a

GAO

United States Government Accountability Office

Report to Congressional Requesters

July 2007 HUMAN 

TRAFFICKING

Monitoring and 

Evaluation of 

International Projects 

Are Limited, but 

Experts Suggest 

Improvements

GAO-07-1034
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

July 2007

HUMAN TRAFFICKING

Monitoring and Evaluation of 

International Projects Are Limited, but 

Experts Suggest Improvements 

Highlights of GAO-07-1034, a report to 

congressional requesters 

Human trafficking—a worldwide

crime involving the exploitation of 

men, women, and children for

others’ financial gain—is a

violation of human rights. Victims 

are often lured or abducted and 

forced to work in involuntary

servitude. Since 2001, the U.S.

government has provided about

$447 million to combat global

human trafficking. As GAO

previously reported, estimates of 

the number of trafficking victims 

are questionable. In this report,

GAO examines (1) collaboration 

among organizations involved in 

international antitrafficking efforts, 

(2) U.S. government monitoring of 

antitrafficking projects and 

difficulties in evaluating these 

projects, and (3) suggestions for 

strengthening monitoring and 

evaluation. GAO analyzed agency

documents; convened an expert 

panel; interviewed officials; and 

conducted fieldwork in Indonesia, 

Thailand, and Mexico. 

What GAO Recommends

GAO recommends that the

Secretaries of State and Labor and 

the Administrator of USAID 

consider taking actions to

(1) improve information about 

project impact on human

trafficking and (2) address

monitoring and evaluation in 

project design. In their comments,

State agreed to implement the 

recommendations. While agreeing

that monitoring and evaluation are 

important, Labor and USAID did

not directly respond to GAO’s 

recommendations. 

While governments, international organizations, and nongovernmental 

organizations have recognized the importance of collaborating and have 

established some coordination mechanisms and practices, they will need to 

overcome challenges that have impeded collaboration in the past for their 

efforts to be successful. In two of the three countries GAO visited, it found 

that host governments—which bear ultimate responsibility for combating 

trafficking within their borders—have passed national antitrafficking laws 

and enacted national action plans. However, organizations continue to face

numerous challenges when collaborating to combat human trafficking, 

including varying levels of government commitment and capacity. For 

example, some governments treat foreign trafficking victims as illegal 

immigrants and deport rather than protect them. In addition, according to 

officials in two of the three countries GAO visited, the ministries responsible 

for coordinating antitrafficking efforts have limited authority and capacity.

U.S. government-funded antitrafficking projects often lack some important 

elements that allow projects to be monitored, and little is known about 

project impact due to difficulties in conducting evaluations. Project 

documents GAO reviewed generally include monitoring elements, such as an 

overarching goal and related activities, but often lack other monitoring 

elements, such as targets for measuring performance. To oversee projects, 

State officials supplement their efforts with assistance from U.S. embassy 

staff, but have not established written guidance for oversight. Officials said 

that they are working to improve performance measures and develop 

monitoring guidance. Conducting impact evaluations of antitrafficking 

projects is difficult due to several factors, including questionable projectlevel estimates of the number of trafficking victims. These estimates are

needed for baselines by which to evaluate how effectively specific 

interventions are reducing trafficking. Elements in the design of certain 

projects, such as objectives that are too broad, further impede evaluation. 

Because of these difficulties, few impact evaluations have been completed, 

and little is known about the impact of antitrafficking interventions. 

A GAO-convened panel of experts identified and discussed ways to address 

the factors that make it difficult to monitor and evaluate antitrafficking 

projects. Panelists’ suggested approaches included improving information 

on the nature and severity of trafficking and addressing monitoring and 

evaluation in project design. To improve information on trafficking, 

panelists suggested methods that have been used to sample other hard-toreach populations, including domestic violence victims. One suggested 

method is sampling of “hot spots”—an intensive search for victims in areas 

known to have high concentrations of victims. To address weaknesses in 

project design that impede monitoring and evaluation, panelists suggested

that officials design projects that clearly link activities to intended outcomes,

identify measurable indicators, and establish procedures for setting and 

modifying targets. 

www.gao.gov/cgi-bin/getrpt?GAO-07-1034.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Thomas Melito 

at (202) 512-9601 or melitot@gao.gov. 
Page i GAO-07-1034 Human Trafficking

Contents

Letter 1

Results in Brief 3

Background 5

Organizations Have Taken Steps to Collaborate, but Continue to 

Face Challenges 11

U.S. Government-Funded Antitrafficking Projects Lack Some Key 

Monitoring Elements; Little Is Known about Project Impact Due 

to Difficulties in Conducting Evaluations 18

Expert Panel Identified Ways to Address the Difficulties of 

Monitoring and Evaluating Antitrafficking Projects 25

Conclusions 28

Recommendations for Executive Action 29

Agency Comments and Our Evaluation 29

Appendixes

Appendix I: Objectives, Scope, and Methodology 32

Appendix II: Selected International Organizations Involved in Combating 

Human Trafficking 36

Appendix III: Methods Suggested by Expert Panel to Estimate the Number 

of Human Trafficking Victims 40

Appendix IV: Comments from the Department of State 42

GAO Comments 48

Appendix V: Comments from the Department of Labor 49

GAO Comments 55

Appendix VI: Comments from the United States Agency for International 

Development 56

Appendix VII: Comments from the Department of Health and Human 

Services 58

Appendix VIII: GAO Contact and Staff Acknowledgments 59

Tables Table 1: U.S. Funding Obligated for Activities to Combat Global 

Human Trafficking, Fiscal Years 2001-2006 7

Table 2: Selected International Organizations’ Funding for 

Antitrafficking Projects 8

Table 3: Selected International Organization Missions and 

Activities to Combat Human Trafficking 36
Contents

Page ii GAO-07-1034 Human Trafficking

Table 4: Sampling Methods Suggested by Expert Panel to Estimate 

the Number of Human Trafficking Victims 40

Abbreviations

ADB Asian Development Bank

COMMIT Coordinated Mekong Ministerial Initiative Against Trafficking

DHS Department of Homeland Security

G/TIP Department of State’s Office to Monitor and Combat Trafficking 

in Persons

HHS Department of Health and Human Services

IDB Inter-American Development Bank

ILO International Labor Organization

IOM International Organization for Migration

NGO nongovernmental organization

OAS Organization of American States

OMB Office of Management and Budget

OSCE Organization for Security and Cooperation in Europe

PRM Department of State’s Bureau of Population, Refugees, and 

Migration 

SPOG Senior Policy Operating Group

TVPA Trafficking Victims Protection Act

UN United Nations

UNHCR United Nations High Commissioner for Refugees

UNICEF United Nations Children’s Fund 

UNODC United Nations Office on Drugs and Crime

USAID United States Agency for International Development

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. It may be reproduced and distributed in its entirety without further 

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other material, permission from the copyright holder may be necessary if you wish to 

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Page 1 GAO-07-1034 Human Trafficking

United States Government Accountability Office

Washington, D.C. 20548

A

July 26, 2007 Letr

The Honorable Ileana Ros-Lehtinen

Ranking Member

Committee on Foreign Affairs

House of Representatives

The Honorable F. James Sensenbrenner, Jr.

House of Representatives

Human trafficking—a worldwide crime involving the exploitation of men, 

women, and children for others’ financial gain—is a violation of 

fundamental human rights. Victims are often lured or abducted from their 

homes and subsequently forced, through various means, to work in 

prostitution, sweatshops, agricultural settings, or domestic service, among 

other types of servitude. In addition to inflicting grave personal damage 

upon its victims, trafficking undermines government authority, fuels 

organized criminal groups and gangs, and imposes social and public health 

costs. As we have previously reported, estimates of the number of 

trafficking victims are questionable due to data and methodological 

weaknesses.1

To combat global human trafficking, the U.S. government directly 

implements projects overseas and contributes financial support to the 

United Nations (UN) and other international organizations. The U.S. 

government has strongly supported antitrafficking efforts and, since 2001, 

has provided approximately $447 million in foreign assistance to 

nongovernmental organizations (NGO), international organizations, and 

foreign governments to combat and help eliminate human trafficking.2

 In 

addition, since the mid-1990s, the United States has played a leading role in 

putting human trafficking on the international community’s agenda. In 

2000, Congress enacted the Trafficking Victims Protection Act3

 (TVPA) to 

combat trafficking in persons; in 2003 and 2005, Congress reauthorized the 

1

GAO, Human Trafficking: Better Data, Strategy, and Reporting Needed to Enhance U.S. 

Antitrafficking Efforts Abroad, GAO-06-825 (Washington, D.C.: July 18, 2006). 

2

In 2003, the President announced the launch of a $50 million initiative to support 

organizations active in combating trafficking and child sex tourism, and in rescuing women 

and children.

3

Pub. L. No. 106-386.
Page 2 GAO-07-1034 Human Trafficking

act,4 which is due for reauthorization in 2007. In December 2005, the United 

States became a party to the United Nations’ Protocol to Prevent, Suppress 

and Punish Trafficking in Persons, Especially Women and Children, 

Supplementing the United Nations Convention Against Transnational 

Organized Crime,

5

 which entered into force in 2003 and, as of July 2007, 

has 117 signatories and 113 party nations.

This review is part of a larger body of work that you requested on U.S. and 

international efforts to combat human trafficking in the United States and 

abroad.6

 To review efforts to combat human trafficking, we examined 

(1) collaboration among organizations involved in international 

antitrafficking efforts, (2) U.S. government agencies’ monitoring of 

antitrafficking projects and difficulties in evaluating these projects, and 

(3) suggestions for strengthening monitoring and evaluation.

To address these objectives, we reviewed relevant planning, funding, and 

project documents on human trafficking from the Departments of State, 

Justice, Labor, Homeland Security (DHS), and Health and Human Services 

(HHS) and the U.S. Agency for International Development (USAID). We 

also reviewed planning and project documents from relevant UN and other 

international agencies and offices, including the UN Office on Drugs and 

Crime (UNODC), International Labor Organization (ILO), International 

Organization for Migration (IOM), United Nations Children’s Fund 

(UNICEF), and UN High Commissioner for Refugees (UNHCR). In 

addition, we discussed international antitrafficking efforts with officials 

from the above agencies and organizations, as well as foreign government 

officials and NGO representatives, in Washington, D.C., and during our 

fieldwork in Indonesia, Thailand, and Mexico. We selected these countries 

on the basis of the amount of U.S. funding provided for international 

4

Congress amended and reauthorized this act—the Trafficking Victims Protection 

Reauthorization Act of 2003 and the Trafficking Victims Protection Reauthorization Act of 

2005. (Pub. L. Nos. 108-193 and 109-164.)

5

This agreement, also known as the Palermo Protocol, seeks to prevent trafficking, protect 

victims, and promote antitrafficking cooperation among nations. The protocol supplements 

the U.N. Convention Against Transnational Organized Crime. It was opened for signature in 

Palermo, Italy, in December 2000. 

6

We issued our first report, GAO-06-825, in July 2006. See also Human Trafficking: A 

Strategic Framework Could Help Enhance the Interagency Collaboration Needed to 

Effectively Combat Trafficking Crimes, GAO-07-915 (Washington, D.C.: July 26, 2007), 

which addresses U.S. federal law enforcement agencies’ efforts to investigate and prosecute 

human trafficking crimes in the United States. 
Page 3 GAO-07-1034 Human Trafficking

antitrafficking projects and the number of U.S. government agencies and 

international organizations working in each country. In April 2007, we 

worked with the National Academy of Sciences to organize a 2-day expert 

panel on challenges and alternative strategies for monitoring and 

evaluating international antitrafficking projects. We conducted our review 

from August 2006 to June 2007 in accordance with generally accepted 

government auditing standards. Appendix I provides a detailed description 

of our objectives, scope, and methodology. 

Results in Brief While governments, international organizations, and NGOs have 

recognized the importance of collaborating and have established some 

coordination mechanisms and practices, they will need to overcome 

challenges that have impeded collaboration in the past for their efforts to 

be successful. The UN General Assembly passed a resolution in December 

2006 recognizing that broad international cooperation is essential for 

combating trafficking, and UNODC launched the Global Initiative to Fight 

Human Trafficking in March 2007. In two of the three countries we visited, 

we found that host governments—which bear ultimate responsibility for 

combating trafficking within their borders—have passed national 

antitrafficking laws and enacted national action plans. However, 

organizations continue to face numerous challenges when collaborating to 

combat human trafficking, including varying levels of government 

commitment and capacity. For example, some governments treat foreign 

trafficking victims as illegal immigrants and deport rather than protect 

them. In addition, according to officials in two of the three countries we 

visited, the ministries responsible for coordinating antitrafficking efforts 

have limited authority and operational capacity.

U.S. government-funded antitrafficking projects often lack some important 

elements that allow projects to be monitored, and little is known about 

project impact due to difficulties in conducting evaluations. Project 

documents we reviewed generally include monitoring elements, such as an 

overarching goal and related activities, but they often lack other 

monitoring elements such as targets for measuring performance. To 

oversee antitrafficking projects, State officials told us they need to 

supplement their efforts with assistance from U.S. embassy staff, but they 

have not established written guidance for oversight. Officials said that they 

are working to improve performance measures and develop monitoring 

guidance. Conducting impact evaluations of antitrafficking projects is 

difficult due to several factors, including questionable project level 

estimates of the number of trafficking victims. These estimates are needed 
Page 4 GAO-07-1034 Human Trafficking

for baselines by which to evaluate how effectively specific interventions 

are reducing trafficking. In addition, elements in the design of certain 

antitrafficking projects, such as short time frames and objectives that are 

too broad, further impede evaluation. Because of these difficulties, few 

evaluations that determine impact have been completed. As a result, little is 

known about the impact of antitrafficking interventions. 

A GAO-convened panel of experts identified and discussed ways to address 

the factors that make it difficult to monitor and evaluate antitrafficking 

projects. Panelists’ suggested approaches included improving information 

on the nature and severity of human trafficking and addressing monitoring 

and evaluation weaknesses in the design of antitrafficking projects. To 

improve information on the nature and severity of human trafficking, 

panelists suggested several sampling methods that have been used to 

sample other hard-to-reach populations, including the homeless, hidden 

migrants, missing and exploited children, and domestic violence victims. 

One suggested method is sampling of “hot spots”—an intensive search for 

victims in areas known to have high concentrations of victims or in areas to 

which many victims return. To address weaknesses in project design that 

impede monitoring and evaluation, panelists suggested that officials design 

projects that clearly link activities to intended outcomes, identify 

measurable indicators, and establish procedures for setting and modifying 

targets. Panelists further advised officials to determine which projects are 

ready to be evaluated before conducting an evaluation. 

To improve the monitoring and evaluation of antitrafficking projects, we 

are making two recommendations to the Secretaries of State and Labor and 

the Administrator of USAID because they provided the most U.S. funding 

for projects to combat global human trafficking. First, to improve 

information about project impact on the nature and severity of human 

trafficking, we are recommending that these three officials consider 

several actions, where appropriate, such as developing better data about 

the incidence of trafficking at the project level and applying rigorous 

evaluation methodologies. Second, to address monitoring and evaluation 

weaknesses in the design of antitrafficking projects, we are recommending 

that these three officials consider other actions, such as developing 

frameworks that clearly link activities with project-level goals, indicators, 

and targets; conducting “evaluability assessments” to determine whether a 

project is ready to be evaluated; and building evaluation into project design 

before the project is implemented. 
Page 5 GAO-07-1034 Human Trafficking

We received written comments on a draft of this report from State, Labor, 

USAID, and HHS, which are reprinted in appendixes IV, V, VI, and VII, along 

with our responses to specific points. State said that the report confirms 

several challenges inherent in foreign assistance efforts, including 

antihuman trafficking programs. However, State disagreed with our finding 

that monitoring is limited, stating that monitoring is in place at the 

department and improving. While we recognize that State and other U.S. 

agencies have certain elements of monitoring in place, we report that most 

projects lack other important elements, including a logic model that clearly 

explains how activities are linked to project goals and targets that will 

establish benchmarks for measuring performance. Labor said the report 

provides a good overall assessment of international cooperation regarding 

antitrafficking efforts and the need to enhance collaboration, and 

highlights important areas for improving monitoring and evaluation. 

However, Labor stated that the report does not fully reflect several 

mechanisms it uses, including audits and process evaluations, to monitor 

and oversee antitrafficking projects. In response, we revised the text to 

further clarify Labor’s monitoring and evaluation efforts. USAID 

commented that it is concerned with the challenges of coordination, 

monitoring, and evaluation, and agreed to continue working to make 

improvements in these areas. State agreed to implement our 

recommendations, while Labor and USAID did not directly respond to our 

recommendations. HHS said that the report substantively covers the range 

of programs and services available to combat human trafficking. 

Background Human trafficking generally involves the use of force, fraud, or coercion to 

enslave individuals in situations that are exploitative and often illegal and 

dangerous. Since 2001, the U.S. government has contributed approximately 

$447 million worldwide to foreign governments, NGOs, and international 

organizations—such as UNODC, ILO, and IOM—to combat human 

trafficking. U.S. agency and international organization projects generally 

aim to prevent trafficking, protect victims, and prosecute traffickers. 

Organizations have different requirements for monitoring and evaluating 

their antitrafficking projects.

Human Trafficking Cases 

Often Follow a Similar 

Pattern

Although the crime of human trafficking can take different forms in 

different regions and countries around the world, most human trafficking 

cases follow a similar pattern—that is, traffickers use acquaintances or 

false advertisements to recruit men, women, and children in or near their 
Page 6 GAO-07-1034 Human Trafficking

homes, and then transfer them to and exploit them in another city, region, 

or country.7According to the TVPA, victims of severe forms of trafficking 

include those who are recruited or transported for labor through the use of 

force, fraud, or coercion and for the purpose of subjecting them to 

involuntary servitude.8

 The use of fraud, force, or coercion typically 

distinguishes human trafficking victims from individuals who are 

smuggled. In some cases, individuals may enter freely into agreement with 

and pay smugglers to help them cross international borders. After arriving 

at their destination, however, individuals who do not understand the 

destination country’s language or culture may be exploited by individuals 

who take advantage of their vulnerability. 

Traffickers control their victims’ living and working conditions by 

physically confining them, taking away their identity documents, and 

threatening their families. Traffickers also exploit victims’ fears that 

authorities will prosecute or deport them if they seek help. Victims may be 

forced to work in legal or illegal and often dangerous areas, including 

brothels, sweatshops, agricultural businesses, and people’s homes. 

Documented human trafficking cases have involved victims such as 

children forced to beg for money in cities, work in carpet shops, and 

participate in pornography and sex acts with adults; women held in slaverylike conditions as domestic servants, strip club dancers, and prostitutes; 

and men forced to perform work in the agricultural sector and on fishing 

vessels.

7

The Palermo Protocol defines trafficking in persons as the recruitment, transportation, 

transfer, harboring, or receipt of persons, by means of the threat or use of force or other 

forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a 

position of vulnerability or of the giving or receiving of payments or benefits to achieve the 

consent of a person having control over another person, for the purpose of exploitation. 

Exploitation includes, at a minimum, the exploitation or the prostitution of others or other 

forms of sexual exploitation, forced labor or services, slavery, or practices similar to slavery, 

servitude, or the removal of organs.

8

Under the TVPA, victims of severe forms of trafficking are defined as those persons subject 

to (1) sex trafficking in which a commercial sex act is induced by force, fraud, or coercion, 

or in which the person induced to perform such acts is under age 18 or (2) the recruitment, 

harboring, transportation, provision, or obtaining of a person for labor or services, through 

the use of force, fraud, or coercion, for the purpose of subjection to involuntary servitude, 

peonage, debt bondage, or slavery. The TVPA does not specify movement across 

international boundaries as a condition of trafficking; it does not require the transportation 

of victims from one locale to another. (Pub. L. No. 106-386.)
Page 7 GAO-07-1034 Human Trafficking

U.S. Government and 

Multilateral Organizations’ 

Projects Focus on Three 

Areas

To combat the diverse forms of global human trafficking, 5 U.S. 

departments, USAID, and at least 15 international organizations have 

provided assistance to governments and civil society organizations in more 

than 100 countries. Assistance generally aimed to enhance efforts to 

1. prevent human trafficking through public awareness, outreach, 

education, and advocacy campaigns; 

2. protect and assist victims by providing shelters as well as health, 

psychological, legal, and vocational services; and 

3. investigate and prosecute human trafficking crimes by providing 

training and technical assistance for law enforcement officials, such as 

police, prosecutors, and judges.

These categories of interrelated victim-centered assistance activities—

prevention, protection, and prosecution—are commonly referred to as “the 

three p’s.” Each type of assistance is viewed as critical for reducing the 

incidence of human trafficking.

Since 2001, U.S. government agencies have provided approximately $447 

million in foreign assistance to international organizations, NGOs, and 

foreign governments to combat human trafficking (see table 1). Of the U.S. 

agencies, State, Labor, and USAID have provided the most funding to 

combat global human trafficking.

Table 1: U.S. Funding Obligated for Activities to Combat Global Human Trafficking, Fiscal Years 2001-2006

Source: GAO analysis of data provided by the Department of State’s Office to Combat and Monitor Trafficking in Persons and the 

Department of Labor.

Note: Funding is reported upon obligation by agencies in the year in which it is obligated. 

Dollars in millions

FY 2001 FY 2002 FY 2003 FY 2004 FY 2005 FY 2006 Total

State $11.47 $23.01 $28.13 $33.36 $34.41 $18.36 $148.74

USAID 6.74 10.72 15.42 27.59 21.34 27.31 109.12

Labor a 22.26 32.93 48.31 18.65 35.90 28.05 186.10

Justiceb 0 0 0 0.20 0 0 0.20

HHS 0 0 0 0 2.20 0 2.20

DHSc n/a 0 0 0.20 0 0 0.20

Total $40.47 $66.66 $91.86 $80.00 $93.85 $73.72 $446.56
Page 8 GAO-07-1034 Human Trafficking

a

In response to inquiries from GAO, Labor reclassified projects funded in 2001 and 2005 and 

subsequently revised figures for these years. In addition to the $28,048,000 allocated for projects to 

combat trafficking in 2006, Labor provided $300,000 for a trafficking research project.

b

In addition to the $200,000 in Justice funding, State provided additional funding to the department’s 

Office of Overseas Prosecutorial Development, Assistance and Training and International Criminal 

Investigative Training Assistance Program to conduct training overseas. In fiscal year 2004, State 

provided a total of $6.50 million to the two Justice programs; in fiscal year 2005, it provided $2.08 

million. In fiscal year 2006, State and USAID provided $1.90 million. These amounts are reflected in 

the State total in this table.

c

DHS officials stated that additional funds used to carry out antitrafficking activities, including law 

enforcement activities, come from its regular budget and cannot be broken out.

As we have previously mentioned, U.S. agencies support antitrafficking 

projects implemented worldwide by various international organizations, 

which also receive funding from other donor governments and 

organizations. As shown in table 2, for UNODC, ILO, and IOM, total 

resources allocated to combating trafficking since 2000 totaled about $255 

million. The U.S. government provided about $122 million to UNODC, ILO, 

and IOM to combat human trafficking, according to data provided by these 

organizations and State’s Office to Combat and Monitor Trafficking and 

Persons (G/TIP). In addition, according to UNICEF’s annual reports, 

between 2003 and 2005, UNICEF allocated more than $453 million to its 

worldwide child protection program, which includes projects to combat 

trafficking and the sexual exploitation of children.9

Table 2: Selected International Organizations’ Funding for Antitrafficking Projects

9

UNICEF was not able to break out budget data for trafficking-specific projects or activities. 

According to State G/TIP data, U.S. government support to UNICEF for antitrafficking 

projects from fiscal years 2002 to 2006 totaled $7.14 million.

Dollars in millions

U.S. government 

funding for 

antitrafficking projectsa

Total funding for 

antitrafficking projects from the 

United States and other donors

Worldwide organizations

UNODC b $5.28 (2002-06) $18.16 (2002 to present)

ILO c 46.35 (2000 to present) 84.47 (2000 to present)

IOM d 70.10 (2000 to present) 152.18 (2000 to present)

Total $121.73 $254.81
Page 9 GAO-07-1034 Human Trafficking

Source: GAO analysis of data provided by State, UN agencies, multilateral development banks, and regional organizations.

Note: Organizations included in this table were able to separate funding amounts for trafficking-specific 

projects. Information on other international organizations involved in combating human trafficking—but 

for which funding information for trafficking-specific projects was not available—is included in appendix 

II.

a

Amounts reflect U.S. government extrabudgetary support specifically for antitrafficking projects. 

Amounts do not reflect the U.S. government’s regular contributions to these organizations.

b

Amount of U.S. government funding to UNODC was based on GAO analysis of data provided by State 

G/TIP. Amount of total UNODC funding for antitrafficking projects was based on GAO analysis of data 

provided by State and UNODC.

c

Amounts of U.S. government funding and total ILO funding were provided by ILO.

d

Amounts of U.S. government funding and total IOM funding were provided by IOM. Totals were 

calculated, in part, on the basis of U.S. dollar amounts converted from other currencies using 

exchange rates as of May 2007. 

e

Amounts reflect donor pledge amounts provided by OSCE for a 2-year period (2004-2006), as of May 

2007. Funding amounts in Euros—552,617 and 4,387,454—were converted to U.S. dollars using a 

weighted average annual exchange rate for the period beginning 2004 and ending March 2007. 

According to GAO analysis of State G/TIP data, total U.S. funding for OSCE antitrafficking projects for 

the 4-year period from 2002 to 2006 was approximately $1.5 million.

f

Amounts reflect funding data provided by OAS’s Department of Public Security for its antitrafficking 

projects. In addition, according to State G/TIP data, USAID provided $367,150 to the OAS InterAmerican Commission on Women for antitrafficking projects in fiscal year 2003, and G/TIP provided 

$405,548 to implement an OAS coordinator’s antitrafficking activities in fiscal year 2004.

g

IDB also funded two countries’ security programs, one capacity-building project and one gender 

mainstreaming project, that each included antitrafficking components.

h

According to ADB, this amount was allocated to trafficking-specific activities included in five technical 

assistance projects. In addition, ADB included human trafficking prevention components in 16 

transport projects totaling $2.3 billion. The amount of trafficking-specific components in these projects 

was not available.

Regional organizations

Organization for 

Security and 

Cooperation in 

Europe (OSCE)e $0.69 (2004-2006) $5.50 (2004-2006)

Organization of 

American States 

(OAS)f 1.21 (2000 to present) 1.40 (2000 to present)

Multilateral development banks

Inter-American 

Development Bank 

(IDB)g $1.43

Asian Development 

Bank (ADB)h 1.69

(Continued From Previous Page)

Dollars in millions

U.S. government 

funding for 

antitrafficking projectsa

Total funding for 

antitrafficking projects from the 

United States and other donors
Page 10 GAO-07-1034 Human Trafficking

Some U.S. agencies and international organizations have provided 

assistance that, although not specifically related to human trafficking, may 

help to combat trafficking by reducing individuals’ vulnerability to 

becoming victims and by strengthening countries’ judicial systems. For 

example, USAID, the World Bank, the Asian Development Bank, and the 

Inter-American Development Bank have implemented projects to root out 

corruption, build host governments’ legal systems, and improve the 

economic conditions of vulnerable populations in developing countries. 

See appendix II for additional information on international organizations’ 

missions and antitrafficking activities. 

U.S. Agency and 

International Organizations’ 

Monitoring and Evaluation 

Requirements Vary

Monitoring and evaluation are important tools for managing projects and 

should be considered when designing projects. Performance measurement 

involves developing a logic framework to explain how an intervention is to 

achieve its intended outcomes. Monitoring helps agencies determine 

whether the project is meeting its goals, update and adjust interventions 

and activities as needed, and ensure that funds are used responsibly. 

Monitoring includes, among other things, the development of indicators 

that are linked as closely as possible to the variables identified in the logic 

framework. These indicators are to be used throughout implementation to 

assess whether the project is likely to achieve the desired results. 

Monitoring also involves the choice of baseline and target values for each 

indicator and includes plans for periodic performance reports and data 

quality reviews. Evaluation is needed to assess a project’s impact or 

effectiveness. Project evaluation involves the development of a 

methodology that will be used to assess the project’s impact and describes 

plans for collecting baseline, interim, and final data on project results. 

The TVPA requires the President’s Interagency Task Force to Monitor and 

Combat Trafficking in Persons to measure and evaluate the progress of the 

U.S. government’s efforts to combat trafficking. The Trafficking Victims 

Protection Reauthorization Act of 2003 (TVPRA 2003) includes a 

congressional finding that additional research is needed to fully understand 

the phenomenon of trafficking in persons and to determine the most 

effective strategies for combating trafficking. The TVPRA 2003 also 

requires an annual report from the U.S. Attorney General to Congress to 

provide information on U.S. government activities to combat trafficking in 

persons. In addition to these reports, Justice began preparing annual 

assessments of U.S. government activities to combat trafficking in persons 

in 2003. All six U.S. organizations’ guidelines also require implementers to 

monitor and report on project performance. In addition, Labor also 
Page 11 GAO-07-1034 Human Trafficking

requires independent midterm and final evaluations for all international 

antitrafficking projects. 

Organizations Have 

Taken Steps to 

Collaborate, but 

Continue to Face 

Challenges 

Global, regional, and country-level organizations recognize the importance 

of collaborating to effectively combat human trafficking. Although 

organizations involved in combating trafficking—governments, multilateral 

organizations, and donors—have implemented some practices to 

strengthen collaboration, to succeed they will need to overcome challenges 

that can impede collaboration, including varying levels of government 

commitment and capacity. 

Global, Regional, and 

Country-Level 

Organizations Recognize the 

Importance of Collaborating 

to Effectively Combat 

Human Trafficking

At the global level, several UN organizations have acknowledged the 

importance of collaborating to effectively combat human trafficking. The 

UN Chief Executives Board10 recognized the challenges in countering 

human trafficking and proposed establishing an interagency mechanism to 

strengthen coordination in 2005. In July 2006, a UN Economic and Social 

Committee resolution requested that UNODC organize a meeting to 

coordinate the technical assistance that UN and other intergovernmental 

organizations provide. In December 2006, the UN General Assembly 

adopted a resolution recognizing that broad international cooperation 

between member states and intergovernmental and nongovernmental 

organizations is essential for effectively countering the threat of human 

trafficking, and underlined the importance of bilateral, subregional, and 

regional partnerships, initiatives, and actions. This resolution further 

encouraged member states to initiate and develop working-level contacts 

among countries of origin, transit, and destination, especially among 

police, prosecutors, and social authorities. 

Organizations at the regional level have also recognized the importance of 

collaboration. For example, in a September 2006 report, the Organization 

for Security and Cooperation in Europe’s (OSCE) antitrafficking unit noted 

that, since trafficking is a transnational crime, collaboration is crucial to 

enable transnational mechanisms of communication and cooperation 

among governments, law enforcement, judiciary, and NGOs. In addition, six 

10The Chief Executives Board furthers coordination and cooperation on substantive and 

management issues facing UN system organizations. The board brings together on a regular 

basis the executive heads of the organizations of the UN system, under the chairmanship of 

the UN Secretary General.
Page 12 GAO-07-1034 Human Trafficking

countries in the Mekong subregion of Southeast Asia have called for 

strengthened cooperation to combat human trafficking under a process 

called the Coordinated Mekong Ministerial Initiative Against Trafficking 

(COMMIT). 

At the country level, donor governments and UN organizations have also 

recognized the need to establish coordination mechanisms to, among other 

things, share information and leverage the comparative advantages of each 

organization. The Paris Declaration of Aid Effectiveness11 establishes the 

importance of donor coordination, stating that excessive fragmentation of 

aid at the global, country, or sector level impairs its effectiveness. It further 

states that a pragmatic approach to the division of labor and burden 

sharing increases complementarity and can reduce costs. Through the 

declaration, donors committed to make use of their respective comparative 

advantage at a sector or country level by delegating authority to lead 

donors for the execution of projects, activities, and tasks. To draw on the 

collective strengths of the UN agencies and programs operating in a 

country, UN country teams and the host government develop a national 

analysis, called a common country assessment. They subsequently produce 

a national development assistance framework, which describes the 

collective UN response and the expected results to achieve national 

priorities.

For U.S. government agencies, a 2002 presidential directive stated that 

strong coordination among agencies working on domestic and foreign 

policy is crucial.12 The directive called for departments and agencies to 

coordinate U.S. foreign assistance programs, including those that provide 

funding to governmental or nongovernmental organizations to combat 

trafficking in persons. State officials told us that this is done through the 

Senior Policy Operating Group (SPOG), which, among other activities, 

facilitates a review by SPOG programming agencies of each other’s grant 

proposals for antitrafficking projects. 

11The Paris Declaration, endorsed on March 2, 2005, is an international agreement under the 

Organization for Economic Cooperation and Development that aims to provide a practical, 

action-oriented road map to improve the quality of aid and its impact on development. The 

56 partnership commitments are organized around 5 key principles: ownership, alignment, 

harmonization, managing for results, and mutual accountability. The United States is one of 

the participating countries.

12National Security Presidential Directive 22 (signed on Dec. 16, 2002).
Page 13 GAO-07-1034 Human Trafficking

Organizations Face 

Challenges in Collaborating 

to Combat Trafficking

Organizations—governments, multilateral organizations, and NGOs—face 

several challenges in collaborating to combat human trafficking, including 

the following:

• Government commitment varies. State’s annual Trafficking in Persons

Report, which analyzes and ranks foreign governments’ compliance 

with minimum standards to combat trafficking, as outlined in the TVPA, 

illustrates governments’ varied efforts to address the issue. For 

example, governments might not recognize trafficking as a problem. 

They may treat foreign trafficking victims as illegal immigrants and 

deport them back to their home countries, rather than protect them. 

They also may not recognize trafficking within their own borders as a 

problem. Moreover, some government officials are themselves involved 

in human trafficking.

• Government capacity varies. Governments with greater resources and 

more established institutions have a greater capacity to address 

trafficking than countries that are poorer or less stable. In addition, 

changes in government leadership and personnel, due to elections, 

coups, assassinations, or other events, may result in the loss of expertise 

in combating human trafficking. Furthermore, governments may put 

trafficking under the purview of ministries with limited authority, such 

as women’s ministries.

• Organizations that combat trafficking vary in perspective and may be 

in competition for limited funds. Combating trafficking involves 

organizations—at the international and country levels—with expertise 

in raising awareness, assisting child and adult victims, and investigating 

trafficking cases, among other areas. Organizations may view trafficking 

through their own mandates or viewpoints and may perceive each other 

not only as collaborators but also as competitors for scarce resources. 

As such, they may not share information, which could lead to 

duplication and waste of funds.13

• Understanding of trafficking varies across languages and cultures. 

Countries approach trafficking in different ways. For example, some 

countries’ national antitrafficking strategies do not include men as 

Given the large number of organizations

involved, collaboration is crucial to combating 

human trafficking. As we have previously 

reported, organizations can enhance and 

sustain their collaborative efforts by engaging in 

the following practices:

• Define and articulate common outcomes.

• Establish mutually reinforcing or joint 

strategies.

• Identify and address needs by leveraging 

resources.

• Agree on roles and responsibilities.

• Establish compatible policies and procedures

and other means to operate across agency 

boundaries.

• Develop mechanisms to monitor, evaluate, 

and report on the results of the collaborative 

effort.

• Reinforce agency accountability for 

collaborative efforts through agency plans 

and reports.

• Reinforce individual accountability for 

collaborative efforts through performance 

management systems.

All of these practices may not necessarily apply 

to all levels of collaboration; individual 

circumstances should determine which 

practices and what level of detail are needed. 

Factors such as leadership and trust are also 

necessary conditions for establishing, 

sustaining, and reinforcing a collaborative 

culture.

Some Practices Can Help Enhance and 

Sustain Collaboration 

Source: GAO, Results-Oriented Government: Practices That 

Can Help Enhance and Sustain Collaboration among Federal 

Agencies, GAO-06-15 (Washington, D.C.: Oct. 21, 2005).

13UN Chief Executives Board High Level Committee on Programs, Follow-up to CEB/HLCP 

decisions: Curbing Transnational Crime, CEB/2004/HLCP/VIII/CRP (Sept. 9, 2004).
Page 14 GAO-07-1034 Human Trafficking

potential trafficking victims; also, in some countries, parents in villages 

often sell their children to work as domestic servants in large cities. 

Furthermore, translation issues can complicate establishing a common 

understanding of what constitutes trafficking. For example, although 

the legal term in Spanish for human trafficking is “trata de personas,” 

English speakers have translated human trafficking into Spanish as 

“tráfico de personas,” which in fact means human smuggling. 

Organizations Have Taken 

Steps to Strengthen 

Collaboration, but 

Challenges Remain at the 

Global, Regional, and 

Country Levels

Global and Regional 

Collaboration Efforts Have 

Recently Been Initiated

Organizations at the global level have defined a common outcome—to end 

human trafficking and slavery—and have recently initiated various efforts 

to strengthen collaboration. In March 2007, UNODC launched the Global 

Initiative to Fight Human Trafficking to generate political will, an action 

plan, and financial resources to combat trafficking worldwide. The steering 

committee of the initiative includes the six leading international 

organizations involved in combating trafficking in persons: UNODC, ILO, 

IOM, UNICEF, OSCE, and the Office of the United Nations High 

Commissioner for Human Rights. UNODC also created the Interagency 

Cooperation Group Against Trafficking in Persons in September 2006 with 

the intended outcome of improving coordination between UN agencies and 

other international organizations, and to facilitate a holistic approach to 

preventing and combating human trafficking. The group’s functions include 

exchanging information and promoting the effective and efficient use of 

resources. 

Most existing regional coordination efforts that we reviewed have defined a 

common outcome and established action plans for carrying out 

antitrafficking activities. These efforts vary regarding whether they are 

specifically directed against trafficking or are included in discussions on 

migration or smuggling. In addition, they vary in number of participating 

members from as few as 6 countries in the Mekong subregion to as many as 
Page 15 GAO-07-1034 Human Trafficking

56 countries in Europe, Asia, and North America. For example, the 

governments involved in a UN project that specifically focused on 

strengthening cooperation to combat trafficking in the Mekong subregion 

have agreed to undertake 18 actions to combat human trafficking, as part 

of an effort called the COMMIT process. Officials stated that this 

agreement strengthens these countries’ incentives to undertake the actions 

through mutual accountability. In addition, COMMIT developed an action 

plan that groups existing activities into a single framework delineating 

roles and responsibilities of UN organizations, implementing partners, and 

governments in the six Mekong countries. Officials contrasted the 

COMMIT process, which includes a small group of countries in one region 

with interconnected trafficking problems, to larger organizations such as 

the Bali Process, which approaches trafficking issues in conjunction with 

issues related to smuggling in the Asia-Pacific region and has a larger 

geographic scope, consisting of 38 governments across several regions. 

These officials stated that having a larger geographic scope makes it more 

difficult for the governments of these countries to hold each other 

accountable for implementing the regional action plan. In addition to these 

examples, OSCE initiated the Alliance against Trafficking in Persons, which 

established a partnership with major actors working to combat human 

trafficking to, among other things, develop joint strategies and provide 

OSCE participating states and others with harmonized decision-making 

aids. In Southeastern Europe, the International Center for Migration Policy 

Development has begun a project to facilitate the creation of a 

transnational referral mechanism by 10 governments in the region and 

national NGOs to improve transnational case management and victim 

protection. Furthermore, in the western hemisphere, the Organization of 

American States (OAS) held a conference in 2006 that resulted in guidelines 

for the 34 member states and OAS to combat human trafficking.

Organizations continue to face obstacles as they work on global and 

regional initiatives to collaborate to combat trafficking. For example, 

governments disagree on whether there is a difference between “forced” 

and “voluntary” prostitution. Such disagreements can hinder collaborative 

efforts in combating sex trafficking. These global and regional initiatives 

may eventually implement additional practices to enhance collaboration, 

but it is too early to determine the success of the current initiatives.
Page 16 GAO-07-1034 Human Trafficking

Country-Level Organizations 

Have Taken Some Steps to 

Strengthen Collaboration, but 

Continue to Face Difficult 

Challenges

Although organizations—including host governments, UN organizations, 

U.S. government agencies, and other donor governments—in the three 

countries we visited have implemented practices to strengthen 

collaboration in combating trafficking, they continue to face challenges. 

None of the three countries has mechanisms to coordinate the efforts of all 

organizations involved in combating trafficking. Host governments bear 

ultimate responsibility for combating trafficking within their borders, and 

governments of the countries we visited have taken some steps to 

collaborate. For example, the Indonesian and Thai governments have 

passed national antitrafficking laws and enacted national action plans that 

define common outcomes, outline strategies, and assign roles and 

responsibilities. However, neither government’s action plan includes 

trafficking of men in its definition of human trafficking. Officials in 

Indonesia stated that they expect to revise the plan to include the 

trafficking of men, as well as women and children, based on legislation 

passed in 2007. Although both the Indonesian and Thai governments hold 

interagency meetings, the ministries responsible for coordinating 

antitrafficking efforts have limited authority and operational capacity, 

according to officials we interviewed. Unlike Indonesia and Thailand, 

Mexico has neither a national antitrafficking law nor an action plan. 

Mexican officials stated that they convened one interagency meeting on 

human trafficking and plan to institute additional coordination 

mechanisms after the government passes a national antitrafficking law.

In Indonesia and Thailand, UN organizations, in conjunction with host 

governments, have developed country assessments and assistance 

frameworks to articulate overall development goals—including combating 

trafficking—joint strategies, and roles and responsibilities. UN 

organizations working on trafficking in Thailand also meet as part of the 

Mekong regional project that we previously discussed; although, according 

to one donor government official, attendance among UN organizations is 

sporadic. UN officials in Indonesia told us that they share information 

informally, but do not meet on a regular basis to discuss trafficking.

According to U.S. government officials in Indonesia and Thailand, donor 

governments have made sporadic and informal efforts to leverage 

resources and avoid duplication of effort.14 For example, as a result of 

informal coordination, Justice and French government officials worked 

14The United States is the only government donor that implements antitrafficking projects in 

Mexico.
Page 17 GAO-07-1034 Human Trafficking

together on a criminal justice training project in Indonesia. In Thailand, 

according to a U.S. official, although most of the major donors attend the 

Mekong regional project’s meetings, these meetings are generally focused 

on UN activities, with little opportunity for donors to coordinate. Officials 

in Indonesia and Thailand acknowledged the need to establish regular 

bilateral donor coordination efforts on trafficking issues and, at the time of 

our fieldwork, had begun discussing the establishment of regular 

coordination meetings. 

While U.S. government agencies overseas have developed some 

collaboration mechanisms to combat trafficking, they continue to face 

challenges in coordinating their efforts. The U.S. embassies in the three 

countries we visited, Indonesia, Thailand, and Mexico, include trafficking 

in persons in their mission performance plans, which establish combating 

trafficking as a component of the U.S. government’s overall strategy in each 

country. U.S. officials in these countries told us they organize traffickingspecific meetings that include U.S. government agencies and their 

implementing partners, primarily to share information. The U.S. 

government officials who were involved in antitrafficking issues were 

responsible for other issues as well. In Indonesia, for example, the primary 

U.S. embassy contact for trafficking was also temporarily assigned deputy 

chief of mission in East Timor. In Mexico, one agency official, whose 

responsibilities consisted solely of human trafficking issues, had been 

named to also serve as coordinator and primary contact for all U.S. 

antitrafficking efforts. After this official's departure in December 2006, her 

portfolio was added to the existing portfolio of another official from the 

same U.S. agency. At the time of our visit in February 2007, State, USAID, 

and DHS officials, who also covered other issues, were holding meetings to 

coordinate their antitrafficking efforts internally. However, a new U.S. 

antitrafficking coordinator for Mexico had not been designated. 

Consequently, some Mexican government officials expressed uncertainty 

about which U.S. agency official had the role of lead U.S. government 

coordinator for trafficking in Mexico.

Furthermore, some U.S. government officials noted challenges in 

coordinating between officials in Washington, D.C., and those overseas. 

For example, a U.S. official in Thailand was unaware of a U.S.-funded 

project in the country until that project hosted a conference and requested 

additional funding from the U.S. embassy. The project had not been 

included in the list of antitrafficking activities in Thailand that the official 

received from State’s trafficking office, which is based in Washington. 

According to some agency officials overseas, not knowing what other 
Page 18 GAO-07-1034 Human Trafficking

agencies and bureaus plan to spend on antitrafficking activities in a 

particular country makes it difficult for them to determine how much of 

their budgets to allocate to antitrafficking activities. Although State’s new 

Office of Foreign Assistance has begun to address the issue of better 

coordinating all U.S. foreign assistance by bringing together core State and 

USAID teams to discuss U.S. development priorities in each recipient 

country, some U.S. officials expressed uncertainty regarding which part of 

the U.S. government would be responsible for outlining a new country-level 

strategy and budget for combating trafficking.

U.S. GovernmentFunded Antitrafficking 

Projects Lack Some 

Key Monitoring 

Elements; Little Is 

Known about Project 

Impact Due to 

Difficulties in 

Conducting 

Evaluations

Antitrafficking project documents we reviewed generally include 

monitoring elements, such as an overarching goal and related activities; 

however, they often lack other monitoring elements, such as targets for 

measuring performance. Various other factors also make it difficult to 

evaluate the impact of antitrafficking projects. These factors include 

questionable estimates of the number of trafficking victims at the project 

level, which are needed to evaluate the effectiveness of specific 

antitrafficking interventions. Certain project elements may further impede 

evaluations, including short time frames and overly broad objectives. 

Because of these factors, few evaluations that determine impact have been 

completed. As a result, little is known about the impact of antitrafficking 

interventions. 

U.S. Government-Funded 

Antitrafficking Projects 

Lack Some Important 

Monitoring Elements; State 

Is Taking Steps to 

Strengthen Monitoring

Most of the project documents we reviewed generally include one or more 

monitoring elements, but lack others. We reviewed documents for 23 U.S. 

government-funded antitrafficking projects in Indonesia, Thailand, and 

Mexico, which generally include statements of project goals and a 

description of activities.15 However, the majority of these documents lack a 

logic framework that clearly links activities with project-level goals, 

indicators, and targets. Specifically:

15To inform our site visits in Mexico, Indonesia, and Thailand, we requested project 

documents for U.S.-funded antitrafficking projects that were being implemented during the 

time of our review. These documents are not generalizable to a larger universe. We received 

documents for 23 projects. The projects are illustrative of the U.S. agencies' currently 

applied monitoring practices. The 23 projects were funded or implemented by 6 U.S. 

agencies: State (11), Labor (4), USAID (3), Justice (2), HHS (2), and DHS (1). 
Page 19 GAO-07-1034 Human Trafficking

• Eighteen of the 23 projects do not clearly explain how activities will 

achieve stated goals. For example, the project proposal for a Statefunded project in Thailand does not provide clear linkages 

demonstrating how the training of local officials and screenings of a 

public awareness video will achieve the project’s overall goal of 

reducing trafficking among vulnerable adolescents and women. In 

contrast, all 4 Labor-funded projects in Indonesia, Mexico, and Thailand 

clearly link project goals and activities. For example, 1 goal of a project 

in Mexico is to develop a system to identify networks of exploiters. 

Activities to achieve this goal include developing computer software 

and training government officials in its use.

• Twenty-one of the 23 projects identify indicators, but of these, only 10 

specify targets by which performance is measured. For example, a 

State-funded project in Thailand included the “number of victims 

rescued” and the “number of arrests of traffickers” as performance 

indicators, but did not set numerical targets for measuring performance. 

In contrast, a State-funded project implemented by IOM in Indonesia 

established an expected result that 500 victims of trafficking receive 

rehabilitation and reintegration assistance. For the 13 projects that did 

not specify targets, the performance standards to which grantees were 

held accountable were not clear. Of the 10 projects that did specify 

targets, 5 explained how targets were set. These 5 projects included all 4 

of the Labor projects we reviewed. 

Another element of monitoring project performance is to supplement 

implementing partners’ reporting of programmatic and financial progress 

with independent review through site visits at the field level. For example, 

Labor officials reported that the International Labor Affairs Bureau’s Office 

of Child Labor, Forced Labor, and Human Trafficking has engaged ILO’s 

external auditor to conduct audits of a sample of ILO’s international 

program for the elimination of child labor projects. This office also has 

contracted with a certified public accounting firm to conduct independent 

attestation engagements of its Education Initiative projects. Among the 

objectives of these audits and attestation engagements is an assessment of 

the accuracy and reliability of performance data from grantees’ progress 

reports. 
Page 20 GAO-07-1034 Human Trafficking

State G/TIP has 4 Washington, D.C.-based staff members who are 

responsible for overseeing projects in approximately 70 countries.16 G/TIP 

officials stated that because they cannot visit all of the projects, they rely 

on U.S. embassy staff to provide additional field-level oversight. However, 

the office has not established written guidance for conducting such 

oversight. During our fieldwork, an embassy official expressed frustration 

at the lack of clear guidance and procedures. Embassy officials also told us 

that they meet with project staff, but have other responsibilities that limit 

the time they can devote to overseeing antitrafficking projects. According 

to State’s Bureau of Population, Refugees,and Migration (PRM) officials, 

the bureau has only 3 staff to monitor and oversee its antitrafficking 

projects currently being implemented in over 20 countries, and these staff 

cannot conduct site visits to all projects. PRM staff also stated that they 

review progress reports submitted by project implementers, but do not 

have a database or system for compiling the information they receive from 

the field. 

To address some of these concerns, State officials told us that they are 

taking steps to strengthen monitoring, including developing new indicators 

and written guidance for monitoring antitrafficking projects. State G/TIP 

officials told us that they are developing a system of key indicators to 

better inform management decision making that would be consistently 

used for each of the three main types of antitrafficking programs—

prevention, protection, and prosecution. State PRM and IOM, its key 

implementing partner, have also been involved in an effort to develop and 

standardize an indicator framework across IOM missions, although this 

effort was not completed during the time of our review. Officials stated that 

this effort will serve as a way to exchange ideas about best practices in 

different parts of the world and will provide managers with information on 

implementation needed to make decisions about current or future projects. 

Factors Impede Evaluations 

of Antitrafficking Projects 

and Little Is Known about 

Project Impact 

Various factors impede impact evaluations of antitrafficking projects. First, 

data on human trafficking are questionable, including estimates of the 

number of trafficking victims, making it difficult to determine a preproject 

baseline. Second, elements of project design, such as overly broad 

objectives or short project duration, diffuse potential impact. Because of 

these factors, it has been difficult to evaluate the effectiveness of 

16State G/TIP officials told us that the office has had 4 program officers for only a few 

months. For more than a year, the office had 2 or fewer officers. 
Page 21 GAO-07-1034 Human Trafficking

antitrafficking interventions, and few evaluations that determine impact 

have been completed. As a result, little is known about the impact of 

antitrafficking interventions. 

Lack of Project-Level Baseline 

Estimates Limits Evaluations 

The lack of accurate baseline estimates of the number of trafficking victims 

is a limitation to conducting evaluations. As we have previously reported, 

the accuracy of current estimates is questionable.17 Without estimates of 

the scope of human trafficking to use as baselines in project locations, it is 

very difficult to determine where interventions are most needed or where 

interventions would have the greatest impact. Developing baseline 

estimates is difficult for the following reasons:

• Victims are a hidden population. Victims may be unaware, unwilling, 

or unable to acknowledge that they are trafficking victims. Therefore, it 

is difficult to reach them to collect information using standard sampling 

techniques.

• Service providers may be unwilling to share victim data due to 

confidentiality concerns. For example, the global database maintained 

by IOM18 is not publicly available since assisted victims are in a 

precarious position and revealing their identity could have a detrimental 

effect on their safety.19

• The definition of the term “trafficking in persons” is broad and varies 

in meaning across different languages. As we previously discussed, 

the understanding of trafficking varies across languages and cultures. 

These variations in definition hinder the comparability of data across 

countries and organizations. 

• There are no commonly agreed-upon criteria for identification of 

human trafficking victims. This lack of criteria hinders the ability to 

17GAO-06-825.

18IOM has the only global database, which contains systematically collected standardized 

data on actual victims assisted by IOM. According to IOM, 30 missions input data into the 

global database in 2007. The information covers information about trafficked victims from 

more than 100 source and destination countries. 

19In commenting on a draft of this report, IOM noted that it can share with external parties 

nonpersonal aggregate data from the database upon written request. The IOM CounterTrafficking Division also produces quarterly statistical reports based on the data from the 

database.
Page 22 GAO-07-1034 Human Trafficking

identify victims, create consistent statistical databases, and design 

analytical tools for surveys and estimates.20

• Existing data may not be reliable. Developing countries, which are 

typically the countries of origin, have limited capacity for data 

collection, and their governments’ commitment to combating trafficking 

may be insufficient. Thus, sufficiently reliable data needed for 

estimating trafficking incidence may not be available. 

Elements of Project Design 

Impede Evaluations

Elements in the design of certain antitrafficking projects, including a 

tendency to focus on very broad, high-level objectives across a diverse 

range of activities, diffuse projects’ potential impact and create challenges 

for evaluations. 

When projects focus on overly broad objectives and contain too many 

types of activities, their potential impact is diffused, which makes them 

difficult to evaluate.21 For example, some antitrafficking projects have very 

high-level goals or objectives, such as “creating an environment for 

effective action against trafficking,” or “strengthening the initiatives of 

government and others against human trafficking” and contain activities 

covering 2 or more of the 3 key types of antitrafficking interventions—

prevention, protection, and prosecution. Of 153 U.S. international 

antitrafficking projects funded in fiscal year 2004, 2005, or 2006, 56 percent 

included 2 or more of these interventions and 29 percent included all 3 

interventions. Activities included public awareness campaigns, victim 

assistance, and training for law enforcement officials.

While projects funded with greater resources could lead to more noticeable 

longer-term changes, the impact of a shorter-term, smaller-scale 

intervention may be difficult to attribute and quantify. Antitrafficking 

projects vary significantly in terms of their time frames and funding levels. 

For example, the projects we reviewed varied in duration from 1 year to 

20G/TIP, in collaboration with PRM, IOM, and other organizations, is currently developing 

core indicators in an attempt to work toward commonly agreed-upon criteria for victim 

identification and assistance as well as for data collection and analysis.

21In commenting on a draft of this report, ILO suggested that it is useful to clearly define the 

scope of the impact that can be measured within the time frame and levels of results. For 

example, the expected impact on trafficking differs depending on whether one is looking at 

one project only, a collection of projects from one source of funding within a country, all of 

the projects and activities within a country, or the impact of all projects in all countries from 

one source of funding.
Page 23 GAO-07-1034 Human Trafficking

about 4 years, and projects’ funding levels varied from $15,000 to $6 

million. Officials stated that some organizations, such as State G/TIP, tend 

to fund smaller, shorter-term projects, while Labor usually funds larger, 

longer-term projects. Overall, experts told us that organizations also have 

generally limited funding for impact evaluations and for research on the 

nature and scope of human trafficking. 

Experts stated that another factor impeding evaluations is that little 

attention has generally been devoted at the start of projects to evaluation 

design. For example, questions related to determining the control group, 

the type of design for impact evaluation, the data that would be collected, 

and the analytical methods that would be most suitable are often not 

addressed before implementation. Furthermore, experts stated that 

although projects target several groups of beneficiaries, it is generally 

unclear how they can be reached and to which group they would be 

compared. As a result, it is difficult to determine what would constitute 

successful project implementation. 

Little Is Known about Project 

Impact

Because of the difficulties in evaluating antitrafficking projects, the few 

evaluations that have been completed are qualitative rather than 

quantitative, focus on process rather than impact, and rarely trace victims 

over time. 

The few evaluations completed used qualitative methods that are valuable 

for documenting victims’ perceptions and experiences, but, unlike 

quantitative methods, they cannot be used to generalize results to broader 

populations.22 For example, IOM’s Office of Inspector General has carried 

out impact evaluations of a select number of antitrafficking projects. Our 

review of these evaluations shows that they covered interventions in 

various parts of the world funded by different donors. All of the available 

evaluations applied qualitative methodologies, consisting of document 

reviews, site visits, interviews, and focus groups with stakeholders. In 

addition, in a USAID-funded assessment of child trafficking victims 

residing at a shelter in Nepal, an evaluator used qualitative methods, such 

as observations and interviews, to collect information on their daily lives, 

needs, and preparation for reintegration into the community. The evaluator 

concluded that skill-based training provided by the shelter does not 

adequately prepare the girls for their reintegration into their communities; 

22Agencies have required or employed various qualitative methodologies such as interviews, 

focus group discussions, direct observation techniques, and rapid assessment techniques.
Page 24 GAO-07-1034 Human Trafficking

however, this qualitative result could not be generalized to the national 

level.

Completed evaluations also typically focused on process rather than 

impact.23 Process evaluations are an important tool for improving service 

delivery and assessing program effectiveness by assessing whether 

activities conform to program design. Impact evaluations assess the net 

effect of a program by comparing program outcomes with an estimate of 

what would have happened in the absence of the program. However, 

impact evaluations are an emerging field in antitrafficking interventions. 

For example, a process evaluation of a Labor-funded project aimed at 

reducing the victimization of minors who have been trafficked or are at risk 

of being trafficked in Thailand focused on the project’s planning, 

implementation, and management. This process evaluation was designed to 

monitor implementation and assess project outcomes. However, the 

evaluation did not ultimately assess the project’s impact in reducing the 

victimization of minors. 

Finally, our review identified few evaluations that track individual victims 

who have been reintegrated into their communities over time. For example, 

ILO is currently pilot-testing an application of a tracer study methodology 

in the context of trafficking prevention. In addition, according to Labor 

officials, in some cases the office has conducted follow-up studies that 

examine a sample of beneficiaries to document changes that have 

occurred. Furthermore, IOM officials noted that several of its missions 

provided statistical information to gauge the success of its victim 

reintegration efforts over time based on specific indicators.24 According to 

experts, such evaluations are costly and time-consuming. Tracking victims 

by country can also be difficult because country boundaries are permeable 

and many trafficking routes cross national borders. 

23According to GAO’s Performance Measurement and Evaluation: Definitions and 

Relationships, GAO-05-739SP (Washington, D.C.: May 2005), there are four types of 

evaluations: process, outcome, impact, and cost-benefit analysis. 

24For example, according to IOM officials, IOM’s mission in Kiev uses indicators such as 

employment rates, reinsertion into the educational system, return abroad, and retrafficking 

as tools for its caseload management by identifying more-effective mechanisms for victim 

identification and referral.
Page 25 GAO-07-1034 Human Trafficking

Expert Panel Identified 

Ways to Address the 

Difficulties of 

Monitoring and 

Evaluating 

Antitrafficking Projects

A GAO-convened panel of experts identified and discussed ways to address 

the factors that make it difficult to monitor and evaluate antitrafficking 

projects. Panelists suggested approaches to improve the monitoring and 

evaluation of antitrafficking projects, by improving information on the 

severity of human trafficking and addressing weaknesses in the design of 

antitrafficking projects. 

Conduct Research on the 

Nature and Severity of 

Human Trafficking

Panelists acknowledged that the lack of existing data on the nature and 

severity of human trafficking limits evaluations of antitrafficking projects, 

and suggested ways to improve information on the nature and severity of 

human trafficking. According to the panelists, researchers need to gather 

evidence to answer the following questions: 

• What is the nature and severity of human trafficking? Panelists stated 

that it is necessary to understand the nature of trafficking in terms of its 

underlying conditions and the types of traffickers and victims. 

Trafficking is a multidimensional, complex problem that involves a wide 

range of victims; recruiters, brokers, and intermediaries; and abusive 

employers and sexual exploiters. Understanding the incentives of the 

people engaged in trafficking is an important first step. 

The severity of human trafficking can be measured by using qualitative 

and quantitative methodologies. Panel members suggested several 

sampling methods that have been used to sample other hard-to-reach 

populations, including the homeless, hidden migrants, missing and 

exploited children, domestic violence victims, inmates, and drug users. 

One suggested method is sampling of “hot spots”—an intensive search 

for victims in areas known to have high concentrations of victims or in 

areas to which many victims return. Other methods include adaptive 

cluster, double, indirect, and snowball sampling. (For a more detailed 

discussion of sampling methods, see app. III.) These methods could be 

used individually or in combination. Panelists further emphasized that, 

whenever feasible, it is important to use methodologies that are 

appropriate for the location sampled. In addition, it is critical to 

determine whether the results are unique to a certain location or 

whether they can be generalized to other locations. Panelists 

recommended that research start at the local level. Such research would 

identify successful small-scale interventions, increase the knowledge of 
Page 26 GAO-07-1034 Human Trafficking

victims’ needs, and develop meaningful performance measures. Lessons 

learned at the local level could then be expanded to national and 

regional levels. 

• What is the projects’ estimated effect on the nature and severity of 

human trafficking? Panelists emphasized the necessity of designing 

rigorous methods to evaluate antitrafficking projects, such as 

randomized control trials.25 For example, as baseline estimates in 

trafficking hot spots are obtained and interventions are undertaken in 

that location to reduce trafficking, the use of “place-randomized trials”26

for evaluation would become possible. To determine the interventions’ 

impact, data obtained from interventions in hot spots could then be 

compared with locations where there had been no interventions. 

Although randomized trials may be difficult to execute for many 

trafficking projects, they are important ways to generate evidence about 

interventions’ effectiveness. Randomized trials should be pilot-tested in 

carefully chosen settings so that the evaluator can identify and correct 

any problems encountered before expanding the trials to larger 

populations or areas. Panelists pointed out that such rigorous evaluation 

has occurred in the fields of public health and criminal justice. For 

example, a randomized study was done of brothels in Thailand to obtain 

information on the HIV/AIDS rates of prostitutes. 

Address Monitoring and 

Evaluation Weaknesses in 

the Design of Antitrafficking 

Projects 

To address weaknesses in project design that impede monitoring and 

evaluation, such as projects with very broad, high-level objectives, 

panelists made the following recommendations:

25According to the Office of Management and Budget (OMB), randomized control trials meet 

the highest standards of impact evaluation and should be used whenever feasible. As 

defined by OMB’s guidance, a randomized controlled trial is “a study that measures an 

intervention’s effect by randomly assigning individuals or other units into an intervention 

group, which receives the intervention, and into a control group, which does not. At some 

point following intervention, measurements are taken to establish the difference between 

the intervention group and the control group.” However, randomized controlled trials are 

not suitable for every program and generally can be employed only under special 

circumstances. See OMB, “What Constitutes Strong Evidence of a Program’s Effectiveness?” 

(http://www.whitehouse.gov/omb/part/2004_program_eval.pdf).

26A place-randomized trial is a study in which a number of places are randomly assigned to 

two or more interventions to learn which intervention works best.
Page 27 GAO-07-1034 Human Trafficking

• Develop a logic framework. Given the weaknesses of some 

antitrafficking projects that have overly broad objectives across a 

diverse range of activities, panelists suggested that officials design 

projects with a logic framework that has clear objectives and narrow the 

focus of interventions. They also recommended that officials design 

projects that clearly link activities to intended outcomes, identify 

measurable indicators, and establish procedures for setting and 

modifying targets. Measurable indicators with mutually agreed-upon 

targets allow project officials to assess how a project is achieving its 

overall goals and objectives. For example, a Labor-funded project 

implemented by ILO in Mexico includes a logic framework that links 

project activities and outputs to outcome objectives, and includes clear 

indicators and means of verification. The project’s overall goal of 

eliminating the commercial sexual exploitation of children in Mexico 

links to four immediate objectives that, in turn, link back to project 

activities and outputs. One objective—that at least 300 child victims of 

sexual exploitation or at-risk children and their families receive 

assistance—is linked to 28 activities and 8 outputs, such as increasing 

families' employment opportunities. These 28 activities include 

disseminating employment promotion programs, organizing 

employment training, and monitoring and analyzing the impact of these 

dissemination and training efforts. Panelists emphasized that donors 

and implementers should agree on the project’s logic framework during 

the design phase. 

• Determine whether a project is ready to be evaluated. Given the 

significant variance in project duration and funding levels, panelists 

emphasized that evaluators would not be able to evaluate all existing 

projects, but should first determine which projects are ready to be 

evaluated. In conducting such “evaluability assessments,” evaluators 

determine, among other things, whether (1) the project is large enough, 

has sufficient resources, and has been implemented long enough to 

make an impact; (2) the project is reaching its target population; (3) 

project documents specify and clearly link objectives, goals, and 

activities; and (4) sufficient information exists to determine impact. For 

example, larger, long-term projects are more likely to have an impact 

and, thus, may be better candidates for evaluation than smaller, shortterm projects. Because larger antitrafficking projects generally include a 

diverse range of interventions, panelists suggested narrowing the 

evaluation to focus on discrete interventions or aspects of the project. 
Page 28 GAO-07-1034 Human Trafficking

• Build monitoring and evaluation into project design. Given that 

evaluation is not generally considered during design, panelists 

emphasized that project officials should consider how the project will 

be evaluated before the project is implemented. Most importantly, 

organizations need to define the project’s intended impact and how that 

impact will be measured. To do this, organizations would have to 

determine the project beneficiaries and to which group they would be 

compared, the data they would have to collect, and how they would 

analyze those data. Management would not only need to collect data 

during implementation to monitor if the project works according to 

plan, but also collect data before and after implementation to determine 

what works best.

Conclusions The United States has played an important role in combating global human 

trafficking and spurring other governments to increase their efforts in 

doing so. As organizations around the world increasingly collaborate in 

combating trafficking, their ultimate success will depend on the extent to 

which they are able to overcome difficult challenges, such as varying levels 

of government commitment and capacity, that have impeded collaboration 

in the past. More than 7 years after the passage of the UN protocol, little is 

known about which interventions have been the most effective in 

preventing human trafficking, protecting victims, and prosecuting 

traffickers.

The United States and other governments, international organizations, and 

NGOs continue their efforts to fight trafficking, but there is little 

information available to inform their decisions about project 

implementation and selection. Although antitrafficking projects contain 

some important elements for monitoring, they often lack other important 

elements for measuring performance on a real-time basis, such as targets. 

Such elements are critical in monitoring project performance to determine 

whether interventions are being implemented as expected, or whether they 

need to be changed to better combat human trafficking. Evaluation is also 

important in determining whether antitrafficking projects have been 

effective. However, few impact evaluations have been completed due to the 

difficulties involved. As a result, little is known about the impact of 

antitrafficking interventions. 

Given the grave personal suffering of victims and negative impacts on 

society that human trafficking creates, strengthening collaboration, 

monitoring performance, and evaluating impact are important to ensure 
Page 29 GAO-07-1034 Human Trafficking

that organizations fund antitrafficking interventions with the greatest 

impact, where they are most needed, and through the effective and efficient 

use of resources. 

Recommendations for 

Executive Action 

We recommend that the Secretaries of State and Labor and the 

Administrator of USAID improve the monitoring and evaluation of their 

projects to combat global human trafficking by considering the following 

actions, where appropriate:

1. Improve information about project impact on the nature and severity of 

human trafficking, including

• developing better data about the incidence of trafficking at the 

project level and

• applying rigorous evaluation methodologies.

2. Address monitoring and evaluation weaknesses in the design of 

antitrafficking projects, including 

• developing a framework that clearly links activities with project-level 

goals, indicators, and targets;

• conducting “evaluability assessments” to determine whether a 

project is ready to be evaluated; and

• building monitoring and evaluation into project design before the 

project is implemented.

We are addressing our recommendations to State, Labor, and USAID 

because they provided the most U.S. funding for projects to combat global 

human trafficking.

Agency Comments and 

Our Evaluation

We requested comments on a draft of this report from the Secretaries of 

State, Justice, Health and Human Services, Homeland Security, and Labor; 

the Administrator of USAID; and cognizant officials at UNODC, IOM, ILO, 

OAS, OSCE, the World Bank, IDB, and ADB or their designees. We received 

written comments from State, Labor, USAID, and HHS, which are reprinted 

in appendixes IV, V, VI, and VII along with our responses to specific points. 
Page 30 GAO-07-1034 Human Trafficking

In its comment letter, State noted that it will implement the 

recommendations in the report in ways that are relevant and appropriate to 

the mandates of the State offices working on antitrafficking efforts. State 

further noted that the recommendations are entirely consistent with the 

department’s current activities and direction. State also generally agreed 

that the antitrafficking field is well-served by more information about the 

nature and severity of human trafficking and recognized that effective 

project design is critical to successful project implementation and program 

monitoring and can lay the foundation for evaluation. However, State 

disagreed with our finding that monitoring is limited, stating that 

monitoring is in place at the department and improving. While we 

recognize that State and other U.S. agencies have certain elements of 

monitoring in place, we report that they lack others. For example, we 

found that for the 23 antitrafficking projects we reviewed, the majority do 

not have a logic model that clearly explains how activities are linked to 

project goals. In addition, the majority of these projects do not specify 

targets that will establish benchmarks for measuring performance. State 

also emphasized that many of its projects are designed to be of more 

limited size, scope, and duration than those of other agencies, such as 

Labor. State further noted that these projects of limited duration are 

worthy of funding, but are not necessarily appropriate for evaluation. In the 

report, we state that the impact of a shorter-term, smaller-scale 

intervention may be difficult to attribute and quantify. 

Labor commented that the report provides a good overall assessment of 

international cooperation and the need to enhance collaboration among 

key agencies and governments regarding antitrafficking efforts. Labor also 

commented that the report highlights important areas for improving 

monitoring and evaluation of U.S.-funded antitrafficking programs. 

However, Labor stated that the report does not fully reflect efforts 

particular federal agencies are taking in the monitoring and evaluation of 

antitrafficking projects. As an example, Labor stated that it uses several 

mechanisms, including audits and process evaluations, in its monitoring 

and oversight of international technical assistance projects, including 

antitrafficking projects, to ensure that U.S. funds lead to planned outputs 

and results. In response, we made additions or revisions to the text to 

further clarify Labor’s monitoring and evaluation efforts. We believe the 

overall monitoring of antitrafficking projects is limited because the 

projects funded by the other five agencies did not have the elements of 

monitoring we found in Labor’s projects.
Page 31 GAO-07-1034 Human Trafficking

USAID said it appreciates the thoughtfulness of GAO’s report. USAID also 

commented that it is concerned with the challenges of coordination, 

monitoring, and evaluation, and that while it has made considerable efforts 

to coordinate within the U.S. government and with other organizations, it 

will continue to work within the interagency process in Washington and in 

the field. USAID also agrees that monitoring and evaluation of its 

antitrafficking efforts are very important and that they rely on the 

availability of both human and financial resources. USAID further agrees 

that the issues inherent in the evaluation of antitrafficking activities are 

particularly challenging because there is no baseline against which to 

measure progress. 

HHS said the report is a sound document that substantively covers the wide 

range of programs and services available to combat human trafficking. 

We also received technical comments from Justice and DHS, as well as 

from UNODC, IOM, ILO, OAS, OSCE, the World Bank, IDB, and ADB, which 

we have incorporated in the report as appropriate.

We are sending copies of this report to interested congressional 

committees; the Secretaries of State, Justice, Health and Human Services, 

Homeland Security, and Labor; the Administrator of USAID; ILO; IOM; and 

UNODC. We will also provide copies to others on request. In addition, the 

report will be available at no charge on the GAO Web site at 

http://www.gao.gov. 

If you or your staffs have any questions about this report, please contact 

me at (202) 512-9601. Contact points for our Offices of Congressional 

Relations and Public Affairs may be found on the last page of this report. 

GAO staff who made major contributions to this report are listed in 

appendix VIII.

Thomas Melito

Director, International Affairs and Trade
Page 32 GAO-07-1034 Human Trafficking

Appendix I

Objectives, Scope, and Methodology AAppenednxidexiIs

Our objectives were to examine (1) collaboration among organizations 

involved in international antitrafficking efforts, (2) U.S. government 

agencies’ monitoring of antitrafficking projects and difficulties in 

evaluating these projects, and (3) suggestions for strengthening monitoring 

and evaluation.

To examine collaboration among organizations involved in international 

antitrafficking efforts, we reviewed relevant planning, funding, and project 

documents on human trafficking from the Departments of State, Justice, 

Labor, Homeland Security, and Health and Human Services and the U.S. 

Agency for International Development (USAID). We reviewed planning and 

project documents from relevant United Nations (UN) and other 

international agencies and offices, including the UN Office on Drugs and 

Crime (UNODC), International Labor Organization (ILO), International 

Organization for Migration (IOM), United Nations Children’s Fund 

(UNICEF), and UN High Commissioner for Refugees (UNHCR). We also 

reviewed UN reports and resolutions that address coordination as well as 

documents from regional organizations, such as the Organization for 

Security and Cooperation in Europe (OSCE), the Coordinated Mekong 

Ministerial Initiative Against Trafficking (COMMIT), and the Regional 

Conference on Migration.

In addition, we reviewed documents from and discussed international 

antitrafficking efforts with officials from the above agencies and 

organizations as well as officials from host government, donor government, 

and nongovernmental organizations (NGO), in Washington, D.C., and 

during our fieldwork in Indonesia, Thailand, and Mexico. We also reviewed 

documents describing these countries’ national mechanisms to combat 

trafficking, including legislation and action plans, where applicable. We 

selected Thailand because it is the country with the largest number of 

international organizations working to combat human trafficking. We 

selected Indonesia and Mexico because they receive a large amount of U.S. 

funding for international antitrafficking projects and have a relatively large 

number of U.S. government agencies and international organizations 

working in each country. All 3 countries are origin, transit, and destination 

countries for human trafficking victims and have projects addressing 

prevention, protection, and prosecution. 

To examine organizations’ monitoring and evaluation of antitrafficking 

programs, we reviewed documentation from 23 projects in the 3 countries 

we visited and illustrative projects from other countries. We worked with 

U.S. agency officials in Washington and in the field to identify U.S.-funded 
Appendix I

Objectives, Scope, and Methodology

Page 33 GAO-07-1034 Human Trafficking

antitrafficking projects in Indonesia, Thailand, and Mexico that were 

ongoing during the time of our review (August 2006 to June 2007). We 

requested project documents—including proposals, grant agreements, and 

progress reports—from these U.S. officials for projects identified in these 

countries. In response to this request, we received documents for 23 

antitrafficking projects that were funded or implemented by 6 U.S. agencies 

involved in international antitrafficking efforts. We examined the project 

documents for the following elements: statement of goals or objectives, 

statement of activities, identification of indicators and targets, explanation 

of how targets were selected, and inclusion of a logic model or framework. 

While we recognize that these 23 projects may not be the complete 

universe of antitrafficking projects in these 3 countries, we consider these 

23 projects sufficient for the purposes of our review.1

 Although we cannot 

assume that the issues we identified exist across all projects, they 

nevertheless represent areas for improvement in monitoring antitrafficking 

projects. We also reviewed a set of 4 State Office to Combat and Monitor 

Trafficking in Persons (G/TIP) antitrafficking projects in India, Israel, 

Afghanistan, and Costa Rica. These projects were selected to illustrate 

some current monitoring and evaluation practices for existing projects in 

different parts of the world and different types of exploitation. They 

showed the variation in monitoring practices that can only increase with 

sample size. Thus, the projects provided the background information and 

context needed to understand State G/TIP’s current efforts to standardize 

monitoring requirements. The reviewed documents for all projects 

included proposals, applications for assistance, project descriptions, 

strategy papers, concept papers, causal models, cooperative or grant 

agreements, and periodic and final reports. 

We also reviewed articles and books on monitoring, evaluation, and 

statistics, such as Sampling by Steven K. Thompson, Wiley Series in 

Probability and Mathematical Statistics (1992); Adaptive Sampling by 

Stephen K. Thompson and George A.F., Seber, Wiley Series in Probability 

and Mathematical Statistics (1996); Better Evaluation for Evidence-Based 

Policy: Place Randomized Trials in Education, Criminology, Welfare, 

and Health by Robert Baruch, The Annals of the American Academy of 

Political and Social Science (2005), vol. 599, 6-18; Program Evaluation 

Methods: Measurement and Attribution of Program Results, Third 

1

We could not determine the universe of projects currently being implemented in these three 

countries because multiple U.S. agencies are involved in international antitrafficking efforts 

and there is no one central repository to identify all U.S.-funded projects. 
Appendix I

Objectives, Scope, and Methodology

Page 34 GAO-07-1034 Human Trafficking

Edition, Treasury Board of Canada, Secretariat; and Monitoring and 

Evaluation: Some Tools, Methods and Approaches, the World Bank (2004). 

To examine suggestions for strengthening monitoring and evaluation, we 

worked with the National Academy of Sciences to organize a 2-day expert 

panel on challenges and alternative strategies for monitoring and 

evaluating the results of international antitrafficking programs and projects 

in April 2007. We invited the following groups of panel participants:

• Experts with broad-based, subject-area knowledge of human trafficking.

• Experts with specialized knowledge of monitoring and evaluation of 

programs aimed at hidden populations similar to trafficking victims, 

such as the homeless and irregular migrants. This group included 

experts with specific knowledge of baseline data estimation of such 

populations. 

Panelists had backgrounds in academia, research, consulting, and project 

implementation in the field. Using a nominal group technique, panelists 

chose to focus on the intervention “safe return” as a starting point for 

discussion. Experts provided presentations and participated in a 

discussion and cross-fertilization of ideas. Using a nominal group 

technique, panel members also ranked two topics in order of importance to 

the human trafficking field—estimating the number of trafficking victims 

and evaluability assessments. None of the panel members were 

compensated for their work on this project. The following experts 

participated in the panel: 

• Richard Berk, Professor of Criminology and Statistics, Department of 

Criminology, University of Pennsylvania

• Robert Boruch, University Trustee Chair Professor, Graduate School of 

Education and Statistics Department, Wharton School, University of 

Pennsylvania

• Mario Thomas Gaboury, Professor and Chair of Criminal Justice, 

University of New Haven

• Adele Harrell, Consultant 

• Kristiina Kangaspunta, Chief, Anti-Human Trafficking Unit, United 

Nations Office on Drugs and Crime
Appendix I

Objectives, Scope, and Methodology

Page 35 GAO-07-1034 Human Trafficking

• Jonathan Martens, Counter-Trafficking Project Specialist, CounterTrafficking Division, International Organization for Migration

• Jeffrey S. Passel, Senior Research Associate, Pew Hispanic Center

• Lisa Rende-Taylor, Technical Advisor to the United Nations Inter-Agency 

Project on Human Trafficking in the Greater Mekong Subregion 

• Peter Reuter, Professor, School of Public Policy, Department of 

Criminology, University of Maryland

• W. Courtland Robinson, Assistant Professor, Center for Refugee and 

Disaster Response, Johns Hopkins Bloomberg School of Public Health

• Debra Rog, Associate Director, Westat Corporation

• Jane Nady Sigmon, Senior Coordinator for International Programs, 

Office to Monitor and Combat Trafficking in Persons, U.S. Department 

of State

We conducted our review from August 2006 to June 2007 in accordance 

with generally accepted government auditing standards.
Page 36 GAO-07-1034 Human Trafficking

Appendix II

Selected International Organizations Involved 

in Combating Human Trafficking ApendxiI

This appendix describes the general mission and antitrafficking activities 

of 15 international organizations that implement international 

antitrafficking projects.

Table 3: Selected International Organization Missions and Activities to Combat Human Trafficking

Organization/General mission Activities to combat human trafficking

Worldwide organizations

United Nations Office on Drugs and Crime 

(UNODC): Assist member countries to combat 

illicit drugs, crime, and terrorism. 

As the Secretariat of the Conference of the Parties to the UN Convention against 

Transnational Organized Crime and its protocols, including the Trafficking in Persons 

Protocol, UNODC is required to “ensure the necessary coordination with the 

secretariats of relevant international and regional organizations.”

UNODC’s Global Program to Combat Trafficking in Persons comprises data collection, 

assessment, and technical cooperation.

International Labor Organization (ILO): Promote 

social justice and internationally recognized 

human and labor rights. The ILO Declaration on 

Fundamental Principles and Rights at Work 

expresses the commitment of governments and 

employers' and workers' organizations in four 

areas, including the elimination of forced, 

compulsory, and child labor. 

The International Program on the Elimination of Child Labor aims to eliminate child 

labor by strengthening national capacities and creating a worldwide movement to 

combat it.

The Special Action Program to Combat Forced Labor seeks to

• raise global awareness and understanding of forced labor;

• assist governments to develop and implement new laws, policies, and action plans;

• develop and disseminate guidance and training materials on forced labor and 

trafficking; and

• implement programs that integrate policy, institutional capacity building, and direct 

support for the prevention of forced labor and identification and rehabilitation of 

victims. 

International Organization for Migration (IOM): 

Ensure the orderly and humane management of 

migration, to promote international cooperation 

on migration issues; to assist in the search for 

practical solutions to migration problems; and to 

provide humanitarian assistance to migrants, 

including refugees and internally displaced 

people.

IOM’s counter-trafficking projects primarily aim to prevent human trafficking, and to 

protect victims while offering options of safe and sustainable reintegration and/or 

return. Activities include:

• Information campaigns that educate the public about human trafficking and equip 

vulnerable populations with the information necessary to protect themselves from the 

recruitment tactics of traffickers.

• Research on human trafficking that explores routes and trends, the causes and 

consequences of human trafficking as well as the structures, motivations, and modus 

operandi of organized criminal groups.

• Direct assistance to trafficking victims that provides accommodation in safe places, 

medical and psychosocial support, skills development and vocational training, 

reintegration assistance, and the options of voluntary and dignified return to the 

country of origin or resettlement to a third country in extreme cases.

• Technical cooperation that builds the capacity of government and civil society 

institutions to better address the challenges posed by human trafficking through 

specialized training and technical support in the development of counter-trafficking 

policies and procedures, legal frameworks, and infrastructural upgrades.
Appendix II

Selected International Organizations 

Involved in Combating Human Trafficking

Page 37 GAO-07-1034 Human Trafficking

United Nations Children’s Fund (UNICEF): 

Advocate for the protection of children's rights, 

help meet children’s basic needs, and aim to 

expand their opportunities.

UNICEF’s Child Protection Program focuses on

• government commitment and capacity;

• legislation and enforcement;

• attitudes, customs and practices;

• open discussion;

• children’s life skills, knowledge, and participation;

• family and community capacity;

• essential services, including prevention, recovery, and reintegration; and

• effective monitoring, reporting, and oversight.

Joint United Nations Program on HIV/AIDS 

(UNAIDS): Support efforts of 10 UN system 

organizations to help the world prevent new 

HIV/AIDS infections, provide care for those 

already infected, and mitigate the impact of the 

epidemic.

Using a human rights approach, UNAIDS aims to address the root causes of human 

trafficking, including poverty, limited access to education and jobs, and social and 

cultural attitudes and practices that devalue women, girls, and children. UNAIDS 

promotes law enforcement and other activities to prevent trafficking; protect victims; 

punish traffickers; and target demand for the services of trafficked workers, women, and 

girls. UNAIDS also advocates for voluntary counseling and testing, the provision of HIV 

care and treatment services, and the elimination of stigma and discrimination.

United Nations Development Program (UNDP): 

Increase knowledge, experience, and resources 

to developing countries in such areas as 

poverty, HIV/AIDS, energy and the environment, 

democratic governance, and crisis prevention 

and recovery. Focus on encouraging human 

rights and women’s empowerment.

UNDP approaches trafficking as a voluntary and involuntary migration issue. UNDP 

aims to identify the factors that increase women’s and girls’ vulnerability to trafficking 

and to develop responses for the facilitation of safe mobility.

United Nations Educational, Scientific, and 

Cultural Organization (UNESCO): Promote 

international cooperation in the fields of 

education, science, culture, and 

communication. 

UNESCO undertakes policy-oriented research on specific factors leading to the 

trafficking of women and children in pilot countries in Africa and Asia. 

The Project to Fight Human Trafficking in Africa aims to promote effective and culturally 

appropriate policymaking to combat trafficking in Western and Southern Africa. It 

organizes training workshops for policymakers, NGOs, community leaders, and the 

media to raise awareness and inspire innovative policymaking. 

The Trafficking and HIV/AIDS Project attempts to solve the problems of HIV/AIDS, 

trafficking, and nontraditional drug use in the Greater Mekong subregion, by 

researching, developing, and implementing programs that work to support sustainable, 

locally managed projects with ethnic minorities.

United Nations Development Fund for Women 

(UNIFEM): Provide financial and technical 

assistance to programs and strategies to foster 

women’s empowerment and gender equality. 

Cover the gender issues of HIV/AIDS, poverty, 

economics, and violence.

UNIFEM addresses the trafficking of women within the context of violence against 

women—as a violation of their human rights and as a development issue.

United Nations High Commissioner for 

Refugees (UNHCR): Coordinate international 

action to protect refugees and resolve refugee 

problems worldwide.

UNHCR provides a safeguard to the rights and well-being of refugees so that they can 

exercise the right to seek asylum and find safe refuge in another country, with the 

option to return home voluntarily, integrate locally, or resettle in a third country. 

(Continued From Previous Page)

Organization/General mission Activities to combat human trafficking
Appendix II

Selected International Organizations 

Involved in Combating Human Trafficking

Page 38 GAO-07-1034 Human Trafficking

Regional organizations

Organization for Security and Cooperation in 

Europe (OSCE): Address a wide range of 

security concerns, including arms control, 

confidence- and security-building, human 

rights, national minorities, democratization, 

policing strategies, counterterrorism, 

antitrafficking, and economic and environmental 

activities.

The Office of the Special Representative and Coordinator for Combating Trafficking in 

Human Beings supports the development and implementation of antitrafficking policies 

in OSCE participating countries. In addition, the office coordinates the activities of 

OSCE bodies, promotes cooperation among the participating states, and raises the 

public and political profile of trafficking in persons.

The Office for Democratic Institutions and Human Rights assists countries in preventing 

trafficking and protecting victims by

• supporting the establishment of national referral mechanisms,

• improving victim identification and assistance, and

• enhancing trafficking victims’ awareness of their rights.

The Office of the Coordinator of OSCE Economic and Environmental Activities aims to 

address both the demand and supply side of trafficking in human beings by

• promoting self-regulation of the private sector;

• raising the awareness of trafficking in countries of destination, in particular in western 

countries; and

• creating economic empowerment opportunities for potential victims of trafficking in 

countries of origin.

The OSCE Secretariat’s Action Against Terrorism Unit, Conflict Prevention Center, 

Strategic Police Matters Unit, Border Unit, the Office of the Senior Gender Adviser, and 

field offices are also engaged in combating human trafficking.

Organization of American States (OAS): 

Strengthen cooperation on democratic values, 

defend common interests, and debate the major 

issues facing the western hemisphere and the 

world. 

The Anti-Trafficking in Persons Section’s goals are to carry out antitrafficking efforts 

with a regional perspective that allows OAS to address human trafficking in a way that 

is difficult for any single national government. The section provides the necessary 

logistical information for training seminars, technical assistance to governments, 

exchange of information, and proposals. Also, the section develops new information, 

monitors new literature in the field, and catalogues existing reports and documents. 

The focus of antitrafficking efforts consists of

• broadening awareness and understanding of trafficking in persons,

• sharing information with governments and civil society,

• identifying policies that will reduce human trafficking,

• working with officials on implementing concrete antitrafficking measures, and

• identifying new partners and financial resources for fighting trafficking in the 

hemisphere.

Four key areas of action are to

• foster national action by governments;

• advance effective antitrafficking best practices in prevention, protection, investigation, 

and prosecution;

• gain new allies for the hemisphere; and

• implement existing antitrafficking projects and training programs as well as develop 

new ones.

(Continued From Previous Page)

Organization/General mission Activities to combat human trafficking
Appendix II

Selected International Organizations 

Involved in Combating Human Trafficking

Page 39 GAO-07-1034 Human Trafficking

Sources: International organizations and development banks.

Association of Southeast Asian Nations 

(ASEAN): Accelerate economic growth, social 

progress, and cultural development for the 

participating countries in the southeast region 

of Asia. Promote regional peace and stability 

through respect for justice and the rule of law. 

In 1997, ASEAN member countries signed the Declaration on Transnational Crime, 

which commits members to taking measures to combat transnational crimes, including 

human trafficking. The organization’s work program to implement this declaration 

includes actions to enhance information exchange, increase awareness of trafficking, 

support the criminalization of trafficking, and develop regional training programs.

In 2004, ASEAN member countries signed the Declaration Against Trafficking in 

Persons, Particularly Women and Children, which commits members to establishing a 

regional focal network to combat trafficking and adopting measures to prevent the 

fraudulent use of identity documents, among other things.

Multilateral development banks

World Bank: Provide financial and technical 

assistance to developing countries to promote 

education, health, infrastructure, and 

communications to reduce global poverty and 

improve living standards. 

The World Bank conducts analytical work on topics, such as gender or migration, that 

may address the incidence of and factors leading to human trafficking and child labor.

The International Finance Corporation supports job creation and skills improvement 

projects in Asia that assist vulnerable populations, including human trafficking victims. 

In addition, the corporation applies its performance standard related to child labor to 

the projects it finances, in an effort to help client companies assess and manage these 

issues.

Asian Development Bank (ADB): Reduce 

poverty in Asia and the Pacific. ADB helps 

improve the quality of people’s lives by 

providing loans and technical assistance for a 

broad range of development activities.

ADB conducts regional research addressing the incidence and factors leading to the 

trafficking of women and children in Asia. Where trafficking vulnerabilities are identified, 

ADB recommends that its borrowers include an antitrafficking component (normally 

involving community and laborer awareness raising, targeted poverty reduction 

program for women and children, and capacity building of NGOs and community 

groups) often in conjunction with an HIV/AIDS prevention component. ADB also 

facilitates policy dialogues within and among countries in Asia, especially through its 

active regional cooperation assistance.

Inter-American Development Bank (IDB): 

Contribute to the acceleration of the process of 

economic and social development of the 

regional developing member countries.

IDB seeks opportunities within its Poverty Reduction and Social Equity and Social 

Development Strategies to address the issue of human trafficking in its borrowing 

member countries. IDB promotes mainstreaming the subject in the traditionally 

financed operations in the areas of violence, social exclusion, attention to vulnerable 

groups, gender, citizen security, justice reform, and corruption. IDB encourages 

countries to include human trafficking in their country strategies and provides technical 

assistance grants and citizen security loans with trafficking elements. In addition, IDB 

has launched communications campaigns to improve awareness and visibility of 

human trafficking and promote the use of emergency hotlines, which are also used to 

gather information on origin and destination locations of trafficking victims and 

trafficking routes. 

(Continued From Previous Page)

Organization/General mission Activities to combat human trafficking
Page 40 GAO-07-1034 Human Trafficking

Appendix III

Methods Suggested by Expert Panel to 

Estimate the Number of Human Trafficking 

Victims ApendxiI

This appendix describes the sampling methods suggested by a GAOconvened panel of experts to estimate the number of human trafficking 

victims.

Table 4: Sampling Methods Suggested by Expert Panel to Estimate the Number of Human Trafficking Victims

Method Description of method Application to human trafficking

Stratified random 

sampling to oversample 

rare units

The population is divided into subgroups, and 

random samples are selected from each subgroup.

Geographic areas are divided into subareas, which 

allows for a more-intensive search of cases in trafficking 

“hot spots.”

Double sampling After selecting a sample of primary units to obtain 

preliminary estimates, a sample of secondary units 

is selected to obtain more accurate counts.

First, a preliminary estimate of human trafficking cases is 

obtained from reported cases in certain geographic 

areas. Second, a more precise estimate of actual victims 

is obtained by focusing on the areas with a higher 

concentration of reported cases.

Adaptive cluster 

sampling

After an initial set of units is selected, additional 

units in its neighborhood are added to the sample.

After an initial trafficking case is identified, additional 

cases in its “vicinity” are identified. The goal is to find 

clusters that are usually defined geographically.

Capture-recapture 

sampling

Two random samples are independently drawn, 

and the number of common and different units is 

used to estimate the size of the population.

Two random samples of reported trafficking cases are 

independently drawn, and the number of common and 

different cases is used to estimate the total number of 

reported cases.a

Indirect sampling A “sisterhood approach” to sampling involves 

sampling a related population that is not as difficult 

to sample as the population of interest. An estimate 

is obtained by using the relationship between the 

“hard-” and “easy-to-reach” populations.

Relatives or friends of trafficking victims are interviewed, 

and an estimate is obtained on the basis of the 

relationship between the two groups.

Sentinel site surveillance A nonrandom sample of sites is selected over time 

to observe changes in characteristics.

Sites with higher concentrations of trafficking cases can 

be identified and observed over time to determine 

whether there is a change in the number of victims found 

or rescued, or both.

Snowball sampling An initial observation is taken and augmented by 

the participants. This is a participant-driven 

approach.

An identified victim identifies other victims with whom he 

or she has been in contact. In turn, these victims identify 

others.

Model-based estimator A model of human trafficking is developed, followed 

by empirical work aimed at obtaining parameter 

estimates.

Based on the underlying relationships of a human 

trafficking model, a multiplier of identified cases is used 

to extrapolate to a total or aggregate estimate.

Use of decoys Decoys are used to estimate an elusive population. 

For example, the U.S. Census Bureau used decoys 

in studies of the homeless to estimate how many of 

the homeless were not found.

An initial estimate of reported victims can be adjusted on 

the basis of the number of decoys that are not found by 

the enumerators to account for victims who may have 

been missed.
Appendix III

Methods Suggested by Expert Panel to 

Estimate the Number of Human Trafficking 

Victims

Page 41 GAO-07-1034 Human Trafficking

Source: GAO analysis of expert panel proceedings.

a

This procedure was used by ILO to obtain its global estimate of forced labor. For a detailed 

discussion, see Patrick Belser, Michaelle de Cock, and Ferhad Mehran, ILO Minimum Estimate of 

Forced Labour in the World, ILO (Geneva: April 2005).

Random approximation This procedure is an approximation of and is more 

practical than true random sampling. For example, 

systematic random sampling requires random 

sampling in the first step, while the units in the 

second step are selected in some systematic 

fashion. 

Every 5th or 10th employment establishment, household, 

or reintegrated trafficking victim is selected to generate 

an estimate that can be used without losing the ability to 

generalize. 

Sampling with certainty Particular units are removed from the sampling 

design to reduce the variation in the estimates. 

These units are selected “with certainty,” while the 

“noncertainty” units are randomly selected.

Some geographic areas with a known high incidence of 

trafficking can be included in the estimation with 

certainty, while sampling procedures can be applied in 

other parts of a country or region.

(Continued From Previous Page)

Method Description of method Application to human trafficking
Page 42 GAO-07-1034 Human Trafficking

Appendix IV

Comments from the Department of State ApendxiIV

Note: GAO comments 

supplementing those in 

the report text appear 

at the end of this 

appendix.
Appendix IV

Comments from the Department of State

Page 43 GAO-07-1034 Human Trafficking

See comment 1.

See comment 2.
Appendix IV

Comments from the Department of State

Page 44 GAO-07-1034 Human Trafficking

See comment 2.
Appendix IV

Comments from the Department of State

Page 45 GAO-07-1034 Human Trafficking
Appendix IV

Comments from the Department of State

Page 46 GAO-07-1034 Human Trafficking
Appendix IV

Comments from the Department of State

Page 47 GAO-07-1034 Human Trafficking

See comment 2.

See comment 3.
Appendix IV

Comments from the Department of State

Page 48 GAO-07-1034 Human Trafficking

The following are GAO’s comments on the Department of State letter dated 

July 13, 2007.

GAO Comments 1. State said that the report’s title is not apt because program monitoring 

is in place and improving. We believe that monitoring is limited for the 

following reasons: for the 23 projects we reviewed, the majority did not 

have a logic model that clearly explains how activities are linked to 

project goals; the majority of these projects also did not specify targets 

that establish benchmarks for measuring performance; of the 10 

projects that did specify targets, only 5 explained how targets were set; 

and, finally, State lacked written guidance for field-level oversight. 

2. State noted that many of its projects are designed to be of more limited 

size, scope, and duration, and that such projects are not necessarily 

suitable for evaluation. They also added that larger and longer-term 

projects are more suitable candidates for impact evaluation than 

shorter projects. Finally, State commented that a relatively short time 

frame for projects is not a design weakness. In the report, we state that 

the impact of a shorter-term, smaller-scale intervention may be difficult 

to attribute and quantify. 

3. State noted that baseline data are not required for all interventions. We 

disagree. In the report, we state that baseline and target values of 

indicators are needed to assess project performance. For example, 

baselines for a victim assistance program could include the number of 

victims served or assisted, or the number of vocational training 

sessions held. Moreover, project-level estimates are needed for 

baselines by which to evaluate how effectively interventions are 

reducing trafficking. For this type of baseline, panelists suggested 

methods for baseline estimation, such as gathering data in trafficking 

hot spots, that would allow for more rigorous impact evaluations.
Page 49 GAO-07-1034 Human Trafficking

Appendix V

Comments from the Department of Labor ApendxiV

Note: GAO comments 

supplementing those in 

the report text appear 

at the end of this 

appendix.
Appendix V

Comments from the Department of Labor

Page 50 GAO-07-1034 Human Trafficking

See comment 1.
Appendix V

Comments from the Department of Labor

Page 51 GAO-07-1034 Human Trafficking
Appendix V

Comments from the Department of Labor

Page 52 GAO-07-1034 Human Trafficking

See comment 2.

See comment 3.
Appendix V

Comments from the Department of Labor

Page 53 GAO-07-1034 Human Trafficking

See comment 4.
Appendix V

Comments from the Department of Labor

Page 54 GAO-07-1034 Human Trafficking
Appendix V

Comments from the Department of Labor

Page 55 GAO-07-1034 Human Trafficking

The following are GAO’s comments on the Department of Labor letter 

dated July 13, 2007.

GAO Comments 1. Labor noted that federal agencies are carrying out monitoring and 

evaluation activities or are making efforts to improve monitoring and 

evaluation of antitrafficking activities. Labor also provided details of its 

monitoring policies, procedures, and activities. We recognize that Labor 

has monitoring procedures and activities in place, and we revised text 

in several locations to provide further clarification on Labor’s activities. 

We clarified that all four Labor projects in Indonesia, Mexico, and 

Thailand clearly link goals and activities, specify targets, and explain 

how targets were set. We added language stating that Labor engaged 

ILO’s external auditor to conduct audits of a sample of ILO’s projects to 

eliminate child labor and contracted with a certified public accounting 

firm to conduct independent attestation engagements of its Education 

Initiative projects. We believe the overall monitoring of antitrafficking 

projects is limited because the projects funded by the other five 

agencies did not have the elements of monitoring we found in Labor’s 

projects.

2. Labor stated that it requires midterm and final evaluations for its 

technical assistance projects, and that, in some cases, it engages in 

longer-term follow-up studies. We revised the text to further clarify and 

recognize Labor’s evaluation requirements and activities. In addition, 

we added text specifying that Labor funds follow-up studies to 

document changes that have occurred to a sample of beneficiaries over 

time. 

3. Labor agreed with the need to carry out more systematic impact 

evaluations, but also emphasized that process evaluations are an 

important prerequisite of impact evaluations. Labor further commented 

that randomized trials are not appropriate for all projects, and 

requested that we specify where agencies should conduct randomized 

trials and where other methods would be more appropriate. We agree 

that process evaluations are important and revised the text to further 

differentiate process evaluations from impact evaluations. We believe 

each agency should determine whether randomized trials are 

appropriate for the specific project they are evaluating. 

4. We made changes to the draft of this report on the basis of Labor’s 

specific technical comments, where appropriate. 
Page 56 GAO-07-1034 Human Trafficking

Appendix VI

Comments from the United States Agency for 

International Development ApendxiVI
Appendix VI

Comments from the United States Agency for 

International Development

Page 57 GAO-07-1034 Human Trafficking
Page 58 GAO-07-1034 Human Trafficking

Appendix VII

Comments from the Department of Health and 

Human Services ApendxiVI
Page 59 GAO-07-1034 Human Trafficking

Appendix VIII

GAO Contact and Staff Acknowledgments ApendxiVI

GAO Contact Thomas Melito (202) 512-9601 or melitot@gao.gov

Staff 

Acknowledgments

Cheryl Goodman, Assistant Director; Jeremy Latimer; Christina Werth; 

Todd M. Anderson; Gergana Danailova-Trainor; Terry Richardson; and 

Debbie Chung made key contributions to this report. In addition, Elizabeth 

Curda, Bruce Kutnick, Mary Moutsos, Barbara Stolz, and Susanna Kuebler 

provided technical or legal assistance. 

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