a

GAO

United States Government Accountability Office

Report to the Chairman, Committee on 

the Judiciary and the Chairman, 

Committee on International Relations, 

House of Representatives

July 2006 HUMAN 

TRAFFICKING

Better Data, Strategy, 

and Reporting Needed 

to Enhance U.S. 

Antitrafficking Efforts 

Abroad

GAO-06-825
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

July 2006

HUMAN TRAFFICKING

Better Data, Strategy, and Reporting 

Needed to Enhance U.S. Antitrafficking 

Efforts Abroad 

Highlights of GAO-06-825, a report to the 

Chairman, Committee on the Judiciary 

and the Chairman, Committee on 

International Relations, House of 

Representatives 

Human trafficking is a worldwide

form of exploitation in which men, 

women, and children are bought,

sold, and held against their will in 

involuntary servitude. In addition 

to the tremendous personal

damage suffered by individual

trafficking victims, this global

crime has broad societal

repercussions, such as fueling 

criminal networks and imposing 

public health costs. In 2000, 

Congress enacted the Trafficking 

Victims Protection Act (TVPA) to

combat trafficking and

reauthorized this act twice. This 

report reviews U.S. international 

antitrafficking efforts by examining 

(1) estimates of the extent of global

trafficking, (2) the U.S. 

government’s strategy for 

combating the problem abroad, and

(3) the Department of State’s 

process for evaluating foreign 

governments’ antitrafficking efforts.

What GAO Recommends

GAO recommends that the

Secretary of State (1) improve

information on trafficking, (2) 

develop and implement a strategy

that clarifies agencies’ roles and 

responsibilities and establishes a

way to gauge results abroad, and 

(3) clearly document the rationale 

and support for country rankings. 

In their comments, the agencies 

primarily responsible for these 

activities generally concurred with

our recommendations. 

The U.S. government estimates that 600,000 to 800,000 persons are trafficked

across international borders annually. However, such estimates of global 

human trafficking are questionable. The accuracy of the estimates is in 

doubt because of methodological weaknesses, gaps in data, and numerical 

discrepancies. For example, the U.S. government’s estimate was developed 

by one person who did not document all his work, so the estimate may not 

be replicable, casting doubt on its reliability. Moreover, country data are not 

available, reliable, or comparable. There is also a considerable discrepancy 

between the numbers of observed and estimated victims of human 

trafficking. The U.S. government has not yet established an effective 

mechanism for estimating the number of victims or for conducting ongoing 

analysis of trafficking related data that resides within government entities. 

While federal agencies have undertaken antitrafficking activities, the U.S. 

government has not developed a coordinated strategy for combating 

trafficking abroad or developed a way to gauge results and target its overall 

assistance. The U.S. government has established coordination mechanisms, 

but they do not include a systematic way for agencies to clearly delineate 

roles and responsibilities in relation to each other, identify needs, or 

leverage activities to achieve greater results. Further, the U.S. government 

has not established performance measures or conducted evaluations to 

gauge the overall impact of antitrafficking programs abroad, thus preventing 

the U.S. government from determining the effectiveness of its efforts or 

adjusting its assistance to better meet needs. 

The Department of State assesses foreign governments’ compliance with 

minimum standards to eliminate trafficking in persons; but the explanations 

for ranking decisions in its annual Trafficking in Persons Report are 

incomplete, and the report is not used consistently to develop antitrafficking

programs. It has increased global awareness, encouraged government 

action, and raised the risk of sanctions against governments who did not 

make significant efforts to comply with the standards. However, State does 

not comprehensively describe compliance with the standards, lessening the 

report’s credibility and usefulness as a diplomatic tool. Further, incomplete 

country narratives reduce the report’s utility as a guide to help focus U.S. 

government resources on antitrafficking programming priorities. 

Principal U.S. Government Agencies with Responsibilities for Antitrafficking Programs 

Sources: U.S. agencies listed in figure (data) and Corel (logos).

 Department of State

USAID

Health and Human Services Department of Labor

Department of 

Homeland Security

Department of Justice

State Department 

Office to Monitor 

and Combat 

Trafficking in 

Persons

DEPARTMENT OF JUSTICE

www.gao.gov/cgi-bin/getrpt?GAO-06-825.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Thomas Melito, 

202-512-9601, melitot@gao.gov. 
Page i GAO-06-825 Human Trafficking

Contents

Letter 1

Results in Brief 2

Background 4

Estimates of Global Human Trafficking Are Questionable, and U.S. 

Data Collection Efforts Are Fragmented 10

Lack of Strategy and Performance Measures Prevents U.S. 

Government from Determining Overall Program Effectiveness 

Abroad 21

Department of State’s Annual Report Ranks Foreign Governments’ 

Antitrafficking Efforts but Has Limited Credibility and Does Not 

Consistently Influence Antitrafficking Programs 26

Conclusion 36

Recommendations for Executive Action 37

Agency Comments and Our Evaluation 38

Appendixes

Appendix I: Objectives, Scope, and Methodology 41

Appendix II: Methodologies Used by Four Organizations to Collect Data 

on Human Trafficking 44

Appendix III: Eight U.S. Government Entities’ Data on Human 

Trafficking 46

Appendix IV: State’s Process for Assessing Foreign Governments’ 

Compliance with U.S. Minimum Standards to Eliminate 

Human Trafficking 47

Appendix V: Comments from the Department of State 50

GAO Comments 60

Appendix VI: GAO Contact and Staff Acknowledgments 64

Tables Table 1: Funding Obligated for International Activities to Combat 

Trafficking in Persons, Fiscal Years 2001-2005 9

Table 2: Victim Profiles in U.S. government, ILO, UNODC, and IOM 

databases 12

Table 3: Reasons that Limit the Quality of Trafficking Data 15

Table 4: Four Organizations’ Data Sources and Validation 44

Table 5: Four Organizations’ Methodologies, Key Assumptions and 

Limitations 45

Table 6: Data on Human Trafficking Maintained by U.S. 

Government Entities 46
Contents

Page ii GAO-06-825 Human Trafficking

Table 7: Minimum Standards and Criteria for the Elimination of 

Human Trafficking 47

Figures Figure 1: Principal U.S. Government Agencies with 

Responsibilities for Antitrafficking Activities and 

Associated Coordination Entities 7

Figure 2: Profile of 7,711 Trafficking Victims IOM Assisted between 

1999 and 2005 20

Figure 3: Tier Definitions 27

Figure 4: Fiscal Year 2005 Obligations for Antitrafficking Activities 

by Tier Ranking 34

Figure 5: Completeness of Country Narratives for Governments in 

Tier 2 Watch List and Tier 3 36

Figure 6: Key Elements of the Trafficking in Persons Report

Process 49

Abbreviations

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

ILO International Labor Organization

IOM International Organization for Migration

NGO nongovernmental organization

SPOG Senior Policy Operating Group

TVPA Trafficking Victims Protection Act

UNODC United Nations Office on Drugs and Crime

USAID United States Agency for International Development

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Page 1 GAO-06-825 Human Trafficking

United States Government Accountability Office

Washington, D.C. 20548

A

July 18, 2006 Letr

The Honorable Jim Sensenbrenner, Jr.

Chairman

Committee on the Judiciary

House of Representatives

The Honorable Henry J. Hyde

Chairman

Committee on International Relations 

House of Representatives

Human trafficking is a worldwide form of exploitation in which men, 

women, and children are bought, sold, and held against their will in 

slave-like conditions. People are trafficked and forced to work in the 

commercial sex trade, sweatshops, agricultural settings, domestic service, 

and other types of servitude. In addition to the tremendous personal 

damage suffered by individual trafficking victims, this global crime has 

broad societal repercussions. It fuels criminal networks, imposes public 

health costs, and erodes government authority. 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 Act (TVPA) to combat trafficking in persons 

and established the President’s Interagency Task Force to Monitor and 

Combat Trafficking in Persons (Interagency Task Force). Congress 

reauthorized this Act—in the Trafficking Victims Protection 

Reauthorization Act of 2003 (TVPA 2003) and the Trafficking Victims 

Protection Reauthorization Act of 2005 (TVPA 2005). This legislation 

requires the Secretary of State to report to Congress annually on foreign 

governments’ compliance with minimum U.S. standards for the elimination 

of trafficking. Since 2001, the U.S. government has provided about $375 

million1

 in antitrafficking assistance to foreign governments and 

nongovernmental organizations to help eliminate human trafficking.

1

This amount includes over $150 million from the Department of Labor, which was unable to 

break out funding amounts that specifically addressed trafficking but include funding 

amounts for activities that either have trafficking as a central focus, one component of a 

larger project linked to trafficking, or as an issue within the overall context of the project.
Page 2 GAO-06-825 Human Trafficking

This review is part of a larger body of work that you requested.2 To review 

the status of U.S. international efforts to combat trafficking in persons, we 

examined (1) estimates of the extent of global trafficking in persons, (2) 

the U.S. government’s strategy for combating trafficking in persons abroad, 

and (3) the Department of State’s (State) process for evaluating foreign 

governments’ antitrafficking efforts. 

To address these objectives, we reviewed pertinent State, Justice, Labor, 

Homeland Security, Health and Human Services, and U.S. Agency for 

International Development planning, funding, and program documents for 

international human trafficking. We discussed U.S. international trafficking 

efforts with officials from these departments, along with knowledgeable 

officials from international and nongovernmental organizations. We 

conducted an extensive analysis of the global trafficking databases 

developed and maintained by the U.S. government, the International 

Organization for Migration, the International Labor Organization, and the 

U.N. Office on Drugs and Crime (UNODC).3

 We also analyzed the country 

narratives in State’s 2005 Trafficking in Persons Report to determine how 

it assesses compliance with the minimum standards for the elimination of 

trafficking, as laid out in the Trafficking Victims Protection Act of 2000. We 

conducted our review from September 2005 to May 2006 in accordance 

with generally accepted government auditing standards.

Results in Brief The U.S. government estimates that 600,000 to 800,000 persons are 

trafficked across international borders annually; however such estimates 

of global human trafficking are questionable. The accuracy of the estimates 

is in doubt because of methodological weaknesses, gaps in data, and 

numerical discrepancies. For example, the U.S. government’s estimate was 

developed by one person who did not document all of his work, so the 

estimate may not be replicable, casting doubt on its reliability. Moreover, 

the quality of existing country level data varies due to limited availability, 

reliability, and comparability. There is also a considerable discrepancy 

between the numbers of observed and estimated victims of human 

2

We have also initiated a review of U.S. efforts to investigate and prosecute trafficking in 

persons, and will soon begin a review of multilateral organizations’ antitrafficking efforts. 

3

The International Organization for Migration is a multilateral organization that works with 

migrants and governments to respond to migration challenges. The International Labor 

Organization is a United Nations agency that promotes human and labor rights. UNODC 

assists member states in fighting illicit drugs, crime, and terrorism. 
Page 3 GAO-06-825 Human Trafficking

trafficking. The U.S. government has not yet established an effective 

mechanism for estimating the number of victims or for conducting ongoing 

analysis of trafficking related data that resides within various government 

agencies. 

More than 5 years after the passage of the landmark antitrafficking law, the 

U.S. government has not developed a coordinated strategy to combat 

trafficking in persons abroad, as called for in a presidential directive, or 

evaluated its programs to determine whether projects are achieving the 

desired outcomes. Task forces and other coordinating mechanisms have 

been established to coordinate U.S. government efforts abroad; the focus 

of these mechanisms is to avoid duplication of effort and ensure 

compliance with U.S. government policy. However, the process does not 

include a systematic approach for agencies to clearly delineate roles and 

responsibilities in relation to each other, identify needs, and target ways to 

complement each others’ activities to achieve greater results. In addition, 

the Interagency Task Force has not established performance measures or 

conducted evaluations to measure the impact of the U.S. government’s 

antitrafficking programs abroad. The lack of a coordinated strategy and 

evaluation plan prevents the U.S. government from determining the 

effectiveness of its efforts to combat human trafficking abroad or to adjust 

its assistance to better meet needs. 

The Department of State annually assesses foreign governments’ 

compliance with U.S. minimum standards to eliminate trafficking in 

persons, but State’s explanations for its ranking decisions are incomplete, 

and the report is not used consistently to develop governmentwide 

antitrafficking programs. Each year since 2001, State has issued the 

Trafficking in Persons Report that ranks foreign governments into one of 

three categories, or tiers, depending on their efforts to comply with the 

minimum standards and criteria established in U.S. legislation. This report 

has increased global awareness of human trafficking, encouraged action by 

governments who failed to comply with the minimum standards, and raised 

the risk of sanctions against governments who did not make significant 

efforts to comply with these standards. However, some of the minimum 

standards are subjective, and the report does not comprehensively explain 

how they were applied, lessening the report’s credibility and hampering its 

usefulness as a diplomatic tool. For example, country narratives for most 

countries in the top category (tier 1) failed to clearly explain compliance 

with the second minimum standard, regarding prescribed penalties for sex 

trafficking crimes, established in the TVPA. The report is also intended to 
Page 4 GAO-06-825 Human Trafficking

serve as a guide to antitrafficking programming priorities overseas, but 

agencies do not systematically link programs with reported deficiencies. 

To improve U.S. efforts to combat human trafficking abroad, we are making 

several recommendations. To improve information on global trafficking 

that could be used to effectively target resources and programs, we are 

recommending that the Chair of the President’s Interagency Task Force to 

Monitor and Combat Trafficking in Persons work closely with relevant 

agencies in researching a mechanism to develop a reliable global 

trafficking estimate. We are also recommending that the Chair develop and 

implement a strategy that would delineate agency roles and responsibilities 

and mechanisms for integrating activities; and determine priorities, 

measurable goals, time frames, performance measures, and a methodology 

to gauge results. Finally, to improve the credibility of State’s annual report 

on trafficking in persons, we are recommending that the Secretary of State 

clearly document the rationale and support for tier rankings and improve 

the report’s usefulness for antitrafficking programming. 

In commenting on a draft of this report, State generally agreed with our 

recommendations. In response to agencies’ technical comments, we 

clarified our second recommendation to state that agencies’ roles and 

responsibilities should be delineated in relation to each other, consistent 

with our report findings. The U.S. government agency that prepares the 

trafficking estimate fundamentally concurs with our characterization of the 

U.S. global estimate of trafficking flows. 

Background Human trafficking occurs worldwide and often involves transnational 

criminal organizations, violations of labor and immigration codes, and 

government corruption. Although their circumstances vary, fraud, force, or 

coercion typically distinguishes trafficking victims from people who are 

smuggled. Moreover, most trafficking cases follow the same pattern: 

people are abducted or recruited in the country of origin, transferred 

through transit regions, and then exploited in the destination country.4

People may also be trafficked internally, that is, within the borders of their 

own country. Trafficking victims include agricultural workers who are 

brought into the United States, held in crowded unsanitary conditions, 

threatened with violence if they attempt to leave, and kept under constant 

4

UNODC. Trafficking in Persons Global Patterns. (April 2006).
Page 5 GAO-06-825 Human Trafficking

surveillance; child camel jockeys in Dubai who are starved to keep their 

weight down; Indonesian women who may be drawn to a domestic service 

job in another country, are not paid for their work and are without the 

resources to return home; child victims of commercial sexual exploitation 

in Thailand; and child soldiers in Uganda. 

During the 1990s, the U.S. government began drawing attention to the 

problem of human trafficking before various international forums and 

gatherings. In 1998, a presidential memorandum5

 called on U.S. 

government agencies to combat the problem through prevention of 

trafficking, victim assistance and protection, and enforcement. This 

approach came to be known as “the three p’s”—prevention, protection, and 

prosecution. 

In 2000, Congress enacted TVPA6 and reauthorized and amended the act 

twice.7 The act defines victims of severe forms of trafficking 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. Under the TVPA, an alien, who is identified as a victim of a 

severe form of trafficking in the United States and meets additional 

conditions, is eligible for special benefits and services. 

The TVPA, as amended, provides a framework for current U.S. 

antitrafficking efforts. It addresses the prevention of trafficking, protection 

and assistance for victims of trafficking, and the prosecution and 

punishment of traffickers. The TVPA also laid out minimum standards for 

eliminating trafficking to be used in the Secretary of State’s annual 

5

Memorandum for the Secretary of State, the Attorney General, the Administrator of the 

Agency for International Development, the Director of the United States Information 

Agency on “Steps to Combat Violence against Women and Trafficking in Women and Girls” 

(Mar. 11, 1998).

6

Pub. L. No. 106-386.

7

TVPA 2003 (Pub. L. No. 108-193) and TVPA 2005 (Pub. L. No. 109-164).
Page 6 GAO-06-825 Human Trafficking

assessment of foreign governments’ antitrafficking efforts. It authorized 

U.S. foreign assistance for efforts designed to meet these standards and 

established sanctions—withholding nonhumanitarian, nontrade-related 

assistance—that could be applied against governments of countries not in 

compliance with the standards and not making significant efforts to bring 

themselves into compliance.8

Responsibility for implementing U.S. government antitrafficking efforts 

domestically and abroad is shared by the Departments of State, Justice, 

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

the U.S. Agency for International Development (USAID). Each agency 

addresses one or more of the three prongs of the U.S. antitrafficking 

approach. Some agencies have more responsibility for implementing 

international trafficking efforts than others. Figure 1 shows agencies and 

task forces with responsibilities for antitrafficking efforts.

8

The United States is also a signatory 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, G.A. res. 55/25, 

annex II, 55 U.N. GAOR Supp. (No. 49) at 60, U.N. Doc. A/45/49 (Vol. I) (2001), which entered 

into force on December 25, 2003. The United States ratified the protocol on December 3, 

2005.
Page 7 GAO-06-825 Human Trafficking

Figure 1: Principal U.S. Government Agencies with Responsibilities for 

Antitrafficking Activities and Associated Coordination Entities

Note: The TVPA 2000, 2003, and 2005 establish that the members of the President's Interagency Task 

Force and the Senior Policy Operating Group include the agencies listed above, as well as the Director 

of National Intelligence, the Secretary of Defense, and such other officials as may be designated by 

the President.

DEPARTMENT OF JUSTICE

Sources: Departments of Health and Human Services, Homeland Security, Justice, Labor, and State, and the U.S. Agency for 

International Development (data); Corel (logos).

 Department

of

State

USAID

Department 

of Labor

Health and 

Human 

Services

Department 

of Homeland 

Security

Department

of Justice

State 

Department 

Office to Monitor 

and Combat 

Trafficking in 

Persons

President’s Interagency Task Force to Monitor and 

Combat Trafficking in Persons

Key entities to coordinate antitrafficking efforts State Justice Labor HHS USAID DHS

– Senior Policy Operating Group (SPOG)

Human Smuggling and Trafficking Center (HSTC)

Trafficking in Persons and Worker Exploitation Task Force
Page 8 GAO-06-825 Human Trafficking

The government has also created several coordinating mechanisms for 

these antitrafficking efforts, as shown in figure 1. The TVPA directed the 

President to establish the Interagency Task Force to Monitor and Combat 

Trafficking in Persons, comprised of various agency heads and chaired by 

the Secretary of State, to coordinate the implementation of the act, among 

other activities. Furthermore, the TVPA authorized the Secretary of State to 

create the Department of State’s Office to Monitor and Combat Trafficking 

in Persons (Trafficking Office) to provide assistance to the task force. 

Subsequently, TVPA 2003 established the Senior Policy Operating Group, 

which addresses interagency policy, program, and planning issues 

regarding TVPA implementation. The TVPA 2003 directed the Director of 

the Office to Monitor and Combat Trafficking in Persons to serve as chair 

of the group. In addition, the Intelligence Reform and Terrorism Prevention 

Act of 2004,9

 passed in December 2004, established the Human Smuggling 

and Trafficking Center to be jointly run by the Departments of State, 

Justice and DHS. This center houses several agency data systems to collect 

and disseminate information to build a comprehensive picture of certain 

transnational issues, including, among other things, human trafficking. 

Since 2001, the U.S. government has obligated approximately $375 million 

for international projects to combat trafficking in persons. For example, in 

fiscal year 2005, the U.S. government supported more than 265 

international antitrafficking programs in about 100 countries. State, Labor, 

and USAID are the three largest providers of international assistance to 

target trafficking (see table 1).

9

Pub. L. No. 108-458.
Page 9 GAO-06-825 Human Trafficking

Table 1: Funding Obligated for International Activities to Combat Trafficking in 

Persons, Fiscal Years 2001-2005 

Source: GAO analysis of data provided by State, Labor, Justice, HHS, DHS, and USAID. 

Note: The information represents the most current data provided respectively by these agencies. The 

annual reporting of these data may vary by agency based on when the funds were considered 

obligated.

a

The Department of Labor was unable to break out funding amounts that address trafficking. Totals 

include obligations for activities that either have trafficking as a central focus, one component of a 

larger project linked to trafficking, or as an issue within the overall context of the project. 

b

In addition to the $200,000 in Department of 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 $6.5 million to the two programs. In fiscal year 2005, it provided 

$2.08 million. These amounts are reflected in the State total in table 1. Department of Justice officials 

stated additional funds used to carry out antitrafficking activities, including law enforcement activities, 

come from the regular budget and cannot be broken out.

c

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

enforcement activities, come from the regular budget and cannot be broken out. The $200,000 

reported in 2004 was from State’s Presidential Initiative funding for overseas project initiation.

During an address to the U.N. General Assembly in September 2003, the 

President declared trafficking in persons a humanitarian crisis and 

announced that the U.S. government was committing $50 million to support 

organizations active in combating sex trafficking, sex tourism, and the 

rescue of women and children. In 2004, eight priority countries for the 

initiative were identified—Brazil, Cambodia, India, Indonesia, Mexico, 

Moldova, Sierra Leone, and Tanzania. The initiative was centered on 

developing the capacity of each country to rescue women and children, to 

provide emergency shelters, medical treatment, rehabilitation services,

Dollars in millions

FY 2001 FY 2002 FY 2003 FY 2004 FY 2005

Total FY 

2001-2005

Department of State $11.47 $23.01 $28.13 $33.36 $34.41 $130.38

U.S. Agency for 

International 

Development 6.74 10.72 15.42 27.59 21.34 81.81

Department of Labora 20.65 32.93 48.31 18.65 38.40 158.94a

Department of Justiceb 0 0 0 0.20b 0b 0.20b

Department of Health 

and Human Services 0 0 0 0 2.20 2.20

Department of Homeland 

Securityc N/A 0 0 0.20 0 0.20

Total $38.86 $66.66 $91.86 $80.00 $96.35 $373.73
Page 10 GAO-06-825 Human Trafficking

vocational training, and reintegration services, and to conduct law 

enforcement investigations and prosecutions. 

Estimates of Global 

Human Trafficking Are 

Questionable, and U.S. 

Data Collection Efforts 

Are Fragmented

Existing estimates of the scale of trafficking at the global level are 

questionable, and improvements in data collection have not yet been 

implemented. The accuracy of the estimates is in doubt because of 

methodological weaknesses, gaps in data and numerical discrepancies. For 

example, the U.S. government’s estimate was developed by one person who 

did not document all of his work, so the estimate may not be replicable, 

casting doubt on its reliability. Moreover, country data are generally not 

available, reliable or comparable. There is also a considerable discrepancy 

between the numbers of observed and estimated victims of human 

trafficking. The U.S. government has not yet established an effective 

mechanism for estimating the number of victims or for conducting ongoing 

analysis of trafficking related data that resides within various government 

agencies. While trafficking data collection in the United States is 

fragmented, the database created by the International Organization for 

Migration (IOM) provides a useful systematic profile of victims and 

traffickers across countries. 

Accuracy of Estimates in 

Doubt Because of 

Methodological 

Weaknesses, Gaps in Data, 

and Numerical 

Discrepancies

The U.S. government and three international organizations gather data on 

human trafficking, but methodological weaknesses affect the accuracy of 

their information. Efforts to develop accurate trafficking estimates are 

further frustrated by the lack of country level data. Finally, there is a 

considerable discrepancy between the numbers of observed and estimated 

victims of human trafficking.

Methodological Weaknesses Cast 

Doubt on U.S. and International 

Estimates

The U.S. government and three international organizations have gathered 

data on global human trafficking. However, these organizations face 

methodological weaknesses and institutional constraints that cast doubt on 

the accuracy of the collected data.

The four organizations with databases on global trafficking in persons are 

the U.S. government, International Labor Organization (ILO), IOM,10 and 

UNODC. The U.S. government and ILO estimate the number of victims 

10IOM’s database was funded in part by State’s Trafficking Office.
Page 11 GAO-06-825 Human Trafficking

worldwide, IOM collects data on victims it assists in the countries where it 

has a presence, and UNODC traces the major international trafficking 

routes of the victims. The databases provide information on different 

aspects of human trafficking since each organization analyzes the problem 

based on its own mandate. For example, IOM looks at trafficking from a 

migration and rights point of view11 and ILO from the point of view of 

forced labor. 

Despite the fact that the databases use different methodologies for data 

collection and analysis and have various limitations, some common themes 

emerge. For example, the largest percentage of estimated victims is 

trafficked for sexual exploitation. In addition, women constitute the 

majority of estimated victims. However, the estimated percentage of 

victims that are children ranges from 13 to 50 percent. Table 2 describes the 

victim profiles that emerge from the data. 

11The database is primarily a social service and protection case management tool.
Page 12 GAO-06-825 Human Trafficking

Table 2: Victim Profiles in U.S. government, ILO, UNODC, and IOM databases

Source: GAO analysis of U.S. government, ILO, UNODC, and IOM data.

a

For a detailed discussion, see Belser, Patrick, de Cock, Michaelle and Ferhad Mehran, ILO Minimum 

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

b

For a detailed discussion, see UNODC, Trafficking in Persons Global Patterns, (Vienna: April 2006).

c

For a detailed discussion, see IOM, Data and Research on Human Trafficking: A Global Survey, 

(Geneva: 2005).

d

The estimate was repeated in the 2005 and 2006 Trafficking in Persons Reports. 

e

The numbers refer to the percentage of different sources (i.e., source institutions) that have reported 

in any of their publications a trafficking route, in which women, men and children have been trafficked 

for sexual exploitation or forced labor. The sum of the percentages is greater than 100 because one 

source can indicate more than one victim profile or form of exploitation.

f

Women and girls.

g

Women and girls, where the gender/age information is available.

h

Women only.

U.S. Data Methodological weaknesses and limitations cast doubt on the U.S. estimate 

of global trafficking flows. We identified several important limitations:

U.S. government ILOa UNODCb IOMc

Main focus Global estimate of victims Global estimate of victims Country and regional 

patterns of international 

trafficking 

Actual victims assisted by 

IOM in 26 countries

Number of victims 600,000 to 800,000 

people trafficked across 

borders in 2003d

 (est.)

At least 2.45 million 

people trafficked 

internationally and 

internally during 1995 to 

2004 (est.)

Not available 7,711 victims assisted 

during 1999 to 2005

Type of exploitation

Commercial sex 

Economic or

forced labor 

Mixed and other

66%

34%

43% 

32% 

25%

87%e

28%

81% 

14%

5%

Gender and age of 

victims

80% femalef

50% minors

80% femaleg

40% minors

77% femaleh

 9% male 

33% children

83% female

15% male 

 2% not identified

13% minors

Definition of trafficking 

used

TVPA 2000 U.N. Protocol U.N. Protocol U.N. Protocol

Criteria for data 

collection

Transnational trafficking Internal and transnational 

trafficking

Transnational trafficking Internal and transnational 

trafficking
Page 13 GAO-06-825 Human Trafficking

• Estimate not entirely replicable. The U.S. government agency that 

prepares the trafficking estimate is part of the intelligence community, 

which makes its estimation methodology opaque and inaccessible. 

During a trafficking workshop in November 2005, the government 

agency provided a one-page overview of its methodology, which allowed 

for only a very limited peer review by the workshop participants. In 

addition, the U.S. government’s methodology involves interpreting, 

classifying, and analyzing data, which was performed by one person 

who did not document all of his work. Thus the estimate may not be 

replicable, which raises doubts about its reliability.

• Estimate based on unreliable estimates of others. The biggest 

methodological challenge in calculating an accurate number of global 

trafficking victims is how to transition from reported to unreported 

victims. The U.S. government does not directly estimate the number of 

unreported victims but relies on the estimates of others, adjusting them 

through a complex statistical process. It essentially averages the various 

aggregate estimates of reported and unreported trafficking victims 

published by NGOs, governments, and international organizations, 

estimates that themselves are not reliable or comparable due to 

different definitions, methodologies, data sources, and data validation 

procedures. Moreover, the methodologies used to develop these 

estimates are generally not published and available for professional 

scrutiny.12

• Internal trafficking data not included. The U.S. government does not 

collect data on internal trafficking, which could be a significant problem 

in countries such as India, where forced labor is reportedly widespread. 

According to the 2005 Trafficking in Persons Report, many nations may 

be overlooking internal trafficking or forms of labor trafficking in their 

national legislations. In particular, what is often absent is involuntary 

servitude, a form of severe trafficking. The report also noted that the 

TVPA specifically includes involuntary servitude in the U.S. definition of 

severe forms of trafficking. Nonetheless, the U.S. government estimate 

does not account for it, because it only collects data on offenses that 

cross national borders.

12Because of concerns with the reliability and credibility of aggregate data, ILO chose not to 

use such data in developing its global trafficking estimate.
Page 14 GAO-06-825 Human Trafficking

• Estimate not suitable for analysis over time. The U.S. government 

methodology provides an estimate of trafficking flows for a 1-year 

period and cannot be used to analyze trafficking over time to determine 

whether it is increasing, decreasing, or staying the same. Therefore, the 

estimate cannot help in targeting resources and evaluating program 

effectiveness.

International Data Methodological weaknesses also raise questions about the accuracy of 

trafficking information from international organizations. For example, 

UNODC’s methodology attempts to identify global trafficking flows across 

international borders. It tracks and totals the number of different source 

institutions that have reported a country having a trafficking incident. 

However, whether the trafficking incident involved 5 or 500 victims is 

irrelevant for UNODC’s methodology. In addition, by classifying countries 

in five categories based on the frequency of reporting, UNODC might rank 

a country very high as, say, a destination country, due to the country’s 

heightened public awareness, transparency and recognition of trafficking 

as a serious crime. Alternatively, ILO’s methodology provides a global 

estimate of trafficking victims. However, it attempts to overcome the gap 

between reported and unreported victims using an extrapolation that is 

based on assumptions and observations that have not been rigorously 

tested and validated. Moreover, global databases are based on data sources 

drawn from reports from a limited number of countries or restricted 

geographically to specific countries. For example, IOM’s data only come 

from countries where IOM has a presence, which are primarily countries of 

origin, and the organization is constrained by issues related to the 

confidentiality of victim assistance. Finally, although the three 

organizations are trying to collaborate in the area of data collection and 

research, they are having difficulty in mobilizing the necessary resources 

for their efforts. Therefore, this fragmentary approach prevents the 

development of a comprehensive and accurate view of global trafficking. 

(See app. II for additional information about the different methodologies, 

analytical assumptions, data validation, and data sources used by the 

international organizations and the U.S. government.) 

Reliable and Comparable 

Country Data Do Not Exist

The quality of existing country level data varies due to limited availability, 

reliability, and comparability. Table 3 summarizes the main limitations of 

trafficking data, identified in our review of literature on human trafficking.
Page 15 GAO-06-825 Human Trafficking

Table 3: Reasons that Limit the Quality of Trafficking Data

Source: GAO analysis of reports, articles and presentations from international organizations, the U.S. government and academia.

The availability of data is limited by several factors. Trafficking victims are 

a hidden population because trafficking is a clandestine activity, similar to 

illegal migration and labor exploitation. This limits the amount of data 

available on victims and makes it difficult to estimate the number of 

unreported victims. Trafficking victims are often in a precarious position 

and may be unwilling or unable to report to, or seek help from, relevant 

authorities. Moreover, HHS reported that victims live daily with inhumane 

treatment, physical and mental abuse, and threats to themselves or their 

families back home. Victims of human trafficking may fear or distrust the 

government and police because they are afraid of being deported or 

because they come from countries where law enforcement is corrupt and 

feared. In such circumstances, reporting to the police or seeking help 

elsewhere requires courage and knowledge of local conditions, which the 

victims simply might not have. 

In addition, some governments give low priority to human trafficking 

violations and do not systematically collect data on victims. In most 

countries where trafficking data are gathered, women and children are 

seen as victims of trafficking, and men are predominantly seen as migrant 

workers, reflecting a gender bias in existing information. Men are also 

perceived as victims of labor exploitation that may not be seen as a crime 

but rather as an issue for trade unions and labor regulators. Thus, data 

collection and applied research often miss the broader dimensions of 

trafficking for labor exploitation. For example, the demand for cheap labor, 

domestic service, slavery, and child labor have not been sufficiently 

investigated as factors affecting the scale of human trafficking.

The reliability of existing data is also questionable. In developing countries, 

which are usually countries of origin, capacity for data collection and 

Availability Reliability Comparability

1. Trafficking is an illegal activity and victims are

 afraid to seek help from the relevant

 authorities.

2. Few countries collect data on actual victims

 on a systematic basis.

3. Data collection is focused on women and

 children trafficked for sexual exploitation, and

 other forms of trafficking are likely to be

 underreported.

1. Capacity for data collection and analysis in

 countries of origin is often inadequate.

2. Trafficking convictions in countries of

 destination are based on victim testimony.

3. Estimates of trafficking are extrapolated

 from samples of reported victims, which

 may not be random and thus representative

 of all trafficking victims.

1. Countries and organizations define

 trafficking differently.

2. Official statistics do not make clear

 distinctions among trafficking,

 smuggling, and illegal migration. 

3. Data are often program specific and

 focus on characteristics of victims

 pertinent to specific agencies.
Page 16 GAO-06-825 Human Trafficking

analysis is often inadequate. In countries of destination, human trafficking 

convictions are often based on victim testimony. Moreover, estimates of 

trafficking are extrapolated from samples of reported cases, which are not 

random. Therefore, it is difficult to determine how representative those 

cases are of the general population of all human trafficking victims and 

what biases have been introduced. 

Data quality is further constrained by limited data comparability. Countries 

and organizations define trafficking differently. A practice that is 

considered trafficking in one country may be considered culturally and 

historically acceptable in another country. For example, in West African 

countries, people, in particular children, commonly move within and 

across borders in search of work and are placed in homes as domestic 

servants or on farms and plantations as laborers. Due to economic 

deprivation and an abundant supply of children from poor families, a child 

may be sold by his or her parents based on promises for job training and 

good education or may be placed with a creditor as reimbursement. 

The incompatibility of definitions for data collection is exacerbated by the 

intermingling of trafficking, smuggling, and illegal migration in official 

statistics. Countries have used different definitions regarding the scope and 

means of trafficking; the activities involved, such as recruitment, 

harboring, transportation and receipt of victims; the purpose; the need for 

movement across borders; and the consent of victims. For example, there 

are discrepancies in the collection of data on sex trafficking. Under the 

TVPA, participation of children under the age of 18 in commercial sex is a 

severe form of trafficking. However, some countries define children as 

people under the age of 16 and, according to U.S. government officials, this 

difference has implications for how countries collect data on children 

engaged in commercial sex.

Finally, data are often program and institution specific and focus on the 

needs of individual agencies. Estimates may be developed for the purpose 

of advocacy. For example, some NGOs record all victims based on the first 

contact made with them regardless of whether they subsequently meet the 

criteria for receiving assistance such as legal counsel, shelter, financial 

support, or support during a trial, while others record only those who 

receive assistance. Data are also collected for operational purposes within 

criminal justice systems, and individual authorities use their own 

definitions and classifications. 
Page 17 GAO-06-825 Human Trafficking

Significant Difference Exists 

between Numbers of Estimated 

and Observed Victims

There is significant discrepancy between the number of estimated victims 

and the number of observed victims, which include officially reported, 

certified, registered and assisted victims. For example, the U.S. 

government estimated that the number of people trafficked into the United 

States ranged from 14,500 to 17,500 in 2003.13 Despite concerted U.S. 

government efforts to locate and protect victims, the government certified 

fewer than 900 victims in the United States during the 4 1⁄2 years between 

March 2001 and September 2005.14 The June 2006 Attorney General's 

Annual Report to Congress on U.S. Government Activities to Combat 

Trafficking in Persons for Fiscal Year 2005 indicates that the 14,500 to 

17,500 figure may be overstated because it was an early attempt to quantify 

a hidden problem. The number of certified victims may not reflect the total 

number of victims identified. For example, some alien victims need not 

seek certification because they can remain in the United States through 

family connections. The Justice Department indicates that further research 

is under way to determine a more accurate figure based on more advanced 

methodologies and a more complete understanding of the nature of 

trafficking. Similarly, the U.S. government estimated that a total of 600,000 

to 800,000 people were trafficked across transnational borders worldwide 

annually. Yet, since 1999, fewer than 8,000 victims in 26 countries have 

received IOM assistance. 

Organizations may also publish estimates that incorrectly characterize the 

data reported by others. For example,15 in a 2001 report a Cambodian 

nongovernmental organization states that there were 80,000 to 100,000 

trafficked women and children nationwide. However, this statement is 

based on a report which discusses 80,000 to 100,000 sex workers in the 

country, who may or may not be trafficking victims. Moreover, the latter 

report uses two other sources that did not corroborate this estimate. 

Several factors could explain the differences between the numbers of 

observed and estimated victims, but it is unclear the extent to which any 

single factor accounts for the differences. For example, the 2005 

132004 Trafficking in Persons Report, Department of State.

14Adult aliens are eligible for certification; victims under age 18 do not need to be certified to 

receive benefits. To be certified, the alien must be willing to assist law enforcement in the 

investigation and prosecution of severe forms of trafficking. Also, the alien’s presence in the 

United States must be required to ensure prosecution of traffickers in persons or the alien 

must have made application for a T visa. 

15As reported in a USAID report.
Page 18 GAO-06-825 Human Trafficking

Trafficking in Persons Report cited cases in which victims reported by law 

enforcement were deported before they reached an assistance agency. In 

addition, agencies may not make sufficient efforts in identifying and 

helping victims or may have constraints imposed by certain assistance 

requirements. Victims assisted by IOM missions are those willing to go 

back to their country of origin. However, if there are other opportunities 

available in the country of destination, such as receiving a residence 

permit, victims may not be willing to accept IOM assistance. In the United 

States, one requirement of receiving official certification is that victims of 

human trafficking must be willing to assist with the investigation and 

prosecution of trafficking cases. According to an HHS official, this 

requirement may work to limit the number of recorded victims. Given the 

weaknesses in data and methods, it also cannot be dismissed that the 

estimates may overstate the magnitude of human trafficking. 

Trafficking Data Collection 

in the United States Is 

Fragmented While IOM’s Is 

Systematic 

The U.S. government has not yet established an effective mechanism for 

estimating the number of victims or for conducting ongoing analysis of 

trafficking related data that resides within various government agencies. 

The TVPA 2005, passed in January 2006, called on the President, through 

various agencies, to conduct research into the development of an effective 

mechanism for quantifying the number of victims of trafficking on a 

national, regional, and international basis. Since 2005, the U.S. government 

has funded a project to develop a transparent methodology for estimating 

the number of men, women, and children trafficked into the United States 

for purposes of sex or labor trafficking. To date, the modeling has been 

limited to 10 countries of origin—Colombia, Venezuela, Ecuador, Peru, El 

Salvador, Guatemala, Nicaragua, Mexico, Haiti, and Cuba—and one arrival 

point in the United States—the southwest border. The firm developing this 

methodology is in the early stages of this effort and plans to continue to 

refine and test its methodology. Thus, it is too early to assess this 

methodology. The U.S. government also recently funded an outside 

contractor to improve future global trafficking estimates. To date, the U.S. 

government has funded few projects to improve estimates of trafficking on 

a regional or international basis.

In addition, the Intelligence Reform and Terrorism Prevention Act of 2004 

established the Human Smuggling and Trafficking Center16 to serve, among 

16Pub. L. No. 108-458. The Human Smuggling and Trafficking Center is a joint State, DHS, 

and Justice operation.
Page 19 GAO-06-825 Human Trafficking

other responsibilities, as a clearinghouse for all relevant information and to 

convert it into tactical, operational, and strategic intelligence to combat 

trafficking in persons. The Human Smuggling and Trafficking Center 

collects trafficking information from U.S government agencies and sends 

this information to other agencies that have an interest in it for law 

enforcement purposes. Center officials stated that they receive and collate 

trafficking information from federal government agencies. However, 

officials stated that they do not systematically analyze the trafficking 

information they receive and lack the human and financial resources to do 

so. In addition, we identified eight entities within the federal government 

that possess some information related to domestic and international 

trafficking. The Justice Department alone has four different offices that 

possess domestic trafficking information. None of the federal agencies 

systematically shares their international data with the others, and no 

agency analyzes the existing data to help inform international program and 

resource allocation decisions. (See app. III for information on the type of 

trafficking data available within agencies.)

Furthermore, based upon our analysis of agency data sets, we found that 

federal agencies do not have data collection programs that could share 

information or include common data fields. As a result, it is difficult to use 

existing agency trafficking data to compile a profile of trafficking victims. 

In previous work, we have reported that it is good practice for agencies to 

establish compatible policies, procedures, standards, and data systems to 

enable them to operate across agency boundaries.17 Although some 

information exists, agencies were unable to provide an account of the age, 

gender, type of exploitation suffered, and origin and destination of 

trafficking victims into the United States. Moreover, some agencies with 

law enforcement missions were generally unwilling to share demographic 

trafficking data with us and would release statistics for law enforcement 

purposes only. The U.S. National Central Bureau was able to extract limited 

profile information from its case management system. 

While the information on trafficking victims collected by U.S. agencies is 

fragmented, the database created by IOM allows for the development of a 

useful, in-depth profile of traffickers and their victims across 26 countries. 

Although IOM’s data are limited to countries where IOM provides direct 

assistance to trafficking victims, has a short history of about 7 years, and 

17GAO, Results-oriented Government: Practices that Can Help Enhance and Sustain 

Collaboration among Federal Agencies, GAO-06-15 (Washington, D.C.: Oct. 21, 2005).
Page 20 GAO-06-825 Human Trafficking

may not be easily generalizable, it is the only one of the four databases that 

contains data directly obtained from victims. Drawing from more than 

7,000 cases, it includes information about the victims’ socioeconomic 

profile, movement, exploitation, abuse, and duration of trafficking. 

Moreover, the database tracks victims from the time they first requested 

IOM assistance, through their receipt of assistance, to their subsequent 

return home. Importantly, it also tracks whether victims were subsequently 

retrafficked. These factors provide information that could assist U.S. 

efforts to compile better data on trafficking victims.

As shown in figure 2, the victims IOM assisted often were enticed by 

traffickers’ promise of a job, most believed they would be working in 

various legitimate professions, and were subjected to physical violence.

Figure 2: Profile of 7,711 Trafficking Victims IOM Assisted between 1999 and 2005

Note: All estimates are a result of GAO analysis of IOM data and are based on cases with available 

data.

a

IOM's policy is to use the term "prostitute" rather than "sex worker" although the latter is used in their 

database.

In addition, based on cases with available data on the duration of the 

trafficking episode, the average duration of stay in the destination country 

before seeking help from IOM is more than 2 years. Most of the sexual 

exploitation victims worked 7 days a week and retained a small fraction of 

their earnings. Moreover, about 54 percent of the victims paid a debt to the 

recruiter, transporter and/or other exploiters, and about 52 percent knew 

they were sold to other traffickers at some stage of the trafficking process. 

• Enticed by promise of a job

(85%)

• Unemployed (55%) but had 

work experience in the country 

of origin (91%)

• Single (66% )

• Living with their families (80%)

• Waitresses (22%)

• Domestic workers (14%)

• Sales associates (10%)

• Dancers and entertainers (10%)

• Sex workersa

 (10%)

• Forced to engage in an activity 

against their will (87%)

• Subjected to physical violence 

(52%)

• Completely denied freedom of 

movement (50%)

Prior to being trafficked, 

victims were:

Victims believed they 

would be working in the 

following professions:

After their arrival in 

destination countries, 

victims were:

Source: GAO analysis of IOM data.
Page 21 GAO-06-825 Human Trafficking

The database also contains information about the recruiters’ and 

traffickers’ networks, nationality, and relationship to victims. It thus 

provides insights into the traffickers and the mechanisms traffickers used 

to identify and manipulate their victims. For example, in 77 percent of the 

cases, contact with the recruiter was initiated based on a personal 

relationship. Moreover, the correlation between the nationality of the 

recruiter and that of the victim was very high (0.92). Trafficking networks 

may have a complex organization, with the recruiter being only one part of 

the whole system. The organization may involve investors, transporters, 

corrupt public officials, informers, guides, debt collectors, and money 

launderers. The extent of information on victims and traffickers in the 

database improves the overall understanding of the broader dimensions of 

trafficking.

Lack of Strategy and 

Performance Measures 

Prevents U.S. 

Government from 

Determining Overall 

Program Effectiveness 

Abroad 

While federal agencies have undertaken activities to combat trafficking in 

persons, the U.S. government has not developed a coordinated strategy to 

combat human trafficking abroad, as called for in a presidential directive. 

The U.S. government has established an interagency task force and 

working group on human trafficking, which have focused on complying 

with U.S. policy on prostitution and avoiding duplication of effort, but they 

have not focused on developing and implementing a systematic way for 

agencies to clearly delineate roles and responsibilities in relation to each 

other, and identify targets of greatest need and leverage overseas activities 

to achieve greater results. In addition, governmentwide task forces have 

not developed measurable goals and associated indicators to evaluate the 

overall effectiveness of efforts to combat trafficking abroad or outlined an 

evaluation plan to gauge results, making the U.S. government unable to 

determine the effectiveness of its efforts abroad or to adjust its assistance 

to better meet needs.

U.S. Government Has No Overall 

Strategic Framework to Combat 

Human Trafficking Abroad

Although the U.S. government established an interagency task force and 

working group in 2002 to coordinate U.S. agencies’ antitrafficking 

activities,18 as required by legislation, it has not developed a coordinated 

strategy to combat trafficking in persons abroad, as called for by a 

18The working group was first established as the Senior Policy Advisory Group in 2002, 

according to the Department of State, and became the Senior Policy Operating Group as 

mandated in TVPA 2003.
Page 22 GAO-06-825 Human Trafficking

presidential directive.19 The directive further stated that strong 

coordination among agencies working on domestic and foreign policy is 

crucial and that departments and agencies shall coordinate U.S. foreign 

assistance programs to combat trafficking in persons. In addition, our 

previous work on issues that are national in scope and cut across agency 

jurisdictions has shown that a strategic framework can be useful in guiding 

agency resource and policy decisions.20 Furthermore, our previous work 

has shown that lack of a coordinated strategy creates the risk of overlap 

and fragmentation that may result in wasting scarce funds and limiting 

program effectiveness.21

Despite the presidential directive that requires the Senior Policy Operating 

Group (the Group) to develop a coordinated strategy to combat human 

trafficking, agency officials acknowledged that there is no coordinated 

government strategy for efforts abroad. One senior agency official stated 

that her agency uses the three-pronged approach of prevention, protection, 

and prosecution as guidance. However, officials agreed that a strategic plan 

could help improve understanding and coordination among agencies. In 

addition, of the six government agencies that conduct antitrafficking 

programs abroad, only two—State’s Trafficking Office and 

USAID—provided us with strategy-type documents that specifically 

addressed trafficking abroad and included a majority of the characteristics 

that we have identified in previous work as necessary to implement a 

national strategy. Both agencies’ documents, at least partially, address the 

six characteristics we identified. However, neither agency’s documents 

clarified roles in relation to other agencies or established clear and 

strategic performance measures to gauge results and evaluate 

effectiveness. 

19National Security Presidential Directive (NSPD) 22, signed on December 16, 2002.

20We identified six desirable characteristics to include in a national strategy: (1) purpose, 

scope, and methodology; (2) problem definition and risk assessment; (3) goals, subordinate 

objectives, activities, and performance measures; (4) resources, investments, and risk 

management; (5) organizational roles, responsibilities, and coordination; and (6) integration 

and implementation. See GAO, Combating Terrorism: Evaluation of Selected 

Characteristics in National Strategies Related to Terrorism, GAO-04-408T (Washington, 

D.C.: Feb. 3, 2004), and Prescription Drugs: Strategic Framework Would Promote 

Accountability and Enhance Efforts to Enforce the Prohibitions on Personal Importation, 

GAO-05-372 (Washington, D.C.: Sept. 8, 2005).

21GAO-04-408T.
Page 23 GAO-06-825 Human Trafficking

Coordination Efforts Focused on 

Avoiding Duplication Abroad, 

Not on Leveraging Resources to 

Maximize Impact

As required by TVPA 2003, the U.S. government has established the Group 

to coordinate the activities of federal agencies regarding policies involving 

international human trafficking; but, although the coordination efforts have 

focused on compliance with U.S. policy on prostitution and avoiding 

duplication of effort, the efforts do not include a focus on developing and 

implementing a systematic way for agencies to clearly delineate roles and 

responsibilities in relation to each other and to identify targets of greatest 

need and leverage activities to achieve greater results. The presidential 

directive calls on agencies to work together through the Group to address 

coordination, sharing of information, and marshalling of law enforcement 

resources. 

According to participating agency officials, the Group—through the work 

of its various subcommittees—served as a forum for agency officials to 

discuss trafficking policy and programs. The Group also instituted a grants 

funding notification system that requires agencies to notify members about 

each antitrafficking grant program that an agency is considering awarding. 

According to the Group’s guidance, agencies can offer comments on 

potential duplication, partnership opportunities, and whether a proposed 

project or grantees comply with the U.S. government policy on 

prostitution.22 Information provided to the Group for notification includes 

the name of the recipient, location, short description of the project, and the 

proposed amount. Members can comment on a grant, but they do not 

provide approval; the awarding agency makes the final decision about 

whether to award the grant. According to agency officials, the formal 

notification process takes place after the awarding agency has held its own 

grants panel and has chosen its final grants, making it too late for other 

agencies’ comments to have a significant impact on the grant. 

According to officials knowledgeable with the Group’s actions, it has not 

developed or implemented a systematic way for agencies to identify 

22The TVPA 2003 added the provision that no funds made available to carry out the TVPA as 

amended may be used to promote, support, or advocate the legalization or practice of 

prostitution. In addition, no funds made available to carry out the TVPA, as amended, may 

be used to implement any program that targets victims of severe forms of trafficking 

through any organization that has not stated in a grant application or agreement that it does 

not promote, support, or advocate the legalization or practice of prostitution. National 

Security Presidential Directive 22, signed on December 16, 2002, states that U.S. policy 

opposes prostitution and prostitution-related activities, such as pimping, pandering, or 

maintaining brothels, as contributing to the phenomenon of trafficking in persons. The U.S. 

government’s position is that these activities should not be regulated as a legitimate form of 

work for any human being.
Page 24 GAO-06-825 Human Trafficking

priorities and target efforts abroad to complement each others’ activities to 

achieve greater results than if the agencies were acting alone.23 The 

presidential directive required agencies to submit plans to implement the 

provisions in the directive. Agencies submitted these plans. Our review of 

these plans found that, for the most part, they provide information 

summarizing ongoing activities, but officials from several agencies were 

unable to explain if, or to what extent, they used them to target resources 

and coordinate activities. One Trafficking Office official stated that the 

office never used its implementation plan; however, the official further 

stated that the office is in the process of updating it to make it more 

applicable. 

The U.S. Government Does 

Not Have a Plan to Evaluate 

Its Overall Antitrafficking 

Efforts Abroad

Despite the mandate to evaluate progress, the Interagency Task Force has 

not developed a plan to evaluate overall U.S. government efforts to combat 

trafficking abroad. In TVPA 2000, Congress called upon the Interagency 

Task Force to measure and evaluate the progress of the United States and 

other countries in preventing trafficking, protecting and providing 

assistance to victims, and prosecuting traffickers. However, the Task Force 

has not developed an evaluation plan or established governmentwide 

performance measures against which the U.S. government can evaluate the 

overall impact of its international antitrafficking efforts.24 In previous work, 

we have reported that monitoring and evaluating efforts can help key 

decision makers within agencies, as well as clients and stakeholders, 

identify areas for improvement.25 Further, in its 2005 annual assessment of 

U.S. government activities to combat human trafficking, the Department of 

Justice recommended that the U.S. government begin measuring the 

impact of its antitrafficking activities. Although the project-level 

documentation that we reviewed from agencies, such as USAID and the 

Department of Labor, included measures to track activities on specific 

projects, officials stated that USAID’s agency-level aggregate indicators are 

intended as a way of communicating agency outputs, not as a means of 

23In previous work, we broadly defined collaboration as any joint activity intended to 

produce more public value than could be produced when the organizations act alone. 

GAO-06-15. 

24In previous work on desirable characteristics of a national strategy, we have found that 

identifying priorities, milestones, and performance measures, usually developed in 

conjunction with a strategic framework, can help agencies achieve results, and enable more 

effective oversight and accountability. See GAO-04-408T.

25GAO-06-15.
Page 25 GAO-06-825 Human Trafficking

evaluating the effectiveness of programs. In addition, according to the 2005 

State Department Inspector General report, State’s Trafficking Office needs 

to better identify relevant, objective, and clear performance indicators to 

compare progress in combating trafficking from year to year. Officials 

from State’s Trafficking Office recognized the need to establish 

mechanisms to evaluate grant effectiveness. However, officials stated that 

the office lacks the personnel to monitor and evaluate programs in the field 

and that it relies on U.S. embassy personnel to assist in project monitoring. 

In early 2006, the Trafficking Office adopted a monitoring and evaluation 

tool to assist embassy personnel in monitoring its antitrafficking programs, 

but it is too soon to assess its impact.

Our review of the Department of State documentation and discussions with 

agency officials found little evidence of the impact of various 

antitrafficking efforts. For example, the 2005 Trafficking in Persons Report 

asserts that legalized or tolerated prostitution nearly always increases the 

number of women and children trafficked into commercial sex slavery, but 

does not cite any supporting evidence. However, apart from a 2005 

European Parliament sponsored study26 on the link between national 

legislation on prostitution and the trafficking of women and children, we 

found few studies that comprehensively addressed this issue. In addition, 

the State Inspector General report noted that some embassies and 

academics questioned the credentials of the organizations and findings of 

the research that the Trafficking Office funded. The Inspector General 

recommended that the Trafficking Office submit research proposals and 

reports to a rigorous peer review to improve oversight of research efforts. 

In addition, according to agency officials in Washington, D.C. and in the 

field, there is little or no evidence to indicate the extent to which different 

types of efforts—such as prosecuting traffickers, abolishing prostitution, 

increasing viable economic opportunities, or sheltering and reintegrating 

victims—impact the level of trafficking or the extent to which rescued 

victims are being retrafficked. 

26The study concluded that a country’s legal position on prostitution was not the only factor 

that influences the number of women and children trafficked for sexual exploitation and 

that a final evaluation of the legislative model and the impact on the number of victims 

should be based on a wider, more reliable and comparable set of data. Transcrime, Study on 

National Legislation on Prostitution and the Trafficking in Women and Children, a report 

prepared for the European Parliament, August 2005.
Page 26 GAO-06-825 Human Trafficking

Department of State’s 

Annual Report Ranks 

Foreign Governments’ 

Antitrafficking Efforts 

but Has Limited 

Credibility and Does 

Not Consistently 

Influence 

Antitrafficking 

Programs 

As required by the TVPA, the Department of State issues an annual report 

that analyzes and ranks foreign governments’ compliance with minimum 

standards to eliminate trafficking in persons. This report has increased 

global awareness about trafficking in persons, encouraged action by some 

governments who failed to comply with the minimum standards, and raised 

the threat of sanctions against governments who did not make significant 

efforts to comply with these standards. The Department of State includes 

explanations of the rankings in the report, though they are not required 

under the TVPA. However, the report’s explanations for these ranking 

decisions are incomplete, and agencies do not consistently use the report 

to influence antitrafficking programs. Information about whether a country 

has a significant number of trafficking victims may be unavailable or 

unreliable, making the justification for some countries’ inclusion in the 

report debatable. Moreover, in justifying the tier rankings for these 

countries, State does not comprehensively describe foreign governments’ 

compliance with the standards, many of which are subjective. This lessens 

the report’s credibility and hampers its usefulness as a diplomatic tool. In 

addition, incomplete country narratives reduce the report’s utility as a 

guide to help focus U.S. government resources on antitrafficking 

programming priorities. 

Department of State’s 

Annual Report Assesses 

Foreign Governments’ 

Efforts to Eliminate 

Trafficking

Each year since 2001, State has published the congressionally mandated 

Trafficking in Persons Report, ranking countries into a category, or tier, 

based on the Secretary of State’s assessment of foreign governments’ 

compliance with four minimum standards for eliminating human 

trafficking, as established in the TVPA. These standards reflect the U.S. 

government’s antitrafficking strategy of prosecuting traffickers, protecting 

victims, and preventing trafficking. The first three standards deal with 

countries’ efforts to prohibit severe forms of trafficking and prescribe 

penalties for trafficking crimes, while the fourth standard relates to 

government efforts to eliminate trafficking.27 The TVPA instructed the 

Secretary of State to place countries that are origin, transit, or destination 

countries for a significant number of victims of severe forms of trafficking 

in one of three tiers. In 2003, State added a fourth category, the tier 2 watch 

27The fourth standard provides 10 indicia that can be used to assess these efforts. According 

to the Trafficking Office, it focuses on 5 of the 10 as core criteria: (1) prosecution of 

traffickers, (2) prosecution of corrupt government officials who contribute to trafficking, 

(3) protection of victims, (4) prevention of trafficking, and (5) demonstrated progress in 

combating trafficking from year to year (see app. IV).
Page 27 GAO-06-825 Human Trafficking

list, consisting of tier 2 countries that require special scrutiny in the coming 

year (see fig. 3). Governments of countries placed in tier 3 may be subject 

to sanctions by the United States. 

Figure 3: Tier Definitions

In addition to the rankings, each Trafficking in Persons Report contains 

country narratives intended to provide the basis for each country’s tier 

placement. Although the narratives are not required by the TVPA, they state 

the scope and nature of the trafficking problem, explain the reasons for the 

country’s inclusion in the report, and describe the government’s efforts to 

Tier 1

(24 countries)

Tier 2

(77 countries)

Tier 2 watchlist

(27 countries)

Tier 3

(14 countries) 

Countries whose governments fully comply with 

the minimum standards.

Countries whose governments do not fully 

comply with the minimum standards but are 

making significant efforts to do so.

Countries whose governments do not fully comply 

with the minimum standards but are making 

significant efforts to do so and:

have a very significant or increasing number of 

victims

fail to show increasing efforts to combat 

trafficking from previous year or

have been assessed as making significant efforts

to comply based on commitments to take steps

over the next year.

Countries whose governments do not comply 

with minimum standards and are not making 

significant efforts to do so.

Source: 2005 Trafficking in Persons Report.

●

●

●
Page 28 GAO-06-825 Human Trafficking

combat trafficking and comply with the minimum standards contained in 

U.S. legislation. For countries placed in the lowest two tiers, State develops 

country action plans to help guide governments in improving their 

antitrafficking efforts. 

Trafficking in Persons

Report Has Raised Global 

Awareness about Human 

Trafficking

The Trafficking in Persons Report has raised global awareness about 

human trafficking and spurred some governments that had failed to comply 

with the minimum standards to adopt antitrafficking measures. According 

to U.S. government and international organization officials and 

representatives of trafficking victim advocacy groups, this is due to the 

combination of a public assessment of foreign governments’ antitrafficking 

efforts and potential economic consequences for those that fail to meet 

minimum standards and do not make an effort to do so.

U.S. government officials cited a number of cases in which foreign 

governments improved their antitrafficking efforts in response to their tier 

placements. For example, State and USAID officials cited the case of 

Jamaica, a source country for child trafficking into the sex trade, which 

was placed on tier 3 in the 2005 report. The country narrative noted 

deficiencies in Jamaica’s antitrafficking measures and reported that the 

government was not making significant efforts to comply with the 

minimum standards. Jamaica failed to investigate, prosecute, or convict 

any traffickers during the previous year, despite the passage of a law to 

protect minors. In response, the Jamaican government created an 

antitrafficking unit within its police force and conducted raids that led to 

nine trafficking-related arrests. 

In addition, the 2004 report placed Japan on the tier 2 watch list, and the 

country narrative noted that Japan is a destination country for large 

numbers of foreign women and children who are trafficked for sexual 

exploitation. It highlighted weaknesses in Japan’s law enforcement efforts. 

For example, the lack of scrutiny of Japan’s entertainer visas reportedly 

allowed traffickers to use them to bring victims into the country. The 

country narrative also mentioned Japan’s failure to comply with minimum 

standards for protecting victims, deporting foreign trafficking victims as 

undocumented aliens who had committed a crime by entering the country 

illegally. According to State officials and the 2005 report, the Japanese 

government responded to the report’s criticisms by tightening the issuance 

of entertainer visas and ceasing the criminal treatment of trafficking 

victims. 
Page 29 GAO-06-825 Human Trafficking

Governments of countries placed on tier 3 that do not implement the 

recommendations in the country action plan may be subject to sanctions or 

other penalties. The United States, for example, may oppose assistance for 

the country from international financial institutions such as the 

International Monetary Fund.28 Since 2003, full or partial sanctions have 

been applied to eight countries,29 most of which were already under 

sanctions from the United States. 

Limitations in the 2005 

Trafficking in Persons 

Report Affect Its Credibility 

as a Diplomatic Tool

According to the presidential directive and the 2005 Trafficking in 

Persons Report, the annual report is intended as a tool to help the United 

States engage foreign governments in fighting human trafficking. 

According to U.S. government officials, the report’s effectiveness as a 

diplomatic tool for discussing human trafficking with foreign governments 

depends on its credibility. The country narratives used as the basis for 

ranking decisions should provide clear and comprehensive assessments of 

foreign governments’ antitrafficking efforts and demonstrate consistent 

application of the standards. Our analysis of the 2005 report found 

limitations in the country narratives, and State officials in the Regional 

Bureaus expressed concerns that these limitations detract from the report’s 

credibility and usefulness. These include some countries’ inclusion in the 

report based on unreliable data, incomplete explanations of compliance 

with the minimum standards by some of the highest-ranked countries, and 

country narratives that did not clearly indicate how governments complied 

with certain standards and criteria. We also found criticisms of the process 

for resolving disputes about country inclusion and tier rankings.

Some Countries’ Inclusion in the 

Report Based on Unreliable Data

The TVPA requires State to rank the antitrafficking efforts of governments 

of countries that are sources, transit points, or destinations for a 

“significant number” of victims of severe forms of trafficking. Since 2001, 

28In 2001, we assessed whether the Treasury Department was able to influence operations at 

the International Monetary Fund (Fund) in a direction that would be consistent with U.S. 

policies. We found that it was difficult to attribute Fund operations to any one member 

because the Fund generally operates on a consensus decision-making basis. GAO, 

International Monetary Fund: Efforts to Advance U.S. Policies at the Fund, GAO-01-214

(Washington, D.C.: Jan. 23, 2001).

29In 2003, the President decided to impose full sanctions on Burma, Cuba, and North Korea 

and partial sanctions on Liberia and Sudan. In 2004, full sanctions were again imposed on 

Burma, Cuba, and North Korea and partial sanctions on Equatorial Guinea, Sudan, and 

Venezuela. In 2005, full sanctions were imposed on Burma, Cuba, and North Korea and 

partial sanctions on Cambodia and Venezuela.
Page 30 GAO-06-825 Human Trafficking

State has used a threshold of 100 victims to determine whether or not to 

include a country in the Trafficking in Persons Report.

30 However, as 

discussed earlier in this report, reliable estimates of the number of 

trafficking victims are generally not available. For example, according to 

State officials, one country was included in the report because a junior 

political officer stated that at least 300 trafficking victims were in the 

country and that the government’s efforts to combat trafficking should be 

assessed. According to these officials, this statement was based on the 

political officer’s informal survey of brothels in that country. Since then, 

other embassy officials, including the ambassador, have argued that the 

country does not have a significant number of victims, but it continues to 

appear in the report. In addition, State officials cited Estonia as a country 

that was included in the report based on an IOM official’s informal estimate 

of more than 100 victims. State officials said that a subsequent 

embassy-funded study of trafficking in Estonia found that the country had 

around 100 confirmed victims in a 4-year period, but internal discussions 

have not led to the removal of Estonia from the Trafficking in Persons 

Report. However, the country narrative for Estonia in the 2005 report was 

modified from previous years to state that Estonia is a source and transit 

country for a “small number” of trafficking victims. 

Our review of country narratives in the 2005 report revealed some cases in 

which it was not clear how the situations used to justify the country’s 

inclusion in the report constituted severe forms of trafficking under U.S. 

law. For example, the country narratives for Algeria, Saudi Arabia, and 

Singapore described cases in which human smugglers abandoned people, 

domestic workers were abused by their employers, and foreign women 

engaged in prostitution. The narratives either did not clearly establish 

whether the situation involved victims of severe forms of trafficking or 

failed to provide enough information about the magnitude of the problem 

to convey the sense that the number of victims had reached 100 people. 

According to State officials, inclusion of human rights abuses or labor 

issues in the description of foreign countries’ human trafficking problem 

can damage the report’s credibility with foreign governments. Some State 

officials have suggested abandoning the threshold of 100 victims and 

including all countries in the report.

30The threshold of 100 victims is not legislatively mandated.
Page 31 GAO-06-825 Human Trafficking

Unclear Threshold for Meeting 

Standard on Prescribed 

Punishment 

Our analysis of the 2005 report found that many narratives did not clearly 

state whether and how the government met the minimum standard 

regarding stringency of punishment for severe forms of trafficking (see 

app. I for a description of the methodology used to analyze the 2005 

report). This standard requires that prescribed penalties for severe forms 

of trafficking be sufficiently stringent to deter such trafficking and that they 

reflect the heinous nature of the offense. The Trafficking Office has not 

defined a threshold for what constitutes “sufficiently stringent” 

punishment. Our analysis showed that in over one-third of cases, the 2005 

report’s country narratives did not characterize the prescribed penalties as 

sufficiently stringent. Moreover, in many cases the narratives do not state 

whether or not the government met this minimum standard. State officials 

agreed that this subjectivity makes it difficult for reports staff and foreign 

governments to know what constitutes compliance, negatively affecting 

the report’s credibility and utility as a diplomatic tool. 

Narratives for Highest-Ranked 

Countries Did Not Fully Explain 

Their Placement

Our analysis of the 2005 report found that many country narratives do not 

provide a comprehensive assessment of foreign governments’ compliance 

with the minimum standards, resulting in incomplete explanations for tier 

placements. Although the 2005 report discusses the importance of 

imposing strict penalties on traffickers, we found that only 2 of the 24 tier 1 

country narratives clearly explained compliance with the second minimum 

standard established in the TVPA, which, among other things, calls for 

governments to prescribe punishment for sex trafficking that is 

commensurate with that for grave crimes such as forcible sexual assault. 

The narratives for 17 (71 percent) of the tier 1 countries provided 

information on penalties for sex trafficking but did not compare these with 

the governments’ penalties for other grave crimes. Five (21 percent) tier 1 

countries did not mention whether the governments complied with this 

standard at all. 

Our analysis of the tier 1 country narratives in the 2005 report also showed 

that, while most explained how these governments fully met the core 

criteria for the fourth minimum standard, related to government efforts to 

eliminate severe forms of trafficking, some did not. A senior official at the 

Trafficking Office confirmed this finding. We found that country narratives 

for 11 (46 percent) of the 24 tier 1 countries raised concerns about the 

governments’ compliance with key parts of core criteria used to determine 

if the government is making a serious and sustained effort to eliminate 

severe forms of trafficking. However, the narratives failed to explain 

whether and how the governments’ success in meeting the other core 
Page 32 GAO-06-825 Human Trafficking

criteria outweighed these deficiencies and justified their placement in tier 

1. 

For example, the 2005 report described France, a tier 1 country, as a 

destination for thousands of trafficked women and children. Although the 

report states that the French government fully complied with the minimum 

standards, our analysis of the narrative found that the first three standards 

were not mentioned. Furthermore, the narrative also discussed the French 

government’s failure to comply with the criterion on protecting trafficking 

victims, one of the key objectives of U.S. antitrafficking legislation. The 

narrative discusses a French law, which harmed trafficking victims by 

arresting, jailing, and fining them. Senior officials at the Trafficking Office 

are concerned about France’s lack of compliance with the victim 

protection criterion. The narrative, however, did not balance the discussion 

of these deficiencies by explaining how the government’s compliance with 

the other core criteria allowed it to meet the fourth minimum standard and 

thus be placed in tier 1. 

Similarly, the country narratives for two tier 1 countries stated that the 

governments were not taking steps to combat official corruption, which the 

2004 report highlights as a major impediment to antitrafficking efforts. For 

example, the narrative for Nepal, a source country for women and children 

trafficked to India and the Middle East, states that the government fully 

complied with the minimum standards. However, the narrative noted that 

the government has not taken action against immigration officials, police 

and judges suspected of benefiting from trafficking-related graft and 

corruption, and it did not explain how the deficiency in this core criteria 

was outweighed by Nepal’s efforts with other core criteria. 

Internal Process for Resolving 

Disagreements Lacks Credibility

According to State officials, there are a considerable number of 

disagreements within State about the initial tier placements proposed by 

the Trafficking Office. These disagreements are not surprising, given that 

the Trafficking Office focuses exclusively on antitrafficking efforts while 

the Regional Bureaus manage bilateral relations, which comprise a wide 

range of issues. However, it is important that the process for resolving 

these conflicts be credible. Some disagreements on tier rankings are 

resolved in meetings between the Trafficking Office and the Deputy 

Assistant Secretaries of the Regional Bureaus, but most are elevated to the 

undersecretary level. A few disagreements are even referred to the 

Secretary of State for resolution. According to State officials, some 

disputes are worked out by clarifying misunderstandings or providing 

additional information. Although Trafficking Office staff said that these 
Page 33 GAO-06-825 Human Trafficking

discussions are constructive, staff in State’s Regional Bureaus said that 

many disagreements over tier rankings are resolved by a process of 

“horsetrading,” whereby the Trafficking Office agrees to raise some 

countries’ tier rankings in exchange for lowering others. In these cases, 

political considerations may take precedence over a neutral assessment of 

foreign governments’ compliance with minimum standards to combat 

trafficking. Senior officials at the Trafficking Office acknowledged that 

political considerations sometimes come into play when making the tier 

ranking decisions. 

Trafficking in Persons 

Report Is Not Used to 

Prioritize Programs or 

Target Resources 

The Trafficking Office’s implementation plan and the 2005 Trafficking in 

Persons Report states that the report should be used as a guide to target 

resources to prosecution, protection, and prevention programs. However, 

we found that U.S. government agencies do not systematically link the 

programs they fund to combat trafficking overseas with the tier rankings or 

the deficiencies that are identified in the report’s country narratives. For 

example, U.S. agencies did not use the report when they selected 

high-priority countries to participate in the 2-year $50 million Presidential 

Initiative to Combat Trafficking in Persons. Moreover, we found that 

many of the country narratives describing deficiencies in foreign 

governments’ antitrafficking efforts were incomplete, making it difficult to 

use them to guide programming. 

U.S. Government Lacks 

Mechanism to Link Its Overseas 

Programs to Deficiencies 

Identified In Trafficking in 

Persons Report

Officials from State’s Trafficking Office acknowledged that the 

management processes and staff responsible for producing the report are 

not linked with those managing overseas assistance programs. State’s 

Inspector General reported in November 2005 that the lack of 

synchronization between the Trafficking Office’s grants cycle (January and 

February) and reporting cycle (June) makes it difficult to address the 

shortcomings identified in the report and the countries’ programming 

needs. In addition, most of the State requests for grant proposals that we 

reviewed were generic in scope and were not tailored to address a specific 

problem or priority. For example, one request for proposal was directed 

broadly at prevention and protection programs in Africa, the Caribbean, 

and Latin America. In addition, officials from State’s regional bureaus said 

that most of their requests for grant proposals are sent to all the embassies 

in their region and are not targeted to those countries on lower tiers. 

However, officials from one regional bureau stated that they sent a request 

for grant proposals dealing with law enforcement issues only to those 

countries on the tier 2 watch list to ensure the programs were targeted 

where they were most needed.
Page 34 GAO-06-825 Human Trafficking

The presidential directive stated that agencies are to develop a consensus 

on the highest priority countries to receive antitrafficking assistance 

through interagency consultation and in consultation with U.S. missions 

overseas. The Trafficking Office’s implementation plan called for using the 

annual Trafficking in Persons Report as a guide to target assistance, with 

priority to countries ranked in the lowest tiers and assistance to only those 

tier 1 and 2 countries with limited resources and whose governments 

showed a clear commitment to combat trafficking. In fiscal year 2005, the 

U.S. government obligated about $96 million to support more than 265 

international antitrafficking programs in about 100 countries. Only 

one-fourth of this money went to countries ranked in the lowest two tiers 

(see fig. 4).

Figure 4: Fiscal Year 2005 Obligations for Antitrafficking Activities by Tier Ranking

Note: The "other" category refers to obligations directed to multicountry or regional programs that 

cannot be categorized by tier placement.

Through the Senior Policy Operating Group, in January 2004 agencies 

selected eight countries to target their efforts for the presidential initiative 

to combat trafficking in persons; however, documentation of the 

decision-making process does not mention use of the Trafficking in 

Source: GAO analysis. 

5% 4%

49%

18%

24%

Tier 1

Tier 2

Tier 3

Other

Tier 2 watch list 
Page 35 GAO-06-825 Human Trafficking

Persons Report’s tier rankings or country narratives to affect this selection. 

Officials from the Trafficking Office and the documents we reviewed stated 

that the Group selected countries based on several factors, including 

anticipated host government commitment and the ability to start 

implementation in a short time frame. The eight countries selected were 

ranked in tier 2 in the 2003 Trafficking in Persons Report, suggesting that 

their governments showed some commitment to combating trafficking by 

making efforts to comply with the minimum standards and criteria outlined 

in the TVPA. However, it was not clear how the Group applied the criteria 

in selecting the countries. For example, host government commitment to 

combat trafficking did not necessarily translate into a willingness to 

receive U.S. assistance. The Department of State cables indicate that the 

governments in Brazil and India did not support U.S. efforts to fund 

antitrafficking programs under the presidential initiative. In addition, 

despite an emphasis on selecting countries in which the United States 

could start implementation in a short time frame, agreements necessary to 

conduct law enforcement projects were not in place in Brazil and Mexico, 

causing these initiatives to be delayed. Also, according to an agency official 

and documents we reviewed, Tanzania was included because a senior 

official had just traveled there and thought trafficking might be a problem. 

Incomplete Assessments of 

Foreign Governments’ 

Antitrafficking Deficiencies 

The country narratives’ incomplete assessments of deficiencies in foreign 

governments’ efforts to combat trafficking diminish the Trafficking in 

Persons Report’s utility as a programming guide. Our analysis of the 2005 

report found that many country narratives failed to include information on 

the governments’ compliance with some standards and core criteria, 

making it difficult for U.S. government officials to use the report as a 

programming guide. For example, all narratives for countries in the lowest 

two tiers contained some discussion of government efforts to protect 

trafficking victims. However, we found that 80 percent failed to mention 

key aspects of the victim protection criterion, including whether victims 

were encouraged to cooperate with law enforcement, whether the 

government provided legal alternatives to deportation, and whether victims 

were protected from inappropriate treatment as criminals (see fig. 5). In 

addition, 92 percent of country narratives for tier 2 countries, which 

receive the largest share of U.S. government antitrafficking funds, did not 

mention compliance with certain standards and criteria.31

31Our finding that 92 percent of tier 2 narratives did not mention compliance with certain 

standards and criteria is based on a random probability sample and is surrounded by a 95 

percent confidence interval that extends from 82 percent to 95 percent.
Page 36 GAO-06-825 Human Trafficking

Figure 5: Completeness of Country Narratives for Governments in Tier 2 Watch List 

and Tier 3 

Conclusion The United States has placed trafficking on the international agenda and 

has spurred governments and organizations into action through its funding 

of international programs and the publication of the annual Trafficking in 

Persons Report. Additionally, the development of a victim-centered 

approach based upon prevention, protection, and prosecution programs 

has provided an operational framework for both governments and 

practitioners in the field. However, more than 5 years since the passage of 

the TVPA, the U.S. government lacks fundamental information on the 

nature and extent of the global trafficking problem and an overall strategy 

for agencies to target their programs and resources abroad.

As the United States and other countries work to identify victims of 

trafficking, the scope of the global trafficking problem remains unknown in 

terms of overall numbers within countries of origin; victims’ gender, age, 

0

10

20

30

40

50

60

70

80

90

100

Adopt key victim protection measures

Prescribe sufficiently stringent punishment for trafficking crimes

Combat official trafficking-related corruption

Tier 2 watchlist and tier 3

country narratives that

do not mention whether

governments:

Source: GAO analysis.

Percentage of narratives
Page 37 GAO-06-825 Human Trafficking

and type of exploitation suffered; and the profile and methods of the 

perpetrators. The United States has provided about $375 million in 

antitrafficking assistance since 2001 for projects in about 100 countries. 

However, the lack of an overall government strategy which ties together 

and leverages the program expertise and resources of agencies with the 

knowledge of victims’ identity and location, raises questions about whether 

antitrafficking activities are targeted where they are most needed. 

Furthermore, little evaluation research has been conducted to determine 

which international antitrafficking activities are working or how best to 

tailor them to meet specific needs.

The fight against human trafficking will almost certainly require years of 

effort and the continued monitoring of governments’ actions. To enhance 

its usefulness as a diplomatic tool, the narratives and country rankings in 

the annual Trafficking in Persons Report must be viewed as credible by 

governments and informed human rights and country observers. However, 

the report does not comprehensively or clearly describe how decisions 

about tier rankings were reached. Moreover, problems identified in the 

report provide the means to better identify program needs and allocate 

resources, but agencies have not linked their activities to identified 

deficiencies.

Recommendations for 

Executive Action

To improve efforts to combat trafficking in persons abroad, we recommend 

that the Secretary of State, in her capacity as Chair of the Interagency Task 

Force to Monitor and Combat Trafficking, consider the following actions:

1. Work closely with relevant agencies as they implement U.S. law calling 

for research into the creation of an effective mechanism to develop a 

global estimate of trafficking. This could include assigning a trafficking 

data and research unit to serve as an interagency focal point charged 

with developing an overall research strategy, collecting and analyzing 

data, and directing research.

2. In conjunction with relevant agencies, develop and implement a 

strategic approach that would delineate agency roles and 

responsibilities in relation to each other, strengthen mechanisms for 

integrating activities, and determine priorities, measurable goals, time 

frames, performance measures, and a methodology to gauge results.

3. To improve the credibility of State’s annual report on trafficking in 

persons, we recommend that the Secretary of State ensure that the 
Page 38 GAO-06-825 Human Trafficking

report clearly documents the rationale and support for tier rankings 

and improve the report’s usefulness for programming by making the 

narratives more comprehensive. 

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; the U.S. government agency that prepares the 

trafficking estimate; and cognizant officials at the ILO, IOM, and UNODC, 

or their designees. We received written comments from State, which are 

reprinted in appendix V along with our responses to specific points. 

State generally agreed with our recommendations. State agreed with our 

first recommendation to work closely with relevant agencies as they 

implement U.S. law calling for research into the creation of an effective 

mechanism to develop a global estimate of trafficking and provided 

detailed suggestions for areas of future research that are consistent with 

our findings. Regarding our second recommendation that the Secretary of 

State develop and implement a strategic approach, State recognized the 

need for better performance measures and enhanced interagency 

coordination while also stating that roles and responsibilities have been 

established. In response, we clarified our recommendation to state that 

agencies’ roles and responsibilities should be delineated in relation to each 

other, consistent with our report findings. In response to our third 

recommendation, State said that while its annual Trafficking in Persons 

Report can improve, it has become a much richer, more useful product 

since first published in 2001. State also said our report includes some 

useful recommendations that the department will explore integrating with 

ongoing efforts in light of available resources. In addition, State 

commented that its 2006 Trafficking in Persons Report offers a greater 

and more consistent examination of the minimum standards as they apply 

to each country. We conducted a selective review of 26 tier 1 country 

narratives in the 2006 report and found that many of the concerns we cited 

in our report remain. For example, none of the tier 1 country narratives 

clearly explained whether or not the government complied with the second 

minimum standard established in the TVPA, which, among other things, 

calls for governments to prescribe punishment for sex trafficking that is 

commensurate with that for grave crimes such as forcible sexual assault.

In oral comments, the U.S. government agency that prepares the trafficking 

estimate fundamentally concurs with our characterization of the U.S. 

global estimate of trafficking flows. The agency stated that it has sought to 
Page 39 GAO-06-825 Human Trafficking

improve upon the 2004 estimate’s accuracy and utility through working 

with an outside contractor with the intention of thoroughly documenting 

and vetting a methodology, as well as preparing detailed recommendations 

for improving future estimates. According to the agency, many of this 

contractor’s initial recommendations have been in-line with those 

delineated in our report. Despite these efforts and the inherent difficulty of 

preparing estimates of hidden populations, the agency agreed with our 

overall findings—particularly with the idea that housing the estimate in the 

intelligence community makes it opaque and inaccessible. The agency 

stated that it believes that other U.S. government agencies are best 

positioned to produce the global trafficking estimate in the future, because 

they have access to the same unclassified data, would be better able to vet 

the methodology, and could provide additional information to allow for a 

closer link between international and domestic human trafficking flow 

estimates. 

State, Justice, Labor, USAID, the U.S. government agency that prepared the 

trafficking estimate, and the ILO, IOM, and UNODC submitted technical 

comments which we have incorporated into this report as appropriate.

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies of this report to the 

Secretaries of State, Justice, Health and Human Services, Homeland 

Security, and Labor; the Administrator of USAID; the U.S. government 

agency that prepares the trafficking estimate; ILO; IOM; and UNODC; and 

interested congressional committees. Copies of this report will also be 

made available to other interested parties on request. In addition, this 

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

http://www.gao.gov.
Page 40 GAO-06-825 Human Trafficking

If you or your staff 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 VI. 

Thomas Melito, Director

International Affairs and Trade
Page 41 GAO-06-825 Human Trafficking

Appendix I

Objectives, Scope, and Methodology AAppenednxidexiIs

Our objectives were to examine (1) estimates of the extent of global 

trafficking in persons, (2) the U.S. government’s strategy to combat 

trafficking in persons abroad, and (3) the Department of State’s (State) 

process for evaluating foreign governments’ antitrafficking efforts. 

To examine estimates of the extent of global human trafficking, we 

conducted an analysis of the global trafficking databases developed and 

maintained by the U.S. government, the International Organization for 

Migration (IOM), the International Labor Organization (ILO), and the U.N. 

Office on Drugs and Crime (UNODC). We met with officials from each 

organization, determined the reliability of their global trafficking data, 

reviewed documents and assessed their methodologies for collecting and 

analyzing human trafficking data, and analyzed the data collected by IOM. 

We examined ILO, UNODC, and IOM reports.1

 We also reviewed the 

existing relevant literature on data and methodologies used in global 

human trafficking research. We collected reports, journal articles, 

conference presentations, U.S. government sponsored studies, and books 

that discuss human trafficking. We read and analyzed these documents and 

used them to identify issues that affect the quality of data on trafficking. We 

grouped these issues into three major categories: availability, reliability, 

and comparability. 

To examine the U.S. government’s strategy for combating human 

trafficking abroad, we reviewed U.S. laws and presidential directives 

describing actions that various U.S. government entities were to undertake 

in combating trafficking. These include the Trafficking Victims Protection 

Act (TVPA) of 2000 and its reauthorizations in 2003 and 2005, Executive 

Order 13257, and National Security Presidential Directive 22. We also 

analyzed documents and interviewed officials from the Departments of 

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

Labor, State, and the United States Agency for International Development 

(USAID). Documents we reviewed include each agency’s plan to implement 

the presidential directive, agency and project-level monitoring and 

evaluation documents, project proposals, interagency coordination 

guidance, the Bureau Performance Plan from State’s Office to Monitor and 

Combat Trafficking in Persons, USAID’s strategy to combat trafficking in 

1

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

Labor in the World, ILO (Geneva: April 2005); UNODC, Trafficking in Persons Global 

Patterns, (Vienna: April 2006); and IOM, Data and Research on Human Trafficking: A 

Global Survey (Geneva: 2005).
Appendix I

Objectives, Scope, and Methodology

Page 42 GAO-06-825 Human Trafficking

persons, as well as regional and country-level strategic framework 

documents.

To examine State’s process for evaluating foreign governments’ 

antitrafficking efforts, we reviewed 122 country narratives in the 2005 

Trafficking in Persons Report. We examined the narratives for all 66 

countries in tier 1, tier 2 watch list, and tier 3. For the 77 narratives in tier 2, 

we reviewed all of the narratives for the 35 countries whose tiers had 

changed from the previous year’s report. For the remaining 42 country 

narratives, we drew a random probability sample of 21 countries. With this 

probability sample, each narrative in the 2005 report had a nonzero 

probability of being included and that probability could be computed for 

any member. Each sample element was subsequently weighted in the 

analysis to account statistically for all the narratives in the 2005 report, 

including those not selected. Because we followed a probability procedure 

based on a random selection of tier 2 countries, our sample is only one of a 

large number of samples that we might have drawn. Since each sample 

could have provided different estimates, we express our confidence in the 

precision of our particular sample’s results as a 95 percent confidence 

interval (e.g., plus or minus 5 percentage points). This is the interval that 

would contain the actual population value for 95 percent of the samples we 

could have drawn. As a result, we are 95 percent confident that each of the 

intervals in this report will include the true values in the study population. 

All percentage estimates from the narrative review have margins of error of 

plus or minus 7 percentage points or less, unless otherwise noted.

In addition, we systematically compared the country narratives describing 

these governments’ antitrafficking efforts with the minimum standards and 

five core criteria in the legislation and determined whether or not the 

country narrative mentioned each standard or criteria. If the country 

narrative did not mention a standard or criteria, we coded that as “not 

mentioned.” If the country narrative did mention a standard or criteria, we 

determined whether the narrative showed that the government complied or 

did not comply with the standard or criteria. If we determined that the 

narrative showed that the government complied with the standard or 

criteria, we coded that as “yes.” If we determined that the narrative showed 

that the government did not comply with the standard or criteria, we coded 

that as “no.” In some cases, the narrative mentioned a standard or criteria, 

but we could not determine conclusively whether or not the narrative 

demonstrated the government’s compliance. We coded those cases as “not 

clear.” Finally, elements of some criteria were not applicable to certain 

countries. For example, if the report described a country as a source of 
Appendix I

Objectives, Scope, and Methodology

Page 43 GAO-06-825 Human Trafficking

trafficking victims rather than as a destination for victims, the criterion 

regarding provision of victims with legal alternatives to deportation would 

not apply. We coded these cases as “not applicable.” We then tallied the 

number of responses in each category. 

Finally, to ensure analytical validity and reliability, our analysis involved 

multiple phases of checking and review of analytical procedures, 

categories, and results. Two GAO analysts reviewed a selection of country 

narratives, independently coded them, and agreed on the basis for the 

coding decisions. Next, one GAO analyst performed the coding for the 

remaining country narratives. A second GAO analyst reviewed a number of 

these coding decisions and both analysts discussed them. Finally, a third 

GAO analyst performed a review of all coding decisions and tabulations. In 

addition, to ensure the reliability of the funding data used, we reviewed the 

information collected by the State Department on each agency’s funding 

obligations. We then checked with each individual agency to verify that the 

amounts State reported were correct.

We conducted our review from September 2005 to May 2006 in accordance 

with generally accepted government auditing standards.
Page 44 GAO-06-825 Human Trafficking

Appendix II

Methodologies Used by Four Organizations to 

Collect Data on Human Trafficking ApendxiI

This appendix describes the data sources, data validation, methodology, 

and key assumptions used by the U.S. government, ILO, UNODC, and IOM 

to collect data on and/or estimate the extent of human trafficking as well as 

the limitations of these databases. (See tables 4 and 5.) 

Table 4: Four Organizations’ Data Sources and Validation

Source: GAO analysis of U.S. government, ILO, UNODC, and IOM data.

a

For a detailed discussion, see Belser, Patrick, de Cock, Michaelle and Ferhad Mehran, ILO Minimum 

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

b

For a detailed discussion, see UNODC, Trafficking in Persons Global Patterns (Vienna: April 2006).

c

For a detailed discussion, see IOM, Data and Research on Human Trafficking: A Global Survey

(Geneva: 2005). 

U.S. government ILOa UNODCb IOMc

Episodes/ cases 1500 1534 4950 7711

Data sources Public sources—articles 

primarily identified and 

translated into English by 

the Foreign Broadcasting 

Information Service, Stop 

Traffic List Serve, IOM, 

UN, ILO and NGOs based 

on trafficking incidents in 

2000 to 2001.

Public sources—1500 

publications in multiple 

languages such as reports, 

court and police records, 

trade unions, NGOs, 

academia and the media 

between 1995 to 2004.

Public sources—

publications such as 

reports, periodicals, 

books, Web sites and 

others from 113 individual 

source institutions 

between 1996 to 2003.

Data collected by

IOM missions from 

victims starting in Kosovo 

in 1999/2000 and 

expanding to 26 

countries through 2005. 

Data validation Performed by one analyst. Based on an organized 

procedure involving four 

steps.

Performed by one 

researcher.

Inaccuracies corrected by 

the original data entry 

official.
Appendix II

Methodologies Used by Four Organizations 

to Collect Data on Human Trafficking

Page 45 GAO-06-825 Human Trafficking

Table 5: Four Organizations’ Methodologies, Key Assumptions and Limitations

Source: GAO analysis of U.S. government, ILO, UNODC, and IOM data.

a

For a detailed discussion, see Belser, Patrick, de Cock, Michaelle and Ferhad Mehran, ILO Minimum 

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

b

For a detailed discussion, see UNODC, Trafficking in Persons Global Patterns (Vienna: April 2006). 

c

For a detailed discussion, see IOM, Data and Research on Human Trafficking: A Global Survey

(Geneva: 2005).

d

The data augmentation is performed using Monte Carlo Markov chain simulations with Bayesian 

inference. Making use of plausible values for unknown information, the technique replaces missing 

data under a wide range of conditions to reflect uncertainty in the open source information regarding 

the type of trafficking, age group, gender, country of origin and destination.

e

The estimation procedure uses the capture-recapture method. Two random samples of reported 

human trafficking cases are independently drawn and the counts of common and different cases 

between the two samples are used to estimate the total number of reported trafficking cases.

f

Under the most conservative assumption, the minimum estimate corresponds to assigning to the 

probability of being reported a value of 1.

U.S. government ILOa UNODCb IOMc

Methodology (A) average of 

aggregate estimates of 

reported and unreported 

victims

(B) data augmentation 

to fill in missing values.d

Estimation based on two 

extrapolations:

(A) estimation of all 

reported victimse

(B) estimation of all 

reported and unreported 

victims.f

(A) assignment of a score 

of 1 each time a country 

is reported by a different 

institution

(B) coding gender, age, 

and type of trafficking 

using the same 

technique.

Not applicable.

Key assumptions For (A) above—

underlying data of total 

victims are reliable and 

comparable; 

For (B) above—

 technical conditions 

for the procedure are 

plausible. 

For (A) above—technical 

conditions for the 

procedure are met;

For (B) above—

the ratio of the average

duration of a case divided 

by the probability of being 

reported is greater than or 

equal to 10. 

For both (A) and (B) 

above—

 how much a country is 

affected by the trafficking 

problem depends on the 

frequency of it being 

reported by different 

institutions.

Not applicable.

Limitations • internal trafficking not 

studied

• subject to very limited 

peer review

• may not be replicable

• limited to sources in 11 

languages

• no information about the 

number of victims

• no measure of the 

severity of the problem

• internal trafficking not 

studied

• data limited to the 

countries where IOM 

has a presence

• confidentiality of victim 

assistance

• may not be 

generalizable

• cannot be used for time series studies 

• not based on reliable country level data
Page 46 GAO-06-825 Human Trafficking

Appendix III

Eight U.S. Government Entities’ Data on 

Human Trafficking ApendxiI

This appendix describes the data on human trafficking maintained by eight 

U.S. government entities. (See table 6.)

Table 6: Data on Human Trafficking Maintained by U.S. Government Entities

Sources: Departments of Justice, HHS, DHS, Labor, and the National Central Bureau.

a

Federal law enforcement officials who encounter alien victims of severe forms of trafficking in persons 

who are potential witnesses to that trafficking may request that DHS grant the continued presence of 

these victims in the United States in order to ensure prosecution of those responsible.

Agency Trafficking data fields

Justice—Office for Victims of Crime —Type of trafficking (labor, sex, other)

— Identification of victims (nationality, age, gender)

Justice–Civil Rights Division Trafficking cases prosecuted in the United States, including 

—Information about traffickers

—Type of trafficking (commercial sex, involuntary servitude)

Justice–Federal Bureau of Investigation, Criminal Investigation 

Division

—Information about traffickers (names, business involved, criminal 

organization connections)

—Type of trafficking (commercial sex, migrant farms, construction, 

labor camps, domestic servitude)

—Identification of victims (nationality, age, gender, recruitment 

method)

—Points of entry 

—Logistics (use of illegal documents, funding) 

Justice—Bureau of Justice Assistance —Number of potential domestic victims identified by task forces

—Number of identified potential domestic victims for which law 

enforcement has requested continued presencea

 in the United 

Stataes

HHS Trafficking victims certified in the United States, including

—Age (minor or adult)

—Gender

—Geographic distribution of the certification (i.e., which U.S. state)

—Nationality

DHS Trafficking victims awarded continued presence:

—Date of birth

—Gender

—Nationality

Information about traffickers, including:

—Name

—Nationality

—Gender

—Date of Birth

—Violation type

—Statute used to arrest the violator

Labor Nature and extent of 144 countries’ worst forms of child labor, 

including children involved in forced labor and sexual exploitation

National Central Bureau (INTERPOL) Individuals wanted internationally for trafficking/smuggling related 

crimes 
Page 47 GAO-06-825 Human Trafficking

Appendix IV

State’s Process for Assessing Foreign 

Governments’ Compliance with U.S. Minimum 

Standards to Eliminate Human Trafficking ApendxiIV

Table 7: Minimum Standards and Criteria for the Elimination of Human Trafficking

Standard 1 The government of the country should prohibit severe forms of trafficking in persons and punish acts 

of such trafficking.

Standard 2 For the knowing commission of any act of sex trafficking involving force, fraud, coercion, or in which 

the victim of sex trafficking is a child incapable of giving meaningful consent, or of trafficking which 

includes rape or kidnapping or which causes a death, the government of the country should prescribe 

punishment commensurate with that for grave crimes, such as forcible sexual assault.

Standard 3 For the knowing commission of any act of a severe form of trafficking in persons, the government of 

the country should prescribe punishment that is sufficiently stringent to deter and that adequately 

reflects the heinous nature of the offense.

Standard 4 The government of the country should make serious and sustained efforts to eliminate severe forms of 

trafficking in persons.

Criterion 1 Whether the government of the country vigorously investigates and prosecutes acts of severe 

forms of trafficking in persons, and convicts and sentences persons responsible for such acts, 

that take place wholly or partly within the territory of the country. After reasonable requests 

from the Department of State for data regarding investigations, prosecutions, convictions, and 

sentences, a government, which does not provide such data, consistent with the capacity of 

such government to obtain such data, shall be presumed not to have vigorously investigated, 

prosecuted, convicted or sentenced such acts. During the periods prior to the annual report 

submitted on June 1, 2004, and on June 1, 2005, and the periods afterwards until September 30 

of each such year, the Secretary of State may disregard the presumption contained in the 

preceding sentence if the government has provided some data to the Department of State 

regarding such acts and the Secretary has determined that the government is making a goodfaith effort to collect such data.

Criterion 2 Whether the government of the country protects victims of severe forms of trafficking in 

persons and encourages their assistance in investigation and prosecution of such trafficking, 

including provisions for legal alternatives to their removal to countries in which they would 

face retribution or hardship, and ensures that victims are not inappropriately incarcerated, 

fined, or otherwise penalized solely for unlawful acts as a direct result of being trafficked. 

Criterion 3 Whether the government of the country has adopted measures to prevent severe trafficking in 

persons, such as measures to inform and educate the public, including potential victims, 

about the causes and consequences of severe trafficking.

Criterion 4 Whether the government of the country cooperates with other governments in the investigation and 

prosecution of severe forms of trafficking in persons.

Criterion 5 Whether the government of the country extradites persons charged with acts of severe forms of 

trafficking in persons on substantially the same terms and to substantially the same extent as persons 

charged with other serious crimes (or, to the extent such extradition would be inconsistent with the 

laws of such country or with international agreements to which the country is a party, whether the 

government is taking all appropriate measures to modify or replace such laws and treaties so as to 

permit such extradition.)

Criterion 6 Whether the government of the country monitors immigration and emigration patterns for evidence of 

severe forms of trafficking in persons and whether law enforcement agencies of the country respond 

to any such evidence in a manner that is consistent with the vigorous investigation and prosecution of 

acts of such trafficking, as well as with the protection of human rights of victims and the internationally 

recognized human right to leave any country, including one’s own, and to return to one’s own country.
Appendix IV

State’s Process for Assessing Foreign 

Governments’ Compliance with U.S. 

Minimum Standards to Eliminate Human 

Trafficking

Page 48 GAO-06-825 Human Trafficking

Sources: TVPA 2000 and TVPA 2003.

Note: Criteria in bold text are those that the Trafficking Office has designated “core criteria.”

Criterion 7 Whether the government of the country vigorously investigates, prosecutes, convicts, and 

sentences public officials who participate in or facilitate severe forms of trafficking in persons, 

and takes all appropriate measures against officials who condone such trafficking. After 

reasonable requests from the Department of State for data regarding investigations, 

prosecutions, convictions, and sentences, a government, which does not provide such data, 

consistent with the capacity of such government to obtain such data, shall be presumed not to 

have vigorously investigated, prosecuted, convicted or sentenced such acts. During the 

periods prior to the annual report submitted on June 1, 2004 and on June 1, 2005, and the 

periods afterwards until September 30 of each such year, the Secretary of State may disregard 

the presumption contained in the preceding sentence if the government has provided some 

data to the Department of State regarding such acts and the Secretary has determined that the 

government is making a good-faith effort to collect such data.

Criterion 8 Whether the percentage of victims of severe forms of trafficking in the country that are noncitizens of 

such countries is insignificant.

Criterion 9 Whether the government of the country, consistent with the capacity of such government, 

systematically monitors its efforts to satisfy the criteria described in paragraphs (1) through (8) and 

makes available publicly a periodic assessment of such efforts.

Criterion 10 Whether the government of the country achieves appreciable progress in eliminating severe 

forms of trafficking when compared to the assessment in the previous year.

(Continued From Previous Page)
Appendix IV

State’s Process for Assessing Foreign 

Governments’ Compliance with U.S. 

Minimum Standards to Eliminate Human 

Trafficking

Page 49 GAO-06-825 Human Trafficking

Figure 6 illustrates the Department of State’s process for producing the 

annual Trafficking in Persons Report.

Figure 6: Key Elements of the Trafficking in Persons Report Process

Department of State 

Trafficking Office

Media

sources

August -

March

June June September DecemberFebruary

Site visits

U.S.

Embassies

Nongovernmental

organizations

International

organizations

Annual Trafficking

in Persons Report

Country Action

Plans

– Introduction

– Tier rankings

– Country narratives

For tier 2 watch list 

and tier 3 countries

Presidential

Determination on 

Sanctions and

Secretary of State’s

Reassessments

Interim Assessments

of Special Watch

List Countries’

Progress in

Combating

Trafficking For tier 3 countries

Source: GAO analysis of Department of State information.
Page 50 GAO-06-825 Human Trafficking

Appendix V

Comments from the Department of State ApendxiV

Note: GAO comments 

supplementing those in 

the report text appear 

at the end of this 

appendix.
Appendix V

Comments from the Department of State

Page 51 GAO-06-825 Human Trafficking
Appendix V

Comments from the Department of State

Page 52 GAO-06-825 Human Trafficking

See comment 2.

See comment 1.
Appendix V

Comments from the Department of State

Page 53 GAO-06-825 Human Trafficking

See comment 3.
Appendix V

Comments from the Department of State

Page 54 GAO-06-825 Human Trafficking
Appendix V

Comments from the Department of State

Page 55 GAO-06-825 Human Trafficking

See comment 4.
Appendix V

Comments from the Department of State

Page 56 GAO-06-825 Human Trafficking

See comment 5.
Appendix V

Comments from the Department of State

Page 57 GAO-06-825 Human Trafficking

See comment 6.
Appendix V

Comments from the Department of State

Page 58 GAO-06-825 Human Trafficking

See comment 7.
Appendix V

Comments from the Department of State

Page 59 GAO-06-825 Human Trafficking
Appendix V

Comments from the Department of State

Page 60 GAO-06-825 Human Trafficking

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

dated June 30, 2006.

GAO Comments 1. State agreed that more research would help in the fight against human 

trafficking. State said that its Trafficking in Persons office (G/TIP) 

continues to pursue better estimates of the scope of trafficking; that the 

Senior Policy Operating Group (the Group) has established a 

subcommittee on trafficking research to, among other things, ensure 

regular interagency communication on research and close the most 

important data gaps; that G/TIP plans to set aside a substantial portion 

of its program budget for trafficking research; and that G/TIP funds 

IOM’s database. We recognize two ongoing projects to develop better 

estimates of trafficking and note that it is too early to assess the results 

of these projects. The Group subcommittee began meeting within the 

past year and, at the time of our review, had not established research 

priorities. During our review, G/TIP staff expressed concern about the 

limited amount of funding available for research, including continued 

funding for IOM’s database, which G/TIP partially funds. 

2. State said that a better global estimate of the number of trafficking 

victims should not be the primary focus of additional research 

initiatives. State said a more valuable approach would be information 

on the comparative severity of trafficking in particular regions, 

countries, or localities; on the methods used by traffickers; and the 

effectiveness of antitrafficking programs. We believe our 

recommendation is consistent with State’s comments. We agree that 

additional research on these areas is valuable as discussed in the 

report. We report that reliable and comparable country data do not 

exist. We also report that U.S. agencies collect information on 

traffickers and their victims but do not share their information or 

analyze the information to identify trends and compile a profile of 

victims. We also describe the value of IOM’s database in providing 

information on traffickers’ routes and nationalities and the mechanisms 

they use to identify and manipulate their victims. We also agree that 

more information on the effectiveness of antitrafficking programs is 

needed, and we note that little or no evidence is currently available to 

indicate the extent to which different types of efforts impact the level 

of trafficking. Our recommendation calls upon the Secretary of State, 

in her capacity as Chair of the Interagency Task Force to Monitor and 

Combat Trafficking in Persons, to consider assigning a trafficking data 
Appendix V

Comments from the Department of State

Page 61 GAO-06-825 Human Trafficking

and research unit but does not call for setting up a new unit as State’s 

comments suggest.

3. State agreed with the need for better performance measures, said that 

the Group is looking at how to reconcile the different agency grants 

processes so as to achieve an earlier exchange of information, and said 

that State will address enhanced interagency coordination in its 

upcoming G/TIP office strategy. State said that roles and 

responsibilities of government agencies in combating trafficking in 

persons have been established. We have clarified our recommendation 

to state that agencies’ roles and responsibilities should be delineated in 

relation to each other, consistent with our report findings. State also 

said that the Group creates an active forum where interagency 

representatives work together to identify strengths and weaknesses of 

of the Group’s the U.S. approach to combat trafficking in real time. 

State also said that the Attorney General’s annual report and several of 

the Group’s subcommittees focus on improving efforts to combat 

trafficking in persons. We reported findings from the Attorney 

General’s report. We also reported that the Group, through the work of 

its various subcommittees, served as a forum for agency officials to 

discuss trafficking policy and programs. However, based on 

information from the other Group members, we believe that our report 

remains accurate in also stating that the Group has not developed or 

implemented a systematic way for agencies to identify priorities and 

target efforts abroad to complement each others’ activities to achieve 

greater results than if the agencies were acting alone. 

4. The Department of State agrees with our finding that its annual 

Trafficking in Persons Report could provide more comprehensive and 

clearer explanations for the tier ranking decisions. The Department of 

State said that the 2006 report offers a greater and more consistent 

examination of the minimum standards as they apply to each country. 

We conducted a selective review of 26 tier 1 country narratives in the 

2006 report and found that many of the concerns we cited in our report 

remain. For example, none of the tier 1 country narratives clearly 

explained how the government complied with the second minimum 

standard established in the TVPA, which, among other things, calls for 

governments to prescribe punishment for sex trafficking involving 

force, fraud, or coercion that is commensurate with that for grave 

crimes such as forcible sexual assault. Also, as in the 2005 report, our 

review found that some tier 1 country narratives in the 2006 report 

described governments’ failure to comply with certain core criteria, but 
Appendix V

Comments from the Department of State

Page 62 GAO-06-825 Human Trafficking

the narratives did not explain how the governments’ success in meeting 

the other core criteria outweighed these deficiencies and justified their 

placement in tier 1. We acknowledge in our report that the Department 

of State is not legislatively mandated to include country narratives in 

the annual Trafficking in Persons Report. However, the 2006 

Trafficking in Persons Report and reports from previous years 

characterize the country narratives as “an assessment of the 

government’s compliance with the minimum standards ... as laid out in 

the TVPA of 2000, as amended.” According to the report, the narratives 

are also intended to explain the basis for the tier ranking decisions. 

5. State said that under G/TIP’s current guidelines to keep narratives 

short, readable, and focused on deficiencies, the Trafficking in 

Persons Report does not provide (and the law does not require) an 

exhaustive examination of compliance with all of the minimum 

standards’ criteria. According to State, such an approach would create 

lengthy country narratives that would lose their readability, 

effectiveness, and policy relevance and would significantly increase the 

size of the report. As described in our report, we did not assess 

whether the 2005 report’s country narratives considered all 10 criteria 

for the fourth minimum standard, and we do not criticize the 

Department of State for failing to provide an exhaustive examination of 

governments’ compliance with all 10 of these criteria. Instead, our 

analysis focused on the four minimum standards required by the TVPA; 

and for the fourth standard, we looked only at whether the narratives 

explained governments’ compliance with the five core criteria 

identified by the Trafficking Office. We believe these issues can be 

discussed while maintaining a concise reporting format. 

6. State said the TVPA requires the Trafficking in Persons Report to 

include countries with a “significant number of victims of severe forms 

of trafficking.” As a matter of policy the minimum “significant number 

of victims” has been defined as 100. As discussed in our report, our 

interviews with State officials as well as our review of the 2005 report’s 

country narratives indicated that some countries’ inclusion in the 

report was questionable. State acknowledges that many countries have 

not analyzed their crime statistics through the prism of trafficking in 

persons, making the available data unreliable. 

7. State said the law does not clearly define what constitutes a sufficient 

sentence to deter, or that adequately reflects the heinous nature of the 

offense. The department has defined “sufficiently stringent” 
Appendix V

Comments from the Department of State

Page 63 GAO-06-825 Human Trafficking

punishment to mean time in jail, preferably at least several years in jail.

We recognize the subjectivity of the third minimum standard in our 

report. Even though some narratives indicate that countries prescribe 

jail time, State’s report does not explicitly state the department’s 

definition that sufficiently stringent means some jail time nor did some 

of the narratives state that the punishment was sufficiently stringent. 

Thus, it is unclear how the government complied with this minimum 

standard. 
Page 64 GAO-06-825 Human Trafficking

Appendix VI

GAO Contact and Staff Acknowledgments ApendxiVI

GAO Contact Thomas Melito (202) 512-9601 or melitot@gao.gov

Staff 

Acknowledgments

Cheryl Goodman, Assistant Director; Suzanne Dove; Christina Werth; 

Gergana Danailova-Trainor; Bruce Kutnick; Barbara Stolz; and Patrick 

Dickriede made key contributions to this report. In addition, Lynn Cothern, 

Martin de Alteriis, Etana Finkler, and Mary Moutsos provided technical or 

legal assistance.

(320374)
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