A new approach to an old issue? Modern slavery in supply chains may be investigated under anti-money laundering provisions

When the UK’s Modern Slavery Act came into force in 2015, it was heralded as one of the first pieces of legislation in the world to specifically tackle modern slavery. Today, the UK’s regulatory regime is at risk of falling behind those of other jurisdictions. While reforms are being considered, a High Court judgment has turned attention to the other mechanisms UK enforcers might use to hold businesses to account for criminal activity in their supply chains, including proceeds of crime legislation.