Pro Bono

Helping Financial Institutions Combat Child Exploitation through Compliance Programmes

How can a typology-driven data analytic framework help in the fight against child exploitation?

In 2023, the National Center for Missing & Exploited Children (“NCMEC”) analysed an alarming 36.2 million reports1 of suspected child sexual abuse material, a figure that has more than doubled in just five years.2 New forms of exploitation, such as financial sextortion and AI-generated imagery, highlight the urgent need for Safety by Design.3 Specifically, the NCMEC received 26,718 reports of financial sextortion in 2023, a significant increase from 10,731 in 2022.4 Additionally, in 2023 NCMEC’s CyberTipline received 4,700 reports of Child Sexual Abuse Material, or other sexually exploitative content related to generative AI, emphasizing the pressing nature of these issues.

With online sexual exploitation of children rising, early detection and prevention of suspicious activities is essential. Monitoring and tracking suspicious financial behaviour might provide insight into sources of child exploitation, so banks and financial institutions (“FIs”) have an opportunity to form compliance programmes, which address this directly. In late 2020, FTI Consulting’s investigations and financial crime compliance experts were engaged by a top-tier law firm on behalf of ICMEC to develop a toolkit on how banks and FIs might structure their compliance programmes to detect and prevent suspicious activities.

Our Impact

The toolkit and high-level typology-driven data analytics framework that was developed enables banks and FIs to identify and report transactional activity indicative of child exploitation.


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Person reviewing and marking financial documents with charts and graphs beside an open laptop displaying data on a desk.

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Our Role

Providing subject-matter expertise to educate and raise awareness about child exploitation and typology-driven data analytics

Each organization brought distinct expertise to the collaboration. Through a teach-in, FTI Consulting contributed deep knowledge of payment flows and transaction monitoring, including how these vary across retail banks and other payment intermediaries, as well as insight into potential areas of weakness for financial institutions in identifying and reporting issues and engaging with regulators and law enforcement. Freshfields brought legal expertise across AML frameworks and multi-jurisdictional compliance obligations, while ICMEC provided the child protection intelligence and policy context underpinning the toolkit's typologies.

  1. Our team assisted in developing a process to better understand how select FIs identify transactions that are potentially related to the online sexual exploitation of children.

  2. Our team participated in outreach to FIs to understand their risk management practices around monitoring child exploitation in their respective institutions.

  3. FTI Consulting experts helped develop materials for anti-money laundering (“AML”), investigations and AML data analytics teams.

  4. The FTI Consulting team completed Phase II of the engagement, where they played a key role in launching the Child Protection Toolkit for Financial Institutions, designed to combat misuse of the financial system for online child sexual exploitation.

Georgia Dawson

Senior Partner, Freshfields

Bindu Sharma

Vice President Global Policy & Industry Alliances and Managing Director APAC, ICMEC

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