Significantly increase efforts to investigate and prosecute traffickers for labor trafficking crimes, including those involving migrant workers exploited in domestic servitude, under the anti-trafficking law, and seek adequate penalties for convicted traffickers, which should involve significant prison terms. * Draft formal SOPs for victim identification and referral to care and train stakeholders on their use. * Proactively identify trafficking victims by screening for trafficking indicators among vulnerable populations, including foreign workers, particularly women in commercial sex, domestic workers who have fled their employers, and other vulnerable documented and undocumented migrants. * Ensure authorities do not inappropriately penalize victims solely for unlawful acts committed as a direct result of being trafficked or return victims to a trafficking situation or abusive employers. * Increase efforts to identify and provide protective services for labor trafficking victims, including those held in exploitive conditions at recruitment agency accommodations. * Strengthen efforts to refer cases with labor trafficking indicators, such as complaints of non-payment of wages, passport confiscation, and restriction of movement, for investigation and prosecution as potential trafficking crimes, rather than punishing such crimes administratively. * Consistently enforce regulations and oversight of labor recruitment companies, including by holding fraudulent labor recruiters criminally accountable and ensuring any recruitment fees are paid by employers. * Expand trainings to officials across all emirates to better identify potential trafficking cases that originate as labor violations and adequately employ new labor inspector standard guidance to improve identification of such cases. * Expand the mandatory use of the WPS to all domestic worker professions. * Execute implementing regulations for and strengthen enforcement of the domestic worker law that expands legal protections for domestic workers. * Amend labor and domestic worker laws to include deterrent penalties for passport confiscation and provide training to officials to consider passport confiscation as a trafficking indicator. * Screen any North Korean workers for signs of trafficking and refer them to appropriate services, in a manner consistent with obligations under United Nations Security Council resolution 2397.

The government maintained law enforcement efforts. In October 2023, the government enacted Federal Law No. 24 of 2023, repealing Federal Law No. 51 of 2006 and its 2015 amendments. Federal Law No. 24 of 2023 criminalized sex trafficking and labor trafficking and prescribed penalties ranging from five years to life imprisonment and fines of no less than one million Emirati dirhams (AED) ($272,260) and deportation for non-citizens. These penalties were sufficiently stringent and, with respect to sex trafficking, commensurate with those prescribed for other grave crimes, such as rape. While the new law did not substantially alter the existing provisions criminalizing trafficking offenses, it increased financial penalties for convicted traffickers, clarified the irrelevance of victim consent when establishing a trafficking crime occurred, and expanded protections for victims and witnesses during criminal proceedings.

The government investigated 37 trafficking cases – 36 for sex trafficking and one for “selling” a child victim – compared with 27 investigations in 2022. The government did not report investigations related to labor trafficking in 2023. The government reported defendants in a labor trafficking investigation initiated in 2022 involving a foreign unlicensed recruitment agency who illegally facilitated a recruitment scheme of African domestic workers to the UAE were tried in an appeals court and found innocent due to a lack of evidence. The government prosecuted 141 alleged traffickers in 44 cases, including 107 alleged sex traffickers and seven individuals for “selling” victims; the government also prosecuted four alleged labor traffickers and 23 alleged sex traffickers from cases initiated in previous reporting periods. This was compared with the prosecution of 50 alleged traffickers in 16 cases in 2022. Courts convicted 54 traffickers – 49 for sex trafficking, two for labor trafficking, and three for “selling” victims; courts convicted 45 traffickers in 2022. For the first time, the government reported the conviction of Emirati nationals for the labor trafficking of migrant workers. Courts sentenced the traffickers to between six months’ and life imprisonment, with the majority of perpetrators receiving imprisonment of one year or more with additional fines. The vast majority of convicted traffickers were foreign nationals subject to deportation at the conclusion of their sentences. Courts acquitted two labor traffickers for lack of evidence. The government did not report any investigations, prosecutions, or convictions of government employees complicit in trafficking crimes.

Observers reported Emirati institutions continued to have a limited understanding of how to differentiate between labor trafficking crimes and labor violations. The government did not routinely investigate as possible trafficking crimes labor law violations that exhibited trafficking indicators, such as passport confiscation, delayed or nonpayment of wages, fraud, contract switching, restriction of movement, and related abuses; generally, the government settled these cases by levying administrative fines or canceling business licenses in lieu of criminal proceedings. The Ministry of Human Resources and Emiratization (MOHRE) continued to address labor violations, including those involving labor trafficking, through administrative dispute resolution processes and labor courts, including mandating back pay in severe wage theft cases, including collective disputes. For example, during the year, MOHRE identified two potential labor trafficking victims after receiving labor complaints from workers alleging employer abuse. MOHRE referred the cases to law enforcement for investigation. Police reportedly investigated both cases; both employers were charged with physical abuse and detained and fined 200,000 AED ($54,450). Despite both potential victims exhibiting indicators of labor trafficking including physical abuse and wage theft, authorities did not pursue trafficking charges. Following both potential victims’ request for financial compensation through settlement in exchange for waiving criminal proceedings, both cases ended in financial settlement or remained pending settlement at the end of the reporting period.

The government maintained specialized anti-trafficking units at emirate-level police headquarters across the country and in the Public Prosecution Offices (PPO) at the federal and local level. The government, both independently and in partnership with international organizations, provided regular training for government officials, police, prosecutors, judges, shelter staff, and civil society on the anti-trafficking law, investigation techniques, victim identification and protection, and trafficking trends. Observers noted Emirati officials would benefit from additional targeted training on effective implementation of the anti-trafficking law, victim-centered approaches to law enforcement efforts, screening procedures to identify potential trafficking victims from those arrested for immigration violations or commercial sex, distinguishing potential labor trafficking cases from labor violations, and criminally investigating potential labor trafficking crimes. The government reported cooperating with INTERPOL by participating in two international operations with Asian and African governments, including one operation focused on labor trafficking in online scam operations. The government coordinated with the Indonesian Consulate in Dubai on a sex trafficking case. The government maintained MOUs with Italy, Poland, and Serbia on law enforcement and judicial cooperation for human trafficking cases.

The government moderately increased efforts to protect trafficking victims. The government identified and referred to care 59 victims, compared with 67 victims identified and referred to care in 2022. Of the 59 victims identified, traffickers exploited 55 in sex trafficking, including 10 children, two in labor trafficking, and two children were victims of “selling.” All identified victims were foreign nationals from Bangladesh, the People’s Republic of China (PRC), Egypt, Ethiopia, Indonesia, Pakistan, the Philippines, Sri Lanka, Syria, and Thailand.

The government remained without formal victim identification SOPs for whole-of-government use. While the Ministry of Interior (MOI) had standard procedures to assist law enforcement officers and immigration in victim identification when encountering potential victims, particularly at police stations, some officials did not regularly employ these procedures proactively and continued to rely predominantly on third-party referrals to identify victims, including from foreign embassies, religious institutions, or tips received through government hotlines or shelter hotlines (two victims were identified via the Abu Dhabi shelter’s hotline in 2023), smartphone applications, and the internet. MOHRE collaborated with the Dubai Police and the National Committee to Combat Human Trafficking (NCCHT) to draft guidance for labor inspectors, focusing on indicators of labor trafficking and processes for identifying and referring potential labor trafficking cases. Officials reported implementing the guide while conducting inspections of domestic worker recruitment agencies but did not identify any victims. Authorities continued to implement a formal referral process to transfer potential trafficking victims from detention centers, hospitals, houses of worship, facilities run by source country embassies or consulates, and those identified from shelter-operated hotlines to government shelters. Government shelter staff reported that although police were supposed to refer all potential trafficking victims to government shelters, in some cases, police only referred individuals whom police officially determined to be trafficking victims. Shelter staff assessed all individuals upon arrival using an international organization-issued screening questionnaire to better assess victims’ needs. While this assessment was shared with law enforcement, authorities did not always consider the shelter’s determination and instead came to a separate conclusion on whether the individual was officially a trafficking victim. However, shelter staff reported all potential victims had access to shelter and services regardless of law enforcement’s determination and victims could self-refer to shelters without law enforcement approval. In cases where a victim self-referred, shelter staff informed law enforcement authorities to begin an investigation while the victim received care. However, authorities also sometimes held potential victims who encountered law enforcement first at a transitional center until they could make an official determination of their trafficking victim status. At times, female or male police officers in plain clothes – intended to allay victims’ anxieties – escorted officially identified victims from a government-run detention center to a shelter. In previous reporting periods, some diplomatic contacts and community leaders reported they were hesitant to refer potential labor trafficking victims to shelters, as authorities did not always recognize these crimes as trafficking but rather considered them labor violations. In May 2023, the NCCHT established a sub-committee to update the government’s existing victim identification and referral guidelines that would constitute a new National Referral Mechanism (NRM) planned for executive review by June 2024.

Individual donations, local emirate governments, private businesses, religious institutions, and the NCCHT provided most shelter funding. The government maintained oversight and funding for shelters in four of the seven emirates (Dubai, Abu Dhabi, Sharjah, and Ras Al Khaimah), offering housing and assistance for all female and child sex trafficking and abuse victims across the country. The government operated one shelter for men in Abu Dhabi but did not serve any male victims during the year. Protective services included medical, legal assistance, education programs, free healthcare, reintegration support, counseling, and vocational training and certificates. Child trafficking victims and dependents of trafficking victims received services tailored to their needs, including separate living sections and case managers, as well as teachers who provided age-appropriate educational and psycho-social support. All police departments had a dedicated room for interviewing children and other vulnerable victims. The government continued to utilize a multi-purpose shelter in Dubai – opened in the previous reporting period – specifically to care for children who experienced abuse, including trafficking —between 3 and 13 years old; it provided services to 25 children during the year. The Bangladeshi, Philippine, Indian, Sri Lankan, and Ugandan embassies in Abu Dhabi and the Philippine, Indonesian, and Sri Lankan consulates in Dubai provided shelter and other protective services to an unspecified number of trafficking victims among their nationals. Officials distributed 587,900 AED ($160,060) through the Victims Support Fund to trafficking victims residing at government shelters across the Emirates, which financially supported victims by providing housing and education services, and covering medical expenses, repatriation, or resettlement. The government provided 416,000 AED ($113,260) for such efforts in 2022.

Per the new anti-trafficking law, victims could not be held criminally or civilly liable for unlawful acts committed as a direct result of being trafficked; the previous law held victims accountable if they willingly participated, violated their worker contracts or residency law. Although shelter staff reported law enforcement screened individuals arrested or detained for engaging in commercial sex for trafficking indicators and communicated to prosecutors about any victims identified, investigative media reports, independent observers, rights groups and diplomats alleged authorities returned some sex trafficking victims to a trafficking situation upon seeking police assistance, rather than providing protection services, which increased victims’ vulnerability to re-trafficking. In other cases, observers reported authorities sometimes inappropriately penalized potential and unidentified victims for immigration offenses or labor law violations such as “absconding” from employers, committed as a direct result of being trafficked. Reports also persisted some potential victims were unwilling to approach law enforcement officials due to fear of being sent to prison for immigration or other violations, such as “absconding” from their employer, rather than being accepted into a shelter as victims of crime. MOHRE could reject an “absconding” charge on several grounds, including if the charge was filed for “vexatious” or “fictitious” reasons or if the worker already had a pending claim against their employer with the government, and it also did not force the employee to return to his or her former place of employment. MOHRE did not report how many “absconding” claims it received nor the number it rejected. The Dubai police continued to implement a policy that encouraged employers to report their “absconded” domestic workers to authorities to prevent employers from hiring workers illegally and reduce losses incurred by employers whose workers left. Employers could be fined for hiring a worker illegally and compensated for filing “absconding” charges against a worker; employers had 10 days to report “absconding” workers or risk being fined. This policy may have exacerbated vulnerabilities of some workers attempting to leave exploitative situations.

The government reported it exempted from fines trafficking victims who overstayed their visas and reported at least one victim benefited from this exemption. The government did not provide permanent or formal temporary residency status to victims; however, it permitted victims to stay in shelters and participate in court proceedings. The government worked with international organizations to resettle victims in third countries who could not return to their countries of origin. The government repatriated 35 victims. MOI officials could amend the immigration status of victims to enable them to seek job opportunities in the UAE, typically when the victim requested to remain in the UAE. The law entitled migrant workers whose employer had not paid them for 60 days to legally remain in country and search for a new employer. Shelter staff noted they assisted an unknown number of trafficking victims in finding new employment or sponsors on an ad-hoc basis.

The government provided victim-witness assistance to victims who chose to participate in criminal proceedings, including private interview rooms, free legal counseling, the opportunity to speak to shelter staff instead of law enforcement upon arrival to the shelter, and safe transportation to court hearings; the new anti-trafficking law also permitted educational assistance for victims, particularly children. Police took measures to prevent communication between victims and suspects. Police also enforced two governmental decrees aimed at ensuring the media adhered to victims’ right to privacy and that shelters adequately protected victims. The 2023 anti-trafficking law reaffirmed protections of victims and witnesses, clarifying the definition of “harm,” and increasing the penalties for individuals who seek to disclose or reveal a victim or witness’ identity. According to the NCCHT, officials informed victims of their rights when giving testimony. The anti-trafficking law stipulated prison terms for officials who were found to have coerced victims to provide false testimony or withhold it. Shelter staff reported courts attempted to accommodate victims’ desire to leave the country, and most victims participating in criminal proceedings were able to depart the UAE with a letter from the presiding judge after the first court hearing. Both police and shelter representatives reported victims often chose immediate repatriation at the UAE’s expense rather than remaining in country to testify against alleged traffickers or see a case through to final adjudication. In 2023, officials did not report the number of victims who participated in court proceedings. The government continued to utilize remote court trials and provided the opportunity for victims to submit video or written testimony; however, it did not report if any victims utilized such options. The government continued to employ its Witness Protection Program through Federal Law No. 14 of 2020, which gave judicial officials the authority to enroll witnesses to keep their identities confidential during legal proceedings. The government reported it could award restitution during criminal proceedings while victims could file civil suits to receive compensation but did not report if any victims received compensation or were awarded restitution.

The government modestly increased efforts to prevent trafficking. The NCCHT, chaired by the Minister of Justice, led government anti-trafficking efforts and met regularly. The NCCHT, in cooperation with two international organizations, identified gaps in the government’s current anti-trafficking response and finalized a 2023-2025 action plan to address such gaps. The NCCHT had a budget of 4.2 million AED ($1.14 million) annually, which funded planned activities under its new NAP. The government held awareness campaigns targeting government officials, recruitment agencies, employers, populations vulnerable to trafficking, and the general public on trafficking risks, reporting mechanisms, the anti-trafficking law, and protection services available to trafficking victims. The government funded and operated a 24-hour toll-free hotline for reporting cases of trafficking, delayed wage payments, or other labor violations; it operated in Arabic, English, Russian, and Urdu. Hotline staff alerted police of all calls categorized as potential trafficking. Additionally, MOHRE, MOI, and shelters operated multilingual toll-free hotlines; MOI continued to host a mobile phone application that allowed users to access certain police services on their phones, and trafficking victims or witnesses could use the application to file reports. In Dubai, law enforcement authorities operated a separate hotline, and there remained a 24-hour toll-free number for migrant workers UAE-wide to make complaints or general inquiries. The PPO maintained a mobile app to receive reports related to human trafficking – including photos, videos, and audio recordings. The government reported identifying two trafficking victims from all hotlines.

The government made efforts to prevent labor trafficking primarily through labor regulatory and monitoring mechanisms. The government employed full-time labor inspectors, including some dedicated trafficking inspectors, to conduct routine and unannounced inspections of company housing and worksites. If inspectors found that a company violated the labor law, the government could fine the company or curtail its ability to operate or hire additional workers. Individuals could face jail time if they engaged in fraud that led to labor trafficking. In 2023, MOHRE conducted more than 1,000 inspection visits to private-sector facilities; from these inspections, officials identified more than 75,000 labor law violations, including companies operating without proper licenses, non-compliance with the WPS, providing false documentation, and failing to comply with worker accommodation standards. Although MOHRE reported taking legal action against the violating entities – including referral to the PPO for administrative proceedings and imposing fines – it did not report if any of the violations were referred for further investigation or criminal prosecution as a potential trafficking case. MOHRE coordinated with an international organization through a cooperation agreement signed in June 2023 on intensive workshops and training for labor inspectors covering detection of labor trafficking indicators in the workplace.

The government’s WPS required and monitored electronic salary payments for private sector workers via vetted banks, currency exchanges, and financial institutions for all onshore companies employing more than 100 workers (95 percent of the private-sector workforce). The WPS automatically alerted officials to delayed salary payments of more than 60 days or payments that were less than contractually agreed upon, and after a period of 15 days, authorities administered fines and other enforcement actions, including suspending noncompliant companies and employers’ ability to issue new work permits and increased inspections for companies with at least 50 employees. MOHRE reported it issued letters to companies and the Public Prosecutor for WPS violations after salaries were 45 days late; MOHRE reported it only dropped cases when employers paid the missing wages and the company was current with all salary payments. MOHRE continued to implement 2022 amendments to the WPS regulations, including reducing the percentage of total employees companies must pay through WPS to remain compliant from 90 percent to 80 percent; this change may have limited accountability for employers who neglected to pay their workers, heightening their vulnerability to trafficking. In 2023, the WPS identified approximately 33,000 cases of non-payment of wages or non-compliance with regulations. Despite wage theft being considered a trafficking indicator, the government did not refer any such cases to law enforcement for criminal investigation as potential trafficking crimes. Media and diplomatic sources continued to report some companies retained workers’ bank cards or accompanied workers to withdraw cash, coercively shortchanging employees even when the WPS showed the proper amount paid. Such cases were difficult to prove in labor courts, given the WPS documented accurate payments via designated bank accounts. Government authorities reported installing surveillance cameras at ATMs nationwide to verify the identity of wage recipients in an effort to combat WPS circumvention tactics.  Additionally, officials reported conducting randomized surveys with workers to identify such practices and stated that complaints could also be filed anonymously on either MOHRE’s “Smart Application” or its website as an illegal deduction by their employer. The WPS covered some professions in the domestic sector per a 2022 resolution; the resolution required employers of workers in five out of the 19 domestic worker professions (private agricultural engineers, private trainers, private tutors, public relations officers, and home health care providers) to enroll in the WPS. For the other 14 professions in the domestic worker sector – including domestic workers inside private homes – enrollment in the WPS remained voluntary. This exclusion, coupled with the lack of legal provisions requiring inspections of domestic worker accommodations, wage payment, and work hours, heightened domestic workers’ vulnerability to trafficking. The government did not report how many domestic workers had enrolled in the WPS through MOHRE’s agreement with First Abu Dhabi Bank at the close of the reporting period. Despite the mandatory inclusion of some categories of domestic workers, all domestic workers were still able to file complaints of wage theft with MOHRE; however, the government did not report how many complaints of wage theft it received or the outcomes of such complaints.

Article 6 of Emirati Law No. 33 of 2021 and Article 4 of Cabinet Resolution No. 106 of 2022 prohibited worker-paid recruitment fees. However, NGOs, rights groups, and observers noted many workers paid recruitment fees in their home countries, arriving to the UAE already in debt, heightening their vulnerability to exploitation, including trafficking, as workers were more likely to remain in exploitive employment situations to pay off debts. MOHRE’s labor complaint system continued to register complaints related to illegal worker-paid recruitment fees and employers reducing worker’s salaries to refund employers for recruitment fees paid; the government reported it also used the WPS to monitor unlawful deductions from workers’ salaries, including recruitment fees. MOHRE inspectors’ guidelines continued to include identifying worker-paid recruitment fees or workers’ salary reductions to pay employers for recruitment fees. In 2023, MOHRE identified three cases of worker-paid recruitment fees via inspections, but did not report the outcome of such cases, including if any were subsequently referred to law enforcement for criminal investigation as potential labor trafficking cases.

MOHRE continued to oversee licensing and regulation of both private sector and domestic worker recruitment agencies, including by requiring a bank guarantee, a physical address, and proof of no prior criminal convictions or labor violations, among other requirements, to grant a license. MOHRE could suspend or revoke licenses of recruitment agencies, including in cases of fraud, non-payment of wages, and in cases where the agency committed any act that involved trafficking. The government continued to require all domestic worker recruitment be done through private agencies that obtained MOHRE licenses. The government mandated agencies with licenses provide training to recruited workers, educate them on their legal rights, resolve employee-employer disputes, provide and prove wage payments, verify worker accommodations for compliance with domestic worker law minimum standards, and guarantee repatriation. Each licensed agency was equipped with a room solely for grievance mediation with a video connection to MOHRE for official oversight. Officials also reported that in domestic worker-employer disputes, the worker could request assistance from the licensed agency instead of fleeing their employer, which would render the worker undocumented and vulnerable to trafficking; however, such agencies could not enter or inspect private homes, which made verification of worker accommodations and other protections outlined in the law difficult. Media reported at least one case in 2023 when a recruitment agency told a worker to return to her abusive employer’s home, without screening for trafficking indicators or offering protection services, and verbally abused the worker for refusing. MOHRE mandated licensed agencies cover the cost of employer recruitment fees for domestic workers through an insurance policy with a two-year warranty; this policy aimed at ensuring recruitment fees would not be transferred to domestic workers from employers once they arrived in the UAE. In certain circumstances when a domestic worker terminated employment, employers were entitled to a full refund of the recruitment fees, which the licensed agency would cover. However, observers noted this insurance policy did not protect workers from fees they incurred from legal and unregulated recruiters in their home countries.

As of March 2024, 109 MOHRE-licensed agencies existed to recruit domestic workers. Despite the expansion of agencies with MOHRE licenses, the expensive costs to obtain a license – coupled with mandated insurance requirements to cover recruitment costs – disincentivized some private recruitment agencies from obtaining a MOHRE license; some employers also continued to prefer unlicensed agencies as their services were viewed as cheaper, more flexible, and accessible compared to those with MOHRE licenses. As non-licensed agencies were not strictly regulated, reports continued that many violated labor and immigration laws and failed to guarantee the rights of workers and employers. In October 2023, MOHRE reported it referred 45 agencies to the PPO for recruiting domestic workers without a MOHRE license; the PPO fined owners of four agencies 50,000 AED ($13,610) and MOHRE provided temporary accommodation for the workers at the unlicensed establishments and reportedly transferred the workers to licensed recruitment agencies. MOHRE also revoked licenses of legal agencies for non-compliance. In one case, MOHRE revoked the licenses of two agencies in Ajman for committing legal violations; following the revocation, media reported Kenyan and Ugandan domestic workers alleged physical abuse, passport confiscation, denial of medical care and food, and restriction of movement by one of the non-compliant agencies between 2020 and 2021 while waiting to be hired by employers. Media also reported some women remained stranded in the agency’s accommodations with some unable to exit the country without penalization due to their undocumented status. The government reported it screened all domestic workers for trafficking indicators but did not identify any as victims. Officials reported the government amended the undocumented workers’ status and provided employment for 26 workers; the government repatriated two additional workers. MOHRE reported revoking the licenses of two additional agencies, referring all four (including the two in Ajman) to the PPO for non-compliance and imposed fines of 50,000 AED ($13,610) for each violation. Separately, MOHRE issued 63 administrative fines totaling 226,000 AED ($61,530) against other domestic worker agencies for violating labor regulations. The government did not refer any agencies – either MOHRE-licensed or not – for criminal prosecution for potential trafficking crimes, despite trafficking indicators being present. MOHRE separately penalized 153 employers who allowed domestic workers to work for other sponsors, in violation of the law; the government denied the employers new permits and referred them to the PPO for legal and financial action.

NGOs, rights groups, advocates, and labor-source country embassy representatives continued to raise concerns about the ease with which tourist visas could be converted into work visas for domestic workers looking to circumvent their home countries’ recruitment bans in the UAE and those subjected to deceptive recruitment – a practice that exacerbated the risk of trafficking for these workers, as they often paid fees to recruitment agencies in both their home countries and in the UAE, and had no protection under UAE law when they arrived on tourist visas. For workers aware that they entered the UAE on a tourist visa some were unable to switch their visas to employment visas and continued to work illegally, heightening their vulnerability to trafficking. However, workers on tourist visas could apply for a work visa at a MOHRE-licensed agency and find employment, which would allow MOHRE to track and monitor workers’ employment contracts. Despite authorities mandating all hiring be conducted through MOHRE-licensed agencies, many UAE households continued to employ domestic workers directly or through other recruitment agencies, further increasing the vulnerability of domestic workers to exploitation and trafficking without protection under the law. Rights groups also noted private sector worker vulnerabilities to flexible visa conversion regulations.

Federal Law No. 9 of 2022 provided protections to all 19 types of domestic worker professions and prohibited recruitment and employment of workers younger than the age of 18. However, many of the same limited protections remained from the previous 2017 domestic worker law, including broad regulations on rest days and working hours, access to grievance mechanisms and regulations for in-home inspections, which only were allowed on the basis of complaints or reasonable evidence of violations. Article 20 of Law No. 9 stated a contract could be unilaterally terminated at any time by either employer or worker, under certain conditions, including providing notice. If an employer terminated the contract for reasons not attributed to the domestic worker, the law required the employer pay the worker’s remaining compensation and return ticket; if the domestic worker terminated the employment contract after the probation period in the absence of a contractual breach, the recruitment agency was required to pay for a return ticket and the worker did not owe any compensation to the employer, which may have prevented employers from forcibly holding domestic workers past their contract termination. Article 10 of Cabinet Resolution No. 106 of 2022 granted domestic workers the right to terminate employment without notice or employer permission if an employer failed to meet contractual obligations such as payment of wages, or if the employee was subject to sexual harassment or physical or verbal abuse by the employer. However, the law required the worker to obtain a judicial verdict demonstrating the employer breached contractual obligations and submit the transfer request to MOHRE for approval; otherwise, employer approval was required. In cases of employer abuse, a MOHRE-licensed recruitment agency was required to provide shelter to the domestic worker. However, domestic workers in recruitment agency accommodations, including those who sought assistance after leaving an abusive employer and those waiting to be hired by employers, were subject to physical and verbal abuse, lack of food and medical care, restriction of movement and passport confiscation. Despite protections under the 2022 law, workers continued to be subjected to excessive working hours, denied overtime pay and rest days, nonpayment of wages, passport confiscation, substandard living conditions and restriction of movement by their employers.

Federal law No. 33 of 2021 granted private sector workers the right to terminate their employment contract, leave the country or switch employers at any time without employer approval provided they give between one and three months’ notice. The law also permitted both employers and workers to terminate contracts during the probationary period and allowed a worker 180 days to find a new job following contract termination, without incurring overstay fines or becoming undocumented, which may have prevented potential exploitation, including trafficking for such workers. The 2022 labor law no longer required workers to compensate their employer when terminating a contract prior to its expiration; only in cases where workers or employers did not abide by the notice period, would one party compensate the other for the remaining part of the notice period. In cases of abuse or breach of contract, the worker could terminate the contract without notice.

For both private sector workers and domestic workers, to be able to leave the country or switch employers, workers had to physically possess their passport. Although Article 13 of Law No. 33 of 2021 explicitly prohibited employers confiscating worker’s passports, the law did not stipulate penalties. Separately, Law No. 9 of 2022 for domestic workers also explicitly prohibited employers confiscating passports and stipulated a 500 AED ($140) fine for employers who did so, but it did not criminalize passport confiscation. Despite the explicit prohibition of passport confiscation for all workers, the absence of penalties for private sector workers and low administrative fines for domestic workers did not adequately deter employers from this practice. Observers reported both private sector and domestic workers continued to experience passport confiscation by their employers; in some cases, employers refused to return passports to workers until they reimbursed the employer for visa or license fees (for delivery drivers), exploiting the worker in debt bondage, restricting their ability to seek new employers, and disincentivizing the worker from reporting exploitation. The government did not report how many complaints of passport confiscation it received or the outcome of such cases. However, MOHRE reported retrieving passports from employers and returning them to domestic workers during the year. Because the government did not enforce a prohibition on employers confiscating workers’ passports, this practice remained pervasive and may have left some workers vulnerable to exploitation and potentially trafficking.

The government continued to collaborate with labor-source countries and international organizations to develop orientation programming for workers prior to arrival in the country; separately, the government continued to utilize Tawjeeh Centers to provide mandatory orientation services to migrant workers on their rights, how to file complaints, UAE labor law, and health and safety regulations, as well as a SIM card available in 15 languages. Domestic worker recruitment agencies provided mandatory orientation to newly arrived workers, including on relevant laws and regulations; 21,774 workers received orientation in 2023. In 2023, MOHRE introduced a new “self-orientation” program through a smart application as a flexible option for newly arrived workers, available in 16 languages; 558,240 workers completed this orientation during the year. The government maintained trafficking-related MOUs with Armenia, Australia, Azerbaijan, Bangladesh, Fiji, The Gambia, India, Indonesia, Nepal, Pakistan, the Philippines, Sierra Leone, Thailand, Uganda, and Vietnam to regulate recruitment mechanisms and prevent contract switching; it signed a similar MOU with Mozambique in 2023. The government did not make efforts to reduce the demand for commercial sex acts. The Ministry of Foreign Affairs provided anti-trafficking training to its diplomatic personnel.

As reported over the past five years, human traffickers exploit foreign victims in the UAE. Foreigners comprise nearly 90 percent of the UAE’s population. Lower wage labor, including most manual labor and a significant portion of the service sector, is provided almost entirely by migrant workers predominantly from South and Southeast Asia and the Middle East, with a growing percentage from sub-Saharan Africa. Employers exploit some of these workers through conditions indicative of labor trafficking, such as passport retention, non-payment of wages and unpaid overtime, restrictions on movement, contract switching, fraudulent employment promises, substandard food and housing provisions, debt bondage or a failure to meet other contractual agreements. Adults from some of these countries travel willingly to the UAE to work as domestic workers, security guards, drivers, gardeners, massage therapists, beauticians, hotel cleaners, or elsewhere in the service sector, but traffickers subject some of them to labor and sex trafficking after arrival. In 2023, a rights group reported recruitment agencies and employers exploited migrant workers employed to support the UN Climate Change Conference, hosted by the Government of the UAE in Dubai, in conditions of labor trafficking, including being charged recruitment fees, nonpayment or delayed payment of wages, passport confiscation, restriction of movement, debt bondage and other abuses, including racial discrimination.

Observers continue to report the UAE serves as a trafficking hub where recruiters sell migrants to families who afterwards illegally transport them to other countries in the Gulf. Some recruiters hire workers with false promises of large salaries, medical benefits, and accommodations; however, upon arrival in the UAE, workers discover the companies that hired them are fraudulent, leaving them undocumented, unable to obtain legal work and vulnerable to trafficking. Recruiters in some source countries work as individual agents rather than for regulated companies, complicating law enforcement and monitoring efforts. For foreign workers, including domestic workers, the UAE’s employer-based visa system restricts their ability to leave a position without prior notice. Despite limited legal measures allowing workers to change sponsors or terminate their employment under certain conditions, some employers continue to exercise unilateral power over foreign workers’ movements, deny laborers working illegally the ability to change employers, restrict permission for them to leave the country, seek unlawful payment to approve a job transfer and threaten employees with abuse of immigration processes, which heightens their vulnerability to trafficking. Traffickers subject some women, predominantly from Central Asia, South and Southeast Asia, East Africa, Eastern Europe, Iraq, Iran, and Morocco, to sex trafficking. Most trafficking cases registered in the UAE are classified as sexual exploitation despite significant labor trafficking concerns. Anecdotal reports previously alleged an increase of traffickers in Laos recruiting young women through social media for commercial sex in Dubai. Previous reporting alleged traffickers exploited Mongolian nationals in labor trafficking in the UAE for herding, domestic servitude, and in circus performance. Traffickers exploit foreign national victims in forced labor in online scam operations in the UAE. Some cases of child sex trafficking involve traffickers forging ages on passports to facilitate undetected entry into the UAE.

Many source-country labor recruiters charge workers fees in their home countries, causing workers to commence employment in the UAE owing debts in their respective countries of origin, increasing their vulnerability to trafficking through debt-based coercion. Reports of employers engaging in the practice of contract-switching persist, leading to less desirable and lower paying jobs for migrant workers after arriving in the UAE. Some migrant workers enter the UAE on tourist visas and work for an employer who does not apply to exchange the worker’s tourist visa for the required work visa in order for the worker to have legal residency; employers subsequently use the worker’s legal status as coercion and further exploit the worker. Observers noted the frequency with which migrants sought to convert tourist to work visas remained a prevalent practice; one observer noted Filipino workers transiting UAE for work elsewhere in the region often deplane in Dubai and obtain a tourist visa to seek work in the UAE instead of their final destination. Observers reported increasing numbers of Nepali workers stranded in UAE after unknowingly arriving on tourist visas and paying recruitment fees to agents in Nepal with promises for employment in the United States or Europe. In the previous reporting period, the government announced a “job seekers” visa – which allows a prospective worker to remain in UAE for up to six months while he or she looks for work; however, this visa requires an individual to have a bachelor’s degree or equivalent to apply, and has been reportedly only used by skilled workers who have the income to remain in UAE without a salary for several months while seeking employment. Diplomatic contacts previously reported the government increased scrutiny on individuals residing and traveling to the UAE on tourist visas – and reports claim individuals who overstay their tourist visa could be charged with “absconding.”

Despite widespread expansion of MOHRE-licensed agencies, many UAE households continue to employ domestic workers directly or through private recruitment agencies that were not government regulated, further increasing the vulnerability of domestic workers to trafficking without protection under the law. Furthermore, some employers sponsoring domestic workers and unlicensed recruitment agents continue to use online platforms to advertise the selling of domestic workers. Migrant workers sometimes start with one employer and for various reasons, including abuse or exploitation, low salary, or simple dissatisfaction with the job, will follow alternate employment opportunities that ultimately prove fictitious, as traffickers in the UAE are adept at using manipulation to entice laborers with fraudulent higher salaries. According to reports, there were 110 Cuban government-affiliated medical professionals present in the UAE as part of the COVID-19 pandemic response, of whom 45 returned to Cuba in 2021. The government did not report if others remained in the country in 2023. Government-affiliated Cuban professionals may have been forced to work by the Cuban government. Democratic People’s Republic of Korea nationals working in the UAE may be operating under exploitative working conditions and display multiple indicators of forced labor.