• Increase legal protections for domestic workers by including this population in all relevant articles of Bahraini labor law.
• Expand visa sponsorship reform to allow domestic workers to change jobs without employer consent and allow domestic workers to self-sponsor with Flexi Permit.
• Increase efforts to investigate, prosecute, and convict traffickers, particularly suspects of labor trafficking, including domestic servitude.
• Increase investigations and prosecutions of potential forced labor cases involving passport retention, non-payment of wages, and other indicators as trafficking crimes by expanding training for all officials on the differences between labor violations and forced labor crimes and improving identification of forced labor victims.
• Draft and adopt legislation prohibiting passport confiscation with deterrent penalties and ensure officials are trained to consider passport confiscation as a trafficking indicator.
• Ensure all frontline officials—including immigration and police officers outside the specialized trafficking unit—receive adequate training on proactive victim identification and screening protocols, specifically when encountering vulnerable groups, such as domestic workers, migrant workers, undocumented workers, Cuban medical mission workers, and individuals in commercial sex.
• Expand and clearly define legal protections for Flexi Permit holders to ensure they are protected from labor law violations or employer abuse and have adequate grievance mechanisms through labor courts.
• Fully implement the Wage Protection System, including by holding accountable violators with deterrent penalties.
• Mandate the use of the standard contract for all domestic worker recruitment—either through a regulated recruitment agency or directly by an employer and ensure the standard contract is on file with the government—to mitigate contract switching.
• Ensure that victim’s ability to receive shelter does not depend on confirmation of a trafficking crime from the Public Prosecutor.
• Continue to conduct national anti-trafficking awareness campaigns, strategically targeting migrants, domestic workers, and employers.

The government increased law enforcement efforts. The anti-trafficking law, No.1 of 2008, criminalized sex trafficking and labor trafficking and prescribed penalties ranging from three to 15 years’ imprisonment, plus a fine and the cost of repatriating the victim(s). These penalties were sufficiently stringent and, with respect to sex trafficking, commensurate with penalties prescribed for other serious crimes, such as rape. During the reporting period, the Ministry of Interior (MOI) investigated 43 cases (98 alleged traffickers)—26 were for sex trafficking and 18 for forced labor—an increase compared with the investigation of 19 cases—15 sex trafficking and four forced labor—in the previous reporting period. Four cases, including three sex trafficking cases and one case of forced labor, remained under investigation at the close of the reporting period. Officials prosecuted 54 alleged sex traffickers and two alleged labor traffickers, an increase compared with the prosecution of 27 alleged sex traffickers the year prior. The government’s prosecution of an additional four alleged sex traffickers and one alleged labor trafficker was pending at the close of the reporting period. The forced labor prosecutions—the government’s first in at least five years—involved two cases of domestic workers in debt bondage after their employers forced the workers to illegitimately reimburse the employers for recruitment fees from their wages. Courts convicted 50 sex traffickers, an increase compared with the conviction of 22 sex traffickers during the previous reporting period and sentenced them to between three and 15 years’ imprisonment plus a fine in accordance with the law. For the first time since 2018, courts convicted two traffickers in one case for forced labor, which involved a female worker who was lured by false promises to leave her employer and then sold to one perpetrator who exploited the victim in sex trafficking. After refusing to work in commercial sex, the first perpetrator physically abused the victim and forced her to work in his home as a domestic worker without pay, where she was sexually abused by the second perpetrator. After escaping the first perpetrator’s home, the victim was able to contact police and was subsequently referred to care. The two convicted traffickers received 10 years’ imprisonment and a fine of 2,000 Bahraini dinar ($5,310). The government required convicted traffickers to pay all costs associated with the repatriation of the victims and planned to deport all non-Bahraini traffickers upon the completion of their sentences. The government did not report any investigations, prosecutions, or convictions of government employees complicit in human trafficking crimes.

MOI’s Directorate of Criminal Investigation and Forensic Science (CID) maintained a police unit dedicated to trafficking investigations. The Trafficking in Persons Prosecutor’s Office (PPO) prosecuted all trafficking crimes under the 2008 anti-trafficking law and ensured victims had access to legal recourse and adequate protection services and assistance. Officials reported trafficking cases were regularly fast-tracked to the High Criminal Court, bypassing the lower courts, to accelerate the justice process. In July 2021, CID established two hotlines; one for potential trafficking cases and one for cases involving employers demanding payment from workers to transfer visa sponsorship and change jobs. CID reported it would coordinate with the Labor Market Regulatory Authority (LMRA) to start legal proceedings in credible cases of an employer’s extortion of a worker. The government did not identify any trafficking cases through the national anti-trafficking hotline, but four cases (including three trafficking cases and one case of passport retention) were identified through CID’s trafficking-specific hotline, which received 591 calls since its launch in July 2021, and were subsequently investigated and referred for criminal prosecution during the year.

NGOs and civil society reported that although the government provided training to officials on identifying cases and victims of forced labor, frontline authorities nevertheless sometimes recorded instances of non-payment of wages and passport confiscation as labor violations and rarely referred these cases to the PPO for investigation as potential trafficking cases. The government reported workers continued to be able to file a grievance against an employer in a labor court if arbitration was unsuccessful. Migrant workers reported that the Ministry of Labor and Social Development (MOLSD)’s arbitration process often resulted in settlements in favor of the employer. The LMRA’s Protective Inspection Directorate (PID) and Grievances and Protections Directorate (GPD), established in 2019 and housed within the MOJ’s Labor Case Coordination section, continued to make efforts to identify and refer labor trafficking cases to criminal prosecution, specifically those that originated as labor violations. The PID had a mandate to identify, investigate, and document labor violations with a focus on those with a nexus to trafficking; it was staffed by labor inspection officers trained by two international organizations. The GPD was able to receive, register, and document all labor-related criminal cases. Both directorates were incorporated into the government’s broader national referral mechanism (NRM). Officials reported all labor violations submitted to the LMRA were screened by case workers at three levels. If the GPD subsequently identified a potential trafficking crime through screening, it referred the case to the PID to conduct a full investigation. The LMRA could formally refer potential trafficking cases directly to CID for criminal investigation; however, PID’s investigators could only informally refer potential trafficking cases to the PPO via email, which then sent the case back to CID to conduct a separate investigation before referring the case formally to prosecution. This procedural constraint may have hindered the government’s ability to effectively prosecute potential labor trafficking crimes that originated as labor violations. Nonetheless, the LMRA referred five potential forced labor cases to the CID (through formal channels) and four potential forced labor cases to the PPO (through informal channels) during the year but did not report on the outcome of those referrals.

The government trained—directly and in partnership with Gulf states and international organizations—police and investigators from CID’s anti-trafficking unit, all judges and prosecutors, and LMRA staff on topics related to trafficking, including identification of forced labor cases and victims, evidence collection in forced labor cases, policies and laws, regionally-focused training on combating trafficking in the Gulf and South East Asia, and “Train the Trainer” programs. However, police units outside of CID’s anti-trafficking unit and other first responders, such as immigration officials, did not receive adequate training in identifying potential victims or screening for trafficking indicators when coming into contact with vulnerable populations, which may have left potential victims unidentified in the law enforcement system. Investigators from CID’s anti-trafficking unit who were trained on screening and identifying trafficking indicators often accompanied immigration officials on raids and immigration inspection visits throughout the year to provide victim identification expertise.

The government increased overall efforts to protect victims. The government identified 33 trafficking victims, including 29 adult sex trafficking victims, two child sex trafficking victims, and two victims of forced labor, compared with the identification of 19 adult sex trafficking victims in the previous reporting period. The government did not report identifying or assisting any male victims. All the victims were from Indonesia, Thailand, and Bangladesh. The government continued to utilize its NRM to proactively identify trafficking victims, ensure proper documentation of cases, refer cases to the MOI and PPO for an official determination as a trafficking case, and provide protection services to victims until case resolution or voluntary repatriation. Officials provided 30-page, bilingual English-Arabic NRM booklets to all relevant ministries, labor-source country embassies, and NGO stakeholders. The LMRA reported their digitized case management process under the NRM continued to increase in speed and overall effectiveness in case management and coordination of support to victims. Police stations, other government entities, NGOs, and foreign embassies directly referred victims to the LMRA.

The LMRA’s Expatriate Protection Center (EPC) served workers regardless of their gender or legal status in the country and sheltered presumed trafficking victims, those who experienced severe labor exploitation, and those who were vulnerable to exploitation. According to the procedures of the NRM, a victim could only become eligible for accommodation at the EPC after the PPO confirmed the individual as a trafficking victim. In instances where the PPO did not identify an individual as a trafficking victim, but rather as someone who experienced labor exploitation, the LMRA may have offered that individual shelter depending on the severity of the case. Observers expressed concern that because authorities rarely identified indicators of forced labor as a trafficking crime, some unidentified victims may have been unable to access the shelter or receive protective care. The EPC provided all 33 identified trafficking victims with shelter, food, clothing, medical care, religious support, psycho-social counseling, rehabilitation, transportation, familial reunification, translation services, legal counsel, and repatriation; the government reported it also offered job placement in Bahrain to victims, but no victims utilized this option during the reporting period. The government reported pandemic-related mitigation measures were put in place at the EPC, including the provision of personal protective equipment such as hand sanitizer, gloves, and face masks to those admitted to the shelter. Additionally, it was routine for all residents and staff to be tested for COVID-19. The government provided all confirmed trafficking victims who remained in Bahrain for the duration of their trial with monthly compensation of 93 Bahraini dinar ($250)—via its Victim Assistance Fund. LMRA provided additional funding, as needed, for victim repatriation and daily GPD expenditures, such as payroll and operational expenses. Observers expressed concern that once victims were able to return to work in Bahrain, they were again placed in a situation where their employer controlled their residence and work visa, heightening their vulnerability to exploitation and re-trafficking due to the nature of the sponsorship system. The government reported trafficking victims were eligible to sponsor themselves through the Flexi Permit program as an alternative option to remain in Bahrain to work; the government also reported it could use victim assistance funds to pay the costs of a Flexi Permit for a victim. However, during the year, none of the identified victims became Flexi Permit holders. The government reported it increased the staff at the LMRA’s EPC to handle the increased number of cases of vulnerable or exploited workers and trafficking victims associated with the pandemic during the year. Embassies of labor-source countries reported providing housing on a temporary basis for some potential victims involved in labor disputes or abusive situations who refused to go to the EPC or were unable to reach it.

The government did not universally employ its proactive identification procedures among vulnerable groups, such as undocumented migrant workers—including those who fled their employers, domestic workers, and individuals in commercial sex—therefore, some potential victims may have remained unidentified in the law enforcement system. Furthermore, during the reporting period, observers reported authorities did not screen all individuals for trafficking indicators before deportation. In addition, observers noted the government did not identify potential trafficking victims during raids, and individuals in commercial sex were commonly detained and deported without being screened for trafficking indicators. Some migrant workers who fled abusive employment situations of their visa sponsor chose not to report abuse out of fear of deportation. Bahraini officials provided comprehensive protective assistance to trafficking victims, regardless of their willingness to participate in investigations and court proceedings of their traffickers, and relieved them from all legal and financial penalties related to unlawful acts traffickers compelled them to commit. The government reported it shared with all victims a full evaluation of their cases and their legal right to restitution in the event of a conviction. The protection of witnesses in all periods of criminal proceedings was enshrined in law, and the government reported identities were kept confidential through the stages of the NRM, regardless of whether the individual was declared a victim of trafficking. The government reported victims could testify via written correspondence, video recording, a closed-circuit live video, or in private; the government provided the option to testify via closed-circuit live video to 40 victims and potential victims during the reporting period. In response to the pandemic, officials implemented remote procedures for virtual litigations to take place. The government reported victims could speak in their native language in court proceedings with assistance of an interpreter, while all case-related documents were required to be translated into Arabic before being presented to judges. Observers reported concerns that, because court documents were presented solely in Arabic, attempts to seek redress for vulnerable migrants, including potential trafficking victims, remained difficult. Workers infrequently filed complaints against employers due to distrust of the legal system, protracted court processes, inability to afford legal representation, lack of interpretation and translation services, concern over potential loss of residence permits during proceedings, and fear of additional mistreatment due to employer reprisal. During the reporting period, the government repatriated all 33 identified victims to their countries of origin at the victims’ request.

The government maintained efforts to prevent trafficking. In January 2022, the government reinstated the National Committee to Combat Trafficking in Persons (NCCTIP) after a one-year hiatus and reported the committee planned to create a new national action plan by the end of 2022. In December 2021, the government, in collaboration with two international organizations, launched the first training of the trainers program at its Regional Center of Excellence and Capacity Building for Combating Trafficking. The training targeted first responders, including those in media, healthcare, aviation, and labor inspection, as well as shelter supervisors, judges, and prosecutors, to become capable of sharing expertise on victim identification and train others in their field.

Article 23 of Bahraini Law No.19 of 2006 prohibited “for any person to receive any moneys or obtain any benefit or advantage from an employee in lieu of issuing him a work permit or in return for the employment of such an employee or his retention in his job.” During the reporting year, PPO received six cases of such violations for prosecution. The LMRA continued to oversee the issuing of licenses and regulation of recruitment agencies through quarterly inspection visits and other measures. For example, the government continued to require all recruitment agencies to submit a security deposit equivalent of 10,000 Bahraini dinar ($26,530) that would be forfeited in the event the company violated employees’ rights and required each employer to provide workers accommodation that met the LMRA’s standards. The LMRA’s PID inspectors conducted recruitment agency inspections and monitored for employment and immigration violations. The LMRA increased PID personnel by 45 percent during the year to expand the number of workplace inspections; PID shut down 26 unlicensed agencies and referred them for civil prosecution. PID also rejected the renewal of three agencies’ licenses and canceled four applications for violating LMRA’s terms and conditions. Furthermore, the LMRA referred nine cases for criminal and civil prosecution under the anti-trafficking law and the labor law identified through workplace inspections during the reporting period. In coordination with CID and MOL, PID inspectors also conducted four inspection visits to labor camps; PID referred one case of forced labor to the PPO for further investigation from these inspections. In May 2021, the government launched its Wage Protection System (WPS) for private sector workers. Under the WPS, employers were obligated to pay wages electronically to workers via financial institutions authorized by the Central Bank of Bahrain. The government designed the system to alert the LMRA to instances of non- or delayed-payment of wages with violators subject to penalties and legal action. The government implemented the WPS in three phases, with the third and final phase launched in January 2022 to encompass any employer with one or more employees; all employers were given a six-month grace period from the start of their phase to implement WPS regulations. Employers of domestic workers were not required to enroll in the system; a total of 24 employers had voluntarily registered to pay domestic workers through the WPS at the close of the reporting period. While the government stated employers who failed to comply with the WPS would be fined and barred from receiving work permits, NGOs expressed concern that WPS penalties against violators were weak thereby reducing the incentive for an employer to comply. NGOs reported officials still preferred to mediate WPS wage disputes between the employer and employee, rather than hold the non-compliant employer accountable with penalties. Non- and delayed-payment of wages continued to be common practice; the LMRA reported it received 2,097 claims of unpaid wages from workers during the year.

The government continued to implement its Flexi Permit program, whereby foreign nationals could reside and work in Bahrain without a visa sponsor, thereby reducing the power imbalance between employer and employee inherent in the kafala or sponsorship-based employment system. Migrant workers who retained a valid visa were eligible to enroll in the program without the consent of their employer after the termination or expiry of their work permit. The Flexi Permit cost 432 Bahraini dinar ($1,150) for one year and included a work permit, health insurance, a refundable deposit for travel tickets, an extension of residency timeframes, and waived immigration fines incurred while the worker was undocumented. Since its inception in July 2017, the Flexi Permit has reportedly regularized thousands of undocumented workers. Successful Flexi Permit applicants could work any full- or part-time job with any chosen employer—including multiple jobs concurrently with various employers—and were able to directly negotiate wages and working hours; however, some categories of migrant workers, most notably domestic workers, were excluded from eligibility. While the government had twice temporarily extended eligibility of the Flexi Permit to domestic workers who left their employers or had expired work visas (most recently in the amnesty period concluding in December 2020) and has stated that Flexi Permits could be given to domestic workers on a case-by-case basis, the government did not report giving any domestic workers a Flexi Permit during the reporting period.

Some NGOs and labor rights organizations continued to express concerns that the Flexi Permit was not a suitable alternative for low-income workers who may not be able to afford the high cost of the permit and in some cases must find work to pay for the visa, thereby possibly perpetuating the cycle of debt “bondage.” Rights groups also expressed the need to ensure protections for Flexi Permit holders; as holders who work on a freelance basis or in short-term employment are not required to have a contract with their employer, and rarely do, heightening their vulnerability to wage disputes or other issues related to temporary employment with a temporary employer without protection under the labor law. Furthermore, because Flexi Permit holders are not categorized as “employees,” the labor law does not offer them protection. Flexi Permit holders cannot file grievances or complaints with the labor courts as other workers covered under the law could; rather, Flexi Permit holders could only file cases against employers in civil courts. Additionally, a migrant worker could not apply for a Flexi Permit before arriving in Bahrain. A worker was only eligible for the program once their visa expired, their contract ended, or they were undocumented—which continued to put migrant workers in vulnerable situations where their sponsor or employer was tied to their legal immigration status when first arriving in the country. Since 2011, the government allowed private sector migrant workers freedom to change jobs without their employer’s consent after one year of employment; during the reporting period, 14.65 percent of Bahrain’s migrant worker population changed employers. However, the LMRA still had to approve the transfer. Domestic workers did not have the ability to change jobs or extend their residency visas without employer consent. The government reported all workers were able to terminate employment at any time, with a notice period according to their contract, and leave the country permanently without employer consent. However, reports that employers continued to expect employees to procure an exit permit suggested low awareness of the policy.

Articles 19 and 40 of the Labor Law established limited protections for domestic workers, which include agricultural workers, home security guards, nannies, drivers, and cooks who work for the employer or family members, requiring employers to provide a labor contract specifying annual leave and bonuses and that such workers must be paid at least monthly. However, Article 22, which prohibited contract switching or changes to preset work conditions outlined in the contract, was not applicable to domestic workers, effectively increasing their vulnerability to forced labor. Labor inspectors were unable to conduct unannounced inspections of domestic workers’ accommodations and investigate allegations of abuse in the absence of an official complaint, which may have left some victims at risk of exploitation and without protection. The LMRA continued to disseminate to all registered recruitment agencies in Bahrain copies of the standard labor contract, which required domestic workers to sign, prior to their arrival, a comprehensive work agreement that outlined labor rights and employment obligations. The contract aimed to strengthen protections for domestic workers by requiring employers to disclose duties, hours to be worked, salary, rest hours, and weekly days off. Domestic workers, brought into Bahrain by recruitment agencies, were able to accept or reject an employment contract in their respective countries of origin, and the LMRA maintained copies of signed contracts to assist in any future labor disputes. The LMRA maintained streamlined processes for obtaining initial visas and visa renewals for domestic workers. The inclusion of domestic workers in the Expatriate Management System, along with all other expatriate workers, increased the LMRA’s oversight capacity by standardizing the application process and retaining all worker-employee documents on the LMRA’s electronic systems. However, NGOs expressed concern that the standard contract lacked mandatory working conditions as it remained up to the employer to determine working hours, minimum wage, and rest time. In contrast, title seven of the labor law stipulated a maximum daily limit of eight working hours for other private sector workers. Additionally, NGOs noted that many vulnerable domestic workers whom they encountered did not know the contents of their contract due to language barriers. Furthermore, domestic workers rarely had a copy of their contract in their possession. NGOs also reported that because it was not compulsory to use a recruitment agency to recruit a domestic worker, those who hired domestic workers directly did not need to provide a standard contract. Instead, the government required a pledge of the employer’s obligations toward the domestic worker, which is not enforceable in a court of law.

Bahraini law did not explicitly prohibit passport retention, even when the employee objected from the practice. The government reported that instances of passport retention were generally prosecuted under Article 395 of the Bahraini penal code as a “breach of trust,” though such prosecutions were rare. Instead, passport retention was frequently handled administratively, when migrant workers filed a grievance for passport withholding with the police, the MOLSD, or the LMRA. When handled by the LMRA, instances of passport retention were reportedly screened by trained GPD staff for indicators of trafficking. Representatives of labor-source country embassies reported cases handled by LMRA resulted in expedient and fair disposition of cases. A worker could also register a complaint to the court directly if the employer refused to return the passport; however, in most cases, once the LMRA, MOLSD, or police approached the employer, they returned the passport to the employee and the worker chose not to pursue criminal charges against the employer. The LMRA reported it received 3,899 claims of passport retention through the NRM and retrieved and returned 3,702 passports to migrant workers in 2021. Police generally did not consider passport retention to be an indicator of trafficking, instead considering it stolen property if the employer refused to return the passport. Officials stated if the employer refused to return the passport to the employee, the LMRA could prohibit it from obtaining new or renewing existing work permits and could refer the employer to law enforcement for legal action. Officials referred one case of passport retention—identified by MOI’s hotline—for criminal prosecution during the year.

The government also made efforts to prevent vulnerable migrant workers, including domestic workers, from further exploitation by ensuring pandemic-mitigation measures were accessible, regardless of residency status. The government reported the LMRA’s PID, the Ministry of Health (MOH), and the MOI coordinated 27 field campaigns to mitigate the spread of COVID-19 by conducting visits to migrant workers’ accommodations to administer vaccinations and booster shots for workers, specifically for those who were reluctant to visit hospitals to receive vaccinations due to their legal status. In partnership with an international organization, the government announced plans to launch a campaign in 2022 to raise awareness on migrant worker rights, but it had not yet launched it by the end of the reporting period. During the previous reporting period, the LMRA launched a website (endtrafficking.bh) featuring information on trafficking and resources for foreign workers; however, NGOs reported key information on the website was only available in English, limiting its application. The LMRA continued to provide booklets outlining labor rights in 13 languages common among expatriate and migrant worker populations and distributed them to such populations upon their arrival at the Bahrain International Airport and at the LMRA when applying for initial or renewed residency cards. The EPC’s trafficking hotline collected reports and educated workers about their rights and available services in nine languages 24 hours a day, seven days a week. The government advertised the hotline’s number and mandate through pamphlets given to each migrant worker upon arrival in Bahrain and on the LMRA’s social media platforms and website. The government reported the LMRA’s trafficking hotline received 13,006 calls during the year; however, no trafficking cases or victims were identified through the hotline. The government continued to uphold memoranda of understanding with several labor source countries, including Pakistan, that focused on oversight of recruitment agencies and protection of migrant workers in Bahrain. The government reported it partnered with an international organization to create orientation programs for migrant workers but did not report if it began implementing such programs by the close of the reporting period. The government made efforts to reduce the demand for commercial sex acts by continuing to enforce the law that makes prostitution illegal. The government provided anti- trafficking training for its diplomatic personnel.

As reported over the past five years, human traffickers exploit foreign victims in Bahrain. Men and women, primarily from India, Bangladesh, Pakistan, Philippines, Nepal, Egypt, Sri Lanka, Jordan, and Yemen, among other countries, migrate voluntarily to Bahrain to work as semi-skilled or unskilled laborers in the construction and service industries and domestic work sector—including agricultural workers, home security guards, nannies, drivers, and cooks, among others. Men from India and Bangladesh account for the vast majority of Bahrain’s male domestic workers. The number of migrant workers from African states, such as Senegal, Cameroon, Uganda, and The Gambia had previously increased, but observers noted pandemic impacts and difficulty in obtaining work permits have slowed the number of African workers coming to Bahrain. Furthermore, during the pandemic, the government reportedly stopped approving work permits for nationals from certain countries, citing “a record of unethical recruitment,” security concerns, analysis of data from the NRM, and a lack of diplomatic representation; most African workers do not have diplomatic representation in Bahrain. Prior to the pandemic, foreigners comprised approximately 80 percent of the total Bahraini workforce, the majority being unskilled or semi-skilled construction or maintenance workers. Likely due to pandemic-related job loss, the economic downturn, and an increased desire for workers to repatriate, Bahrain’s migrant workforce decreased in 2020. The government reported there were roughly 80,000 domestic workers in Bahrain at the end of the reporting period, 85 percent of whom were female, predominantly from the Philippines, Ethiopia, India, Indonesia, Kenya, and Sri Lanka—approximately 15,000 more workers than in the previous reporting period. Domestic workers from African nations are increasingly at risk of forced labor and arrive in Bahrain via direct recruitment from local employers in which workers pay brokers or middlemen in their home country to match them with a visa sponsor in Bahrain. Some employers subject migrant workers to forced labor in Bahrain; indicators include passport retention, strict confinement, contract substitution, non-payment of wages, debt bondage, threats or intimidation, and physical or sexual abuse. NGO and labor-source countries continue to report an increase in incidents of unpaid wages and debt bondage, especially among construction and unskilled workers. Furthermore, reports of unpaid overtime pay and denied vacation time have become more frequent. Some migrant workers are not given or are not in possession of their employment contracts and are generally unfamiliar with the employment terms contained therein. Public opinion supporting the practice of employers retaining workers’ passports to ensure they do not flee, coupled with the fact that passport confiscation is not explicitly prohibited by Bahraini law, enabled this pervasive practice to continue.

Nationals of countries without diplomatic or consular presence in Bahrain, most significantly from African countries, are particularly vulnerable to trafficking, as are domestic workers, who are only partially protected under Bahraini labor law and significantly isolated in their place of work. Government and NGO representatives report physical and sexual abuse of female domestic workers; controlled freedom of movement, withholding of workers’ identity cards and passports, restrictions on outside communication, and employer coercion to prevent employees from reporting exploitation are significant problems in Bahrain. Since the onset of the pandemic in 2020 and subsequent movement restrictions, NGOs continue to report an increase in non- payment of wages and coercion of domestic workers who were forced to stay in their employer’s home and work after completing their contracts. During the reporting period, many migrant workers returned home or sought other employment without receiving a salary from previous employment and without end-of-service payment or benefits, likely due to workers’ fear of lengthy court proceedings coupled with the difficulty of receiving renumeration from a business that closed during the pandemic. Cuban nationals working in Bahrain may have been forced to work by the Cuban government.

While the government maintained regulatory authority over recruitment agencies, some migrant workers arrive in Bahrain independently of regulated agencies. Many workers are paired with employers through intermediaries in Bahrain and unlicensed recruiters in their respective countries of origin; back-and-forth movement between Saudi Arabia and Bahrain via the King Fahad Causeway also contributes to this vulnerability, as Saudi nationals are able to sponsor foreign workers in Bahrain. Local press and media report traffickers recruit women to Bahrain via social media platforms or Bahrain-based acquaintances under false pretenses of high-paying jobs in the hospitality and domestic sectors and subsequently force them into sex trafficking. Traffickers also convince other women, mostly domestic workers already in Bahrain, to leave their employers with false promises of higher paying jobs; after being recruited, traffickers exploit some women in commercial sex through physical threats and debt-related coercion. Some NGOs report that due to pandemic-related shutdowns of the service industry, workers who lose their jobs are consequently exploited in the commercial sex trade. Some unscrupulous employers bring migrant workers to Bahrain under the “free visa” scheme—whereby workers pay an employer a recurring fee to sponsor their work visa while performing work for other employers in violation of local labor law—which can render them vulnerable to trafficking due to their illegal working status. Expatriates residing in Bahrain long-term are also reportedly complicit in the “free visa” scheme. Although notable reforms are underway, Bahrain’s sponsorship-based employment system continues to put some workers, particularly domestic workers, at risk of trafficking by limiting their ability to change employers or leave the country and by giving employers the unilateral power to control the status of residency permits.