for individuals to disclose their exploitation in prison.

The Home Affairs Committee raised concern that despite child criminal exploitation being the largest form of child trafficking in 2022 and 2023, there is no specific statutory definition for child criminal exploitation. They asserted that this lack of definition contributed to continued prosecution of child victims for crimes committed as a direct result of being trafficked. In Northern Ireland, although non-punishment measures exist, there is no publicly available data on how many cases there were. In Scotland, the Human Trafficking and Exploitation (Scotland) 2015 Act required the Lord Advocate to make and publish instructions about the prosecution of a person who is, or appears to be, a victim of human trafficking, which laid out a “strong presumption against” prosecution of cases where defendants were found to be victims of trafficking.

NGOs welcomed government engagement on this issue, but raised concern that current instructions were not an effective safeguard for potential victims, as authorities could not prosecute traffickers until victims received positive final decisions in the NRM. In a recent case, courts convicted and sentenced two Albanian men on drug charges; however, they were later released from prison when the courts established they were trafficking victims. The 2023 Home Affairs Committee report urged training for law enforcement in victim identification and recommended, in line with earlier GRETA recommendations, ensure application of the non-punishment provision. An NGO report found the number of potential trafficking victims in immigration detention centers tripled in the past four years, with some receiving positive “reasonable grounds” decisions while in detention.

NGO reports found victims in detention centers faced risk of re-traumatization or negative impacts to their physical or mental wellbeing, and called for the government to urgently review its process of detaining potential or confirmed victims. In 2022, the Independent Chief Inspector of Borders and Immigration urged the Home Office to introduce greater safeguards for individuals in detention; observers continued to report various mistreatments at an immigration removal center. Multiple observers reported British women and children in camps in northeast Syria were likely trafficking victims; the UK government did not report if it screened for trafficking indicators during repatriation procedures.

PREVENTION

The government maintained prevention efforts. The Home Office was responsible for coordinating the government’s anti-trafficking prevention and protection efforts. In 2022, the UK government shifted responsibility for anti-trafficking efforts from the Minister for Safeguarding to the Minister for Immigration. In July 2023, the Home Office convened the first, quarterly Modern Slavery Engagement Forum (MSEF) with government officials and NGOs.

However, multiple NGOs noted the MSEFs met irregularly and were used to inform NGOs of government decisions rather than to consult them or coordinate on policy. Furthermore, some NGOs claimed the laws and legislation passed not only eroded protections for victims but also may have created new at-risk groups who might face risk of re-trafficking or exploitation, whether due to their removal from the UK or disqualification from the NRM. For the second consecutive year, the Home Office did not publish its annual report on modern slavery. The UK government previously conducted a review of the 2014 Modern Slavery Strategy and engaged with a range of stakeholders, including the interagency, business, academia, civil society, and survivors to develop a new strategy; however, the new strategy remained pending for the second consecutive year.

Experts urged the creation of a new strategy to ensure clear monitoring and evaluation, and reported the current lack of an overall strategy created a fragmented approach to anti-trafficking efforts. Civil society groups initially consulted in the development of the strategy reported the Home Office was no longer consulting them in this process. Similarly, the House Affairs Committee and other experts noted the Modern Slavery Strategy was 10 years old and needed updating. NGOs, including those in Scotland, reported a lack of communication with the Home Office as compared to the Scottish Government on anti-trafficking efforts.

The Home Office appointed a new IASC in October 2023 following an 18-month vacancy. NGOs called for the IASC’s role to be further strengthened and independent, including legal requirements for government departments to report statistics in response to recommendations made by the IASC. The IASC encouraged good practice in the prevention, detection, investigation, and prosecution of trafficking crimes as well as the identification of victims. The Home Affairs Committee reported concerns over the Home Office’s lack of outputs, delayed appointment of an IASC, and lack of an updated Modern Slavery Strategy.

Northern Ireland previously developed and received public consultation on a new three-year strategy for trafficking for 2023-2025; however, the government did not report finalizing the strategy for the second consecutive reporting period. Scotland previously drafted an updated annual Trafficking and Exploitation Strategy progress report with survivor input; an updated progress report was pending publication for second consecutive reporting period. The Scottish government finalized its second review of the 2017 Trafficking and Exploitation Strategy, with inputs from survivors, in September 2023. Although the UK government did not fund a trafficking-specific hotline, NGOs operated multiple hotlines that provided support to potential victims.

The UK government did not report how many calls led to referrals. The UK government funded a specialist helpline that provided advice and support to children and adults on “county lines,” criminal exploitation, and gangs. The UK government conducted awareness campaigns across the UK with a wide range of partners. The government continued to support the Modern Slavery and Human Rights Policy and Evidence Centre (PEC) through a five-year £10 million ($12.7 million) investment through the 2023-2024 fiscal year to better understand how to combat trafficking and to develop research to inform policy choices.

In 2023, PEC published reports, including on the role and responsibility of prisons to secure rights for victims, and funded six new research projects focused on prevention in the UK. The Foreign, Commonwealth and Development Office (FCDO) funded PEC to research survivor engagement in international policy and programming, and the UK government reported various other survivor engagement efforts. In 2022, the Home Office funded the Modern Slavery Prevention Fund; however, this did not continue in 2023. In October 2023, the UK government passed the Online Safety Act, which required technology companies to proactively identify and remove online content related to human trafficking, child sexual exploitation, and other crimes; companies who failed to do so could incur fines of up to £18 million ($22.9 million) or 10 percent of their annual revenue.

The Scottish government funded various awareness raising projects and commissioned a study on the criminal exploitation of children. Northern Ireland reported awareness campaigns for health and law enforcement, business, and financial sectors. In the 2023-2024 fiscal year, the UK government continued to fund the GLAA with £7.77 million ($9.89 million) and established a new entity to produce an annual strategy, published in March 2024, and to coordinate enforcement action among the labor market enforcement bodies. The Employment Agency Standards Inspectorate provided funding for a platform to raise awareness about labor trafficking.

The GLAA did not report updates to its implementation of its new compliance strategy for labor recruitment regulations or investigations into allegations of overseas workers being charged finding fees. The GLAA operated a national licensing scheme in high-risk sectors to prevent trafficking, including in the agriculture, horticulture, shellfish gathering, and food processing sectors. However, NGOs and the Home Affairs Committee continued to note the GLAA remained under-resourced in terms of proactive efforts to prevent human trafficking. Foreign overseas domestic workers (ODW) could legally change employers during the remaining six-month period of their visa.

Observers criticized the short-term nature of the visa, noting workers struggled to change employment in the visa’s short timeframe, leading to workers’ heightened vulnerability to trafficking. Workers on the ODW visa identified as trafficking victims could apply for a two-year visa as a domestic worker, although NGOs contended workers who had suffered abuse would be unlikely to want to return to the same sector. NGOs continued to urge the government to adopt reforms to the ODW visa, particularly considering the heightened exploitation ODWs faced because of the pandemic. Observers also expressed concern about the government’s transit visa scheme for workers in the fishing industry, noting the inability to change vessels or leave the vessel without violating the terms of the visa left workers at risk of labor rights abuses and labor trafficking.

Observers noted concern about the health and care visa scheme for workers in the care sector; a 2023 study found a 600% increase in the number of human trafficking cases in the care sector from 2021 and 2022, including through potential debt bondage from employers charging workers large illegal fees for sponsorship. The UK government continued the seasonal workers program for non-EU migrants. Operators licensed by the GLAA oversee recruitment and placement of workers on farms, although observers noted the GLAA was under resourced. NGOs urged reform of the program, noting it left migrant workers vulnerable to exploitation; according to an NGO study, many of the workers accrued large debts and were limited in their ability to change employers.

In February 2023, the UK government announced it will guarantee seasonal workers in the program a minimum of 32 paid working hours. NGOs continued to express concern the government’s strict immigration policies, especially under IMA, which criminalized the act of working while undocumented, prevented trafficking victims from seeking help. Observers noted the absence of secure reporting options for undocumented individuals to come forward as victims of crime undermined the government’s identification and protection efforts. A 2023 report outlined previous reports of possible abuse, which may amount to forced labor, involving UK-flagged fishing vessels; experts urged the government to proactively screen for trafficking victims among sea fishers.

The border force led a three-year project to respond to potential forced labor in the fishing industry. The MSA required organizations with annual turnover exceeding £36 million ($45.8 million) to publish an annual statement on the government’s modern slavery statement registry detailing efforts to ensure its operations and supply chains were free of human trafficking, although observers noted the MSA did not include a mechanism to ensure compliance. The 2023 Home Affairs Committee report noted the MSA recorded 46 percent fewer statements in 2023 than 2022, and the government has not imposed penalties against noncompliant organizations. The UK government considered measures to strengthen the reporting requirement and introduce financial penalties for organizations failing to meet their reporting obligations; however, observers noted many businesses had not yet submitted statements and the government had not penalized noncompliant businesses.

For the second year, the UK government had not published the 2021-2022 UK government’s modern slavery statement. NGOs reported the Home Office increasingly prioritized the role of business and transparency in supply chains. In March 2023, an NGO urged the government to impose sanctions on People’s Republic of China (PRC)-owned companies providing seafood to UK-based grocery stores, claiming these had forced labor in their supply chains. Media reports indicated potential forced labor in the supply chains of solar panels used by the UK military.

Two local authorities in Scotland amended licensing requirements for nail salons, an industry with known cases of human trafficking, to provide additional regulation. The UK government did not make efforts to reduce the demand for commercial sex acts. The government made efforts to reduce the demand for participation in extraterritorial children sexual exploitation and abuse by its citizens, including by implementing its national action plan on combating extraterritorial sexual exploitation and abuse. The government did not report providing anti-trafficking training to its troops prior to their deployment as peacekeepers.

The UK government funded a wide range of anti-trafficking programs globally, including continued implementation of programs under the £24 million ($30.53 million) dedicated for 2022 to 2025 for the Modern Slavery Fund (MSF), to a range of anti-trafficking efforts, particularly in Albania, Nigeria, Romania, Indonesia, and Vietnam. In Albania, the Philippines, Vietnam, and Romania, the MSF funded awareness campaigns, including a focus on online scam operations. In Nigeria, the MSF continued to provide capacity-building support to Nigerian law enforcement. The MSF funded various law enforcement training projects in Vietnam, Albania, and Romania.

The Modern Slavery Envoy oversaw international partnerships and chaired a quarterly meeting with UK-based civil society organizations to discuss global policy, programming, research, and evidence on anti-trafficking globally; NGOs reported positive engagement with the FCDO on anti-trafficking efforts. The UK government contributed funding to a project on technology-facilitated trafficking across Europe. In October 2023, the GLAA, in cooperation with an IO, conducted trainings on investigative techniques for Malaysian counterparts. The UK government previously collaborated with NGOs to raise awareness on trafficking risks among Ukrainian refugees fleeing Russia’s full-scale invasion of Ukraine.

The Homes for Ukraine sponsorship program allowed Ukrainian refugees to be housed with a UK-based host family. Civil society previously expressed concern about the program’s private citizen sponsorship component, with media reports of some Ukrainian refugees experiencing homelessness or alleged cases where refugees were subjected to exploitation. The UK government conducted a risk assessment and took steps to ensure the protection of Ukrainian refugees. Although the number of Ukrainian potential trafficking victims referred to the NRM has increased since the full-scale invasion, the total number of victims remained low.

NGOs also assessed Ukrainian refugees’ right to work likely reduced their vulnerability to trafficking. TRAFFICKING PROFILE: As reported over the past five years, human traffickers exploit domestic and foreign victims in the UK, and traffickers exploit victims from the UK abroad. Although the UK government reported 17,004 potential victims entered the NRM in 2023, the number of actual victims is likely higher. The majority of potential victims came from the UK, Albania, and Vietnam.

Forty-nine percent of potential victims experienced exploitation that occurred entirely outside the UK. Labor trafficking, including forced criminality, is the most common form of trafficking among adults and children. Migrants crossing the English Channel in small boats are vulnerable to trafficking; more than 36,700 migrants crossed the Channel in 2023, many of whom were unaccompanied children. Nearly half of all trafficking victims identified are children.

Children in the care system and unaccompanied migrant children are particularly at risk of trafficking. Gangs force children to act as drug couriers from larger cities into rural areas across the UK. Traffickers force adults and children to work in agriculture, cannabis cultivation, construction, food processing, factories, domestic service, nail salons, food services, the hospitality industry, car washes, food supply industry, and warehousing, as well as on fishing boats. Traffickers increasingly exploit victims, especially migrants, in the fishing industry, including through debt bondage, physical violence, or unsafe working conditions.

Similarly, a 2023 report indicated commercial vessels accused of forced labor were owned by companies registered in the UK. Traffickers increasingly exploit victims in the care sector. Labor traffickers target adults with disabilities and adults from low socioeconomic backgrounds. Traffickers increasingly recruit and exploit sex trafficking victims, predominantly from Eastern Europe, through social media and online platforms.

Reports indicate traffickers may have subjected some individuals from the UK to forced labor in cyber scam operations. Following Brexit, European Economic Area citizens without legal status in the UK were at increased risk of trafficking. Thousands of Ukrainian refugees, predominantly women and children fleeing Russia’s full-scale invasion of Ukraine, have crossed the UK border seeking sanctuary and are vulnerable to trafficking. In Scotland, most victims are from Vietnam with many forced to work in agriculture, forced criminality, including cannabis farms, the fishing industry, and nail salons.

Increasingly, victims are from Albania, Eritrea, Somalia, and Iran. Scottish authorities report most victim referrals originate in Glasgow and Edinburgh. In Northern Ireland, perpetrators force victims into shoplifting and the cultivation and distribution of illicit drugs. In Northern Ireland, paramilitary groups exploit children for criminal purposes, and unconfirmed media reports suggest children may be recruited by non-state actors, including extremist organizations.

NGOs report paramilitary groups exploit women, including in debt bondage. Young women and girls from Albania, Bulgaria, and Romania, including ethnic Roma, remain vulnerable to sex trafficking in Northern Ireland and increasingly victims are undocumented Somali, Sudanese, and Eritrean nationals, including victims who traffickers exploited on their journey through Libya, Turkey, or Greece who are identified in Northern Ireland. The British Overseas Territories are 14 territories with a constitutional link to the UK. UK officials continued to monitor serious and organized crime risks, including human trafficking, in the British Overseas Territories.

The UK is responsible for foreign relations, security, defense, and good governance in the territories. The UK government reported no evidence of child victims of sex trafficking or forced labor in five overseas territories. The government did not report additional information on its efforts to combat trafficking in the British Overseas Territories. There were Cuban government-affiliated medical professionals in British Overseas Territories during the COVID-19 pandemic, including in Turks and Caicos Islands, British Virgin Islands, Anguilla, and Montserrat.

It was likely these workers departed; however, Cuban government-affiliated medical professionals may have been forced to work by the Cuban government while serving in British Overseas Territories. Observers noted the Falkland Islands, Montserrat, and St. Helena-Ascension-Tristan da Cunha do not have functioning labor inspectorates to enforce labor laws; and in St. Helena-Ascension Tristan da Cunha, observers noted significant legislative gaps with respect to child labor trafficking. On This Page search > < UNITED KINGDOM (Tier 1) PRIORITIZED RECOMMENDATIONS: PROSECUTION PROTECTION PREVENTION TRAFFICKING PROFILE: Tags Bureau of European and Eurasian Affairs Human Trafficking Office to Monitor and Combat Trafficking in Persons Reports United Kingdom