Alexandria, VA, United States of America, Hong Kong, London, United Kingdom (2 September, 2025)

Key players in Finance and Law Enforcement unite to prevent the misuse of payment systems for Online Child Sexual Exploitation

• The International Centre for Missing and Exploited Children, Freshfields and FTI Consulting have collaborated to bring together their child protection, legal, investigations and financial crime compliance expertise to create a toolkit – the Child Protection Toolkit – that aims to support the global payments industry’s fight against online child sexual exploitation. 

• The Toolkit has been designed in collaboration with, and with the benefit of invaluable support and insights from, banks, money service businesses, electronic payment platforms, law enforcement agencies and regulators around the globe.

• Enforcement and prevention efforts across the industry must aim to keep pace with the growing sophistication and commercialisation of international criminals involved in online child sexual exploitation.

• The Toolkit’s primary goal is to support the financial industry in its efforts to detect, disrupt and deter the use and abuse of the global financial system for online child sexual exploitation.

• The launch of the Toolkit is an important evolutionary step in the ongoing and rapidly evolving fight against online child sexual exploitation. It aims to encourage meaningful change by fostering close, cross-border and cross-sector dialogue and collaboration across the financial industry, recognising that bringing together diverse views and perspectives and unified efforts can result in the greatest impact.  The Toolkit is intended to be a creation that, over time, will be refined through real-life user experience and feedback as market payment systems and technology further evolve.

The International Centre for Missing and Exploited Children (“ICMEC”), global law firm Freshfields, and crisis and transformation advisory firm FTI Consulting––in collaboration with global financial institutions, law enforcement agencies and regulators around the world––have developed a Child Protection Toolkit to support the financial industry in its efforts to combat online child sexual exploitation facilitated through the international financial system.

The Child Protection Toolkit’s immediate objective is to assist financial institutions—whether global banks, money service businesses, or fintech platforms—in their efforts to detect and prevent money flows that may be connected with online child sexual exploitation.  Successful detection and prevention of illicit money flows, together with related, targeted law enforcement efforts, should make it more difficult for wrongdoers to benefit from their wrongdoing and, over time, deter misconduct.

The Child Protection Toolkit seeks to raise awareness amongst the key players in the market (financial institutions, law enforcers and regulators, amongst others) of online child sexual exploitation, how it arises, how it is commercialised, who the key players are, and the money flows and financial patterns that may be consistent with misconduct, by consolidating key information in one place.

The scale and systemic nature of the problem is stark.  Unlawful activity takes place in a long list of jurisdictions, and no jurisdiction appears to be immune.  In the Philippines alone, for example, a study published in 2023 by the Philippines’ Anti Money Laundering Council suggests that transaction reports related to suspected online child sexual exploitation surged 150-fold between 2018 and 2022, a period that began before the COVID-19 pandemic up to the tail end of that pandemic in 2022.  With the continued rise of digital technologies and virtual assets, the potential for exploitation will only grow—making awareness, unity of purpose, and coordinated action more critical than ever.

Ultimately, financial institutions are critical gateways to, and nodes in, the global financial system.  So, supporting them at the forefront of their efforts to identify and disrupt illicit financial flows is essential to combatting online sexual exploitation of children.  Success, however, depends on strong and consistent collaboration across disciplines and borders.  A close partnership around the world between financial institutions, law enforcement agencies, and supporting organisations such as ICMEC, can be a powerful force that hinders the ability of criminals to benefit from such crimes.  The Child Protection Toolkit provides a shared foundation for understanding and action and aims to foster that collaboration and partnership.

While the global community continues to make progress, more can and must be done, and done quickly.  Regulators recognise that money laundering can never be completely prevented and eliminated but expect financial institutions to do everything that they reasonably can towards minimising it.  Every tainted transaction or money flow that is identified, prevented and then reported to law enforcers can potentially make a difference.  Every little bit counts.  One child missing, abused, or exploited is one too many.

We extend our gratitude to the following financial institutions who have provided valuable input during this project and remain valued partners in our efforts towards our common goal: ANZ, Citigroup, Inc, HSBC, Mastercard, PayPal, and Western Union.

We further extend our gratitude to the following law enforcement authorities / regulators who have provided valuable input during the course of this project and remain valued partners in our efforts towards our common goal: AUSTRAC, Australian eSafety Commission, New Zealand Department of Internal Affairs, Philippines Anti Money Laundering Council, and Department of Special Investigation, Thailand Ministry of Justice.

Stephen Kavanagh, ICMEC Secretary General, commented:

“The international growth of the finance sector has brought great economic benefits across the world not least by easing the friction involved in international financial transactions.  One unwelcome result has been that the industry has inadvertently made life easier for the perpetrators of international criminal child sex trafficking and child sexual exploitation.  The Child Protection Toolkit aims to give financial institutions around the world the knowhow to fight back against this terrible trade that preys on our young people and exploits the international financial sector to do so.

Child protection is a shared and global responsibility, and we are privileged to partner with Freshfields, FTI Consulting, our finance industry and law enforcement partners to together take action to protect children around the world.  We all stand together against this threat. When we accept responsibility, when we cooperate and agree on a collective response, we know children are safer.”

Georgia Dawson, Senior Partner of Freshfields, added:

“It has been a privilege for us to work with ICMEC and FTI Consulting on such an important project.  In today’s complex world, criminals are increasingly sophisticated and innovative in their efforts to evade the law; and financial institutions find themselves at the frontline of efforts to disrupt that.  The Toolkit aims to be an important weapon for good, by bringing together ICMEC and its supporting organisations, financial institutions and law enforcers so that their efforts can be further aligned and focused, and outcomes magnified.  We look forward to further collaborating with ICMEC and FTI Consulting as this project evolves.”

Roy Huang, Senior Managing Director and Head of Asia & Caribbean of FTI Consulting, added:

“We are proud to have collaborated with ICMEC and Freshfields to develop a comprehensive toolkit and a typology-driven data analytics framework.  By leveraging our subject-matter and technical expertise, we are enabling financial institutions to effectively detect and report suspicious activities, ultimately strengthening their ability to combat the misuse of the financial system in the fight against online sexual exploitation of children.

With criminals constantly finding new ways to circumvent controls, the best defence we have is to continue to be engaged, invested and ready to safeguard the most vulnerable members of our community.  The support we have received from our banking and law enforcement partners has been invaluable and a significant resource in the development of this Child Protection Toolkit.”

Brendan Thomas, AUSTRAC Chief Executive Officer, added:

“Partnerships are critical to the fight against child sexual exploitation.  Financial institutions play an important role in combating child sexual exploitation for financial gain.  Through the development of profiling and transaction monitoring programs, and working in partnership with law enforcement and government agencies, financial institutions are able to target, identify and stop financial transactions associated with the sexual exploitation of children.

AUSTRAC welcomes the development of the Child Protection Toolkit to help educate financial institutions on how to detect and prevent money flows involved with offending, making it harder for child sexual exploitation to take place.  Child sexual exploitation is a heinous crime against some of the most vulnerable members of our community, and requires global responsibility.”

Matthew M. David, Anti-Money Laundering Council Secretariat, Philippines, Executive Director added:

“The Philippines continues to demonstrate its strong commitment to combating online sexual abuse and exploitation of children (OSAEC) through comprehensive legislation, coordinated inter-agency efforts, and the use of actionable financial intelligence. As the country’s primary financial intelligence unit, the Anti-Money Laundering Council (AMLC) plays a crucial role in disrupting the illicit financial flows that enable these crimes. In 2023, the AMLC presented findings from its third study on OSAEC-related suspicious transaction reports during two APAC Financial Coalition Forums organized by the International Centre for Missing & Exploited Children (ICMEC), highlighting emerging typologies and financial trends.[1]

We acknowledge with appreciation that the Child Protection Toolkit—developed by ICMEC, Freshfields, and FTI Consulting—includes the AMLC’s study among its references. This timely and practical resource equips financial institutions with tools to detect and prevent activities related to online child sexual exploitation. The AMLC remains fully committed to supporting initiatives that strengthen the financial sector’s role in protecting children from abuse.”

[1] The AMLC study, “Online Sexual Abuse and Exploitation of Children in the Philippines: An Evaluation Using Suspicious Transaction Report Data,” was presented at the APAC Regional Forum on 28 September 2023 and 09 November 2023, each attended by distinct domestic and international audiences.

Milan Gigovic, ANZ Executive and Head of Financial Crime Threat Management, added: 

“ANZ believes trusted partnerships with Government, law enforcement and industry peers are essential to strengthening the integrity of the global financial system and protecting children. No single organisation can tackle this issue alone. By working with trusted networks and sharing intelligence, we can collectively detect and disrupt illicit financial flows and make it harder for criminals to exploit children. 

The Child Protection Toolkit reflects years of shared expertise and collaboration across the financial ecosystem and stands as a powerful testament to what can be achieved when diverse sectors unite around a common goal. More than a resource, it is a catalyst for change – providing clear, actionable guidance that helps financial institutions respond with precision and impact and strengthening our collective ability to protect the most vulnerable through coordinated, community-driven responses.”

Mamta Thadani, Senior Manager, Risk Assessment, Financial Crime, Asia, HSBC, added:    

“Organisations such as the International Centre for Missing & Exploited Children facilitate cross-industry information-sharing on criminal typologies specific to each geographical region, including evolving risks related to the trafficking and exploitation of adults and children.  The exploitation of children – as well as all forms of human trafficking – have a devastating impact on its victims, their families and the wider community.  As criminals become increasingly sophisticated in concealing the proceeds of their crimes, we too must become smarter and vigilant in detecting those funds, continue to enhance our understanding of trends and typologies, and work with our customers and law enforcement to tackle this scourge on society.”

 Jared Mullen, New Zealand Department of Internal Affairs Director, Digital Safety, added:

“The Department of Internal Affairs supports the implementation of the Child Protection Toolkit.  This is a positive initiative that helps prevent the proliferation of child sexual exploitation material (“CSEM”) and the revictimisation of children.  Given that a significant amount of CSEM is purchased by offenders, improving the ability of the global financial industry to identify offenders and take action to prevent the sale is a welcome step to reducing victimisation and holding offenders to account.”

Khemachart Prakaihongmanee, Director of Bureau of Technology and Cyber Crime, Department of Special Investigation (DSI) Thailand, added:    

“It has been a great opportunity to collaborate with ICMEC in this project.  Nowadays, we are living in a complex world where the crimes have become more faceted.  It is observed that multi-agency cooperation has become crucial to disrupt the attempts of criminals.  Thus, this toolkit is expected to be a powerful weapon to fight against commercial exploitation of children.  I also would like to assure and continue collaboration with ICMEC for further mutual interest.”

Napol Woraprateep, Child Sexual Exploitation Crime Division, Bureau of Technology and Cyber Crime, Department of Special Investigation (DSI) Thailand, further added:

“It has been an invaluable experience working with ICMEC on this project.  In today’s increasingly complex world, crime has taken on many new forms, making collaboration across multiple agencies more essential than ever to effectively disrupt criminal activity.  This toolkit is anticipated to serve as a strong tool in the fight against the commercial exploitation of children.  I am also committed to continuing our partnership with ICMEC in pursuit of our shared goals.”

Scott Apodaca, Vice President, Global Financial Intelligence, Western Union, added:      

“At Western Union, we believe that combatting crimes against the most vulnerable among us is a shared responsibility.  We are proud to contribute to the ICMEC’s collaborative toolkit  that equips the financial industry with practical insights and actionable resources and solutions.  By working together and sharing information across public and private sectors, we can improve overall outcomes for children around the world.”