Anti-trafficking renewal
The Fayed case shows the danger of folding anti-trafficking into immigration policy.
Techniques the Fayeds used are evolving with technology and access, and under-investment leaves our children exposed.
Britain has lost ground on trafficking
The Fayed case is likely the largest sex trafficking case in Britain’s history. Allowed to fester for decades, it is still revealing its gravity and scale: at least 500 survivors had been identified by October 2026. It has surfaced at the very moment Britain’s capacity to police and investigate trafficking has fallen to a critical low.
Trafficking does not only cross borders. It happens inside British institutions, to women and children already living here – and in the name of immigration control, the machinery built to protect them is being dismantled.
National modern slavery policing has been folded into an organised immigration crime unit on less than a third of its pre-2021 funding; the specialist unit that coordinated police forces and shared intelligence across the country has since been closed; the National Crime Agency’s capacity has been cut; and the Independent Anti-Slavery Commissioner leaves office early in 2027 with no successor announced.
NOA is calling on the Government to renew its commitment to tackling domestic trafficking: to separate modern slavery from immigration policy, to reinvest in dedicated modern slavery policing, and to ensure that victims of UK-linked trafficking are recognised wherever they live today.
Because trafficking for sexual exploitation is an overwhelmingly gender-based crime, we are asking for it to be written into the Violence Against Women and Girls Strategy – its prevalence baseline, its ten-year targets and its promised best-practice investigation framework.
And we join calls across the sector to oppose Clause 36 of the Immigration and Asylum Bill, which would order decision-makers to treat delayed disclosure, inconsistency and similarity between victims’ accounts as grounds for doubt. These are the recognised hallmarks of coercion, trauma and organised exploitation; turning them into a statutory credibility penalty would leave survivors like us unidentified, unsupported and denied justice. Clause 36 should be removed.
Why NOA opposes credibility provisions in the Immigration and Asylum Bill
Britain is failing victims of historical sex trafficking – and, in the name of immigration control, Parliament is about to write that failure into law.
The system already fails those who could not report when it happened. The Fayed network, centred on Harrods, exploited around 500 young women and children over decades. Britain’s trifecta of impunity – a criminal justice system that almost never charges the powerful, civil courts where NDAs and settlements bury claims, and libel laws that gag the press – ensured its victims went unheard until Mohamed Fayed was dead.
The Metropolitan Police encountered victims of Fayed trafficking, and the hallmarks of organised, large-scale exploitation, both before and after trafficking was criminalised. Fayed died in 2023 without facing a single charge. Even after his death, the force spent the first 17 months of Operation Cornpoppy, launched in November 2024, treating a multi-perpetrator trafficking network as a single-suspect sexual offences inquiry – and referred no victims to the National Referral Mechanism.
Clause 36 of the Immigration and Asylum Bill would require decision-makers to treat delay in coming forward, inconsistency, omission and “striking similarity” between accounts as damaging a victim’s credibility. In the Fayed cohort, every one of those factors is a product of the trafficking itself: delay manufactured by trauma, NDAs, intimidation and the suppression of press reporting, then compounded by the state’s own failure to refer; and similarity that is the corroborating signature of a network, not a reason to doubt each victim. The clause would convert the state’s failures into a statutory mark against the victims it failed and – because identification is in practice what triggers investigation – would break the chain that finally brought trafficking into the Fayed inquiry.
NOA asks the Government to remove Clause 36 or, at minimum, preserve the independent duty to investigate trafficking whatever the credibility finding; to deliver the VAWG Strategy’s modern slavery commitments and restore the specialist policing capability lost to recent closures and cuts; to separate modern slavery from immigration policy; and to clarify police duties to identify, record and investigate historical trafficking.
Briefing: Britain is failing to protect victims of historical sex trafficking
Evidence to Parliament on the Immigration and Asylum Bill
Alongside the briefing, NOA has given written evidence to two parliamentary committees scrutinising the Immigration and Asylum Bill. Committee rules mean written evidence cannot be shared until the committee itself publishes it; we will post both submissions here as soon as they are released.
Joint Committee on Human Rights – legislative scrutiny of the Immigration and Asylum Bill · 25 August 2026
Our evidence to the JCHR argues that Clause 36 creates an unacceptable risk that genuine victims will be denied identification, and that the clause risks putting the United Kingdom in breach of its obligations under Article 4 of the European Convention on Human Rights and the Council of Europe Convention on Action against Trafficking in Human Beings (ECAT). It sets out the minimum protections Parliament would need to enact if the clause is retained, including an express saving provision preserving the duty to investigate trafficking whatever the outcome of a credibility assessment. Publication pending.
Public Bill Committee – Immigration and Asylum Bill · 4 August 2026
Our evidence to the Public Bill Committee examines what Clause 36 would do in practice, drawing on survivors’ direct experience of the National Referral Mechanism. It argues that the clause would take the very marks of trafficking – disclosure delayed by trauma, coercion, non-disclosure agreements and intimidation; accounts that resemble one another because the same network produced them; the gaps and inconsistencies that abuse leaves behind – and convert them, by statute, into reasons to disbelieve the victim. The submission calls for the clause to be removed, and offers the Committee oral evidence from survivors. Publication pending.
Dismantling of Britain's anti-trafficking protections
Where trafficking is involved, the odds lengthen further. Britain identifies more victims every year – more than 19,000 were referred to the National Referral Mechanism in 2024 – but prosecutes almost none of their exploiters. In the year to June 2024 the Crown Prosecution Service brought 467 prosecutions flagged as modern slavery, and just 58 people were convicted under the Modern Slavery Act, with prosecutors often charging lesser offences to secure a result – a practice evident in Operation Cornpoppy's focus on RASSO offending, noted by GRETA, the Council of Europe's Anti-Trafficking monitoring body.
The capacity to do better is being dismantled. The Independent Anti-Slavery Commissioner found in 2025 that funding for modern slavery policing has been slashed to around 30% of its pre-2021 level, that specialist teams are being merged or disbanded behind immigration enforcement, and that live investigations fell by 18% in two years. GRETA’s 2026 evaluation of the UK urged that trafficking be investigated and prosecuted as such, backed by financial investigation. For a wealthy trafficking network the two failures compound: a sexual offences system that rarely charges, and a trafficking system that rarely looks.
It needn't be this way. The office of Independent Anti-Slavery Commissioner and a consortium of anti-trafficking NGOs have published compelling visions of an alternative future, in which the state swiftly intervenes to stop exploitation.
NOA's engagement with the international community
Under the Council of Europe Anti-Trafficking Convention and Article 4 of the European Convention on Human Rights, the UK must identify potential victims of trafficking and investigate and prosecute trafficking as the crime it is. In the Fayed case it did neither.
When we put these failures to the Home Office, our evidence went unpublished and unanswered. So we took it to the bodies that hold Britain to its international commitments: GRETA, the Council of Europe’s anti-trafficking monitoring body; the US State Department’s annual Trafficking in Persons Report, which grades every government against international minimum standards; the Council of Europe Commissioner for Human Rights; and the UN Special Rapporteur on trafficking in persons.
GRETA’s fourth evaluation of the UK, published in May 2026, cited our evidence, questioned the Met’s characterisation of the case and recommended that trafficking offences be investigated and prosecuted as such – recognition that Britain’s own institutions had refused to give.
The risks and forms of exploitation are evolving
Many Fayed victims recognise the patterns and techniques of their exploitation in accounts of the Tate Brothers – similar methods updated for the digital domain and viral growth through social media. Exploitation evolves with each generation.
We see our children drawn into online worlds where we cannot watch over them. Artificial intelligence is already supercharging criminals' methods.
Policing and policy must stay ahead. We know the costs of failing to act.
