Study on Trafficking in Persons and Smuggling of Migrants in the Context of the Displacement caused by the War in Ukraine

on Trafficking in Persons
and Smuggling of Migrants
in the Context of the Displacement
caused by the War in Ukraine
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Study on Trafficking in Persons and Smuggling of Migrants in the Context of the Displacement
caused by the War in Ukraine was prepared by the Research and Trend Analysis Branch, Division
for Policy Analysis and Public Affairs, United Nations Office on Drugs and Crime (UNODC), under
the supervision of Angela Me, Chief of the Research and Trend Analysis Branch, and under the
coordination of Fabrizio Sarrica, acting Chief of the Research, Innovation and Partnership Section.
Content overview: Angela Me, Fabrizio Sarrica, Sonya Yee
Research, analysis and drafting: Claire Healy
Research support: Chris Chinda, Fiona Dedei, Giulia Serio, Neemat Adel Sharafeldin
Data collection and field research: Taras Fedirko, Roberto Forin (MMC), Maxime Giraudet (MMC),
Olenka Gulenko, Maksym Kameniev, Julia Litzkow (MMC), Liubomyra Yurchenko
Administrative support: Andrada Maria Filip, Anja Korenblik, Iulia Lazar, Luka Zagar, Irmgard
Zeiler
Graphic design and production: Yuliya Sokolova
Cover drawing and ar twork: © Yasser Rezahi
Review and comments: Thanks to Ilias Chatzis, Lara Kuschlanski, Morgane Nicot, Caitlin
Oschadleus, Anastasiia Pryimak, Davor Raus, Samir Rizvo and Harsheth Virk, for their helpful
contributions and comments.
The production of the publication was made possible thanks to the generous financial
contributions of Switzerland, Denmark and the United Kingdom. Field research was carried out by
the Mixed Migration Centre (MMC) of the Danish Refugee Council.
Suggested citation: UNODC, Study on Trafficking in Persons and Smuggling of Migrants in the
Context of the Displacement caused by the War in Ukraine, (United Nations publication, 2025).
© United Nations, February 2025. All rights reserved worldwide.
United Nations
Office on Drugs and Crime
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E-mail: unodc-research@un.org
Table of Contents
Executive Summary ..................................................................................................................... 1
1. Introduction ......................................................................................................................... 12
2. Forced Displacement Context ............................................................................................ 14
2.1 Scale and composition of the displacement .................................................................. 14
2.2 Legal and policy provisions ........................................................................................... 18
2.3 Anti-trafficking measures ............................................................................................... 21
2.4 Situation of people who fled Ukraine in the EU and Switzerland .................................... 24
3. Journeys .............................................................................................................................. 29
3.1 Leaving Ukraine .............................................................................................................. 29
3.2 Risks .............................................................................................................................. 30
3.3 Men exiting Ukraine.. ...................................................................................................... 35
4. Paying for Facilitation of Irregular Border Crossings ................................................... 37
4.1 Smuggling of migrants before 2022.. ............................................................................ 37
4.2 Paying for facilitation of irregular border crossings in the context of displacement
from Ukraine .................................................................................................................. 40
4.3 Paying for facilitation of irregular border crossings by Ukrainian men .......................... 42
5. Trafficking in Persons ......................................................................................................... 46
5.1 Internal trafficking in Ukraine ......................................................................................... 46
5.2 Incidence of cross-border trafficking of people who fled Ukraine ................................. 51
5.3 Cross-border trafficking for forced labour.'. ................................................................... 60
5.4 Cross-border trafficking for sexual exploitation ............................................................. 67
5.5 Cross-border child trafficking.. ....................................................................................... 73
6. Conclusions and Policy Implications .................................................................................. 75
7. Case Studies ....................................................................................................................... 78
8. Methodological Annex ........................................................................................................ 84
9. Annex: Information provided to UNODC by the Government of Ukraine on actions
taken to combat trafficking in persons ................................................................................ 90
Executive Summary
Refugees from Ukraine
The full-scale invasion of Ukraine, beginning on 24 February 2022, and the ongoing war, have
resulted in millions of people being displaced internally and outside Ukraine. This study examines
the risks and incidence of trafficking in persons and smuggling of migrants in the context of the
displacement caused by the conflict in Ukraine, and the implications for policy and practice.
The research applies a phased, mixed-methods approach to analyse the evolution of trafficking
in persons and smuggling of migrants during the years 2022 to 2024. The study combines the
collection and review of relevant literature, statistics, data and information with a survey in 2023
of over 1,600 Ukrainians and non-Ukrainians displaced from Ukraine and two phases of in-depth
interviews in 2023 and 2024 with key informants and refugees in three European capital cities
hosting refugees from Ukraine: Berlin, Germany; Warsaw, Poland; and Bern, Switzerland.
Interviews were also conducted in 2023 and 2024 with key informants in Ukraine and at regional
level.
The population in Ukraine in February 2022 was just over 41 million people. As of October 2024,
around 34 million people were living in Ukraine, including 3.6 million people who were internally
displaced, 3.3 million who were returnees from other parts of Ukraine and one million who were
returnees from abroad.
Ukrainian population
(in millions) as of October 2024
9% IDPs
3.6
8% IDPs
3.3 returnees
AA°7 Population not
17 9 ° displaced or
with hum. needs
2% Returnees
1.02 from abroad
Non-displaced
21 % people with
8.5 humanitarian
needs
1 6% Refugees
6.75 abroad
Source: UNODC calculations based on data from: State Statistics Service Ukraine, International Organization
for Migration (I0M), UN Office for the Coordination of Humanitarian Affairs (OCHA), UN Refugee Agency (UNHCR)
1
Countries of residence of refugees from Ukraine
(in 1,000s) as of October 2024
QO/ USA, Canada,
O 4) o ther
558 non-European 18% Russian
1 228 Federation
QZf.iUO / /o EOuthroepr ean
1 755 countries
Italy
174
1 " r ° Poland
981
Spain
211
Czechia
380
UK
250
Source: UNODC Calculations based on UNHCR data
More than 6.75 million people fled Ukraine to other countries, as of October 2024. Most refugees
from Ukraine reside in the Russian Federation (1.23 million), Germany (1.21 million), Poland
(981,000), North America and other countries outside Europe (560,000) and Czechia (380,000). Of
over 4.16 million Ukrainians (98.3%) and non-Ukrainians (1.7%) with temporary protection status
in the European Union (EU) as of August 2024, 45 per cent are adult women, 23 per cent are adult
men, 1 7 per cent are boys and 1 5 per cent are girls. At least 1 6,670 separated and unaccompanied
refugee children from Ukraine reside in the EU countries, Switzerland and Norway.
Meanwhile, the displacement situation is highly dynamic. Between February 2022 and October
2024, people - of all nationalities - crossed Ukraine's land borders into the country at least 37
million times, for various reasons. Some remained in Ukraine; others stayed for a short period
before leaving the country again.
Ukrainian citizens can enter almost every country on the European continent visa-free. The
Council of the EU activated the 2001 Temporary Protection Directive for people fleeing Ukraine on
4 March 2022. Temporary protection and similar national protection schemes apply to people
fleeing Ukraine and arriving in EU and non-EU European countries. The rights attached to the
status include access to the labour market, social housing, social welfare, healthcare, education
for children and banking services.
The legal framework for refugees from Ukraine arriving in the EU is therefore distinct in very
significant ways from the framework that applies to refugees, asylum applicants and migrants
from other non-EU countries.
2
Comprehensive anti-trafficking response
Due to the suddenness and scale of displacement from Ukraine, it took some time for transit and
host countries to put in place a targeted and effective anti-trafficking response. Nevertheless, in
the course of 2022 and beyond, anti-trafficking stakeholders from the NGO sector, local and state
authorities, and regional and international organizations, mobilized a series of anti-trafficking
policies and actions.
These included:
• information dissemination in Germany, Poland, Switzerland and other host and transit countries
about risks, rights and support services in key locations like border crossings, railway stations
and accommodation centres, and online, in multiple languages. Information was also generated
and shared by displaced Ukrainians themselves, particularly on social media and messaging
apps;
• screening and registration systems for volunteers assisting people fleeing Ukraine in transit
and host countries;
• monitoring of key locations by police, NGOs and other authorities for risks of exploitation and
trafficking, such as brothels, railway and bus stations, and accommodation centres, as well as
websites and social media; and
• strengthened law enforcement and criminal justice responses, including enhanced
identification of potential trafficking cases and specialized prosecutors' networks.
Still, refugees from Ukraine are vulnerable to trafficking in persons specifically in relation to
income generation and accommodation. While the labour market integration of Ukrainian
refugees in host countries is proceeding, there are some gaps. 46 per cent of survey respondents
for this research stated that they were not earning any money at the time of the survey. When
asked why not, 44 per cent of those not earning money stated that they could not find
employment, and nine per cent that they were taking care of children at home.
Much of the labour market integration of Ukrainians is in low-skilled sectors, even for refugees
with higher skill levels. This is largely due to lack of fluency in the local languages of host
countries and challenges in recognition of qualifications obtained in Ukraine. The lack of
sufficient provision for childcare and other caring responsibilities of working-age refugees is a
further obstacle to employment.
3
Labour law violations and potential cases of exploitation experienced by refugees from Ukraine
are linked to lack of contracts, sub-contracting and the use of labour intermediaries, as well as, in
Poland, working under civil-law rather than labour-law contracts. Many exploitative situations
arise also in the context of accommodation, especially when the employer provides the
accommodation. Private hosting arrangements present risks of forced labour in domestic work,
cleaning and agricultural work, and of sexual abuse and exploitation, due to the relationship of
dependency of refugees on accommodation hosts.
Specific groups of people displaced from Ukraine are in a more vulnerable situation, including
unaccompanied and separated children; people who were previously internally displaced in
Ukraine; people who are unable to access temporary protection (because they are not eligible, or
due to lack of information or incorrect information); and elderly people.
Some Ukrainian Roma people have been allocated segregated accommodation and may have
reduced access to essential services. Refugees with disabilities experience challenges in
accessing social welfare, healthcare, mobility aids, assistive technologies and other forms of
support, as well as obstacles to having their disability status officially recognized. Among over
one million non-Ukrainians from outside the EU who fled Ukraine, many experienced
discrimination during the journey and in accessing rights and services in EU countries.
4
Refugees’ journeys
In late February 2022, hundreds of thousands of people began to flee Ukraine. They comprised
mostly women, children and elderly men.
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Refugees generally travelled distinct routes to exit the country, depending on where they were
located in Ukraine. This is due to Ukraine's vast territory, as well as the difficulties and dangers of
travelling within the country due to the conflict. People in west Ukraine generally crossed the
western land borders, regularly entering Poland, Slovakia, Hungary or Romania, while those in the
southwest and around Odesa crossed regularly into Moldova or Romania. People located in east
and north Ukraine generally exited into Russia. They either remained there or transited through
Russia to regularly enter Latvia, Estonia or Finland.
During the years prior to 2022, Ukrainians were among the top nationalities of people detected as
irregularly residing, refused entry by land, and using fraudulent documents in the EU. During the
period 2019-2022, the largest group by nationality of migrant smugglers detected at EU land
borders was Ukrainian, comprising 1 1 per cent of the overall total over that three-year period, with
an increasing trend.
Among 1,414 Ukrainian nationals surveyed for this research in Berlin, Warsaw and Bern in 2023,
five per cent (70) answered "yes" to the survey question "did you pay for services to cross borders
irregularly," though this includes 31 Ukrainian men, who may have exited Ukraine irregularly rather
than irregularly entering another country.
5
Migrant smuggling according to international law is committed if someone facilitates irregular
entry into another country or provides fraudulent travel documents for the purposes of irregular
entry. Among 183 non-Ukrainians from outside the EU who fled Ukraine, six per cent reported
paying for services to cross borders irregularly.
Experiences of paying for facilitation of irregular border crossing among
respondents surveyed in Germany, Poland and Switzerland in 2023
of U5kr%ainia ns 3.6%
surveyed of women surveyed
6% 9.7% of non-Ukrainians
from outside the EU People paying of men surveyed
for facilitation
of irregular border
crossing from Ukraine
s nee 2022
Majority aged 12% 18-24
experienced 42% or witnessed physical,
or 25-44 sexua or abour-re ated
46% abuses
Source: Based on survey for this study of 1 ,602 people who fled Ukraine in 2023 in Berlin, Warsaw and Bern
Most of these people travelled by bus, train or private car - or a combination -, while one in six
were driven in someone else's car. Survey respondents who paid for facilitation of irregular border
crossings were twice as likely as respondents who did not to have experienced or witnessed
abuses, such as non-payment of wages or deception in the context of employment.
In response to the full-scale invasion, the Government of Ukraine declared martial law and general
mobilization. This requires all male citizens of Ukraine aged 18-60 years to carry a military
registration document and present it at the country's borders at the request of the State Border
Guard Service of Ukraine. These men are not permitted to leave Ukraine unless they qualify for an
exemption. The majority of the 391 Ukrainian men surveyed for this research reported situations
that suggest that they qualify for exemptions.
Nevertheless, a significantly higher percentage of men in the sample reported that they paid to
irregularly cross borders (9.7%), compared to women (3.6%). Eighty-two percent of the men in this
category were Ukrainian and almost all these Ukrainian men (30/31) were aged 18-60 years.
Ukrainian men were eligible for conscription as of 27 years old at the time of the survey, though
this was lowered to 25 in April 2024. Forty-five percent of the Ukrainian men who paid to cross
borders were aged 27-60 years.
There are two main ways in which men who do not qualify for exemptions attempt to exit Ukraine,
evading the domestic legal provisions prohibiting their departure. They either cross Ukraine's
borders and enter another country at an unofficial border crossing, or they use fraudulent or
fraudulently obtained documents to qualify for an exemption. Irregular border crossings may
involve assistance from migrant smugglers facilitating irregular entry, in return for payment.
6
Over 24,000 Ukrainians, the majority adult men, were identified attempting to irregularly enter the
EU at the 'Eastern Land Borders' during 2022-2024. The Ukrainian authorities intercepted over
1 1 ,000 Ukrainian men attempting to leave the country in violation of martial law between February
2022 and November 2023, either crossing borders irregularly (73%) or using fraudulent
documents (27%). An unknown number of men in this category managed to exit Ukraine without
being intercepted. At least 30 men died trying to exit Ukraine irregularly, mostly while attempting
to cross the Tizsa river (at Ukraine's borders with Romania and Hungary). It is unclear what
proportion of these crossings involved facilitation by a third party of irregular entry into another
country in return for a financial or other material benefit, thus constituting smuggling of migrants
The Ukrainian authorities have identified over 450 criminal groups involved in assisting men to
irregularly exit Ukraine. Fees range between US$2,000 and $10,000, depending on the service
provided and the country of destination. Facilitation of irregular exit involving fraudulent
documents has also been detected, particularly related to medical exemption certificates
authorizing men's departure from Ukraine. This costs around $2,000-4,000, paid to corrupt
officials or to travel facilitators.
Trafficking in persons in Ukraine and abroad
Inside Ukraine, access to income generation, essential services and goods was substantially
interrupted by the full-scale invasion and continues to be problematic, increasing people's
vulnerability to internal and cross-border trafficking, especially internally displaced people (IDPs).
However, in 2022 and 2023, the Ukrainian authorities identified fewer cases of trafficking in
persons and fewer victims, due to reduced state capacity, as shown in the chart.
Trafficking in persons (TIP) cases and victims identified in Ukraine, 2020-2023
250
232
200
150
100
50
2020 2021 2022 2023
TIP victims identified
Source: Office of the Prosecutor General of Ukraine
7
The TIP offences investigated in Ukraine during 2022-2023 involved labour exploitation (49%);
sexual exploitation (29%); forced criminal activities (21%); and exploitation in pornography (1%).
This marked an increase in the proportion of cases of labour exploitation and forced criminal
activities - and a decrease in the proportion of cases of sexual exploitation and exploitation in
pornography. In 2020-2021, the forms of trafficking investigated were labour exploitation (38%);
sexual exploitation (42%); forced criminal activities (13%); exploitation in pornography (6%), and
other forms (less than 1 %).
The cases of trafficking for forced criminality involve victims committing drug trafficking and
migrant smuggling offences outside Ukraine, as a result of being trafficked. Overall, victims of
trafficking identified in Ukraine during 2020-2023 comprise 43 per cent women, 37 per cent men
and 20 per cent children. This includes the years 2020-2021, during which the COVID-19
pandemic significantly reduced capacities to identify victims globally. An additional 22 cases of
child trafficking were identified during 2022-2023.
Ukrainian victims of trafficking identified globally, 2019-2022
455
152
89
74
2019 2020 2021 2022
Source: UNODC elaboration based on national data - GLOTIP Database
Data on trafficking in persons cases provided to UNODC by countries hosting Ukrainian refugees
indicate increases in Ukrainians identified as victims of trafficking during 2022, particularly in EU
countries. During 2022, the first year of the large-scale displacement from Ukraine, 402 Ukrainian
victims of trafficking were recorded across the EU Member States, comprising 206 women, 192
men and four people of unidentified gender. The majority of these victims are adults trafficked for
forced labour. A further 33 Ukrainian victims were recorded in the UK in 2022. For comparison, 65
Ukrainian victims were identified in the EU in 2021, 38 in 2020 and 36 in 2019.
8
Based on a comprehensive analysis of the available primary and secondary sources included in
this study, there has been an increase in identifications of cases of trafficking in persons involving
refugees from Ukraine in EU countries. This increase occurred in a context where the population
of Ukrainians residing in the EU more than tripled, from about 0.35 per cent of the entire EU
population in 2021 to 1 .24 per cent by the end of 2022.
Number of Ukrainian victims of trafficking identified in the EU, 2021 vs. 2022
200
180 184
160
140
120
100
80
60 48 51
40 31
18 18
2021 2022
Source: UNODC elaboration based on national data - GLOTIP Database *Figures for Czechia in 2022 not available
184 Ukrainians were recorded as victims of trafficking in 2022 in Germany, compared to 18 in
2021. However, at least 101 of these victims were trafficked prior to 2022. 17 Ukrainian adults
were recorded as victims of trafficking for forced labour or services in Poland in 2022. The police
in Switzerland reported two Ukrainian victims of trafficking in 2022.
After Germany, the highest number of Ukrainian victims recorded in any one country in 2022 was
in the Netherlands. The number of Ukrainian victims recorded in the Netherlands increased from
seven in 2021 to 51 in 2022. 49 of the cases in 2022 were labour exploitation. The victims
comprise 33 women and 18 men exploited in agriculture, forestry and fishing, with smaller
numbers in construction, industry and hospitality.
Among 1 ,602 people who fled Ukraine and were surveyed for this research in Berlin, Warsaw and
Bern in 2023, two per cent experienced - or witnessed other people who fled Ukraine experiencing
- abuses that would constitute indicators of potential cases of trafficking for forced labour. Most
indications referred to situations witnessed rather than directly experienced by the respondents.
The potential cases mainly involve non-payment of wages or where pay was less than promised;
deception in relation to the type of work; excessive working hours or unsafe working conditions;
and deception about who the employer was.
9
Based on triangulation and analysis of sources used for this study, the sectors most at risk for
forced labour of Ukrainian refugees are domestic work, cleaning, care work, construction,
manufacturing, agriculture, transportation and logistics and restaurants and hotels - some of
them low-skilled sectors where predominantly women are employed.
Key informants interviewed for this research in 2023 and 2024 reported a relatively low incidence
of situations of potential forced labour or labour trafficking. Nevertheless, they provided a wealth
of information about labour law violations affecting people who fled Ukraine, making them more
vulnerable to trafficking for forced labour. According to survey respondents and key informants,
Ukrainian refugees are sometimes not paid for their work, there may be a significant delay in
payment, they are paid less than national employees for the same work, and they may endure
poor and hazardous working conditions.
There were indications in 2022 of a substantial increase in online demand from European men for
sexual services and pornography from Ukrainian women - which may involve sexual abuse and
exploitation - and for sexual abuse and exploitation of Ukrainian children. The risks of online
sexual exploitation and abuse are acute, as many Ukrainians use messaging apps and social
media to seek support and traffickers may recruit victims and advertise sexual services involving
sexual exploitation online.
Some women who fled Ukraine are involved in sex work and prostitution in the three cities where
field research was undertaken. Registered sex work is legal in all three cities, though it has been
cantonal practice for the Bern authorities not to authorize it for people with temporary protection
status. Indications of prostitution or sex work among refugees from Ukraine were mentioned by
2.5 per cent of respondents to the survey conducted for this research. It is difficult to determine
whether this also involves trafficking for sexual exploitation and forced prostitution, but some
cases present high levels of vulnerability. Risk factors for exploitation are evident in the situations
of prostitution and sex work examined in this research, particularly at massage parlours and
refugee accommodation centres. Some private accommodation providers also request
transactional sex from vulnerable women.
The reported incidence of potential sexual exploitation and risky situations in the context of
prostitution and sex work is lower than that of potential forced labour and labour rights violations
among refugees from Ukraine. Seven survey respondents - 0.4 per cent - reported knowing of
people in forced prostitution (potentially trafficking for sexual exploitation in prostitution), six of
them in Warsaw. None of the 1,602 respondents to the survey reported personally experiencing
sexual exploitation. However, this should be interpreted with caution as sexual exploitation is
likely to be underreported in victimization surveys and in general.
While no children were interviewed or surveyed for this research, key informants mentioned
indications of potential cases of child labour and child trafficking in agriculture, construction,
begging and domestic work, in Ukraine and in host countries. There are also indications of
cross-border trafficking for illegal adoption from Ukraine, including in the context of surrogacy,
which is legal in Ukraine and has continued since February 2022.
10
Outlook
The indications of a relatively low prevalence of trafficking in persons may be because cases
have not yet come to the attention of the authorities. There are various possible reasons for this,
including underreporting, challenges in detecting trafficking, lack of understanding of available
legal frameworks and remedies among criminal justice sector actors, and the stigma attached to
being a victim of trafficking. Some of these factors may be particularly relevant in the context of
trafficking for sexual exploitation. Furthermore, most official data on trafficking in persons for
2023 and 2024 were not yet available at the time of writing. This underlines the urgency of
continuing to monitor smuggling and trafficking affecting refugees from Ukraine, and trafficking
of IDPs and others in Ukraine.
The low figures offer a tentative indication that the incidence of smuggling of migrants and
trafficking in persons among refugees from Ukraine is limited. This suggests that visa-free travel
and rapid access to temporary protection status, applicable in most European countries, together
with extensive anti-trafficking measures in origin, transit and destination countries, have
effectively mitigated the risks of smuggling and trafficking in this context.
Considering the concrete risks highlighted by the findings of this study, the continuation of the
conflict and the large displaced population who continue to be affected, it is welcome that the
legal and policy framework of visa-free travel, rapid access to temporary protection and robust
anti-trafficking responses is being maintained. It could be further strengthened - particularly for
vulnerable groups. These measures also show significant potential for adaptation and
application to other refugee displacements and migration movements in Europe and elsewhere.
11
1. Introduction
The full-scale invasion of Ukraine, beginning in February 2022, and the ongoing war, resulted in the
internal and cross-border displacement of millions of people from Ukraine. The ongoing conflict
raises serious concerns about trafficking in persons inside the country; and about trafficking and
migrant smuggling of people fleeing across borders. This study examines the risks and incidence
of trafficking in persons and smuggling of migrants in the context of the displacement of people
from Ukraine since 2022. 1
Previous research by the United Nations Office on Drugs and Crime (UNODC) shows that
vulnerabilities to trafficking in persons in a country experiencing armed conflict arise from: lack
of opportunities for income generation; interruption in provision of essential services; issues with
rule of law; internal displacement; and the risk of exploitation in the armed conflict itself. People
living in conflict zones may adopt negative coping strategies to gain access to food and other
supplies, or for their own safety and security.
Cross-border displacement of refugees often leads to an increase in smuggling of migrants and
attendant vulnerabilities to trafficking in persons and other forms of abuse and exploitation
during the journey. The legal and economic status of refugees in receiving countries is crucial in
determining their longer-term resilience or vulnerability. 2
To support key stakeholders in the region and beyond to effectively combat trafficking in persons
and smuggling of migrants affecting people fleeing Ukraine and to protect the rights of trafficked
and smuggled people, UNODC conducted an assessment of the incidence and risks of trafficking
in persons and smuggling of migrants in the context of the displacement caused by the war in
Ukraine.
The research applied a phased, mixed-methods approach to analyse the evolution of trafficking in
persons and smuggling of migrants during the years since the beginning of the full-scale invasion
and the resulting internal and cross-border displacement. Field research was conducted in three
capital cities, two of which - Berlin and Warsaw - are among the most important host cities for
Ukrainian refugees globally (see section 2.1 below). The approach combined the collection and
review of relevant literature, statistics and data with the application of a survey and two phases of
in-depth interviews with refugees and key informants, as set out in Table 1, culminating in the
triangulation and analysis of the data and information obtained through these different methods.
Further details on the methodology are included in the Methodological Annex.
1 An earlier Research Brief provided an overview of these potential risks: United Nations Office on Drugs and Crime (UNODC),
Conflict in Ukraine: Key Evidence on Risks of Trafficking in Persons and Smuggling of Migrants, (updated December 2022).
2 Previous research on this topic includes: UNODC, Global Report on Trafficking in Persons 2018, Booklet 2: Trafficking in Persons
in the Context of Armed Conflict, (United Nations Publication, 2018); UNODC, Countering Trafficking in Persons in Conflict
Situations: Thematic Paper, (2018); United Nations Human Rights Council, Report of the Special Rapporteur on trafficking in
persons, especially women and children, A/76/263, (2021); UN HRC, Report of the Special Rapporteur on violence against women,
its causes and consequences, A/HRC/32/42, (2016); Claire Healy, The Strength to Carry On: Resilience and Vulnerability to
Trafficking and Other Abuses among People Travelling along Migration Routes to Europe, (Vienna, International Centre for Migration
Policy Development (ICMPD), 201 9); Claire Healy, Targeting Vulnerabilities: The Impact of the Syrian War and Refugee Situation on
Trafficking in Persons, (Vienna, ICMPD, 201 5).
12
Table 1: Field research overview
Bern/CH Berlin/DE Warsaw/PL Regional Ukraine Total
Ukrainian refugees
surveyed in 2023 584 332 507 - - 1414
Non-Ukrainians surveyed
in 2023 9 78 102 - - 188
Total survey respondents 593 400 609 - - 1602
Key informants 2023 16 14 13 4 - 47
Key informants 2024 9 11 7 4 5 36
Refugees interviewed
2024 3 1 2 - - 6
Total interviewees 28 26 22 8 5 89
While every effort was made to ensure that the research was as comprehensive, representative
and objective as possible, some limitations should be noted. The survey respondents were
selected non-probabilistically, as a convenience sample, which presents limitations in terms of
the extent to which the analysis can be generalized to the entire refugee population. Due to the
ethical and practical implications, no children (anyone aged under 18 years) were interviewed or
surveyed. Around two-thirds of the population of adult refugees from Ukraine in the European
Union (EU) are women, while around three-quarters of survey respondents were women, meaning
that women are slightly over-represented in the survey sample.
The administrative and criminal justice data on trafficking in persons included and analysed in the
study mainly refer to the year 2022. At the time of writing, data for 2023 and 2024 were not
generally available. Indeed, some of the data reported for 2022 refer to trafficking cases that were
identified prior to that year and therefore do not relate to the experience of people displaced by
the full-scale invasion of Ukraine. This means that data for 2023-2024, as and when they become
available, may show a different incidence of trafficking cases than is reflected in this analysis.
The scope of the research covers smuggling of migrants and trafficking in persons from Ukraine,
and trafficking in persons inside Ukraine, in territories under the control of the Ukrainian
Government. This UNODC study sets out research findings on: the scale and composition of
displacement from Ukraine; the legal and policy measures that apply to refugees from Ukraine in
receiving countries, including anti-trafficking measures; and indications of smuggling of migrants
and of different forms of trafficking in persons. The study also includes in-depth case studies of
potential trafficking in persons cases.
13
2. Forced Displacement Context
2.1 Scale and composition of the displacement
Inside Ukraine
In February 2022, the population of Ukraine was just over 41 million people. 3 As of October 2024,
around 34 million people were living in Ukraine, including 3.6 million people who were internally
displaced 4 and around 4.3 million returnees from other parts of Ukraine (76%) and abroad (24%). 5
UN agencies estimate that 14.6 million people in the country need humanitarian aid and
protection assistance, of whom 8.5 million are non-displaced. 6
Ukrainian population
(in millions) as of October 2024
9% |DPs
3.6
8% IDPs
3 3 returnees
A.A 0 / Population not
17 9° displaced or
with hum. needs
2% Returnees
1.02 from abroad
Non-displaced
21% people with
8.5 humanitarian
needs
1 6% Refugees
6.75 abroad
Source: UNODC calculations based on data from: State Statistics Service Ukraine, International Organization
for Migration (IOM), UN Office for the Coordination of Humanitarian Affairs (OCHA), UN Refugee Agency (UNHCR)
3 State Statistics Service of Ukraine, Number of Present Population of Ukraine, as of 1 January. "Excluding the temporarily
occupied territories of the Autonomous Republic of Crimea, and the city of Sevastopol," (2022).
4 International Organization for Migration (IOM) Displacement Tracking Matrix, "Ukraine — Internal Displacement Report — General
Population Survey Round 1 8 (October 2024)", (October 2024).
5 IOM Displacement Tracking Matrix, "Ukraine - Conditions of Report Assessment Factsheet - Round 8", (July 2024). IOM
considers as returnees people who left their place of habitual residence after 24 February 2022, for a period of at least two weeks,
and who since returned.
6 United Nations Office for the Coordination of Humanitarian Affairs (OCHA), Ukraine Humanitarian Needs and Response Plan
2024, (January 2024); OCHA, "Ukraine: Situation Report": https://reports.unocha.org/en/country/ukraine, (accessed 6 November
2024).
14
The unemployment rate in Ukraine peaked after the full-scale invasion at 24.5 per cent in 2022
and is estimated at 1 4.2 per cent in 2024, as compared to 9.8 per cent in 2021 7 As of early 2022,
72 .7 million people with disabilities were living in Ukraine, 8 and during the course of 2022, an
additional 130,000 people in Ukraine registered their disability status. 9
Dynamic cross-border displacement
As of October 2024, more than 6.75 million people have fled Ukraine to reside abroad since the
beginning of the full-scale invasion, according to the UN Refugee Agency (UNHCR). 10 6.2 million
refugees from Ukraine are recorded in European countries and 560,000 in the USA, Canada and
other non-European countries. More than one million non-Ukrainians from outside the EU have
exited Ukraine since the outbreak of the war. 11
People displaced from Ukraine reside in the Russian Federation (1.23 million), 12 1.21 million in
Germany, 981,000 in Poland, 560,000 in North America and other countries outside Europe,
380,000 in Czechia, 250,000 in the United Kingdom (UK), 211,000 in Spain and 174,000 in Italy. 13
All the above figures are as of October 2024. The UK is among the few European countries
requiring entry visas from Ukrainians; as of October 2024, a total of 21 6,000 Ukraine Scheme visa
holders had arrived in the UK. 14
7 International Monetary Fund (IMF) DataMapper Ukraine: www.imf.org/external/datamapper/LUR@WEO/UKR, (accessed 24
October 2024).
8 United Nations Office of the High Commissioner for Human Rights (OHCHR), "Ukraine: 2.7 million people with disabilities at risk,
UN committee warns", (1 4 April 2022).
9 World Bank, Government of Ukraine, EU and UN, Ukraine Rapid Damage and Needs Assessment February 2022 - February 2023,
(March 2023); Key informant interviews 2CH-K-01; UA-K-02.
10 A study by the Ukrainian Centre for Economic Strategy puts the figure significantly lower, at a total of 4.9 million Ukrainian
refugees as of January 2024, based on the statistics of the State Border Guard Service of Ukraine and the statistics on Ukrainians
in Russia and Belarus. Source: Centre for Economic Strategy (CES), Ukrainian refugees. Future abroad and plans to return, (March
2024).
11 IOM, Ukraine and Neighbouring Countries 2022-2024: Two Years of Response, (February 2024).
12 Latest figures available for the Russian Federation are from 31 December 2023. Ukrainians can regularly enter the Russian
Federation and apply for Refugee Status, Temporary Asylum, Temporary Residence Permit, Permanent Residence Permit or
Russian citizenship. Non-Ukrainians fleeing the war can transit the Russian Federation regularly for up to 15 days. Source: UN
Refugee Agency (UNHCR), "Russian Federation", www.unhcr.org/countries/russian-federation, (accessed 6 November 2024).
13 UNHCR Operational Data Portal, "Ukraine Refugee Situation", https://data.unhcr.org/en/situations/ukraine, (accessed 6
November 2024).
14 UK Home Office, "Ukraine Family Scheme, Ukraine Sponsorship Scheme (Homes for Ukraine) and Ukraine Extension Scheme
visa data", (28 October 2024). As of 28 October 2024, 58,500 people had arrived in the UK through the Ukraine Family Scheme
(discontinued since February 2024) and 1 57,400 through the Ukraine Sponsorship Scheme. An additional 33,800 people had their
permission to stay extended under the Ukraine Family Scheme and Ukraine Extension Scheme.
15
Countries of residence of refugees from Ukraine
(in 1,000s) as of October 2024
00/ USA, Canada,
o 4) other
558 non-European 18% Russian
1 228 Federation
/o EOuthroepr ean
1 755 countries 1 s°/
1 213° Germany
QOz
0/0 Italy
174
14% 1 0 Poland
981
0 0/ 0/0 Spain
211
4% ** /o UK
250
6% Czechia
380
Source: UNODC Calculations based on UNHCR data
The cross-border displacement from Ukraine resulted in widespread family separation.
Seventy-eight per cent of over 43,000 refugees from Ukraine interviewed by UNHCR in Ukraine's
neighbouring countries in 2022 had to separate from at least one immediate family member in
order to flee. This is because of martial law provisions prohibiting Ukrainian men aged 18-60
years from leaving the country (with some exemptions, see section 3.3 below) or because the
15 family member(s) did not want to or could not leave Ukraine. 16 Family separation during the
journey makes refugees vulnerable to different forms of trafficking and abuse. 17
15 According to UNHCR, these numbers refer to the: "total number of Refugees from Ukraine recorded across Europe/in country",
reflecting the "estimated number of individual refugees who have fled Ukraine since 24 February and are currently present in
European countries. Figures, including disaggregation by country, include refugees from Ukraine who were granted refugee status,
temporary asylum status, temporary protection, or statuses through similar national protection schemes, as well as those
recorded in the country under other forms of stay (from 24 February 2022), as relevant/applicable.”
16 UNHCR, "Ukraine situation: Regional protection profiling and monitoring factsheet", (21 December 2022).
17 Frontex, Risk Analysis for 2023/2024, (Warsaw, 2023), p. 38.
16
Data on separated and unaccompanied children is available for 18 EU countries, Liechtenstein,
Norway and Switzerland. The data indicate at least 16,670 separated and unaccompanied
refugee children from Ukraine in these countries. Figures for Germany, Poland, Czechia, Spain,
Italy and France, among others, are not included here, but the total includes 1 ,1 00 unaccompanied
and separated refugee children granted temporary protection (Protection Status S) in
Switzerland. 18 Gaps were identified in 2022 in the centralized registration of unaccompanied
children; EU countries were not initially systematically reporting data on unaccompanied children
fleeing Ukraine. 19
Meanwhile, the displacement situation is highly dynamic. As of October 2024, people - of all
nationalities - had crossed Ukraine's land borders into the country at least 37 million times, for
reasons including temporary trips to check on family, property and businesses, joining family,
accessing economic opportunities and perception of safety in specific areas. 20 Ukrainian
refugees based in Poland in particular often travel back and forth regularly to Ukraine, or
seasonally, remaining in Poland only for the winter months. This can have implications for their
access to support and services in Poland. 21
Around 1,030,000 people are considered by the International Organization for Migration (IOM) as
returnees to Ukraine from abroad, as of October 2024. 22 Among respondents to the Survey of
Arriving Migrants from Ukraine (SAM-UKR) conducted by the EU Asylum Agency (EUAA) and the
Organisation for Economic Co-operation and Development (OECD) in 2023, 19 per cent of
respondents planned to return to Ukraine as soon as it is safe, while 43 per cent did not intend to
return. 23
18 Statistical office of the European Union (Eurostat), "Temporary protection for persons fleeing Ukraine - monthly statistics", (3
October 2024), (accessed 6 November 2024).
19 European Union Agency for Fundamental Rights (FRA), Fundamental rights implications for the EU of the war in Ukraine,
(Luxembourg: Publications Office of the European Union, 2023).
20 UNHCR, "Ukraine Refugee Situation", https://data.unhcr.org/en/situations/ukraine, (accessed 6 November 2024); UNHCR and
REACH, Situation Overview: Movement of Ukrainians back into Ukraine from Poland, Slovakia, Hungary, Romania and Moldova, (28
April 2022); UNHCR, Lives on Hold: Profiles and Intentions of Refugees from Ukraine, (July 2022).
21 Key informant interviews 2PL-K-03; 2PL-K-05; Regional Refugee Response for the Ukrainian Situation (IOM), Vulnerability to
Trafficking in persons in the context of the war in Ukraine: The case of Poland and Romania, (2024).
22 IOM Displacement Tracking Matrix, "Ukraine - Conditions of Report Assessment Factsheet - Round 8", (July 2024). IOM con
siders as returnees people who left their place of habitual residence after 24 February 2022, for a period of at least two weeks, and
who since returned.
23 Organisation for Economic Cooperation and Development (OECD) and European Union Agency for Asylum (EUAA), Voices in
Europe: Experiences, Hopes and Aspirations of Forcibly Displaced Persons from Ukraine, (Paris, OECD Publishing, 2024).
17
During the course of 2023, some refugees moved on from the countries bordering Ukraine to
other parts of Europe. Around 67 per cent of 3,41 8 people surveyed for the SAM-UKR in 2023, who
were located in Germany, France, Ireland, Norway and Poland, had already reached their preferred
destination country. The remainder were not yet at their final intended destination (13%) or were
undecided (21 %). 24
The age and gender composition of the refugee population has also changed since the beginning
of the displacement. The population of people with temporary protection in Europe as of August
2024 comprises 45 per cent adult women, 23 per cent adult men, 1 7 per cent boys and 1 5 per cent
girls. 25 The proportion of adult men applying for temporary protection has gradually increased
over the years since the beginning of the full-scale invasion. 26
Now you see more and more men in Warsaw.
At the beginning of the war, it was mainly women
and children. Now you see more families.
Trafficking in Persons Specialist, NGO, Poland, 20 24 27
2.2 Legal and policy provisions
Visa-free travel and rapid access to temporary protection status
Ukrainian citizens can enter the EU and all other European countries without requiring a visa, with
the exception of the UK. Temporary protection and similar national protection schemes apply to
people fleeing Ukraine and arriving in EU and non-EU European countries. 28 The Council of the EU
activated the 2001 Temporary Protection Directive for people fleeing Ukraine on 4 March 2022
and, as of the time of writing, it has been extended until March 2026. 29
24 Ibid.
25 Ukrainian men aged 18-60, and adult women with certain professions, are prohibited under Ukrainian martial law from leaving
the country and taking up residence elsewhere, unless they qualify for exemptions.
26 Statistical Office of the European Union (Eurostat), "Temporary protection for persons fleeing Ukraine - monthly statistics", (3
October 2024), (accessed on 6 November 2024).
27 Key informant interview 2PL-K-01.
28 All 27 EU Member States, Iceland, Liechtenstein, Montenegro, Norway, Serbia, Kosovo: S/RES/1 244 (1 999), Switzerland, UK and
other European countries (e.g., Republic of Moldova, Georgia, Türkiye) grant temporary protection or similar national protection
status.
29 Council of the EU Implementing Decision (2022/382) to activate Article 5 of Council Directive 2001/55/EC of 20 July 2001,
introducing temporary protection for Ukrainians arriving in EU countries, was taken on 4 March 2022. On the most recent
extension of temporary protection, see: Council of the EU, "Ukrainian refugees: Council extends temporary protection until March
2026", press release, (25 June 2024).
18
Temporary protection is a form of protection status that is granted through a swift application
procedure and is based on a person's country of origin or previous residence, rather than on an
individual assessment of each person's application for refugee status in the mainstream asylum
system. Applications for international protection in mainstream asylum systems are usually
decided on a case-by-case basis and therefore generally take much longer to process.
The activation of the Temporary Protection Directive by the Council of the EU is "an exceptional
measure to provide immediate and temporary protection in the event of a mass influx or imminent
mass influx of displaced persons from non-EU countries who are unable to return to their country
of origin." 30
The EU 'Dublin Regulation,' which requires asylum applicants to apply for international protection
in the first EU country they arrive in, does not apply to applicants for temporary protection. This
means refugees from Ukraine can freely decide which EU country to apply for temporary
protection in. The EU temporary protection residence permit is valid for one year and can be
extended for up to three years. The rights attached to the status include access to the labour
market, social housing, social welfare, healthcare, education for children and banking services. 31
People with temporary protection status can travel to and remain in other EU countries for up to
90 days within a 1 80-day period. 32
...the Temporary Protection Directive was a wonderful step
in terms of preventing smuggling of migrants. Otherwise,
we could have had a quite different scenario. [...] The activation
of the Directive is something that should also be considered
in broader contexts, beyond conflict and war.
Key informants from an international organization, 2023 33
The legal framework for refugees from Ukraine arriving in the EU and other European countries is
therefore distinct in significant ways from the framework that applies to refugees, asylum
applicants and migrants from other non-EU countries. Because it is possible to enter the country
regularly and rapidly access temporary protection status, refugees from Ukraine generally do not
need a smuggler to facilitate their journey to the country of refuge.
30 European Commission, Migration and Home Affairs, "Temporary Protection", (accessed 6 November 2024).
31 European Union Agency for Fundamental Rights (FRA), The Russian war of aggression against Ukraine - the broad fundamental
rights impact in the EU: Bulletin #2, (Luxembourg, Publications Office of the European Union, 2022).
32 Ibid.
33 Key informant interview IN-K-02.
19
Key informants interviewed for this research specifically pointed to swift and legal migratory
journeys, rapid granting of temporary protection status and access to the labour market as crucial
sources of resilience to trafficking in persons and labour rights violations in general, as well as
preventing smuggling of migrants. Legal status reduces the risks of refugees being exploited in
informal employment and of irregular status being used by employers to threaten employees. 34
Temporary protection permits in Europe
4,163,700 people were granted temporary protection in the European Economic Area (EEA) 35
during the period March 2022 to August 2024. Over half were granted temporary protection in
Germany (1,122,300) and Poland (975,200) - and 66,500 in Switzerland. 36 They comprise
Ukrainians (98.3%), Russians (0.3%), Nigerians (0.12%), Azerbaijanis (0.10%) and other non-EU
citizens. At 34.6 per 1,000 population, Czechia hosts the highest number of people under
temporary protection per capita, followed by Lithuania and Poland, both hosting over 26 per 1 ,000
population. 37
Few Ukrainians have applied for international protection through the regular asylum systems of
European countries. In the EEA, 409,500 people of all nationalities were granted some form of
refugee status or subsidiary protection (not including temporary protection) in 2023. This
includes 1 0,340 Ukrainians - three per cent of the total granted international protection in the EEA
in that year. 38 This means that the vast majority - 99.5 per cent - of Ukrainians in Europe applied
for temporary protection status rather than international protection.
The majority (83%) of the 1,602 survey respondents for this research in Germany, Poland and
Switzerland had temporary protection status (or the equivalent in Switzerland - Protection Status
S) at the time of the survey, while 1 1 per cent had refugee status or had applied for asylum. A
higher proportion of men surveyed (16%) had refugee status or had applied for asylum than
women (9%). In Switzerland, 98 per cent of respondents had Protection Status S, while in
Germany, 82 per cent of respondents had EU temporary protection status and 12 per cent were
refugees or asylum applicants. In Poland, 70 per cent of respondents had temporary protection
status, while 20 per cent were asylum applicants or refugees.
Non-Ukrainian citizens from outside the EU who were residing in Ukraine at the outbreak of the
war are not necessarily granted visa-free entry to countries of refuge. In certain cases, however,
including for entry into Germany, a visa is not required for non-Ukrainians, as long as the person
in question can prove that they were residing in Ukraine when the full-scale invasion began. 39
Temporary protection is generally granted to recognized refugees and some categories of
long-term permanent residents who had been residing in Ukraine.
34 Key informant interviews 1 DE-K-02; 1 DE-K-07; 1 DE-K-09; 1 DE-K-09; 2DE-K-02; 1 PL-K-01; 1 PL-K-04; 2CH-K-07.
35 The European Economic Area (EEA) comprises all EU Member States, Iceland, Liechtenstein and Norway.
36 Eurostat, "Temporary protection for persons fleeing Ukraine - monthly statistics", 3 October 2024 (accessed on 6 November
2024).
37 Ibid.
38 EUROSTAT, "Asylum decisions - annual statistics", 4 July 2024 (accessed on 5 August 2024).
39 See: Germany, Ukraine Residence Transitional Regulation of 7 March 2022 (BAnz AT 08.03.2022 V1 ), most recently amended by
Article 1 of the Regulation of 1 7 May 2024 (BGBI. 2024 I Nr. 1 68).
20
Among the 1 88 non-Ukrainian people surveyed for this research, most (93.5%) had some form of
regular status in Ukraine before they left - visa-free entry or a residence, employment or study
permit, including 1 6.5 per cent who had applied for asylum in Ukraine. Just six per cent stated that
they were undocumented or did not know.
2.3 Anti-trafficking measures
Mobilizing the anti-trafficking response
As set out in the previous section, key informants for this research identified visa-free travel and
rapid access to temporary protection status as crucial policy tools to prevent trafficking in
persons and related vulnerabilities, as well as to prevent smuggling of migrants. 40 This is
supported by emerging research on the risks of trafficking for people displaced from Ukraine. 41 In
addition, a comprehensive anti-trafficking response was put in place by Ukrainian and host
country authorities and civil society actors. According to a study by the UN's Regional
Anti-Trafficking Task Force for Ukraine in early 2023: "While data and research is limited, it is likely
that the swift and large-scale response prevented widespread vulnerability to trafficking in
persons." 42
The EU Common Anti-Trafficking Plan to respond to the Ukrainian displacement crisis, adopted in
May 2022, considered the threat of trafficking in persons "high and imminent" 43 Due to the
suddenness and scale of the displacement from Ukraine, it took some time for a targeted and
effective anti-trafficking response to be put in place. Gradually, in the course of 2022 and beyond,
anti-trafficking stakeholders from NGOs, local and state authorities, and regional and
international organizations, mobilized a series of anti-trafficking policies and actions. Across the
EU, this includes information campaigns, specialized prosecutors' networks, enhanced
identification of potential trafficking cases, law enforcement and criminal justice responses, and
targeting of criminals victimizing Ukrainian refugees on online platforms. 44
Private companies and state authorities in the countries under study put in place information
dissemination initiatives to encourage formal and safe employment, including employment
information and job search websites specifically for people from Ukraine. 45 National and local
authorities, in partnership with NGOs, set up a comprehensive system of information
dissemination in multiple languages (Ukrainian, Russian, English) on risks of trafficking, rights
and support services.
40 Key informant interviews 1 DE-K-02; 1 DE-K-07; 1 DE-K-08; 1 DE-K-09; 2DE-K-02; 1 PL-K-01; 1 PL-K-04; 2CH-K-07; IN-K-02.
41 See, inter alia: OECD & EUAA, Voices in Europe: Experiences, Hopes and Aspirations of Forcibly Displaced Persons from Ukraine,
(Paris, OECD Publishing, 2024); Regional Refugee Response for the Ukrainian Situation (IOM), Vulnerability to Trafficking in persons
in the context of the war in Ukraine, (2024); IOM, Human Trafficking in the Ukraine Crisis: Regional Anti-Trafficking Task Force -
March 2023; UNODC, Conflict in Ukraine: Key Evidence on Risks of Trafficking in Persons and Smuggling of Migrants, (updated
December 2022); UNHCR, Surviving as We Can...: Poland Summary Report, (October 2023); Mixed Migration Centre (MMC),
Displaced from Ukraine to Warsaw: A case study on journeys, living conditions, livelihoods and future intentions, (2023).
42 IOM, Human Trafficking in the Ukraine Crisis, (March 2023), p. 7.
43 EU Solidarity Platform, A Common Anti-Trafficking Plan to address the risks of trafficking in human beings and support potential
victims among those fleeing the war in Ukraine: Under the lead of the EU Anti-trafficking coordinator, (6 May 2022).
44 For further details on specific anti-trafficking measures for Ukrainian refugees across the EU, see European Commission, Report
on the progress made in the fight against trafficking in human beings (Fourth report), (1 9 December 2022); Key informant interview
NL-K-01.
45 For example, Pracuj.pl, www.pracuj.pl/praca?ua=true; Federal Government of Germany, "The Germany4Ukraine Information
Guide", www.germany4ukraine.de/hilfeportal-en; Switzerland, State Secretariat for Economic Affairs, "Ukraine war - information
for job seekers and employers",
www.arbeit.swiss/secoalv/de/home/menue/institutionen-medien/projekte-massnahmen/ukrainekrise-informationen-stellensuc
hende-arbeitgeber.html; Ukraine Hilfe, www.ukraine-hilfe-bern.ch/angebote.
21
Key informants described multiple information campaigns and communication initiatives to
reduce the risks of refugees being exploited, as well as referring them to services to seek help if
they were victims of abuses. These initiatives were carried out in key locations such as at border
crossings, transport stops and accommodation centres, and on websites and social media. 46
In Bern, Switzerland, this included police and social services organizing information campaigns in
partnership with NGOs, participating in meetings with community leaders, and creating and
disseminating leaflets and posters. 47 The authorities in Warsaw, Poland, disseminated
information leaflets and screened volunteers offering services, with the support of NGOs and
vetted volunteers. 48 Information was also generated and shared by displaced Ukrainians
themselves, particularly on social media and in messaging apps, and some NGOs in host
countries relied on Ukrainian staff members to support their information provision. 49 According
to key informants, however, this information may not always be correct. 50
[Members of the Ukrainian community] actively shared
advice, such as avoiding specific job offers and profiles
of individuals known to be exploitative. This mutual support
network was crucial in protecting vulnerable individuals
from exploitation.
Key informant from an NGO interviewed in Bern 51
Anti-trafficking hotlines operate in the cities under study, and, since 2022, provide services in
Ukrainian and Russian. This includes La Strada NGO's hotline in Warsaw, which can also be
contacted on messaging apps, and is operated in conjunction with the National Intervention and
Consultation Centre for Victims of Human Trafficking (NICC). 52 The Polish Ministry of the Interior
and Administration increased the financing of the NICC by almost 40 per cent in 2023. 53 In Bern,
the National Hotline against Human Trafficking and Exploitation provides services in Ukrainian by
phone and online. 54 In Berlin, anti-trafficking NGOs provide services and information in Ukrainian,
Russian and other languages. 55
46 Key informant interviews 1DE-K-07; 1DE-K-09; 1PL-K-07; 1CH-K-12; 2CH-K-02; 2CH-K-06; 2CH-K-07; 2PL-K-04; see, e.g., Poland,
Ministry of the Interior, Human Trafficking Report: Human trafficking is a crime 2022, (2023).
47 Key informant interviews 1CH-K-1 2; 1CH-K-09; 2CH-K-02.
48 Poland, Ministry of the Interior, Human Trafficking Report: Human trafficking is a crime 2022, (2023).
49 Key informant interviews 1CH-K-07; 1CH-K-06.
50 Key informant interview 1 CH-K-09.
51 Key informant interview 2CH-K-06.
52 La Strada, PeKOMeHflapiT (Translation: Recommendations): https://strada.org.pl/helpua/rekomendatsii.
53 Information provided to UNODC by the Permanent Mission of Poland to the United Nations Office and the International
Organisations in Vienna, on 31 October 2024.
54 ACT212, National Hotline against Human Trafficking and Exploitation, www.act212.ch/en/hotline.
55 For example, Ban Ying, "030-4406373", www.ban-ying.de.
22
Registering and monitoring key locations
Another key aspect of the targeted anti-trafficking response in the three countries where the
research was undertaken was a recognition of the risks of unregistered volunteers offering
transportation and other forms of support to refugees from Ukraine. This was particularly
important in bordering countries such as Poland. 56 According to a key informant who was present
at the Ukraine-Poland border in February-March 2022, more than 100,000 refugees were arriving
per day in Poland at that time and the authorities were overwhelmed. 57 Subsequently, the Polish
police began to register the cars, drivers and passengers in the case of transportation offers. 58
The Polish Ministry of the Interior and Administration, in cooperation with the Polish police, also
developed a mechanism for screening organizations, foreign entities and individuals who wished
to volunteer or provide humanitarian aid to Ukrainian refugees, to prevent abuse or sexual
exploitation of vulnerable people. 59
(They did thousands ofchecks [in Romania] almost daily
of places where Ukrainians live, in small communities.
This also entails checks of the criminal records of hosts -
for instance records of sexual abuse or domestic violence.
Regional key informants interviewed in 2023 60
Police, other authorities and NGOs in Berlin and Bern also increased efforts to monitor certain
locations for risks of exploitation and trafficking, such as at brothels (see section 5.4 below on
trafficking for sexual exploitation), railway and bus stations and accommodation centres, and
online. 61 There were regular verifications at accommodation centres and locations by the
services of the Swiss State Secretariat for Migration (SEM). 62
56 Key informant interview 1 PL-K-07.
57 Key informant interview 2PL-K-06.
58 Key informant interview 1 PL-K-01 .
59 Information provided to UNODC by the Permanent Mission of Poland to the United Nations Office and the International
Organisations in Vienna, on 31 October 2024.
60 Key informant interview IN-K-02.
61 Key informant interviews 1CH-K-01; 1DE-K-07; 1CH-K-12; 2CH-K-06; KOK, Menschenhandel und Ausbeutung im Kontext des
Ukrainekrieges - Eine Untersuchung aus Sicht spezialisierter Fachberatungsstellung zur Situation in Deutschland (Translation:
Trafficking in Persons and Exploitation in the context of the war in Ukraine - Perspectives from help centres about the situation in
Germany), (October 2022).
62 Key informant interviews 1 CH-K-09; 1 CH-K-1 1 .
23
Such operations can, however, be compromised if refugees distrust the authorities, due to general
perceptions of authorities or specific experiences. 63 A key informant interviewed in Bern in 2023
reported that there are still many barriers to reporting abuses to the police, since it involves
approaching and speaking to police officers in a different language in an intimidating and public
location. 64 Another key informant interviewed in 2023 referred to cases discussed in Ukrainian
groups on a messaging app, where Ukrainians had reported issues to the police and the police
had been unable to take any action. 65
2.4 Situation of people who fled Ukraine in the EU and Switzerland
While visa-free travel and rapid access to temporary protection status, together with a robust
anti-trafficking response, appear to have increased the resilience of refugees from Ukraine to
trafficking and exploitation in receiving countries in Europe, some vulnerability factors persist,
particularly in relation to income generation and accommodation. 66
Access to employment
Most people who fled Ukraine have a legal status in receiving countries that allows them to
access the labour market, start a business or attend education. Overall, the integration of
Ukrainian refugees into labour markets in Europe has been proceeding apace, with over 40 per
cent of working-age Ukrainian refugees in employment in countries like the Netherlands,
Lithuania and Estonia. 67
The majority of survey respondents for this research in Berlin, Warsaw and Bern had a stable
income prior to leaving Ukraine (78%), with no differences between genders. However, 46 per cent
stated that they were not personally earning any money at the time of the survey - though this
does not preclude the possibility that someone in their household or immediate family may have
been supporting them financially. This includes 83 per cent of women and 78 per cent of men
surveyed in Bern, Switzerland, where the rates were the highest.
When asked why they were not earning money, 44 per cent of those not earning money stated that
they could not find employment, 1 2 per cent stated that they were retired, and nine per cent stated
that they were taking care of children at home. 22 per cent of all respondents had a regular paid
job, 1 6 per cent were receiving social benefits, seven per cent had casual/occasional work with a
contract and five per cent worked with no contract.
63 Key informant interview 1 DE-K-09.
64 Key informant interview 1CH-K-09.
65 Key informant interview 1 CH-K-07.
66 MMC, Vulnerability and Resilience to Exploitation and Trafficking among People fleeing Ukraine in Berlin, Bern and Warsaw
(Geneva, MMC, 2024).
67 OECD and EUAA, Voices in Europe: Experiences, Hopes and Aspirations of Forcibly Displaced Persons from Ukraine, (Paris, OECD
Publishing, 2024).
24
While 24 per cent of respondents to the SAM-UKR survey in 2022 covered their living expenses
with their wages, 44 per cent did so in 2023. This comprises 35 per cent working in the receiving
country and nine per cent working remotely (for employers in Ukraine or elsewhere). 68 According
to the European Foundation for the Improvement of Living and Working Conditions (Eurofound)
and the Fundamental Rights Agency of the EU (FRA), 62 per cent of adults displaced from Ukraine
had actively looked for a job in the host country, two-thirds of whom had already been employed
there, by early autumn 2022. 69
However, there remain indications of financial precarity. 54 per cent of respondents to the
SAM-UKR survey in 2022 "primarily relied on their personal savings to meet their living expenses."
In 2023, 28 per cent were able to do so. 70 A significant proportion of Ukrainian refugees
interviewed for lOM's research in Poland and Romania stated that their income was insufficient
to cover their expenses - 27 per cent in Poland and 29 per cent in Romania. 71
Much of the labour market integration of Ukrainians has been in low-skilled sectors, including for
refugees with higher skill levels. 72 This is largely due to lack of knowledge of the local languages
of host cities and of their rights, and challenges with the recognition of qualifications obtained in
Ukraine. 73 Eurofound and FRA also pointed to the lack of availability of regular work outside of the
informal labour market. 74
The typical family here, it's mum and grandmother, with one
or two children. [...] this woman cannot work - her children go
to school until noon, then they have two hours for lunch.
So the mum cannot work and language is an additional challenge.
If they have small children, they can only have four hours j
a day of childcare.
Key informant from an anti-trafficking NGO in Bern, interviewed in 2023 75
68 OECD and EUAA, Voices in Europe, (2024), op. cit.
59 Eurofound and FRA, Barriers to employment of displaced Ukrainians, (Luxembourg, Publications Office of the European Union,
2023). Based on an online survey of over 14,000 people.
70 OECD and EUAA, Voices in Europe, (2024), op. cit., p. 43.
71 Regional Refugee Response for the Ukrainian Situation (IOM), Vulnerability to Trafficking in persons in the context of the war in
Ukraine: The case of Poland and Romania (2024).
72 OECD and EUAA, Voices in Europe, (2024), op. cit.; Key informant interview 2PL-K-02.
73 IOM, Vulnerability to Trafficking in persons, (2024), op. cit.; OECD and EUAA, Voices in Europe, (2024), op. cit.; Eurofound and FRA,
Barriers to employment, (2023), op. cit.; Key informant interviews 2DE-K-02; 2DE-K-03; 2DE-K-06; 1PL-K-04; 1PL-K-06; 1PL-K-07;
2PL-K-01; 2PL-K-04; 2PL-K-05; 2CH-K-05; 2CH-K-07; IN-K-02.
74 Eurofound and FRA, Barriers to employment, (2023), op. cit.
75 Key informant interview 1 CH-K-1 1 .
25
The lack of sufficient provision for childcare and for other caring responsibilities (e.g., family
members who are elderly or have disabilities) of working-age refugees present a further obstacle
to employment. 76 According to a key informant in Warsaw, for example, employment
opportunities in certain locations may be limited to shift work in factories, which is particularly
difficult for parents: 'We were told about women who lost their jobs because their children were
getting sick and they had to stay home with them."''’
One of the key vulnerabilities identified among people who fled Ukraine in Poland is the
employment of refugees without contracts or under civil law contracts rather than formal
employment contracts subject to the Labour Code (see section 5.3 below on cross-border
trafficking for forced labour). 78 The civil-law contract (umowa zlecenie, or "contract of mandate")
is a flexible contract, subject to less stringent regulations, with no set limitation on working hours
and no mandatory benefits or leave days. 79 Not having a labour-law contract makes Ukrainian
domestic workers particularly vulnerable to exploitation. Ukrainian domestic workers in Poland
rarely have a contract or access to employment rights. 80
The housing situation
The urgent need to pay for accommodation also makes refugees from Ukraine vulnerable to
forced labour, being underpaid and working below their qualification levels, especially in cases
where the employer provides the accommodation. 81 If someone loses their job, they may no
longer be able to afford accommodation. One key informant also identified a lack of valid identity
documents as an obstacle to accessing accommodation, leaving some refugees homeless. 82
Ukrainians are sometimes housed in hostels with no regular presence of social workers. 83 Lack
of access to accommodation is particularly acute due to a lack of housing supply in general in
important host countries like Germany and Poland. 84
76 OECD and EUAA, Voices in Europe, (2024), op cit.; Key informant interviews 2DE-K-02; -03; -06; IN-K02.
77 Key informant interview 2PL-K-05.
78 Key informant interviews 2PL-K-04; 1PL-K-06; 2PL-K-07; I0M, Vulnerability to Trafficking, (2024), op. cit.
79 Piotr Lewandowski, Jan Baran, Aneta Kielczewska, Jakub Sawulski, Case Study: Gaps in access to social
protection for people working under civil law contracts in Poland, Institute for Structural Research (IBS) for the European
Commission, (Luxembourg, Publications Office of the EU, 2018).
80 JB Klakla, M Koss-Goryszweska, A Kulesa, K Pajak-Zateska and M Zarychta, In the Shadows. Ukrainian Domestic Workers in
Poland, Care International, (Warsaw, 2023).
81 Key informant interviews 2PL-K-01; 2PL-K-02; 2PL-K-03; 2PL-K-04; 2PL-K-05; 2CH-K-02.
82 Key informant interview 2PL-K-03.
83 Key informant interview 2DE-K-07.
84 The housing supply in Poland in 2023 was low, with 419 dwellings per 1,000 population, though this was a slight improvement
compared to 2022 (412). Statistics Poland (2024). "Housing Economy in 2023":
https://stat.gov.pI/download/gfx/portalinformacyjny/en/defaultaktualnosci/3309/10/7/1/housing_economy_in_2023.pdf. The
housing situation in Germany was slightly better, at 51 6 dwellings per inhabitant in 2023: Germany, Statistisches Bundesamt
(Destatis, 2024): www.destatis.de/EN/Themes/Society-Environment/Housing/Tables/liste-dwellings. html#55566. In
Switzerland, housing supply is higher, at 641 dwellings per 1,000 population: Switzerland, Federal Statistics Office (2024):
www.bfs.admin.ch/bfs/en/home/statistiken/bau-wohnungswesen.gnpdetail.2024-0526.html.
26
This was mitigated to a certain extent by the willingness of private individuals to host refugees
from Ukraine, according to a key informant from an NGO in Berlin. 85 However, private hosting
arrangements may present a risk of exploitation in domestic work and of sexual abuse or
exploitation, due to the implicit relationship of dependency of refugees on host families.
According to two key informants, some hosts expect to receive a portion of the social welfare
payments people with temporary protection status are entitled to. 86 Key informants interviewed
in 2023 in Berlin and Warsaw considered the limited vetting procedures for families providing
accommodation to refugees as a risk factor for abuse. 87
Investigative journalists interviewed for this research had screened online offers of assistance for
Ukrainian refugees and identified a number of potentially abusive cases, such as accommodation
being offered to women only. 88 Key informants mentioned sexual harassment, abuse and assault
of Ukrainian women in vulnerable situations, including by accommodation providers and
employers, and people offering Ukrainians help, with the intention of developing a romantic
relationship with them. 89 A Ukrainian NGO worker, who herself travelled via South-Eastern Europe
to Western Europe in early 2022, witnessed men in locations where refugees were congregating
offering Ukrainian women places to stay and requesting their driving licences. 90
A key informant interviewed in 2024 described the experience of a young Ukrainian woman who
used the services of the NGO where the informant works. The woman was renting an apartment
that was connected to her landlord's apartment through a common space. Over time, the landlord
made the woman increasingly dependent on him, socially isolated her and accompanied her
every time she ran errands. She ended up having sexual relations with him, which she felt she had
to do in return for him hosting her. The key informant notes that such cases are challenging to
pursue legally because of the difficulty of proving or disproving consent. The informant was
aware of around eight other similar cases. 91
On the other hand, the fact that the majority of refugees are not housed in camps or collective
accommodation centres may also be a factor of resilience. 92 Large collective accommodation
centres in the cities under study present indicators of vulnerability to abuse and exploitation. Key
informants described the situation at the Tegel First Reception Centre in Berlin, which was
intended for short periods of residence (less than a week) for Ukrainians only. During 2023-2024,
the centre accommodated people of various nationalities for months - around 4,500 people at the
time of the interview in 2024, including around 3,700 Ukrainians and around 800 people of other
nationalities, according to two key informants. 93
85 Key informant interview 1 DE-K-03.
87 Key informant interviews 1 DE-K-03; 1 PL-K-07.
88 Key informant interviews 1 DE-K-08; 1 DE-K-03; 1 PL-K-07; 2DE-K-03; NL-K-02.
89 Key informant interview IN-K-01 .
90 Key informant interviews 1CH-K-07; 2CH-K-02; 2CH-K-03; 2CH-K-04.
91 Key informant interview 1 CH-K-1 1 .
92 Key informant interview 2CH-K-03.
93 Key informant interview 2DE-K-05.
27
Risks were also reported at one of the main accommodation centres for refugees from Ukraine in
Warsaw. A key informant interviewed for this research in 2023 indicated that there were risks of
exploitation but that the security team was actively monitoring these risks. The centre staff also
received training and support on trafficking in persons from an international organization and a
local NGO. Women residing at the centre were reportedly involved in sex work in the vicinity of the
centre, though the key informant did not have further details or any indications of exploitation. 94
Many collective accommodation centres in Poland have been closed since the first year of the
displacement and, since March 2023, the state provides accommodation to people with
temporary protection status only for a period of four months upon arrival. 95
94 Key informant interview 1 PL-K-08.
95 Key informant interview 2PL-K-03. Changes were made on foot of an amendment to the relevant Polish law. See:
Stowarzyszenie Interwencji Prawnej (Association for Legal Intervention (SIP), "The president has signed an amendment to the
Special-purpose Act, (January 2024):
https://ukraina.interwencjaprawna.pl/the-president-has-signed-an-amendment-to-the-special-purpose-act.
28
3. Journeys
3.1 Leaving Ukraine
In late February 2022, hundreds of thousands of people - mostly Ukrainian but also of other
nationalities - began to flee Ukraine. 96 People generally travelled distinct routes to exit the country,
depending on their location in Ukraine. This is due to Ukraine's vast territory, as well as the
difficulties and dangers of travelling within the country. 97
People in west Ukraine generally crossed the land borders regularly into Poland, Slovakia,
Hungary or north Romania, while those in the southwest and around Odesa crossed regularly into
the Republic of Moldova or east Romania. Some remained in these bordering countries, while
others continued on to other parts of Europe. 98 Some people located in east and north Ukraine,
including in occupied territories, travelled to the Russian Federation. They either remained there
or transited through Russia to regularly enter Latvia, Estonia or Finland.
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96 UNHCR, Global Trends: Forced Displacement in 2022 (United Nations publication, 2022).
97 Key informant interview 2CH-K-01 .
98 See: I0M, "Ukrainians and Third-Country Nationals Crossing Back to Ukraine - 2023 Regional Analysis," (I0M, Vienna, April 2024).
29
The majority of border crossings by people displaced from Ukraine to the EU, via Moldova to the
EU, and within the EU, are considered by the European Border and Coast Guard Agency (Frontex)
to be "legal and orderly.'' 99 Among respondents to the Survey of Arriving Migrants from Ukraine
(SAM-UKR) during April 2022 to January 2023, 21 per cent had paid someone for transportation
out of the country. 100 They paid on average €363 (US$388), though amounts ranged from €9.30
to 9,300 ($10.00-10,000). Most referred to transportation costs for exiting Ukraine and regularly
entering transit and destination countries. 101
528 Ukrainian respondents to a survey conducted in late 2022 in Switzerland provided detailed
information about their journeys. The majority (60%) experienced journeys of 3-10 days and 13
per cent travelled for 1 -2 days. For 27 per cent of respondents, the journey lasted longer than ten
days. There were no significant differences according to age or gender. Most (66%) travelled by
train, bus or plane, while 19 per cent travelled in their own car and 19 per cent availed of
transportation organized by charities and support organisations. Ukrainian men used their own
cars more commonly than Ukrainian women. One third of respondents had had to pay money or
other objects of value at some point in order to continue their journey - slightly more common for
women (35%) than men (23.5%). 102
3.2 Risks
There are some indications of risks of abuse, exploitation and trafficking in the context of
refugees' journeys, particularly during the first weeks after the full-scale invasion. Risk factors
included refugees’ determination to flee and travel onwards as quickly as possible, and the large
numbers of unregistered individuals offering help, transportation and accommodation to people
fleeing, a small minority of whom may have intended to traffic refugees. 103 The situation with
regard to risks of unregistered individuals offering transportation, as well as accommodation, has
reportedly improved since then, with some EU countries now requiring such people to register
with the authorities (see section 2.3 above on Anti-trafficking measures). 104
99 Frontex, Risk Analysis for 2022/2023, (Warsaw, 2022), p. 1 5.
100 EUAA, IOM and OECD, "Surveys of Arriving Migrants from Ukraine (SAM-UKR)", Factsheet, (2 February 2023).
101 EUAA, IOM and OECD, Forced displacement from and within Ukraine: Profiles, experiences, and aspirations of affected
populations, (October 2022). The survey was self-administered using a mobile phone and was available to respondents residing in
all EU countries, in Ukrainian, Russian and English.
102 Dirk Baier, Judith Bühler, and Andrea Barbara Hartmann, Ukrainische Flüchtlinge in der Schweiz: Ergebnisse einer Befragung zu
Fluchterfahrungen und zur Lebenssituation (Translation: Ukrainian Refugees in Switzerland: Results of a Survey on Experiences of
the Journey and Living Situations), (Zürich, Zürcher Hochschule für Angewandte Wissenschaften (ZHAW), Department Soziale
Arbeit, 2022).
103 UNODC, Conflict in Ukraine, (updated December 2022), op. cit.
104 Ibid.
30
Among 538 Ukrainians surveyed for an academic study in Switzerland in 2022, just five
respondents said that they had to pay 'helpers' for information or services (no further details
provided). 105 Six per cent had come into conflict with people supporting them in various ways
during the journey, while seven per cent had had to provide some form of non-monetary
compensation, such as labour, in order to continue their journey (no further details provided). 106
2.4 per cent experienced conflicts with the authorities or police - significantly more common for
men than for women. 107
/ have seen a lot of people travelling alone. A lot of people
really wanted to help and came with honest proposals.
But some people may offer to keep documents.
Many Ukrainians had not been to foreign countries before
and had a hard time.
Key informant from an anti-trafficking NGO interviewed in Bern in 2023 108
The journeys were particularly difficult for certain groups. Specific groups of people displaced
from Ukraine are in a more vulnerable situation, including unaccompanied and separated children;
people who were previously internally displaced within Ukraine; 109 people who cannot access
temporary protection (because they are not eligible, or due to lack of information or incorrect
information); Ukrainian Roma people due to discrimination; non-Ukrainians, including
undocumented and stateless people; elderly people; and people with mental and physical
disabilities. 110
105 The wording was: "dass auf Informationen bzw. Dienstleistungen von Helfer.innen gegen Bezahlung zurückgegriffen wurde [that
they resorted to paying for information or services from helpers]." Dirk Baier, Judith Bühler, and Andrea Barbara Hartmann,
Ukrainische Flüchtlinge in der Schweiz: Ergebnisse einer Befragung zu Fluchterfahrungen und zur Lebenssituation, (Zürich, Zürcher
Hochschule für Angewandte Wissenschaften (ZHAW), Department Soziale Arbeit, 2022), p1 1 .
106 The exact wording was: "Ich hatte Konflikte mit anderen Personen, die mich bei meiner Flucht unterstützten [I had conflicts with
other people who were helping me on my journey]" and “Ich musste eine andere Gegenleistung erbringen (z.B. Arbeiten), urn mit
meiner Flucht weiter voranzukommen [I had to provide some other form of compensation (e.g. working), in order to continue my
journey]." Baier, Bühler and Hartmann, Ukrainische Flüchtlinge in der Schweiz (2022), op. cit., p12.
107 Baier, Bühler and Hartmann, Ukrainische Flüchtlinge in der Schweiz (2022), op. cit.
108 Key informant interview 1 CH-K-1 1 .
109 EUAA, IOM and OECD, Forced displacement from and within Ukraine: Profiles, experiences, and aspirations of affected
populations, (2022). 22% of survey respondents had been internally displaced in Ukraine before they entered the EU.
110 For an analysis of vulnerabilities and resilience to trafficking as part of this project, see: MMC, Vulnerability and Resilience to
Exploitation and Trafficking among People fleeing Ukraine in Berlin, Bern and Warsaw (Geneva, MMC, 2024). See also: Suzanne Hoff
and Eefje de Voider, Preventing human trafficking of refugees from Ukraine, (La Strada International and Freedom Fund, 2022);
Europol, Early Warning Notification: War in Ukraine - refugees arriving to the EU at risk of exploitation as part of THB, (The Hague,
Ref. No. 2022-340, 2022); UNICEF, "Children fleeing war in Ukraine at heightened risk of trafficking and exploitation", press release,
(19 March 2022).
31
Many Ukrainians, including Ukrainian Roma, from Zakarpattia (Transcarpathia) oblast in western
Ukraine have dual Ukrainian and Hungarian citizenship, which reportedly on occasion led to
refusals of temporary protection as the applicants were considered Hungarian citizens. 111 Issues
with accessing temporary protection were also linked to some Ukrainian Roma people not having
identity documents. Accounts of racial discrimination against Ukrainians of Roma ethnicity were
provided by several key informants. 112
According to one key informant: "In the beginning, there were a lot oteases of racist experiences.
At the border, people who didn't 'look Ukrainian' weren't allowed to [enter an EU country]." They were
sometimes mislabelled 'fake refugees’ and prevented from travelling to seek temporary
protection. 113 Key informants indicated that Ukrainian Roma people have been prevented from
accessing collective accommodation sites, allocated segregated accommodation and given
reduced access to essential services. 114
One in five families (22%) surveyed by UNHCR in countries bordering Ukraine in 2023 had "at least
one family member with specific needs, such as disabilities and serious medical conditions", with
1 2 per cent having at least one household member with a disability. 115 Refugees with disabilities
experience challenges in accessing social welfare, healthcare, mobility aids and devices,
assistive technologies and other forms of support, as well as obstacles to having their disability
status officially recognized. 116 Services in receiving countries have struggled to respond, as it is
uncommon for elderly refugees and refugees with disabilities to make it to host countries in
Europe. 117
111 See, e.g.: Zdenék Rysavy (17 April 2022), "In Czech Republic, the Hungarian passports held by some Romani refugees from
Ukraine have not proved to be an advantage":
https://romea.cz/en/news/czech/in-czech-republic-the-hungarian-passports-held-by-some-romani-refugees-from-ukraine-have-n
ot-proved-to-be-an-advantage.
112 Melde und Informationsstelle Antiziganismus (MIA), Antiziganismus gegen ukrainische Roma geflüchtete in Deutschland
(Translation: Anti-gypsyism against Ukrainian Roma refugees in Germany), (April 2024); Key informant interviews 2DE-K-03;
2DE-K-04; 2PL-K-05
113 Key informant interview 2DE-K-04. See also: Regional Refugee Response for the Ukrainian Situation (I0M), Vulnerability to
Trafficking in persons in the context of the war in Ukraine, (2024), op. cit.
114 Key informant interviews 2DE-K-03; 2DE-K-04; 2PL-K-05; Regional Refugee Response for the Ukrainian Situation (I0M),
Vulnerability to Trafficking in persons in the context of the war in Ukraine, (2024), op. cit.
115 UNHCR, Displacement Patterns, Protection Risks and Needs of Refugees from Ukraine - Regional Protection Analysis #2, (April
2023), p. 13; See also EUAA, Displaced Ukrainians with Disabilities Seeking Temporary Protection in Europe, Situational Update
Issue No. 20 (1 8 January 2024).
116 Regional Refugee Response for the Ukrainian Situation (I0M), Vulnerability to Trafficking in persons in the context of the war in
Ukraine: The case of Poland and Romania, (2024).
117 Key informant interviews 2DE-K-07; 2CH-K-01; 2PL-K-03.
32
Many people with disabilities were stranded in Ukraine
and did not have enough money or help to leave.
[...] Some people suffered heart attacks or died presumably
because of the stress. Trains from Ukraine to Chelm, [eastern]
Poland, had up to 200 people in one train carriage. It was
difficult for people with disabilities to get on the train. It was
difficult for them to bring what they needed to support their
disability. Some people boarded the trains without their
wheelchairs, due to lack of space, and many people travelled
without their documents.
Key Informant interviewed in Bern in 2024 118
A specific form of abuse was reported, whereby Ukrainian women with disabilities were targeted
by Ukrainian men wishing to leave Ukraine. The men marry the women so that they qualify for an
exemption from martial law provisions prohibiting them from leaving the country (see next
section). Key informants referred to groups on social media where Ukrainian men post that they
wish to marry a woman with a disability and women with disabilities post asking for men to pay
them for the marriage. Key informants knew of cases where the men left the women without
resources after they had successfully left Ukraine. 119
118 Key informant interview 2CH-K-01 .
119 Key informant interviews UA-K-03; 2CH-K-01; 2CH-K-02; 2CH-K-04.
33
A Ukrainian woman's social worker asked her to marry
him so he could leave Ukraine. [...] According to the woman,
her former social worker started physically and mentally
abusing her when they arrived in Germany - not preparing food
for her and not helping her go to the toilet. The woman called
a hotline for domestic abuse in Germany and a hotline
set up by a Ukrainian disability rights activist.
Key informant interviewed in Bern in 2024 120
Among over one million non-Ukrainians from outside the EU who fled the full-scale invasion, 121
many experienced discrimination during the journey. According to a key informant, they were not
always facilitated in travelling onwards from an EU country bordering Ukraine to another EU
country. 122 This group also experienced challenges in accessing rights and services in EU
countries and difficulties obtaining and maintaining a regular residence status. 123 Two key
informants described how some Belarusians, who had refugee status in Ukraine, experienced
difficulties renewing their passports and maintaining a regular legal status in EU countries. 124
One key informant also described issues with residence permits for women from a Southeast
Asian country who fled Ukraine. 125
A Berlin Senate Regulation from August 2022 provides for the support of non-Ukrainian non-EU
citizens who were studying in Ukraine before the war and wish to continue their studies in
Berlin. 126 An organization was founded in Berlin to support such students, financially supported
by the state. 127 Berlin is also one of the German federal states that allows students to remain for
six months until they find a place to study in Berlin. 128
120 Key informant interview 2CH-K-01 .
121 IOM, Ukraine and Neighbouring Countries 2022-2024: Two Years of Response, (February 2024).
122 Key informant interview 2PL-K-02.
123 FRA, The Russian war of aggression against Ukraine - the broad fundamental rights impact in the EU: Bulletin #2, (Luxembourg,
Publications Office of the EU, 2022); Key informant interviews 1PL-K-02; 2PL-K-02; 2PL-K-05; 2DE-K-02.
124 Key informant interviews 2PL-K-02; 2PL-K-05.
125 Key informant interview 2DE-K-02.
126 Germany, Senate Department for Internal Affairs, Digitalization and Sports), Senate Bill No. S-606/2022.
127 Key informant interview 2DE-K-02.
128 Key informant interview 2DE-K-03.
34
3.3 Men exiting Ukraine
The Government of Ukraine declared martial law and general mobilization in response to the
full-scale invasion in February 2022, which have since been extended thirteen times, most
recently at the time of writing until February 2025. 129 Article 22.6 of the Mobilization Law states
that, during the period of general mobilization, all Ukrainian men aged 18-60 years must carry a
military registration document and present it at the country's borders at the request of the State
Border Guard Service (SBGS) of Ukraine. These men are not permitted to leave Ukraine unless
they qualify for an exemption. 130
Exemptions are in place for men with three or more dependent children; single fathers; men with
disabilities or health issues; men with children, spouses or parents with disabilities; carers of sick
spouses, children or parents; senior civil servants, politicians and judges; ambassadors; certain
categories of students and researchers; and relatives of people who died in combat, among
others. 131 The majority of the 391 Ukrainian men surveyed for this research gave responses that
suggest that they qualify for exemptions.
There are two main ways in which men who do not qualify for exemptions attempt to exit Ukraine,
evading the martial law provisions prohibiting their departure. They either cross Ukraine's borders
and enter another country at an unofficial land border crossing point, usually across rivers or
mountains, or they use fraudulent or fraudulently obtained documents to qualify for an exemption
and cross at an official border crossing point. Both situations may involve engagement with
criminal actors to facilitate irregular exit from Ukraine, but migrant smuggling according to
international law is only committed if a third party facilitates irregular entry to another country or
provides fraudulent travel documents for the purposes of irregular entry.
According to the UN Smuggling of Migrants Protocol, smuggling of migrants entails "the
procurement in order to obtain, directly or indirectly a financial or other material benefit, of the
illegal entry of a person into a State Party of which the person is not a national or a permanent
resident [emphasis added]." The Protocol further states that illegal entry means "crossing borders
without complying with the necessary requirements for legal entry into the receiving State" 132
129 The Ukrainian Government declared martial law and general mobilization in February 2022, and has since extended both martial
law (https://itd.rada.gov.ua/billlnfo/Bills/Card/451 1 9) and general mobilization (https://itd.rada.gov.ua/billlnfo/Bills/Card/451 20)
thirteen times, most recently at the time of writing in November 2024 for 90 days until 7 February 2025.
130 Ukraine, Law No. 44, Law of Ukraine: On Mobilization Preparation and Mobilization, (1 993), as amended. Exemptions are set out
in Articles 23-24.
131 Ibid.
132 United Nations, Protocol against the Smuggling of Migrants by Land, Sea and Air, Supplementing the United Nations Convention
against Transnational Organized Crime, (2000), Article 3.
35
During 2023, the Ukrainian SBGS detained around 1 1 ,000 Ukrainian men attempting to leave the
country in violation of the martial law provisions, according to Ukrinform KpiHCpopivi), the
Ukrainian national news agency. Around 8,000 of these men were attempting to walk or swim
across the borders with Romania, Moldova, Poland, Hungary or Slovakia outside of official border
crossings, while around 3,000 presented fraudulent documents at the border indicating that they
were exempt from the provisions prohibiting them from leaving Ukraine (mostly at the border with
Poland). 133 According to the SBGS, most of these men used "organizers". 134
While all of the men intercepted by the Ukrainian authorities were violating the provisions of
domestic Ukrainian martial law and mobilization provisions, not all Ukrainian men in this category
were attempting to irregularly enter another country. Visa-free entry to European countries and
temporary protection status also apply to Ukrainian men subject to the domestic prohibition on
departing Ukraine. This means that if Ukrainian men present themselves at an official border
crossing point with valid travel documents, then their entry into a bordering country is regular.
A significantly higher percentage of men surveyed for this research stated that they paid
someone to help them cross a border irregularly (9.7%) compared to women (3.6%). However,
some Ukrainian men surveyed may have been referring to the facilitation of irregular exit rather
than entry. Eighty-two per cent (31/38) of smuggled men surveyed were Ukrainian and almost all
the smuggled Ukrainian men (30/31 ( were aged 1 8-60 years. Forty-five per cent were aged 27-60
years, while most of the remainder were aged 1 8-26. Ukrainian men were eligible for conscription
as of 27 years old at the time of the survey, though this was lowered to 25 in April 2024. 135
133 Ukrinform, "3a Mac bíühw bmkpmjim Mauxe 400 rpyn, akí flonoMara/in yxmiflHTaM tíiotm 3a KopflOH" (Translation: During the
war, almost 400 groups who helped evaders flee abroad were exposed), 18 March 2024; Key informant interviews 2CH-K-04;
2PL-K-01. See also Regional Refugee Response for the Ukrainian Situation (I0M), Vulnerability to Trafficking in persons in the
context of the war in Ukraine: The case of Poland and Romania, (2024).
134 Ukrinform, "Ahapím fleMMeHKO, peMHMK flepxaBHoi npMKopflOHHOícnyxón" (Translation: Andriy Demchenko, spokesman of
the State Border Service" (29 April 2024):
www.ukrinform.ua/rubric-ato/3857901-andrij-demcenko-recnik-derzavnoi-prikordonnoi-sluzbi.html.
135 On Amendments to the Law of Ukraine "On Military Duty and Military Service" (Information of the Verkhovna Rada (VVR), 2024,
No. 18, Article 75): https://zakon.rada.gov.ua/laws/show/3127-IX.
36
4. Paying for Facilitation of Irregular Border Crossings
4.1 Smuggling of migrants before 2022
Few Ukrainians were identified making irregular border crossings into the EU by sea or land (less
than 100 per year) during the years prior to 2022, as Ukrainians have been able to enter the EU
visa-free since 2017. However, Ukrainians were among the top nationalities of people detected
irregularly residing and using fraudulent documents in the EU before 2022. 136 Ukrainians were the
largest group by nationality refused entry at EU borders during 201 8-2021 , comprising 40 per cent
of the total (see Figure 3). In 2022, the numbers of Ukrainians refused entry at EU borders
decreased significantly: from over 51,500 in 2021 to 28,300 in 2022. 137
Figure 3: Ukrainians refused entry at EU borders
80 000 70,313
70 000
60 000 56,004 51,512 57,576
50 000
40 000
30 000 28, 281
20 000
10 000
2018 2019 2020 2 021 2022
Source: Frontex
During 201 8-2021 , Ukrainians were the sixth largest group by nationality of people detected in the
EU with 'illegal stay’, comprising seven per cent of the total. The number of Ukrainians detected
with 'illegal stay' increased slightly in 2022, compared to 2021 (see Figure 4). 138
136 Frontex, Risk Analysis for 2022/2023, (Warsaw, 2022); Frontex, Risk Analysis for 2021, (Warsaw, 2021); European Migrant
Smuggling Centre (EMSC), 6th Annual Report, (Luxembourg, Publications Office of the EU, 2022).
137 Frontex, Risk Analysis for 2022/2023, (Warsaw, 2022); Frontex, Risk Analysis for 2023/2024, (Warsaw, 2023).
138 Frontex, Risk Analysis for 2022/2023, (Warsaw, 2022); Frontex, Risk Analysis for 2023/2024, (Warsaw, 2023).
37
Figure 4: Ukrainians identified in the EU with "illegal stay
50 000 46,012
45 000
40 000 39,759
35 000 36,299 32,099 33,668
30 000
25 000
20 000
15 000
10 000
5 000
2018 2019 2020 2021 2022
Source: Frontex
In addition to refusal of entry and illegal stay, in 2020, 2021 and 2022, Ukrainians were the largest
national group detected at an EU external border using fraudulent documents, with an increasing
140 trend in 2020 (1,258) and 2021 (3,067), followed by a decrease in 2022 (760). 139
Prior to 2022, Frontex considered Ukraine "a source and transit country of cross-border
criminality.'' 0 During the period 201 9-2022, the largest group by nationality of migrant smugglers
detected at the EU's land borders were Ukrainian, comprising 11 per cent of the total, with an
increasing trend. Ukrainians comprised five per cent of all detected migrant smugglers at the
land, sea and air borders of the EU and inland during this period. 141
139 Frontex, Risk Analysis for 2022/2023, (Warsaw, 2022); Frontex, Risk Analysis for 2023/2024, (Warsaw, 2023).
140 Frontex, Risk Analysis for 2022/2023, (Warsaw, 2022), p. 9.
141 Frontex, Risk Analysis for 2023/2024, (Warsaw, 2023).
38
Figure 5: Ukrainian migrant smugglers detected at EU borders and in the EU
780
416
244
185
2019 2020 2021 2022
Source: Frontex
According to Europol, in 2021, Ukrainians were employed by migrant smuggling groups to
navigate leisure and fishing vessels smuggling West and South Asians from Türkiye to Italy.
Smuggled people were charged up to €1 2,000 (US$1 3,000) per person. The Ukrainian sailors were
sometimes recruited through job advertisements on social media. 142 In 201 9, an organized crime
group of Ukrainians and others, who smuggled over 13,000 people to the EU using fraudulently
obtained visas based on fake employment documentation, was dismantled. During at least six
years of activity, the group had an income of over €2.3 million (US$2.5 million). 143 Ukrainians were
also involved in committing smuggling of migrants offences in South-Eastern Europe as
drivers. 144
Some Ukrainians convicted of smuggling offences abroad were subsequently considered by the
Ukrainian authorities as victims of trafficking for exploitation in forced criminal activities
(smuggling of migrants) by criminal groups. 145 Law enforcement agencies referred a number of
victims for assistance to an anti-trafficking NGO in Ukraine, after they returned from Türkiye in
early 2022, shortly before the beginning of the full-scale invasion. 146
142 EMSC, 6th Annual Report, (Luxembourg, Publications Office of the EU, 2022).
143 EMSC, 4th Annual Report, (Luxembourg, Publications Office of the EU, 2020).
144 Tihomir Bezlov, Atañas Rusev and Dardan Kogani, Borderline: Impact of the Ukraine War on Migrant Smuggling in South Eastern
Europe, Center for the Study of Democracy (CSD) and Global Initiative Against Transnational Organized Crime, (September 2023).
145 Data provided to UNODC by the Office of the Prosecutor General of Ukraine in January 2024.
146 Key informant interview UA-K-03.
39
The National Police of Ukraine (NPU), under the guidance of the Office of the Prosecutor General
(OPG), conducted investigations in seven criminal proceedings on trafficking in persons relating
to members of an organized criminal group that predate the full-scale invasion. Four defendants
were found guilty of recruiting Ukrainian men (sailors) in economically vulnerable circumstances,
with the purpose of involving them in committing migrant smuggling offences relating to people
travelling from the Middle East to the EU. A joint investigative team was formed for these cases,
with participation from Ukraine, Italy and Greece. 147
4.2 Paying for facilitation of irregular border crossings in the context of
displacement from Ukraine
In contrast to the irregular migration and smuggling of Ukrainians prior to 2022, as set out above,
the overwhelming majority of Ukrainians fleeing the country since February 2022 did not pay for
facilitation of irregular border crossings. Among 1,414 Ukrainians surveyed for this research, five
per cent (70) reported paying for services to cross borders irregularly at some point, though these
include 31 Ukrainian men who may have been exiting Ukraine irregularly rather than entering
another country irregularly, as set out above. 148 Most of these people travelled by bus, train or
private car - or a combination -, while 1 7 per cent were driven in someone else's car. Among 1 84
non-Ukrainians from outside the EU who fled Ukraine, six per cent (11) reported paying for
services to cross borders irregularly at some point; they comprised other Eastern Europeans,
West Asians and North Africans.
Overall, the respondents who answered "yes" to the survey question "Did you pay for services to
cross borders irregularly" comprised 38 men (among 391 Ukrainian and non-Ukrainian men
interviewed) and 43 women (among 1,209 Ukrainian and non-Ukrainian women interviewed),
meaning that a significantly higher percentage of men in the sample paid to cross borders
irregularly (9.7%) compared to women (3.6%).
The majority of all those who paid to cross borders irregularly (88%) were aged 18-44 years. A
higher proportion of men who paid to cross borders irregularly (55%) were aged 25-44 years old,
compared to women in this age group (37%). Many women who paid for facilitation of irregular
border crossing were younger, in the 1 8-24 years old age group (47%). 59 per cent of respondents
who had paid for facilitation of irregular border crossing began their journey within the first two
months of the outbreak of the conflict, compared to 53 per cent among all respondents.
147 Information provided to UNODC by the Office of the Prosecutor General of Ukraine in January 2024.
148 See MMC, Displaced from Ukraine to Berlin: A case study on journeys, living conditions, livelihoods and future intentions, 20 June
2023; MMC, Displaced from Ukraine to Warsaw: A case study on journeys, living conditions, livelihoods and future intentions, (29
June 2023).
40
Figure 6: Experiences of paying for facilitation of irregular border
crossing among respondents surveyed in Berlin, Warsaw and Bern in 2023
of U5kr%ainia ns 3.6%
surveyed of women surveyed
6% 9.7% of non-Ukrainians
from outside the EU People paying of men surveyed
for fací htation
of irregular border
crossing from Ukraine
since 2022
Majority aged 18-24 42% 12% experienced
or 25-44 or witnessed abuses
46%
Source: Based on survey of 1 ,602 people who fled Ukraine for this study in 2023 in Berlin, Warsaw and Bern
A higher proportion of people who paid for facilitation of irregular border crossing experienced
abuses compared to those who did not. Just over 12 per cent of people surveyed who paid for
facilitation of irregular border crossing reported directly experiencing or witnessing some form of
abuse during their journey, compared to six per cent among the total sample. These experiences
included not being paid for work, being paid less than promised, being threatened with
deportation, being deceived, restrained or locked up and having identity documents withheld by
an employer.
Two key informants in Ukraine - from a state authority and from an NGO - interviewed in 2024,
mentioned the recruitment of children as guides to assist in facilitating irregular border crossings
at the Ukrainian land borders. The children are reportedly paid small sums for this service, with
their parents' knowledge, as children can avoid criminal prosecution. 149 No other information was
found to corroborate these reports.
Across the EU in 2022, cases were reported involving the use of fraudulent Ukrainian documents,
including identity cards, driving licenses, passports and residence permits, by non-Ukrainians, in
order to enter EU countries and access temporary protection status. However, it is not clear
whether third parties facilitating the provision of the documents were involved. 150 Individual
respondents to the SAM-UKR survey in 2022 indicated corruption and fraudulent activity in the
temporary protection application procedure, through intermediaries advertising their services
online. 151
149 Key informant interviews UA-K-03; UA-K-04.
150 Content analysis of Europol Monitoring Team Reports (EPMT) March - November 2022. Europol Unclassified - Basic
Protection Level; Frontex, Risk Analysis for 2023/2024, (Warsaw, 2023).
151 EUAA, I0M and OECD, Forced displacement from and within Ukraine: Profiles, experiences, and aspirations of affected
populations, (October 2022).
41
The low level of smuggling of migrants in the context of the cross-border displacement of over six
and a half million people contrasts starkly with the situation of other refugee groups in Europe,
from the Middle East, Africa and Asia. The combination of visa-free entry to other European
countries and rapid access to temporary protection has massively prevented smuggling of
migrants related to the war in Ukraine.
4.3 Paying for facilitation of irregular border crossings by Ukrainian men
Clandestine border crossings
During the period January 2022 to December 2024, 24,496 Ukrainians - almost all Ukrainian adult
men - were detected making an "illegal border crossing" at Ukrainian borders with EU countries,
according to Frontex. This is compared to 191 Ukrainians identified making such a crossing
during the period 2019-2021. There was a significant acceleration in numbers in 2024, when
Frontex recorded 14,232 irregular border crossings by Ukrainians at the Eastern Land Borders of
the EU - almost triple the figure for 2023. 152
Figure 7: Detections of Irregular Border Crossings by Ukrainians
into the EU at the Eastern Land Borders*
16 000
14,232
14 000
12 000
10 000
8 000
6 000 5,134 5,130
4 000
2 000
69 58 64
0
2018 2019 2020 2021 2022 2023 2024 2025
Sources: UNODC calculations based on Frontex data.
*'Eastern Land Borders' refers to the approximately 6,000 kilometres of land borders between
Belarus, Moldova, Ukraine and the Russian Federation, and the eastern EU countries - Estonia,
Finland, Hungary, Latvia, Lithuania, Poland, Slovakia and Romania.
152 Frontex, Risk Analysis for 2022/2023, (Warsaw, 2022); Frontex, Risk Analysis for 2023/2024, (Warsaw, 2023); Frontex, Migra
tory Routes", www.frontex.europa.eu/what-we-do/monitoring-and-risk-analysis/migratory-routes/migratory-routes; Frontex, "Mo
nitoring and risk analysis", www.frontex.europa.eu/what-we-do/monitoring-and-risk-analysis/migratory-map, (accessed 14
January 2025).
42
Article 332 of the Ukrainian Criminal Code criminalizes: “Illegal movement of persons across the
state border of Ukraine, organisation of illegal transportation of persons across the state border of
Ukraine, management of such actions or assistance in their commission by advice, instructions,
provision of means or elimination of obstacles" Dangerous conditions, moving several people,
acting as a group and offending by a public official are all considered aggravating
circumstances. 153 Offences falling under this provision that involve facilitating the illegal
departure of Ukrainian men from Ukraine in violation of martial law provisions would constitute
smuggling of migrants according to international law (Smuggling of Migrants Protocol) only if
they also involve facilitation of illegal entry into another state, for a financial or other material
benefit.
Under Article 332 on "Illegal movement of persons across the state border of Ukraine," 343
proceedings were processed by first-tier courts in Ukraine in 2022, and 580 in 2023, compared to
96 in 2021 . 1 53 people were convicted under these provisions in 2022 and 268 in 2023. Between
January and May 2024, 1 61 criminal proceedings were initiated against 51 9 people under Article
332, according to the National Police of Ukraine (NPU). 154
Ukrainian criminal networks are reported to be involved in facilitating the irregular exit of men
from Ukraine in return for a payment. 155 Law enforcement officers in Ukraine had identified
around 450 groups assisting men to illegally exit Ukraine outside of official border crossing points
for money as of April 2024, according to the SBGS cited in a Ukrinform article. 156 The modus
operandi involves identification of clients, who are then taken in groups of between three and 20
people to a pre-arranged location near the land border. They are then escorted across the border
or given directions. 157 If the border is along a river, men may be transported by boat or given
wetsuits. 158 Some current and former employees of state law enforcement authorities have been
involved in committing these offences. 159
153 Criminal Code of Ukraine (Document 2341-111, valid, current version — Revision on September 7, 2024, on the basis - 3902-IX):
https://zakon.rada.gov.ua/laws/show/2341 -1 4.
154 Ukraine, Court Statistics website, https://court.gov.ua/inshe/sudova_statystyka.
155 Tihomir Bezlov, Atañas Rusev and Dardan Kogani, Borderline: Impact of the Ukraine War on Migrant Smuggling in South Eastern
Europe, Center for the Study of Democracy (CSD) and Global Initiative Against Transnational Organized Crime (September 2023),
p. 1 0.
156 Ukrinform, "AHflpiw fleivNeHKo, peMHUK flepxaBHoí npuKopflOHHoi'cnyxón" (Translation: Andriy Demchenko, spokesman of
the State Border Service" (29 April 2024):
www.ukrinform.ua/rubric-ato/3857901-andrij-demcenko-recnik-derzavnoi-prikordonnoi-sluzbi.html.
157 National Police of Ukraine, "U Chernivetskii oblasti vykryto orhanizovanu zlochynnu hrupu, yaka nalahodyla masshtabnyi kanal
perepravlennia ukhyliantiv do Moldovy" Press Release in a telegram group, (20 November 2023):
https://t.me/UA_National_Police/16089.
158 National Police of Ukraine, "6000 dolariv SShA za nezakonnyi peretyn kordonu: stolychni politseiski zneshkodyly zlochynnu
skhemu" Press Release in a telegram group, (27 October 2023): https://t.me/UA_National_Police/1 5502.
159 Ukraine, DBR, "Na Lvivshchyni sudytymut uchasnykiv zlochynnoi hrupy, yaka perepravliala viiskovozoboviazanykh za kordon",
press release, (3 October 2022):
https://dbr.gov.ua/news/na-lvivshhini-suditimut-uchasnikiv-zlochinnoi-grupi-yaka-perepravlyala-vijskovozobovyazanih-za-kordon
1 . For example, see: Ukraine, DBR, "DBR vykrylo pravookhorontsia, yakyi orhanizuvav kanal perepravlennia ukhyliantiv do
Rumunii", press release, (9 August 2024):
https://dbr.gov.ua/news/dbr-vikrilo-pravoohoroncya-yakij-organizuvav-kanal-perepravlennya-uhilyantiv-do-rumunii.
43
One case, identified by the NPU in February 2024, involved a criminal actor smuggling men to
Moldova across the river Dniester in Vinnytsia oblast (central Ukraine) by taxi and then by boat for
the equivalent of US$8,000. Across the border in Moldova, other members of the group met them
and provided safe escort. 160 An unknown number of men in this category managed to exit Ukraine
without being intercepted. Between February 2022 and April 2023, at least 30 men died trying to
exit Ukraine irregularly, mostly while crossing the Tizsa river (also Tysa, Tisa, which runs along
Ukraine's borders with Romania and Hungary), according to the Ukrainian State Border Guard
Service (SBGS). 161
Ukrainian men swim across the river, and very often
at the railway station you see them in diving suits.
They put something on top, but you can still
see these diving tights. They ask for food...
Key informant cited by IOM (2024) 162
The fees for this type of activity vary. According to the Security Service of Ukraine, fees for
facilitating the irregular exit of men out of the country range between US$3,000 and $10, 000. 163
According to a key informant in Bern, Switzerland, who works with Ukrainian refugees, at the
beginning of the war it cost around $5,000-1 0,000 for men to cross the border out of Ukraine with
a smuggler. 164 According to key informants in Warsaw, Poland, some men try multiple times to
cross the border from Ukraine and they pay for each attempt. They cited fees ranging from $2,000
to $3,000, depending on the country of final destination in the EU. 165 A Ukrainian woman
interviewed in Switzerland estimated that it cost around $1,000-3,000 for men to cross the
Ukraine-Hungary border through the forest. 166
160 National Police of Ukraine, "U Kyievi operatyvnyky zatrymaly cholovika, nablyzhenoho do kryminalnoho avtoryteta
«Lavasohly-Batumskoho»" Press Release in a telegram group, (23 February 2023): https://t.me/UA_National_Police/19235.
161 Ukrinform, "Ah pím fleMMeHKO, peMHMK flepxoBHoi npuKopflOHHoí cny>K6n" (Translation: Andriy Demchenko, spokesman of
the State Border Service" (29 April 2024):
www.ukrinform.ua/rubric-ato/3857901-andrij-demcenko-recnik-derzavnoi-prikordonnoi-sluzbi.html.
162 Regional Refugee Response for the Ukrainian Situation (IOM), Vulnerability to Trafficking in persons in the context of the war in
Ukraine: The case of Poland and Romania, (2024), p34.
163 Ukrinform, "3a Mac bíühm Bi/iKpunn Maüxe 400 rpyn, ak¡ flonoMarann yxmisHTaM tíiotm sa KopflOH" (Translation: During the
war, almost 400 groups who helped evaders flee abroad were exposed), 1 8 March 2024.
164 Key informant interview 2CH-K-04.
165 Key informant interview 2PL-K-03.
166 Key informant interview 2CH-K-03.
44
Forged/fraudulent documents and corruption
The Ukrainian National Anti-Corruption Prevention agency (NACP) conducted an analysis of
corruption risks in the activities of Army military medical commissions, commissioned by a
Presidential Decree in September 2023. One of the key risks identified was "involvement of
military enlistment commission officials in corrupt schemes of illegal transportation of men of
military age across the state border of Ukraine"™ 7
The NACP developed and submitted to the Ukrainian Government in August 2023 an "Action Plan
for Eliminating Corruption Risks when Ukrainian Citizens Travel Abroad under Martial Law."
According to the head of the NACR thousands of criminal proceedings have been opened in
167 Ukraine in relation to illegal border crossings by men. 168 The NACP's research, presented in
October 2022, identified eight 'illegal and semi-legal' schemes, including men departing "through
the Shlyach system as a driver or second driver, fictitious documents with information on the
removal of conscripts from the military register, letters from state authorities to the State Border
Guard Service, illegal benefits to the officials involved, etc." 169
The SBGS detected around 3,300 forged documents being used by men intending to exit Ukraine
during 2023. 170 This is slightly less than the 3,800 documents (mostly forged certificates of
clearance by a military medical commission) identified in 2022. 171 In these cases, smuggling of
migrants would only be constituted in cases where forged or fraudulent travel or ID documents
are provided by a third party in return for a fee, with the purpose of facilitating irregular entry to
another country.
The SBGS reports that from February to October 2022, around 245 attempts to bribe border
guards were recorded, during which officials refused illegal benefits totalling over UAH3.8 million
($91, 600). 172 A Ukrainian woman interviewed for this research in Switzerland estimated the cost
of obtaining fraudulent documents for men to leave the country at around $2, 000-4, 000. 173
167 National Agency on Corruption Prevention (NACP), "NACP proposes measures to minimize corruption risks in the Military
medical commissions", (27 December 2023).
168 NACR "Following NSDC meeting, NACP submits plan to eliminate corruption risks while traveling abroad during war to the
Government", (11 August 2023).
169 NACR "Departure from Ukraine abroad under martial law: how to eliminate corruption. The NACP presented the research", (26
October 2022), https://nazk.gov.ua/en/news/74914/. The "Shlyach" system allows for Ukrainian men to travel abroad in order to
transport humanitarian aid or cargo for the Ukrainian Army. SBGS is cited in a media article as recording 192,500 Ukrainians
departing the country under the Shlyach system up to April 2023, of whom 19,000 did not return. Ihor Serov, "Cherez systemu
"Shliakh" vtekly za kordon i ne povernulysia maizhe 1 9 tysiach cholovikiv: nazvano seredniu vartist khabaria", TSN, (27 June 2023):
https://tsn.Ua/exclusive/vtekli-za-kordon-ta-ne-povernulis-mayzhe-19-tis-cholovikiv-nazvano-serednyu-vartist-habarya-2357881.h
tml. See also: NPU, "Holova DSR Andrii Rubel: Levova chastka shakhraiv na temi viiny - areshtanty SIZO i uviazneni", (4 June
2024): www.npu.gov.ua/news/holova-dsr-andrii-rubel-levova-chastka-shakhraiv-na-temi-viiny-areshtanty-sizo-i-uviazneni.
170 Ukraine Media Center (government-supported media platform), "In 2023, border guards uncover 3,300 forged documents used
by individuals to cross the border - state border guard service", (18 January 2024); Key informant interview 2CH-K-04.
171 Ministry of Internal Affairs of Ukraine, "Mai/ixe 3,8 tmcamí niflpoójiem/ix flOKyMeHTÍB 3 nonaTKy bochhofo CTany npMKopflOHHMkm
BMABunn b nyHKTax nponycky" (Translation: Since the beginning of martial law, border guards have found almost 3.8 thousand
forged documents at checkpoints), (13 January 2023).
172 NACR "Departure from Ukraine abroad under martial law: how to eliminate corruption. The NACP presented the research", (26
October 2022), https://nazk.gov.ua/en/news/74914/.
173 Key informant interview 2CH-K-03.
45
5. Trafficking in Persons
5.1 Internal trafficking in Ukraine
Trafficking in persons is criminalized under Article 149 of the Ukrainian Criminal Code. In 2022,
the Office of the Prosecutor General (OPG) of Ukraine set up a specialized unit for the
investigation and prosecution of trafficking in persons cases and, in 2023, a coordination centre
for the support of victims and witnesses. Ukraine's interdepartmental working group on
trafficking in persons met twice during 2023. The Government adopted a State Social Programme
on combating trafficking in persons for the period up to 2025, covering prevention, detection, and
protection and assistance of victims. Ukraine has 217 investigators and 212 prosecutors
specialized in trafficking in persons cases. 174 Further measures on international cooperation and
on access to passports for Ukrainians abroad are detailed in the Annex to this study.
Some positive developments took place, such that now
every community and every district must have an [anti-trafficking]
coordination council and an action plan. This is on the positive
side. Well, every stick has two ends... (
Key informant from an anti-trafficking NGO in Ukraine, 2024 175
The same key informant from an NGO in Ukraine indicated that the conflict precipitated increased
focus on anti-trafficking and described, for example, how the district [raion/paüoi-i] coordination
council in which she participates held around 30 working meetings during the period May 2023 to
March 2024, identifying 12 potential cases of exploitation. 176 During the course of 2022-2024,
various actors in Ukraine implemented information campaigns to prevent trafficking and promote
safe migration in the context of the mass displacement. 177
174 Data provided to UNODC by the Office of the Prosecutor General of Ukraine in November 2023.
175 Key informant interview UA-K-02.
176 Key informant interview UA-K-02. Since 2020, Ukraine has been divided into 136 districts (panoww), the second-level
administrative subdivision after oblasts (od/iacn).
177 Key informant interview UA-K-03.
46
The ongoing conflict, however, presents obstacles for the anti-trafficking response, including
challenges in recruiting and maintaining staffing for dedicated anti-trafficking organizations and
other anti-trafficking stakeholders, and de-prioritization of anti-trafficking due to other concerns.
This leads, according to one key informant in Ukraine, to a higher number of potential trafficking
victims being identified by NGOs than people officially designated victims by the authorities. 178
According to another key informant in Ukraine, efforts to combat child trafficking and child
abduction have also been redirected due to the conflict. 179
Furthermore, key informants consider that wartime conditions and the difficulty for
victim-witnesses of travelling repeatedly to participate in court proceedings, combined with the
likelihood of receiving low or no compensation, is likely to result in low levels of cooperation in
court proceedings and lower sentences or lack of convictions of offenders. 180
Indeed, since February 2022, the Ukrainian authorities identified fewer cases of trafficking in
persons and fewer victims of trafficking compared to previous years, as shown in Figure 8.
Figure 8: Trafficking in persons (TIP) cases and victims identified
by the authorities in Ukraine, 2020-2023
250
232
200
150
100
50
2020 2021 2022 2023
TIP cases investigated TIP victims identified
Source: Office of the Prosecutor General (OPG) of Ukraine
178 Ibid.
179 Key informant interview UA-K-04.
180 Key informant interview UA-K-03.
47
The trafficking in persons criminal offences investigated in Ukraine during 2022-2023 involved
labour exploitation (49%); sexual exploitation (29%); forced criminal activities (21%); and
exploitation in pornography (1%). This marked an increase in the proportion of cases of labour
exploitation and forced criminal activities - and a decrease in the proportion of cases of sexual
exploitation and exploitation in pornography. In 2020-2021, the forms of trafficking investigated
were labour exploitation (38%); sexual exploitation (42%); forced criminal activities (13%);
exploitation in pornography (6%), and other forms (removal of organs and exploitation in armed
conflict, less than 1%). 181 According to the OPG, the majority of the offences recorded were
committed by individuals acting alone. 182
The cases of trafficking for forced criminal activities involved Ukrainian victims committing drug
trafficking offences (as 'couriers') and migrant smuggling offences (as 'sailors') as a result of
being trafficked, outside of Ukraine. 183
Victims of trafficking identified in Ukraine during the period 2020-2021 comprise 55.5 per cent
men, 36 per cent women and 8.5 per cent children. 184 In those years, the COVID-19 pandemic
significantly reduced capacities to identify victims of trafficking globally. A larger proportion of
women victims of trafficking were identified in Ukraine during the period 2022-2023: 43 per cent
women, 37 per cent men and 20 per cent children. An additional 22 cases of child trafficking were
identified during 2022-2023. 185
While the figures above relate to criminal investigations of trafficking in persons, for victim
protection and assistance, the National Social Service of Ukraine assigned the status of victim of
trafficking to 47 people in 2022, 1 1 8 people in 2023, and 43 people in the first quarter of 2024. The
118 victims in 2023 had mostly been trafficked for exploitation in armed conflict (55), forced
labour (22), forced criminal activities (1 7) and sexual exploitation (1 1 ). 186
The International Organization for Migration (IOM) assisted 374 victims of trafficking in Ukraine
in 2023, 23 per cent of whom were internally displaced people (IDPs). 187 of these victims had
been trafficked in 2022 (140) and 2023 (47). They comprised 61 per cent males and 39 per cent
females, trafficked mainly for labour exploitation (83%), as well as sexual exploitation (9%), forced
criminal activities (3%), exploitation in armed conflict, servitude and forced begging. 187 While
most of the 187 victims in 2022-2023 were trafficked within Ukraine (149), 20 were trafficked to
Poland and a further eleven to other countries (Italy, Germany, Tiirkiye, Spain and Czechia). 188 IOM
supported an additional 450 people in 2023 who had experienced "forced labour without the
signs of human trafficking" since February 2022. 189
181 Data provided to UNODC by the Office of the Prosecutor General of Ukraine in November 2024.
182 Data provided to UNODC by the Office of the Prosecutor General of Ukraine in November 2023.
183 Data provided to UNODC by the Office of the Prosecutor General of Ukraine in November 2023. Also mentioned in key informant
interview UA-K-01 .
184 Data provided to UNODC by the Office of the Prosecutor General of Ukraine in November 2023.
185 Data provided to UNODC by the Office of the Prosecutor General of Ukraine in November 2023.
186 Ukraine, Ministry of Social Policy, "Ukraintsi staly chastishe zvertatysia za dopomohoiu u vypadkakh, koly postrazhdaly vid
torhivli liudmy", press release, 1 May 2024: www.msp.gov.ua/news/23691.html; key informant interview UA-K-05.
187 IOM Ukraine. "Trafficking In Persons: IOM Ukraine Caseload (January-December 2023)," (2024).
188 Ibid.
189 The figures for victims of labour exploitation likely include cases in territories under Russian occupation: IOM Ukraine,
"Trafficking in Persons: IOM Ukraine Caseload (January-December 2023)", (Kyiv, IOM Ukraine, 2024); key informant interview
UA-K-03.
48
As regards prosecution, during 2022 and 2023, the Ukrainian authorities dismantled eight
organized crime groups committing trafficking in persons, consisting of a total of 31 people, who
committed a total of 75 offences, involving 103 victims (70 men and 33 women). Five of the
groups were involved in trafficking for labour exploitation and three in trafficking for forced
criminal activities, while none were involved in trafficking for sexual exploitation. 190
At least eight cases of trafficking for forced labour were heard in Ukrainian courts since 24
February 2022, involving treatment centres for people with substance use disorders or other
forms of dependency and shelters for homeless people. These residential centres brokered
service-users' labour to local businesses, often using charitable organizations as a front. 191 One
case of trafficking for forced labour (see Case Study 5 in chapter 7) involved a woman and man
residing at an accommodation centre for IDPs, working in agriculture. 192
Internally displaced adults and children are considered vulnerable to trafficking by key informants
in Ukraine, 193 particularly to forced labour. 194 According to one key informant, recruitment of
internally displaced adults for trafficking usually involves abuse of a position of vulnerability (as
the "means" element of the trafficking offence) and takes place through acquaintances or
online. 195 Increased rent in safe regions and inflation as a result of the conflict may have further
exacerbated IDPs’ vulnerability. 196
Court Case - Trafficking for Forced Labour, 2024
A court case on trafficking for forced labour in Ukraine involved an organized criminal group led
by an active military serviceman, with four accomplices, operating during 2022-2024 in Dnipro
oblast in eastern Ukraine. At transport stops, the trafficking group recruited IDPs and other
disadvantaged Ukrainians without a permanent residence for forced labour in unpaid agricultural
and construction work, street cleaning and at fresh produce warehouses. The group, under the
guise of a charity, promised victims free accommodation, food and paid employment. They then
confiscated victims' mobile phones and closely monitored them, using psychological pressure
and threats of physical violence. The traffickers coordinated their activities through group chats
on a messaging app, where they shared photos of victims. On 27 May 2024, a District Court in
Dnipropetrovsk delivered a guilty verdict. 197
190 Data provided to UNODC by the Office of the Prosecutor General of Ukraine in November 2023.
191 A search of all decisions in the https://reyestr.court.gov.ua database for the period 24.02.2022-18.06.2024 was carried out
using the following search term: 'ct. 149 KK YKpaTHM peaóiJiiTapiMHMLÍ pemp TopriBna nroflbMn', producing 35 decisions
pertaining to eight distinct criminal cases.
192 The account is based on key informant interview UA-K-02; as well as on court records for criminal case no.
1 2023140000001 007 from 1 September 2023. See the original indictment in: Ukraine, Halych District Court in Lviv City, case no.
461/9758/23, (20 November 2023): https://reyestr.court.gov.ua/Review/115023810.
193 Key informant interviews UA-K-03; UA-K-04; UA-K-05.
194 Key informant interview UA-K-04.
195 Key informant interviews UA-K-03; UA-K-05.
196 Key informant interview UA-K-05.
197 Ukraine, Amur-Nyzhnodniprovskyi District Court in Dnipro, Case Nr. 1 99/2273/24. Court decision of 27 May 2024:
https://reyestr.court.gov.Ua/Review/1 19309319; and on group members, of 22 March 2024:
https://reyestr.court.gov.ua/Review/117841193; Ukraine, OPG, "Verbuvaly ta utrymuvaly v trudovomu rabstvi 50 liudei - u Dnipri
zatrymano hrupu osib" (1 1 January 2024):
www.gp.gov.ua/ua/posts/verbuvali-ta-utrimuvali-v-trudovomu-rabstvi-50-lyudei-u-dnipri-zatrimano-grupu-osib.
49
A key informant from an NGO in western Ukraine had received information mostly on internal
trafficking for forced labour since February 2022, but also for sexual exploitation and for
exploitation in armed conflict at the frontlines. 198 According to another key informant from an
NGO in Ukraine, internal trafficking increased due to the impacts of the conflict. This is partly due
to interruptions in the provision of essential services, including social services. 199
In 2023, the OPG sent an indictment to court against a Ukrainian woman who handed over her
children to a 50-year-old man for sexual exploitation, and a man who recruited two children for
sexual exploitation was sentenced to 9 and a half years in prison. 200 A recent development
highlighted by another key informant from an NGO in Ukraine is the increased incidence of online
sexual exploitation of women using webcams, with the women also being sexually exploited
physically, particularly in southern Ukraine. 201
According to a key informant from a state authority, low levels of child trafficking were recorded
in Ukraine prior to 2022. In 201 9, 50 cases were recorded of children involved in criminal activities
and begging, and seven of child trafficking. Criminal gangs used children as pickpockets and
forced them to join the gangs through intimidation and physical violence; in 2020, this indicator
dropped to zero. 202
Orphaned children are particularly vulnerable to trafficking in the context of the war. One potential
trafficking case described by a key informant from a Ukrainian NGO involved a teenage girl who
had been orphaned, whose employer refused to pay her wages. The key informant considered
that the employer was abusing her position of vulnerability as an orphan lacking a support
network. 203
198 Key informant interview UA-K-02.
199 Key informant interview UA-K-03.
200 Data provided to UNODC by the Office of the Prosecutor General of Ukraine in November 2023.
201 Key informant interview UA-K-03.
202 Key informant interview UA-K-04.
203 Key informant interview UA-K-03.
50
5.2 Incidence of cross-border trafficking of people who fled Ukraine
Based on a comprehensive analysis of the primary and secondary sources for this study,
detections of cases of trafficking in persons involving people who fled Ukraine have increased in
European countries. Data on trafficking in persons cases provided to UNODC by countries hosting
Ukrainian refugees indicate the number of Ukrainians identified as victims of trafficking in
persons in 2022. The numbers of Ukrainians recorded as victims of trafficking increased in 2022
compared to the years before the full-scale invasion. This increase took place in a context where
the numbers of Ukrainians residing in the EU and the rest of Europe has massively increased since
early 2022. In 2021 , Ukrainians comprised 0.35% of the entire EU population; by the end of 2022,
they comprised 1 .24%. 204
This section presents indications of the prevalence of trafficking across Europe among people
who fled Ukraine since early 2022, with a specific focus on the countries under study: Germany,
Poland and Switzerland. The indications of a relatively low prevalence of trafficking in persons
may be due to the fact that it takes time for cases of trafficking to be identified and recorded by
national authorities. It may also be because of underreporting for a variety of reasons, challenges
in detecting trafficking, lack of understanding of available legal frameworks and remedies by
criminal justice actors and stigma attached to being a victim of trafficking, factors that may be
particularly relevant in trafficking for sexual exploitation. The 2022 data may not, therefore, reflect
the full extent of trafficking committed in that year. Most official data on trafficking for 2023 and
2024 was not yet available at the time of writing.
These low figures nonetheless offer a tentative indication that the incidence of trafficking among
Ukrainians is limited, and that visa-free travel and temporary protection (as analysed in section
2.2 above) and massive prevention of smuggling of migrants (section 4.1 above), together with
extensive anti-trafficking measures (section 2.3 above), have effectively mitigated the risks of
trafficking in persons in this context. 205
204 Calculations based on: Eurostat, "Population and population change statistics", (6 July 2024), (accessed 9 August 2024).
205 Ella Cockbain and Aiden Sidebottom, The war in Ukraine and associated risks of human trafficking and exploitation: Insights from
an evidence-gathering round table, (April 2022).
51
Figure 9: Ukrainian victims of trafficking identified globally, 2019-2022
455
152
89
74
2019 2020 2021 2022
Source: UNODC elaboration based on national data - GLOTIP Database
According to data submitted by Member States to UNODC, during 2019-2021, a total of 315
Ukrainian victims of trafficking were identified globally, 1 39 (44%) of them in EU countries. During
the first year after the full-scale invasion, 455 Ukrainian victims of trafficking were recorded
around the world, 402 (88%) of them in EU countries and a further 33 (7%) in the UK.
In 2022, the first year of the large-scale displacement from Ukraine, 402 Ukrainian victims of
trafficking were identified across EU Member States, comprising 206 women, 1 92 men and four
people of unidentified gender. For comparison, 65 Ukrainian victims were identified in the EU in
2021, 38 in 2020 and 36 in 2019. The majority of the Ukrainian victims recorded in 2022 are adults
trafficked for forced labour. Most were identified in Germany (184), the Netherlands (51), France
(48), Estonia (31), Luxembourg (18) and Poland (17). In 2021, most Ukrainian victims were
identified in Germany (18), Belgium (14), Estonia (11), France (8) and Poland (5) (see Figure 10
below). 53 Ukrainian victims were identified in 2022 outside of the EU: 33 in the UK and the
remainder in Israel and Türkiye.
52
Figure 1 0: Number of Ukrainian victims of trafficking identified
in the EU, 2021 vs. 2022
200
180
160 .
140
120
100
80
60- ■
40 .
20
0-
184
48 51
31
11 18 18 17
12- -14 11 — 8 - 11
d 2,
2021 2022
Source: UNODC elaboration based on national data - GLOTIP Database Figures for Czechia in 2022 not available
Poland
277 potential victims of trafficking were recorded by the Polish National Public Prosecutor's
Office in 2022, of whom 180 were from outside the EU. The non-EU victims comprised mostly
Latin Americans, as well as 17 Ukrainians trafficked for forced labour or services. 206 Fourteen
Ukrainian victims were assisted by the Polish National Intervention and Consultation Centre
(NICC) for victims of human trafficking in 2022, of a total of 254 people assisted. 207
The Polish Government's Human Trafficking Report for 2022 includes data from various sources.
Polish National Police data indicate that in 2022, 31 potential victims of human trafficking of all
nationalities were identified in 20 proceedings, with 15 people charged (under Article 189a,
sections 1-2 of the Polish Penal Code). The potential victims comprised 19 women and 12 men.
While 11 were Polish citizens, nine were Ukrainian and 11 were from other countries. 13 people
were exploited in forced labour or services, 12 in prostitution or pornography (sexual abuse
material), three in begging and three in other forms of exploitation. 208 In 2022, a decision was
issued to file criminal charges for trafficking in persons under Article 1 89a, section 1 of the Penal
Code against one Ukrainian citizen who exploited people in begging, which was unrelated to the
war in Ukraine. 209
206 Eurostat, Annual Report on Migration and Asylum 2022 Statistical Annex, (Luxembourg, Publications Office of the European
Union, 2023); Ministry of the Interior and Administration Republic of Poland, Human Trafficking Report: Human trafficking is a crime
2022, (2023).
207 Ministry of the Interior and Administration Republic of Poland, Human Trafficking Report, (2023).
208 Ibid.
209 Information provided to UNODC by Permanent Mission of Poland to the United Nations Office and the International
Organisations in Vienna on 31 October 2024.
53
In the course of its official activities in 2022, the Polish Border Guard (PBG) identified 110
potential victims of trafficking, 58 in 2023 and 66 in 2024 (as of 24 October 2024). The identified
victims are mainly people from Latin American countries trafficked for forced labour. In 2022,
among the identified victims was one Ukrainian citizen exploited in domestic servitude, unrelated
to the war in Ukraine. 210
The PBG has not identified any potential victims of trafficking among those fleeing Ukraine since
early 2022. Due to the suspension of voluntary returns to Ukraine by IOM, no Ukrainian citizens
were returned from Poland to their country of origin under the Programme for Support and
Protection of Victims-Witnesses of Human Trafficking in 2022. The PBG investigated a case in
2022 involving forced labour of Ukrainian and Moldovan citizens. 211 The relevant proceedings had
been initiated in 2020 and are unrelated to the full-scale invasion of Ukraine. 212
The Polish National Police reports additional cases of potential trafficking in persons in
2023-2024 involving Ukrainian refugees. One case, identified in 2023, involved two Ukrainian girls,
both aged 17 years old, who fled to Poland in early 2022, and were sexually exploited in
prostitution. 213 Another case identified in May 2024 involved the exploitation of a 43-year-old
Ukrainian woman and her 10-year-old son in forced labour on a farm in Poland. The perpetrators
also took the benefits the Ukrainian family were entitled to as refugees. 214
A number of cases of Ukrainians exploited in illegal cigarette factories have been identified in
recent years in EU countries, including Poland, Spain and Italy, both prior to and since February
2022. 215 Cigarette trafficking in Eastern Europe and the EU, and illicit cigarette production in
Ukraine, have shifted in response to the war and the obstacles at seaports, with production
moving to EU countries. 216
210 Ibid.
211 Ministry of the Interior and Administration Republic of Poland, Human Trafficking Report: Human trafficking is a crime 2022,
(2023).
212 Information provided to UNODC by Permanent Mission of Poland to the United Nations Office and the International
Organisations in Vienna on 31 October 2024.
213 Group of Experts on Action against Trafficking in Human Beings (GRETA), Evaluation Report Poland: Third evaluation round:
Access to justice and effective remedies for victims of trafficking in human beings, (June 2023).
214 Information provided to UNODC by Permanent Mission of Poland to the United Nations Office and the International
Organisations in Vienna on 31 October 2024.
215 For example, see ANSA, "Italy: Ukraine refugees exploited in counterfeit cigarette plant", InfoMigrants, (1 8 April 2022).
216 Yulia Krylova, "The Impact of Russia's Full-Scale Invasion on Illicit Cigarette Trafficking from Ukraine to the European Union",
Journal of Illicit Economies and Development, vol. 6, no. 2 (2024), pp.1 -1 8.
54
Germany
Figure 1 1 : Net Immigration of Ukrainians to Germany, 201 9-2023
1 000 000 960,000
900 000
800 000
700 000
600 000
500 000
400 000
300 000
200 000 121,000
100 000
50 000
7,000 5,000 6,000
0
2019 2020 2021 2022 2023
Source: Germany, Federal Statistical Office
184 Ukrainian victims of trafficking were recorded in Germany in 2022, compared to 1 8 in 2021 .
However, at least 101 of the victims recorded in 2022 were in fact trafficked prior to 2022 (see
Trafficking for forced labour case in section 5.3 below), with the investigation completed and
referred to the prosecutor in 2022. The German statistics on trafficking in persons are based on
the number of investigations completed and referred to the relevant public prosecutor's office
during 2022 by the Criminal Police Offices of the Lander, the Federal Criminal Office (BKA), the
Federal Police and the Financial Control of Undeclared Work Unit of the Customs Administration.
The statistical data on victims do not provide information on whether a prosecutor has brought
charges or on the outcome of pending court proceedings. 217
These numbers should also be qualified by the fact that during the period 2022-2023, the
Ukrainian population in Germany increased more than eight-fold. At the end of 2021, there were
138,000 Ukrainians residing in Germany, comprising 0.2 per cent of the country's population; by
the end of 2023, there were 1.15 million, comprising 1 .4 per cent of the population. In 2022, the
net migration of Ukrainians to Germany was 962,000 people (1.1 million arrived and 138,000
people left) and in 2023 it was 121,000 (277,000 people arrived and 156,000 left). 218
217 Information provided to UNODC by the German Statistical Office, June 2024.
218 Germany, Federal Statistical Office, "Nettozuwanderung von 121 000 Menschen aus der Ukraine im Jahr 2023" (Translation: Net
immigration of 121 000 people from Ukraine in 2023), press release, 22 February 2024.
55
According to key informants interviewed for this research in Germany in 2023, there were no
trafficking in persons cases before the courts involving people who fled Ukraine after February
2022. 219 The authorities had "only scattered reports and investigations initiated on forced
prostitution, trafficking in persons, and other kinds of exploitation [...] and just one case that was
confirmed. The situation has not changed since the beginning of the war." 220
Based on their consultations with 35 anti-trafficking organizations across the country in late
2022, the national umbrella organization of anti-trafficking services in Germany (Bundesweite
Koordinierungskreis Gegen Menschenhandel e.V., KOK) considers that it is difficult to ascertain
the actual number of cases of trafficking and exploitation in Germany as a result of the war in
Ukraine. Around half the 35 organizations that reported to KOK had provided advice to or referred
for assistance people who had fled Ukraine in Germany. At the time of the survey, the
organizations consulted were aware of less than ten cases of suspected trafficking in persons
involving people who fled Ukraine. 221
The anti-trafficking services were providing support in around 1 5 cases of labour exploitation and
in less than 30 cases of sexual exploitation. 222 According to KOK, this number of cases is in line
with Europol's preliminary estimates, that as of October 2022, there were around 60 suspected
trafficking cases and five officially confirmed trafficking cases across Europe. 223
A state agency working on combating trafficking for forced labour in Berlin runs a project for
people who fled Ukraine. Key informants from the agency, interviewed in 2023 and 2024, stated
that that they had seen a very low number of cases of forced labour or exploitation among
Ukrainians and no cases of trafficking in persons. 224 According to other key informants
interviewed in Berlin in 2023, severe forms of labour exploitation have not been identified among
people who fled Ukraine. 225 However, in an interview in 2024, the same key informants stated that
the number of Ukrainians exploited in the workplace is increasing, as more Ukrainian people enter
the labour force. 226
219 Key informant interviews 1 DE-K-08; 1 DE-K-07.
220 Key informant interview 1 DE-K-07.
221 KOK, Menschenhandel und Ausbeutung im Kontext des Ukrainekrieges - Eine Untersuchung a us Sicht spezialisierter
Fachberatungsstellung zur Situation in Deutschland (Translation: Trafficking in Persons and Exploitation in the context of the war
in Ukraine - Perspectives from help centers about the situation in Germany), (October 2022).
222 KOK, Menschenhandel und Ausbeutung im Kontext des Ukrainekrieges, (October 2022), op. cit.
223 Information from EUROPOL: Public Information- Reported potential THB incidents as of 27.10.2022 at the event "EU Civil
Society Platform”, cited in KOK, Menschenhandel und Ausbeutung im Kontext des Ukrainekrieges, (October 2022), op. cit.
224 Key informant interviews 1 DE-K-02; 2DE-K-01 .
225 Key informant interview 1 DE-K-09.
226 Key informant interview 2DE-K-01 .
56
Switzerland
The Swiss authorities reported two Ukrainian victims of trafficking in Switzerland in 2022,
though it is unclear whether these two people arrived in the country before or after February
2022. 227 During 2022, the protection programme for victims of trafficking in German-speaking
parts of Switzerland supported 375 people of all nationalities, of whom 209 were newly identified
in 2022. Thirteen of the newly identified cases in 2022 involved Ukrainian citizens. 228
The Specialized Centre for Trafficking in Women and Women in Migration (Fachstelle
Frauenhandel und Frauenmigration, FIZ) identified 259 of these people as victims of trafficking in
persons, comprising 224 females, 22 males and 1 3 people of diverse gender. The victims in 2022
were exploited in sex work (195), in the household/care sector (28), in other sectors (21) and in
other forms of trafficking (15). Fourteen of the cases were in Bern, while 45 were in Zurich, 62
were abroad and 67 were unknown. 229 During 2023, 1 56 new cases were recorded by FIZ, less
than four of which involved Ukrainians. 230
A key informant from FIZ, interviewed for this research in 2024, said that the organization had
identified two Ukrainian victims of trafficking in Bern and two in other cantons. 231 Other key
informants interviewed in Bern, including NGOs and case workers, agreed that the incidence of
exploitation was low. According to a key informant from an NGO in Bern, herself a Ukrainian
refugee, cases of abuse or exploitation are "very, very rare." 232
As of early 2025, the Swiss Federal Police had not recorded the identification of any victims of
trafficking from Ukraine since the beginning of the full-scale invasion. Police in the canton of
Geneva in western Switzerland, close to the French border, were conducting a preliminary
investigation, not connected to the arrival of Ukrainian refugees since 2022, relating to a Ukrainian
man who had been resident in Switzerland for several years and who had been arrested and
interrogated in the past on suspicion of "illegally bringing Ukrainian women into the country for the
purpose of prostitution." 233
227 Key informant interview 1CH-K-12.
228 Fachstelle Frauenhandel und Frauenmigration (FIZ), Jahresbericht 2022, (2023).
229 Ibid.
230 Fachstelle Frauenhandel und Frauenmigration (FIZ), Jahresbericht 2023, (2024).
231 Key informant interview 2CH-K-07.
232 Key informant interview 1 CH-K-1 1 .
233 Data and information provided to UNODC by the Swiss Federal Police, via the Swiss Federal Department of Foreign Affairs, on
31 January 2025.
57
Rest of the EU
After Germany, the highest number of Ukrainian victims identified in Europe in 2022 was in the
Netherlands. According to the Dutch National Report on Trafficking in Persons, the number of
notifications about Ukrainian victims increased from seven in 2021 to 51 in 2022. 49 of the cases
in 2022 were assumed to be labour exploitation. The victims comprise 33 women and 18 men,
exploited in agriculture, forestry and fishing, with smaller numbers in construction, industry and
hospitality. Ukrainians were the third largest group of foreign victims identified in the
Netherlands. 234
From February 2022 to January 2024, the Dutch Coordination Centre against Trafficking in
Persons (CoMensha - Coordinatiecentrum tegen Mensenhandel) recorded four criminal
trafficking in persons investigations initiated that involved Ukrainians, each involving one victim.
Two cases were trafficking for sexual exploitation and two were for forced labour. Three of these
cases have since been closed and not submitted for prosecution, while one was filed for
prosecution under assault rather than trafficking in persons. 235
A Dutch NGO working on labour law violations, labour exploitation and trafficking for forced
labour supported 396 cases involving Ukrainians during the period 24 February 2022 to 30 June
2024. In the NGO's assessment, around 1 53 of these cases had potential indicators of trafficking
in persons. The potential trafficking victims are 217 women, 165 men and 14 of unknown
gender. 236 Most complaints to a Dutch NGO working on labour rights involving Ukrainians related
to people being not paid or being paid less than promised, working with no contract or with
fraudulent self-employment contracts, false promises, problems regarding occupational health
and unfair dismissals. 237
A statistical report on administrative data indicates that the proportion of Ukrainians among
victims of trafficking identified in France increased from two per cent in 2021 to nine per cent in
2022. 238 France recorded 48 Ukrainian victims of trafficking in 2022. The French Red Cross,
responsible for the reception of Ukrainians in many parts of France, reported attempts at train
stations to recruit young Ukrainian women with deceptive employment offers, as well as
indications of deprivation of liberty and withholding of documents at private and collective
accommodation. Law enforcement authorities consider this trafficking by individual actors -
particularly accommodation hosts -, rather than organized crime groups. 239
234 National Rapporteur on Trafficking in Human Beings and Sexual Violence against Children, Annual figures: Human Trafficking
2022 (The Hague, 2023); data and information provided to UNODC by the Dutch Ministry of Justice and Security on 7 November
2024.
235 Key informant interview NL-K-01.
236 Data and information provided to UNODC by the Dutch Ministry of Justice and Security on 7 November 2024; key informant
interview NL-K-02.
237 Data and information provided to UNODC by the Dutch Ministry of Justice and Security on 7 November 2024.
238 France, Ministry of Justice, La traite et ¡'exploitation des étres humains en 2022: une approche par les données administratives,
(Translation: Human trafficking and exploitation in 2022: an administrative data approach), (2023).
239 Service statistique ministériel de la sécurité intérieure (Ministerial Statistical Service of Interior Security, SSMSI) and Mission
interministérielle pour la protection des femmes centre les violences et la lutte contre la traite des étres humains (Interministerial
Mission for the Protection of Women from Violence and Combatting Trafficking in Human Beings (MIPROF), La traite des étres
humains en France: Le profil des victimes accompagnées par les associations en 2022, (Translation: Trafficking in Human Beings
in France: Profile of victims supported by associations in 2022), (2023).
58
According to the Eurostat and European Migration Network (EMN) Annual Report on Migration
and Asylum, during 2022, five countries reported Ukrainians among the top three nationalities of
non-EU victims of trafficking identified: Bulgaria, Czechia, Estonia, Luxembourg and Sweden. 240 In
Luxembourg, the majority of non-EU victims of trafficking identified in 2022 were from Russia (21 (
and Ukraine (20), almost all adult women trafficked for sexual exploitation. 241 According to FRA
in 2023, the NGO La Strada in Czechia had recorded 123 cases of labour exploitation of people
with temporary protection status. 242
A case reported by the media in Italy was identified early on in the conflict, in April 2022. The case
involved ten victims, some of whom were Ukrainian refugees, exploited in unsafe conditions at a
factory producing counterfeit cigarettes near the capital, Rome. 243 There were 19 suspected
trafficking cases involving Ukrainians in Austria during April to July 2022, and "several" suspected
trafficking cases in Slovenia. Three complaints on the trafficking of Ukrainian refugees for sexual
exploitation or forced labour were being investigated by the Spanish police in Madrid in late
2022. 244 A case involving the potential trafficking for sexual exploitation of 14 Ukrainian and
Belarusian women was identified by the Spanish police in southern Spain in May 2024 245 (see
section 5.4 below on trafficking for sexual exploitation).
The Swedish police recorded 11 suspected trafficking cases involving Ukrainian refugees, for
sexual exploitation and forced labour, in late 2022, and had also "come across Ukrainian women
who had been forced into prostitution after fleeing Ukraine. [...M]any of them come to Sweden
through agencies based in Ukraine that had taken up to 50% of their income" 246 Other suspected
trafficking cases were reported to Europol in 2022 from across the EU, involving suspected
Ukrainian traffickers recruiting Ukrainians for forced labour, forced begging and child trafficking,
particularly in the context of illegal adoption and commercial surrogacy (see section 5.5 below on
cross-border child trafficking). 247
240 Eurostat, Annual Report on Migration and Asylum 2022 Statistical Annex, (Luxembourg, Publications Office of the EU, 2023).
241 Ibid.
242 FRA, Fundamental rights implications for the EU of the war in Ukraine, (Luxembourg, Publications Office of the EU, 2023).
243 ANSA, "Italy: Ukraine refugees exploited in counterfeit cigarette plant", InfoMigrants, (18 April 2022).
244 FRA, The Russian war of aggression against Ukraine - the broad fundamental rights impact in the EU: Bulletin #2, (Luxembourg,
Publications Office of the EU, 2022).
245 Spain, Ministry of the Interior, "Desarticulada una organización criminal dedicada a la explotación sexual de mujeres del este
de Europa" (Translation: Criminal organisation dedicated to the sexual exploitation of women from Eastern Europe dismantled),
press release, (21 June 2024); Europol, "5 arrests for sexual exploitation of Ukrainian refugees in Spain", press release, (21 June
2024).
246 FRA, The Russian war of aggression against Ukraine (2022), op. cit.
247 Content analysis of Europol Monitoring Team Reports (EPMT) March - November 2022. Europol Unclassified - Basic
Protection Level.
59
5.3 Cross-border trafficking for forced labour
Incidence of forced labour and types of abuses
Among 1,602 people who fled Ukraine and were surveyed for this research in 2023 in Warsaw,
Poland (609), Bern, Switzerland (593) and Berlin, Germany (400), a number of respondents
reported indications of abuse or exploitation that could present elements of trafficking in persons
for forced labour. Nine per cent of respondents (138) had themselves experienced or witnessed
other people from Ukraine having problems at work or in the context of their accommodation
since arriving in the country of survey. These problems range from indicators that a person is
being trafficked to general abuse and harm, and were reported by survey respondents in Warsaw
(75), Bern (36) and Berlin (27).
The majority of these respondents cited problems related to finding accommodation and
discrimination while seeking employment or at the place of employment. In Warsaw, most of
these problems arose in the workplace (91%). In Bern on the other hand, 70 per cent of these
problems were in the context of accommodation and in Berlin, 61 per cent were accommodation
and 44 per cent cited the workplace (multiple responses possible). Potential abuse and
exploitation in the accommodation context related to paid and unpaid working arrangements in
exchange for accommodation. Some of these reported issues presented possible indicators of
trafficking in persons.
Six per cent (104/1,602) of respondents cited some form of abuse in the workplace. Around half
of these respondents experienced or witnessed just one form of abuse (49%), while the remainder
experienced or witnessed two (27%) or three (17%) forms of abuse. Seven per cent experienced
four or more forms. Figure 1 2 below presents the types of abuses experienced in the workplace.
Figure 1 2: Abuses Experienced or Witnessed in the Workplace
I 1%
I 1%
I I
2%
P3%
3%
■3% I I
Locked up or restrained
Forced to engage in prostitution
Threatened with physical harm
Restrictions on movement or contact with others
Forced to do ¡I legal/il licit work or activites
Physically harmed (e.g., beaten, kicked, burned)
Threatened with deportation
Physically forced to do something
ID documents kept by employer or host
Deceived about who employer was
Forced to work long hours/in unsafe conditions
Tricked into doing different work than promised
Not paid or paid less than promised
4%
■4%:
I _______ I I
■8%
13%
38%
82%
0% 10% 20% 30% 40% 50% 60% 70% 80% 90%
Source: 2023 survey of 1 ,602 people who fled Ukraine in Berlin, Warsaw and Bern
60
35 out of 1,602 respondents - two per cent - reported that they themselves experienced or had
witnessed other people who fled Ukraine experiencing abuses at the workplace that present
indicators of potential cases of trafficking in persons for the purpose of forced labour. 248 The
majority (32) were surveyed in Warsaw. In six of these cases, workers had their personal identity
documents kept by their employer, among other abuses. In four cases, workers were threatened
with being deported by their employer, and/or were forced to do something against their will. In
three cases, they were forced to do illegal or illicit work activities. A further three were harmed at
the workplace, and/or prevented from moving around freely or speaking to people, and one was
locked up or restrained.
Most indications referred to situations witnessed rather than directly experienced by the
respondents and are thus not indicative of prevalence among the survey respondents. The
potential cases mainly involved non-payment of wages or payment being less than promised;
deception in relation to the type of work; excessive working hours or unsafe working conditions;
and deception about who the employer was. Smaller numbers of respondents reported threats of
being physically harmed or being deprived of sleep, food, water or medical care, or restrictions on
liberty (withholding of ID documents; threats of being deported; and being prevented from moving
freely or contacting relatives), in similar proportions
In parallel research on behalf of the Anti-Trafficking Taskforce for Ukraine, which UNODC
co-chairs, IOM carried out surveys with 190 Ukrainian refugees in Poland in late 2023, as part of
a special module on abuse, violence and exploitation of lOM's regular displacement tracking
matrix (DTM) surveys. Thirteen per cent of respondents reported experiencing abuse, violence or
exploitation during their journey or in receiving countries. This mostly comprised working without
getting the expected payment, an indicator of trafficking for forced labour (1 0.5% of respondents;
n=20). 249
Smaller numbers of respondents in Poland mentioned other indicators of potential abuse,
violence or exploitation: receiving an offer of marriage (5), experiencing physical violence (4) or
being deceived, manipulated or indebted to travel or move (2). Two respondents reported that
they were forced to perform work or other activities against their will and one respondent did not
always have their travel documents with them. No respondents were kept at a location against
their will, forced to travel to a new location, or personally knew anyone who had been identified as
a victim of trafficking by national authorities. 250
248 This includes respondents who reported at least two types of abuses at the workplace (out of 12 possible options), including
at least one of the following: "Someone was physically forced to do something", "Someone was locked up or restrained",
"Someone was physically harmed (e.g., beaten, slapped, hit, kicked, punched, burned)", "Someone was prevented from moving
around freely or speaking to people", "Someone's ID documents were kept by their employer or host", "Someone was threatened
with being deported", "Someone was threatened with being physically harmed", "Someone was forced to do illegal or illicit work
or activities", "Someone was forced to perform sexual acts" and "Someone was forced to engage in prostitution".
249 Regional Refugee Response for the Ukrainian Situation (IOM), Vulnerability to Trafficking in persons in the context of the war in
Ukraine: The case of Poland and Romania, (IOM, 2024).
250 Ibid.
61
For victims of all nationalities, during 2022, the German Federal Criminal Office (BKA) recorded 34
cases of labour exploitation (an increase of 21% compared to 2021), involving 1,019 victims
(+593%) and 76 suspects (+46%) (51 men, 24 women and 1 adult of unknown gender). At least
101 of the victims were Ukrainian and involved in the case described below. The relevant
provisions of German Criminal Law are: trafficking in persons (section 232 of the Criminal Code);
forced labour (section 232b of the Criminal Code) and labour exploitation (sections 233 and 233a
of the Criminal Code). Under section 233, exploitative conditions include low payment, excessive
working hours, excessive commission fees and rent, dangerous working conditions and
withholding of wages. 251
Trafficking in persons involving Ukrainian victims in Germany, 2020-2022
The German Federal Criminal Police Office (Bundeskriminalamt, BKA) describes a case of
trafficking for forced labour that was investigated in 2020 and referred to the public prosecutor's
office in 2022. The criminal network had been active across the country providing employees for
drinks logistics companies in Nordrhein-Westfalen (western Germany) and other German Lander.
The employees were brought to Germany through deception and then exploited through complex
chains of subcontractors. The recruitment company charged inflated amounts for providing
immigration papers, accommodation and transportation to workplaces and the employees were
paid a very low salary.
The members of the criminal group exercised a division of roles within a highly professionalized
structure. In 2021 , search and arrest warrants were issued against company bosses, on suspicion
of trafficking in persons for the purpose of labour exploitation, withholding or embezzlement of
wages, tax fraud and benefit fraud. The investigation indicated a total of 555 potential victims. At
least 224 were exploited in drinks logistics. The nationalities of 397 of the victims were
determined; 101 were from Ukraine, while the remainder were from other Eastern and Central
European countries. 252
251 Germany, Bundeskriminalamt (Federal Criminal Police Office), Menschenhandel und Ausbeutung: Bundeslagebild 2022,
(Translation: Human Trafficking and Exploitation: Federal Crime Report), (2023).
252 Ibid.
62
Sectors of exploitation
Respondents to the survey carried out for this research in Berlin, Warsaw and Bern were working
in agriculture, the civil service, construction, domestic work, transportation, finance and
information technologies (IT). According to key informants interviewed for this research in
Warsaw, forced labour of refugees from Ukraine takes place in warehouses, factories,
construction, other types of manual work, cleaning and care services. 253 Respondents to lOM's
survey in Poland who reported experiencing abuse, violence or exploitation were working in
sectors like domestic work, agriculture, transportation and logistics, hospitality and the services
sector, administration and professional services and manufacturing and construction. 254
The case of a Ukrainian woman in her late forties from eastern Ukraine, who was trafficked for
forced labour in Poland in 2022 by a Ukrainian female acquaintance, was recorded by IOM. She
worked packing frozen meat in cold storage, had been deceived about the nature of the work and
the payment, worked excessive hours, lacked access to means of communication and had her
personal documents withheld, and was living in substandard conditions. 255
According to a state agency working on combating trafficking for forced labour in Berlin: "Before
the war, there were a number of cases of labour exploitation of Ukrainian people in a number of
sectors (construction, agriculture); they were very numerous." 256 As of 2022, the same key
informants from this agency consider the sectors most at risk for forced labour of Ukrainian
refugees to be care work, cleaning, agriculture and hospitality. 257 The few potential cases of
forced labour indicated by interviewees in Bern were in restaurants and hotels, care work,
cleaning and domestic work, and agriculture (see, for example, Case Study 4 in chapter 7). 258
Potential cases of labour exploitation or trafficking for forced labour of refugees from Ukraine in
the research countries involve cleaning work in private households and hotels, often linked to the
provision of accommodation. According to a key informant, in Warsaw in 2022 it was common for
hotels or hostels to offer rooms free-of-charge, and refugees were asked to provide cleaning
260 services in return, without any pay. 259 Ukrainians in private accommodation in Poland are
vulnerable because of power imbalances vis-a-vis hosts (see section 2.4 above), according to
UNHCR, leading to: "expectations among hosts (i.e. for domestic work). While participants
reported feeling obliged to perform domestic work, the extent to which such work was coerced was
not elaborated.™
253 Key informant interviews 2PL-K-03; 2PL-K-04.
254 Regional Refugee Response for the Ukrainian Situation (IOM), Vulnerability to Trafficking in persons in the context of the war in
Ukraine: The case of Poland and Romania, (IOM, 2024).
255 IOM Ukraine. "Trafficking In Persons: IOM Ukraine Caseload (January-December 2023)," (2024).
256 Key informant interview 1 DE-K-02.
257 Ibid.
258 Key informant interview 2CH-K-02.
259 Key informant interview 2PL-K-04.
260 UNHCR, Surviving as We Can: Risks of Gender Based Violence (GBV), and Sexual Exploitation and Abuse (SEA), Relating to Private
and Collective Accommodation, Livelihoods, and Accessibility, for Persons Fleeing Ukraine: Poland Summary Report, (October
2023).
63
A key informant from an anti-trafficking NGO in Berlin described how a Ukrainian woman was
offered accommodation in a private household and then instructed to carry out domestic work,
and her movement was restricted. 261 A similar case reported to the German anti-trafficking
umbrella organization, KOK, involved a Ukrainian woman who was forced into domestic servitude
by her accommodation host and was not allowed to leave the house at certain times. 262
As of early 2025, police in the canton of Vaud, in western Switzerland, close to the border with
France, were investigating a foreign couple who had offered accommodation to Ukrainian women
in return for them carrying out maintenance work on their luxury property. The couple allegedly
misappropriated the refugees' social assistance benefits and forced them to work under abusive
conditions. 263 A key informant interviewed in 2023 in Bern also mentioned an accommodation
provider requiring Ukrainian tenants to clean apartments: “It was an owner who has many
apartments for tourists, and he said the girls [two young Ukrainian women] should be cleaning all
the houses, not just the one they were living in." 264
Another key informant from an NGO, interviewed in Bern in 2024, described how a Ukrainian
woman had called the NGO for assistance because her daughter had applied for a job with a man
who was looking for domestic workers on social media. The man had hinted that he would also
expect sexual services. The NGO informed the local police, who went and checked this person
and determined that he was attempting to exploit job applicants. 265
261 Key informant interview 1 DE-K-04.
262 KOK, Menschenhandel und Ausbeutung im Kontext des Ukrainekrieges, (October 2022), op. cit.
263 Data and information provided to UNODC by the Swiss Federal Police, via the Swiss Federal Department of Foreign Affairs, on
31 January 2025.
264 Key informant interview 1CH-K-09.
265 Key informant interview 2CH-K-06.
64
Labour law violations
It is very difficult to see where it is simply poor working
conditions and where exploitation actually begins.
Trafficking specialist from a Swiss authority, interviewed in 2023 256
A key informant from a Berlin NGO interviewed in 2024 had not come across incidents of forced
labour or trafficking, but reported that labour law violations among people who fled Ukraine in the
city seem widespread, which may leave refugees more vulnerable to trafficking for forced
266 labour. 267 Among the issues identified in the SAM-UKR survey of Ukrainian refugees in 2022-2023
were: earning less than a living wage; excessive working hours; demanding physical labour;
abusive practices by employers; and potential for scams. 268
Key informants in all three cities mentioned situations where Ukrainians refugees are not paid for
their work; experience significant delays in payment; are paid less than national employees for the
same work; experience poor working conditions; and are not given proper employment
contracts. 269 One key informant interviewed described a case where two Ukrainian women
complained about their employer, a business-owner running a storage facility, who had not paid
them for two or three months. When they confronted the employer, the situation escalated into a
physical conflict. 270
The Polish Act on Assistance of Ukrainian Citizens foresees that to hire a Ukrainian citizen,
employers can simply register the employment relationship with the Labour Office and no prior
authorization is required. 271 However, an issue raised by key informants in Warsaw, that leaves
refugees from Ukraine - as well as other workers - vulnerable to forced labour, is working under a
civil-law contract (see section 2.4 above), or working without a contract. 272
266 Key informant interview 1 CH-K-1 2.
267 Key informant interview 2DE-K-01 .
268 OECD and EUAA, Voices in Europe, (2024), op. cit., p. 50.
269 Key informant interviews 2PL-K-02; 2PL-K-04; 2CH-K-02; 1PL-K-07; 2DE-K-06; 1DE-K-09; KOK, Menschenhandel und Ausbeutung
im Kontext des Ukrainekrieges, (October 2022), op. cit.
270 Key informant interview 2DE-K-06.
271 Key informant interviews 1 PL-K-01; 1 PL-K-04.
272 Key informant interviews 2PL-K-01; 2PL-K-02: 2PL-K-04; 2PL-K-05; 1PL-K-07; Regional Refugee Response for the Ukrainian
Situation (IOM), Vulnerability to Trafficking in persons, (2024), op. cit.
65
[Refugees] sometimes work under civil law contracts,
for which the rule that applies is the civil code and not
the labour code. It creates space for exploitation because
in those contracts you can put any stipulation, for instance
if you come to work late, I can pay you 100 PLN [US$25] less.)
Key informants from an international organization in Poland, interviewed in 2023 273
A key informant from an NGO, interviewed in 2024, described Ukrainians in vulnerable situations,
including adults and children, working without proper contracts at hotels and at a football
stadium. 274 In Bern, according to a key informant interviewed in 2024, many Ukrainians work
without a contract because of the bureaucracy attached to hiring someone with Protection Status
S (temporary protection). 275 One Ukrainian woman working at a construction company was told
by her employer that she should work 20 per cent more than her colleagues because she had
Protection Status S, but that she would receive the same salary, according to a key informant. 276
Key informants for the Anti-Trafficking Task Force research also mentioned Ukrainian refugees
experiencing exploitative conditions - including being underpaid or earning less than national
employees and working without formal contracts. 277 Similarly, most complaints to a Dutch NGO
working on labour rights involving Ukrainians related to people not being paid or being paid less
than promised, working with no contract or with fraudulent self-employment contracts, health
issues and unfair dismissals. 278
The role of labour intermediaries was considered a specific vulnerability factor by two key
informants in Warsaw (see, for example, Case Study 3 in chapter 7). 279 A key informant
interviewed in 2024 referred to people looking for work in EU countries before leaving Ukraine,
through recruitment companies, which may deceive applicants about the nature of the job
opportunity. 280 A key informant in Berlin mentioned the issue of employment of refugees through
leasing companies. This can lead to lower wages than agreed and make it easier to terminate the
contract without notice. 281
273 Key informant interview 1 PL-K-07.
274 Key informant interview 2PL-K-01 .
275 Key informant interview 2CH-K-03.
276 Key informant interview 2CH-K-03.
277 Regional Refugee Response for the Ukrainian Situation (I0M), Vulnerability to Trafficking in persons in the context of the war in
Ukraine, (2024), op. cit.; Key informant interviews 2PL-K-02; 2PL-K-03.
278 Key informant interview NL-K-02.
279 Key informant interviews 2PL-K-03; 2PL-K-05.
280 Key informant interview 2PL-K-03.
281 Key informant interview 1 DE-K-09.
66
5.4 Cross-border trafficking for sexual exploitation
Demand
If you look on the internet, for example, pornography sites,
the demand for refugee porn or Ukrainian porn has simply
increased dramatically. [...] you would certainly find more
women from Ukraine on erotic escort sites.
Key informant from an anti-trafficking NGO in Berlin, interviewed in 2024 282
In the early months of the mass displacement of refugees from Ukraine, there were indications of
a significant increase in online demand among European men for sexual services and
pornography from Ukrainian women - some of which may involve sexual abuse and exploitation -
and for child sexual abuse and exploitation of Ukrainian children. 283 The Organization for Security
and Co-operation in Europe (OSCE) cites Thomson Reuters data indicating "huge spikes in online
searches - across multiple languages and countries - for explicit content and sexual services from
Ukrainian women and girls" 284 The risks of online sexual exploitation and abuse are linked to
Ukrainians' regular use of messaging apps and social media to seek support and the resulting
opportunity for sex traffickers to recruit victims and advertise exploitative sexual services
online. 285
Social workers interviewed for this research in Bern in 2023 suggested that the pre-existing high
demand for buying sex from Eastern European women has increased since February 2022. 286 A
key informant from a women's shelter in Berlin also pointed to demand for sex work from
Ukrainian women, particularly online, as a factor of vulnerability. 287
282 Key informant interview 2DE-K-09.
283 Key informant interview IN-K-01 .
284 Organization for Security and Co-operation in Europe (OSCE), Recommendations on enhancing efforts to identify and mitigate
risks of trafficking in human beings online as a result of the humanitarian crisis in Ukraine, 22 April 2022. On internet-based
trafficking, see also UNODC, Global Report on Trafficking in Persons 2020, Chapter 5, (United Nations Publications, 2020).
285 Key informant interviews 2PL-K-05; EUAA, IOM and OECD, Forced displacement from and within Ukraine: Profiles, experiences,
and aspirations of affected populations, (October 2022).
286 Key informant interview 1 CH-K-03.
287 Key informant interview 1 DE-K-1 1 .
67
Sexual exploitation in prostitution
The crime networks existed before. This is a pre-existing
factor for potential sexual exploitation. It has occurred within
Ukraine, and outside of Ukraine, and victims from Ukraine
have been trafficked to Europe and Dubai [United Arab Emirates],
Given the context, the risks are huge, but the scale is unknown. [
Key informants from an international organization, interviewed in Warsaw in 2023 288
This study has found some indications of sex work and prostitution involving women who fled
Ukraine in the cities under research. The reported incidence of potential sexual exploitation and
risky situations in the context of sex work and prostitution was lower than the incidence of
potential forced labour and labour rights violations among refugees from Ukraine. Indications of
prostitution or sex work among refugees from Ukraine were mentioned by 2.5 per cent of
respondents to the survey.
Knowledge of the involvement of other refugees in prostitution or sex work was mentioned by
four per cent of survey respondents in Berlin (15 respondents), two per cent in Warsaw (14) and
two per cent in Bern (12). Key informants also mentioned Ukrainian women involved in
prostitution and sex work. Without further details, it is difficult to determine whether such
involvement presents indications of trafficking for sexual exploitation, but some cases do show
indications of high levels of vulnerability, as set out below.
Of the 41 respondents who mentioned knowing Ukrainians involved in prostitution and sex work,
seven considered the prostitution to be forced, six of them in Warsaw. This means that 0.4 per
cent of respondents reported knowledge of people in forced prostitution (potentially trafficking
for sexual exploitation in prostitution). None of the 1,602 respondents to the survey reported
personally experiencing sexual exploitation. This should be interpreted with caution as it is an
issue that is likely to be underreported in victimization surveys and in general, due to various
factors, including shame, stigma and lack of awareness of what constitutes sexual exploitation.
Among the survey respondents who knew of forced prostitution cases, two reported that the
person in question had been forced to engage in prostitution by their accommodation provider,
two did not know by whom and one said by friends. A further two people, who both clarified that
the person in question had subsequently worked independently on pornography websites, stated
that the perpetrator was "other" and did not provide further details.
288 Key informant interview 1 PL-K-07.
68
In response to a question posed in the Berlin Senate, between February 2022 and August 2023,
the Berlin Police had investigated six suspected cases of forced prostitution of Ukrainian women.
The Berlin Police had been notified of a total of 62 potential cases involving Ukrainians during that
period. 289 KOK, the umbrella organization of German anti-trafficking NGOs, was aware of less
than 30 cases of sexual exploitation of Ukrainian women around the country. 290 Key informants
from an NGO working with women and girls in Berlin noted a minor increase in the number of
potential cases of sexual exploitation they identified among Ukrainian women at the time of the
interview for this research in mid-2023. 291
Key informants interviewed in Warsaw in 2023, including authorities, NGOs and international
organizations, had documented few cases of trafficking for sexual exploitation among people
who fled Ukraine. 292 A key informant interviewed in Warsaw in 2024 mentioned that some
Ukrainian refugee women, including Ukrainian Roma women, were offered deceptive job
opportunities in Poland, which ended up being in prostitution. 293
During 2022, the protection programme for victims of trafficking in German-speaking parts of
Switzerland supported 13 newly identified cases involving Ukrainians. Further details on these
cases are not available, but among 259 people of all nationalities identified by FIZ as victims of
trafficking in persons, 86.5 per cent were female, 8.5 per cent were male and 5 per cent were of
diverse genders. 75 per cent were exploited in sex work. 294 The Swiss authorities reportedly paid
specific attention to Ukrainians working at brothels at the beginning of the crisis, as risks of
sexual exploitation were identified as a major concern. The police had identified Ukrainian sex
workers before the crisis but did not identify any new sex workers from Ukraine in brothels during
the period February 2022 to April 2023. 295
A key informant from a Berlin NGO, interviewed in 2023, mentioned potential cases involving
Ukrainian women looking for work, who were put in touch with intermediaries. These
intermediaries discouraged them from registering for temporary protection and social welfare,
and instead offered them opportunities in sex work and prostitution. Some of these women were
officially registered as sex workers and some were not, and some of the women were recruited in
Ukraine. Reportedly the intermediaries also confiscated their passports and pressured them to
take clients. However, the key informants could not provide details of any specific cases: "The
exploiters are from Ukraine, they are not big networks. Individuals get in touch through knowing
somebody and then recruitment happens through acquaintances, but there are no big groups." 296
289 Marius Gerards, "Zwangsprostitution von Ukrainerinnen: Berliner Polizei ermittelt gegen mutmaiiliche Menschenhandler"
(Translation: Forced prostitution of Ukrainian women: Berlin police investigate suspected human traffickers), Tagesspiegel, (6
October 2023).
290 KOK, Menschenhandel und Ausbeutung im Kontext des Ukrainekrieges, (October 2022), op. cit.
291 Key informant interview 1 DE-K-04.
292 Key informant interviews 1 PL-K-01; 1 PL-K-06; 1 PL-K-07.
293 Key informant interview 2PL-K-05.
294 FIZ, Jahresbericht 2022 (2023), op. cit.; key informant interview 2CH-K-07.
295 Key informant interviews 1CH-K-01; 1CH-K-12.
296 Key informant interview 1 DE-K-04.
69
Ukrainian journalists interviewed in Warsaw in 2023 had identified job offers in Poland implying
the provision of sexual services in locations such as massage parlours. When the journalists
answered some of those offers as part of their investigation, they were reportedly free to leave
when they realized the sexual nature of the job. However, in a few cases, the journalist was offered
a contract abroad, with travel expenses covered. This included several non-disclosure
agreements but no real explanation of the position. 297
One Ukrainian woman told me she wanted to start working
at a massage parlour. It was proposed like a normal job,
but when they came to the interview, the people there said:
'we are not interested in your certificate and skills but your body.’
When she gets a contract, there is nothing about guarantees,
payment, etc., but only about a confidentiality agreement.
She could not talk about the place.
Journalists interviewed in Warsaw in 2023 298
Large accommodation centres in the cities where field research was carried out presented
specific indications of sexual exploitation, as well as risks of sexual exploitation and abuse. There
were indications of abusive and exploitative situations at the first arrival centre for refugees in
Tegel (a decommissioned airport) in northwest Berlin. According to a key informant interviewed
in 2023, groups and chats on messaging apps were set up for young Ukrainian women residing at
the centre to offer sexual services. Refugees are accommodated at Tegel for between a few days
and a few weeks, while their temporary protection registration is being processed. 299
A key informant interviewed in Ukraine in 2024 reported a potential case of trafficking of young
Ukrainian women who fled to a country in Eastern Europe, for sexual exploitation at a brothel. 300
Similar cases were reported by the media in July 2022, when the Ukrainian authorities
investigated a suspected case of sex trafficking of at least ten Ukrainian women abroad. The
National Police of Ukraine (NPU) intercepted a 21-year-old Ukrainian woman, allegedly being
trafficked for sexual exploitation in prostitution. The investigation led to the arrest of a suspected
trafficking organizer in Kyiv, Ukraine. The 30-year-old man allegedly led a group of men who
moderated channels on a messaging app to recruit victims. 301
297 Key informant interview 1 PL-K-03.
298 Ibid.
299 Key informant interview 1 DE-K-07.
300 Key informant interview UA-K-02.
301 Lorenzo Tondo, "Ukraine prosecutors uncover sex trafficking ring preying on women fleeing country", The Guardian, (7 July
2022).
70
Trafficking for sexual exploitation in southern Spain
The Spanish National Police, supported by Europol, investigated a criminal group trafficking
mostly Ukrainian women, but also Belarusian women, for sexual exploitation in prostitution in El
Ejido in the province of Almeria in southern Spain. The women were recruited online with false job
offers, promising work in Spain as hostesses or entertainers. The criminal network used the
services of online agencies specialized in providing women to clubs in Spain for prostitution. On
arrival in Spain, the Ukrainian women were instructed by the group to apply for temporary
protection. They were then sexually exploited in prostitution at a brothel in El Ejido. The victims
were accommodated in three locations managed by the same person who managed the brothel.
The case came to the attention of the Spanish authorities when it was reported to the Victims of
Trafficking in Human Beings Service of the National Police. Five suspects were arrested (one
Spanish, two Ukrainian and two Russian) in May 2024, including the alleged leader of the group,
and fourteen victims were identified. The Police seized two vehicles, €2,495 (US$2,670) in cash,
phones and documents. The suspects are accused of crimes related to prostitution, crimes
against foreign citizens' rights and against workers' rights, and membership of a criminal
organization. The investigation was ongoing as of June 2024. 302
302 Spain, Ministry of the Interior, "Desarticulada una organización criminal dedicada a la explotación sexual de mujeres del este
de Europa" (Translation: Criminal organisation dedicated to the sexual exploitation of women from Eastern Europe dismantled),
press release, (21 June 2024); Europol, "5 arrests for sexual exploitation of Ukrainian refugees in Spain", press release, (21 June
2024).
71
Risks in the context of sex work and prostitution
Sex work is legal in the three cities covered by the research, though according to a key informant,
it has not been cantonal practice for the Bern authorities to authorize this for people with
temporary protection status. 303 According to the German Federal Statistical Office, as of the end
of 2023, 30,635 people were officially registered for prostitution work across the country,
including 1,760 people in Berlin. 304
Risk factors for sexual exploitation in prostitution are evident from the sources analysed for this
research. 305 A key informant from an NGO in Berlin, interviewed in 2024, had conducted 11
outreach visits in brothels, where they met a total of 150 women, 38 of whom were Ukrainian.
These Ukrainian women generally did not speak German and were not aware of their rights. Most
lived at the brothels, and some were monitored by security guards on cameras. The key informant
mentioned two 'erotic massage parlours' (see, for example, Case Study 1 in chapter 7) that
almost exclusively employ women from Ukraine: "When we go there, there's almost always a
woman who is there for the first time. [...] Suddenly it was almost all Ukrainian women or one from
Moldova, but also of Ukrainian origin, and so on." 306
As soon as the [Ukrainian women] leave the camp,
they can do whatever they want. If I see another car taking
them alone, I start thinking, another one doing this.
[...] They are self-assigned, I cannot see any organization
behind it.
Manager of an accommodation centre in Bern, interviewed in 2023 307
Several key informants mentioned Ukrainian women becoming involved in sex work and
prostitution - including online -, and transactional sex, due to their urgent need for
accommodation and the difficulty of finding work in other sectors (see, for example, Case Studies
1 and 2 in chapter 7). 308 A report by UNHCR in Poland on risks of gender-based violence and
sexual exploitation and abuse highlighted the power imbalance between refugees and providers
of accommodation as a key risk. 309
303 Key informant interview 2CH-K-07.
304 Germany, Federal Statistics Office (Destatis), "Gültig angemeldete Prostituierte in Deutschland am 31.12.2023 nach
Bundeslandern” (Translation: Validly registered prostitutes in Germany on 31.12.2023, by federal state), (12 July 2024):
www.destatis.de/DE/Themen/Gesellschaft-Umwelt/Soziales/Prostituiertenschutz/Tabellen/prostitutionstaetigkeit2023.html.
305 Key informant interviews 2DE-K-5; 2DE-K-07; 2DE-K-08; 2DE-K-09; 2PL-K-01; 2PL-K-05; 1 CH-K-03.
306 Key informant interview 2DE-K-08.
307 Key informant interview 1 CH-K-03.
308 Key informant interviews 2PL-K-01; 2PL-K-05; 2DE-K-05; 2DE-K-07; 2DE-K-09; 1 CH-K-03.
309 UNHCR, Surviving as We Can, (October 2023), op. cit.
72
5.5 Cross-border child trafficking
While no children were interviewed or surveyed for this research, key informants mentioned
indications of potential hazardous child labour 310 and child trafficking. For example, a group of
Ukrainian children were reportedly working on farms close to an accommodation centre in
Poland, and in construction, exposed to extreme temperatures and dangerous equipment (see
also Case Study 4 in chapter 7). 311
Other key informants mentioned teenage Ukrainian girls carrying out domestic work for host
families or for their own family members in coercive conditions. 312 Another key informant had
observed Ukrainian children aged around 12-14 years begging, with donation boxes with a
Ukrainian flag and documents indicating the organizations they were purportedly collecting
money for - not legally registered charities. 313
In March 2022, the Hague Conference on Private International Law (HCCH) called for a prohibition
on inter-country adoptions from Ukraine because of the conflict-related cross-border
displacement. 314 A key informant from a state authority in Ukraine considered that cross-border
trafficking for illegal adoption and sale of children had decreased because of the increased
difficulty of crossing Ukraine's air, land and sea borders. 315
However, there are indications of cross-border trafficking for illegal adoption from Ukraine. One
case that was prosecuted involved a former school principal at an orphanage in Zakarpattia
oblast in western Ukraine, who convinced an impoverished woman in Zhytomyr oblast in
northwest Ukraine to sell her infant boy to him for around US$5,000, 316 The State Migration,
Border Guard and Security Services of Ukraine investigated the case and the man was arrested by
the NPU in June 2023, just after he had crossed the border into Slovakia, together with the woman
and her baby. 317 The man was using documents identifying him as a volunteer from a charity, with
authorization in the Shlyach™ system to exit Ukraine. He had planned to give the woman the
money after exiting Ukraine, and he intended to sell the baby in an EU country for $25,000.
Criminal proceedings under article 149 (trafficking in persons) of the Ukrainian Criminal Code
were initiated. 319
310 Hazardous child labour is defined in article 3 of ILO Convention No. 182 concerning the Prohibition and Immediate Action for
the Elimination of the Worst Forms of Child Labour, 1 999, as: "work which, by its nature or the circumstances in which it is carried
out, is likely to harm the health, safety or morals of children" See: Halshka Graczyk, Towards the urgent elimination of hazardous
child labour, (ILO, 2018).
311 Key informant interview 2PL-K-05.
312 Key informant interviews 1 CH-K-1 0; 1 CH-K-1 1 .
313 Key informant interview 2PL-K-01 .
314 Information Note from the Permanent Bureau of the HCCH, "Children deprived of their family environment due to the armed
conflict in Ukraine: Cross-border protection and intercountry adoption", (16 March 2022). The HCCH is an intergovernmental
organization with the mandate to work on the harmonization of the rules of private international law in the area of international
family and child protection law, among other areas.
315 Key informant interview UA-K-04.
316 Ibid.
317 Ukraine, Ministry of Internal Affairs, NPU, "riojiipin 3aKapnarm saipuMana MonoBiKa, hkmm HaMaraBca Kynmn y Maiepi 1 1-mícaMHy
flMTMHy Ta npoflaTM 3a 25 tmcam flo/iapiB b poflMHy 3 CBponn (Translation: Transcarpathian police detained a man who tried
to buy an 1 1 -month-old child from his mother and sell it for 25 thousand dollars to a family from Europe), (26 June 2023).
318 The "Shlyach" system allows for Ukrainian men to travel abroad in order to transport humanitarian aid or cargo for the Ukrainian
Army. See section 4.2 on Paying for facilitation of irregular border crossing by Ukrainian men.
319 Ukraine, Ministry of Internal Affairs, NPU, (26 June 2023), op. cit.
73
In the early months of the war, the European Parliament expressed concern about the risks of
trafficking of women and babies for surrogacy and illegal adoption, calling on:
"the EU and its Member States to pay particular attention to the protection of surrogate mothers
during pregnancy, childbirth and puerperium and to respect all of their rights, as well as those of the
newborns" and stressing "the cross-border implications of this practice, as has been the case for
the women and children affected by the war against Ukraine" 320
Surrogacy is legal in Ukraine and has continued since February 2022. As an indication of the
extent of surrogacy in the country, the CEO of one of the largest companies providing surrogacy
services in Ukraine is quoted in an April 2023 media article stating that around 30 babies had
been born per month at their clinics through surrogacy since the beginning of 2022 - equating to
around 360 babies born through surrogacy per year. 321 In 2022, the Ukrainian authorities reported
to Europol about a criminal network operating in Ukraine and the EU, facilitating illegal adoptions
for EU nationals through surrogacy programmes. 322
According to a key informant in Ukraine, Ukrainian law enforcement identified an organized group
of 12 traffickers in mid-2023, operating in Kyiv and Kharkiv, who induced women to become
pregnant in order to sell the babies in countries where surrogacy is prohibited. The women were
recruited in impoverished locations that had been recently liberated by Ukrainian forces, paid
around €7,000 ($7,640) for one baby and threatened and intimidated. They were either subjected
to artificial insemination from a donor or implanted with a fertilized embryo. The organized crime
group received €50-70,000 ($55-76,000) per baby and was made up of doctors, other medical
staff, administrators and a lawyer. Ukrainian law enforcement prevented the removal of one child
abroad, confirmed the removal of seven more children, and was investigating around 40 more
cases. 323
320 European Parliament, European Parliament Resolution on the impact of the war against Ukraine on women (2022/2633(RSP)),
(5 May 2022).
321 Anette Dowideit, Dmytro Drabyk, Ilya Gridneff, Emily Schultheis, and Alfred Hackensberger, "Die Babyfabrik von Kiew"
(Translation: The baby factory of Kyiv), Welt, (6 April 2023).
322 Content analysis of Europol Monitoring Team Reports (EPMT) March - November 2022. Europol Unclassified - Basic
Protection Level.
323 Key informant interview UA-K-04.
74
6. Conclusions and Policy Implications
The mass displacement of Ukrainians and others across borders and within the country, in
response to the full-scale invasion of Ukraine in February 2022 and the ongoing war, triggered an
unprecedented refugee protection response. The refugee response in EU and non-EU European
countries - maintaining visa-free entry for refugees from Ukraine and facilitating rapid access to
temporary protection or equivalent legal residence statuses - largely prevented smuggling of
migrants. This was in a situation where over 6.7 million people from Ukraine sought refuge
abroad.
Regular journeys due to visa-free travel, and the resulting low levels of migrant smuggling,
combined with rapid access to the rights attached to temporary protection status, ensure that
refugees from Ukraine remain resilient to exploitation and trafficking in persons. Targeted
information campaigns, increased efforts to identify victims of trafficking, law enforcement
cooperation and other anti-trafficking policies and actions by state and non-state actors, in
Ukraine and in countries of transit and destination, may have further strengthened resilience. The
findings of this research suggest that these responses contributed to preventing and mitigating
trafficking in persons in the context of the conflict in Ukraine.
Certain vulnerabilities remain, however. The specific situation of Ukrainian men subject to martial
law and mobilization provisions prohibiting their departure from the country makes them more
likely to engage migrant smugglers to facilitate their journeys if they decide to travel to a country
of refuge. Such men may cross Ukraine's borders at an unofficial land border crossing point, to
evade interception by the Ukrainian authorities, and enter another country unofficially, usually
across rivers or mountains. Others use fraudulent or fraudulently obtained documents to qualify
for an exemption from the departure ban and cross at official border crossing points.
Both situations may involve engagement with criminal actors to facilitate irregular exit from
Ukraine, but migrant smuggling according to international law is only committed if a third party
facilitates irregular entry to another country or provides fraudulent travel documents for the
purposes of irregular entry.
This research identified a limited - though significant - incidence of Ukrainian men paying for
facilitation of irregular border crossings, with considerable sums of money changing hands
(around US$1 ,000-1 0,000 per person). This is an issue that requires a tailored response, to ensure
that this criminal industry can be dismantled, and a legal, policy and protection response that
ensures safety for refugee men who experience these dangerous journeys.
Ukraine has a comprehensive legal, policy and institutional framework for combating trafficking
in persons. The Government has placed an increased focus on the issue since February 2022,
though the ongoing war poses obstacles and challenges. The numbers of identified cases of
internal trafficking for forced labour, forced criminal activities and exploitation in armed conflict
have increased, while the overall number of trafficking cases identified in Ukraine has decreased.
75
Many identified and potential cases of trafficking in persons victimize internally displaced people
(IDPs) and residents at accommodation centres for vulnerable groups, such as drug-users,
homeless people and orphaned children. Some trafficking cases involve organized groups
operating under the guise of charitable organizations serving humanitarian needs. Children from
Ukraine are particularly vulnerable to trafficking for forced labour, domestic servitude and illegal
adoption, both in Ukraine and abroad. Surrogacy continues to take place in Ukraine, which
presents vulnerabilities to trafficking for expectant mothers, other young women and for infants.
The humanitarian and protection response should be supported and expanded in Ukraine,
particularly for groups especially at risk of trafficking, including children, IDPs and residents at
accommodation centres for vulnerable groups. The capacity of Ukrainian anti-trafficking
stakeholders needs to be supported and built to ensure that domestic and cross-border
trafficking can be effectively identified and referred, including forms of trafficking specific to or
exacerbated by the war. Ukrainian stakeholders should be supported to protect children from
forced labour, domestic servitude and illegal adoption, and to identify and refer potential cases.
Precarious employment situations in host countries make refugees from Ukraine vulnerable to
trafficking for forced labour. Refugees may work without a contract or with a contract that does
not adequately protect their labour rights. They may be underpaid or not paid at all, or have their
rights further eroded through sub-contracting or labour intermediaries. Indications of forced
labour are concentrated in certain sectors, such as domestic work, cleaning, agriculture and
factory work. Online tools such as social media and messaging apps may be used to recruit
refugees for forced labour.
Monitoring and enforcing the labour rights of refugees from Ukraine in host countries is of crucial
importance, ensuring that risks of trafficking for forced labour are mitigated and potential cases
are identified and referred, with a particular focus on sectors such as domestic work, cleaning,
agriculture and factory work.
The provision of accommodation to Ukrainian refugees by private hosts - often free-of-charge -
has been a welcome demonstration of solidarity in general, but the relationship of dependency
between refugees and their hosts has been abused by some hosts for the purposes of labour
exploitation and sexual abuse. Systems for the provision of accommodation to refugees by
private hosts should be regulated and monitored to ensure that individual accommodation
providers do not abuse the situation of dependency of refugees on their hosts for the purposes of
forced labour or sexual exploitation.
The involvement of Ukrainian refugee women in prostitution and sex work in host countries also
presents indications of vulnerability and sexual exploitation. This research uncovered several
potential cases of trafficking for sexual exploitation in prostitution, a phenomenon that is likely to
be underreported. There are also risks of sexual exploitation in online prostitution and sex work,
linked to high internet usage among the refugee population and demand from men in host
countries. The situation of Ukrainians sexually exploited in host countries - offline and online -
should be given proper attention to ensure that risks of trafficking are mitigated, and potential
cases of sexual exploitation are immediately identified and referred.
76
While the overall figures for the incidence of smuggling of migrants and trafficking in persons in
the context of displacement due to the war in Ukraine remain relatively low as of the time of
writing, there may be many reasons for non-reporting, underreporting or delayed reporting of
trafficking cases. Data and information that become available after the publication of this study
may alter the picture. This underlines the urgency of continuing to monitor smuggling and
trafficking affecting refugees from Ukraine, and trafficking of IDPs and others in Ukraine, to
ensure that the war does not claim additional victims of abuses, and that smuggling and
trafficking as potential forms of war profiteering are prevented.
The continuation of the legal and policy framework of maintaining visa-free travel and rapid
access to temporary protection - most recently extended in the EU at the time of writing until
March 2026 - together with the comprehensive anti-trafficking response, can hopefully continue
to mitigate the risks of trafficking in persons and smuggling of migrants, though more attention
should be given to vulnerable groups. These measures also show significant potential for
adaptation and application to other refugee displacements and migration movements in Europe
and elsewhere.
77
7. Case Studies
Case Study 1 - Ukrainian woman's experience of sexual exploitation
at a massage parlour in Berlin, Germany
Olena* is a young woman from Kyiv who moved to Warsaw a few years before 2022, learned
Polish, had a job and was accepted for a university programme:
"On 23 February 2022, 1 talked with my mom. They called me early in the morning, they thought that
something had started."
It became more difficult to rent accommodation in Warsaw after February 2022 and Olena could
not work full-time, as she had a student residence permit. She dropped out of university and lived
in shared flats while she waited for her application for a work permit and permanent residence
status to be processed. It was repeatedly rejected. She decided to move to Berlin and apply for
temporary protection: 7 needed to have rights in another country. I can't be illegal in another
country. If they didn’t help me in Germany, I would have apply for a visa to Canada."
Olena travelled by regular bus service to Berlin and applied for temporary protection. In order to
remain in Berlin and not be moved somewhere else in Germany, she needed to rent
accommodation in the city and obtain official registration of her address ("Meldebestatigung”).
This proved difficult and she was running out of savings:
"Then on [social media], I saw photos of a woman I knew, but not well. She was in Berlin. I texted
this woman to see if she could help, if she was renting out a flat or if she could host me. I explained
the situation and she told me that she could help me with the certificate of residence from a
landlord ["Wohnungsgeberbestatigung"].
"[...] This woman gave me an address in Berlin and told me they can help me. [...] There I met the
owner of the erotic massage place. [...] She said I needed to work there. I said I would work there in
order to sort out my documents. [I thought:] it’s not real prostitution, and if someone tries to force
me, I will protect myself.
"I had to pay [US$1 06] a month for a certificate of residence at another address in Berlin, [$31 9] a
month to live and work there, and a [$21 3] deposit in case I broke a mirror or something. [...] At this
massage place, there were women and girls with drug addiction problems. I’m just one example. I
spent my first night at this place, I cried and I was afraid. [...]. / didn't want to be somewhere illegal.
I knew I needed to have some rights. I just wanted to make it right, step by step. I was waiting for
the Immigration Authority but the volunteers at Tegel [first reception centre] had made a mistake in
my email address so I didn’t get the email for the appointment.
"Staying at the place was mentally very hard, you have no right to a normal life. I worked every day.
I saw 5-7 clients a day. The official working hours were from 10am to 10pm. But even at night they
woke me up if there were clients, at 1am or 3am. And in the morning, if there had been a client at
night and you didn’t do it, you had to pay money - [$ 1 28].
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'We earned about [$3,195] a month. But they always deducted money from our wages. From the
[$319] we earned each day the boss easily took [$213]. For one girl [young woman], the boss
earned around [$1 0,652] a month. The boss has many flats in Berlin and some cars.
"[...] It was not that they forced the women to stay, others were okay with it. Many girls [young
women] were addicted, others needed money. [...] They want you to buy expensive things, so you
need money. They don't want to see that you are saving money. It's not a place to talk about your
rights. It can be really dangerous; they can put drugs in your drinks or get angry.
"[...] / left for five days to go on a trip. After this trip, the boss was very angry that I was not working
24/7. She said I wasn't allowed to leave the place without asking her. After that they took my
passport, my money and my laptop. They said the room where I was sleeping and working was not
safe, they would put it in a safe and they didn't let me access the safe. I didn't know the combination.
After two days, when I asked for it back, they said I didn't need the passport. [...] That I can't leave
this place.
"When the boss left, I asked the cleaner, please give me my passport, my stuff, I will leave this place
right here and right now. We had a good relationship. I took my stuff and I left the place. The boss
tried to contact me several times, but I blocked all the phone numbers."
With assistance from NGOs, Olena was registered for integration and professional courses:
"I have money from the job centre, my bank account, maybe a registration address and a place to
live. [...]
I understood that I'm with good people. I plan to finish my degree remotely that I started in Poland.
I just want to live a normal life with my rights."
Refugee interview 2DE-M-01, Berlin, May 2024
*Name changed to protect anonymity.
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Case Study 2 - Ukrainian woman’s experience of sexual exploitation by
her accommodation host in Berlin, Germany
Oleksandra* a young Ukrainian woman, fled to Germany in the early months of the full-scale
invasion. She is university-educated and speaks English but not German. She arrived at the main
train station in Berlin with thousands of other women and children. She was approached by a
man, Carl*, who spoke English and said she could be standing there for days because there was
no online registration system in place. He offered her a place to sleep and said he would have a
job for her and would help with the residency papers.
Oleksandra had left her young child in Ukraine with her mother, who had fallen ill. Carl did not help
Oleksandra to apply for temporary protection or for social assistance at the job centre. As soon
as she moved in with him, Carl started pressuring her, asking her how long she was going to live
with him without paying anything. In the end, she paid him, under pressure, with sexual services,
for being allowed to stay there.
Then Carl started to exploit her in prostitution. He demanded: “now you should pay rent, now you
should pay for the shopping, the cleaner just came". She started engaging in prostitution as she
felt there was no alternative. He frequently physically assaulted her. She had nowhere else to live
and Carl kept taking her money.
At some point, Oleksandra told Carl that she was going to take the money she earned to return to
Ukraine to get her son. Carl physically assaulted her and she ended up homeless. She continued
to work in prostitution. During a police check, she was arrested, as she did not have an official
registration certificate to work in prostitution in Germany. The police confiscated her cash, took
her passport and her details at the police station, and referred her to a women's shelter. NGOs and
the women's shelter organized financial help for her. Oleksandra ultimately decided not to press
charges against Carl.
Case described by a key informant who supported the victim, 2DE-K-09, Berlin, April 2024
*Names changed to protect anonymity
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Case Study 3 - Ukrainian woman’s experience of forced labour in Warsaw
Galina* is a Ukrainian woman, originally from eastern Ukraine, who had been living in Kyiv for
years when the full-scale invasion began. She financially supports her children, who have health
issues, and her grandchildren. After three months living in state-provided accommodation in
Warsaw, an acquaintance offered Galina a room in the accommodation where he was living.
Galina found an employment agency on social media, which found her a job in cleaning services
at a private medical clinic. She works under a civil-law contract with the employment agency. She
earns around US$7.20 gross - $4.20 net - per hour. Galina's contract stipulates that she should
work a maximum of 250 hours per month. She was working additional hours, around 350
altogether. A manager at the employment agency forced her to sign additional papers stating that
she also works as a volunteer and threatened to fire her if she did not sign the contract. They pay
her for the additional hours in cash.
She works 15-16 hours a day to earn minimum wage. She arrives at 5:30am and cleans and
disinfects the entire clinic. After a surgery has taken place, she runs over immediately to clean
and prepare everything for the next procedure. She often has to run from cleaning up after one
surgery to another and does not have time to change her cleaning gloves in between. Chemicals
then enter through the gloves and injure her hands.
Many Ukrainian women working for this employment agency experience the same working
conditions as Galina. They are threatened and verbally harassed by the same person at the
employment agency, who tells them: “you should be grateful for what you have, you are in Poland
and not in Ukraine". Those who complained about their rights were fired immediately. They are
grateful to be employed, so they accept the fact that the employment agency is likely deceiving
them about their wages.
Galina is certain that she is not being paid the full amount for the 350 hours she works per month.
She does not feel that she can claim the wages owed to her because she would get fired. All the
Ukrainian workers earn the same gross pay per hour, but the net pay differs from person to
person. Galina believes that the representatives of the employment agency split whatever wages
they withhold from them among themselves.
Galina wants to bring her case to a lawyer, but she cannot afford to pay for it. 324 She does not
know what her rights are or where to go and she does not have time to seek assistance, with the
hours she is working and her family caring responsibilities.
Refugee interview, 2PL-M-02, Warsaw, February 2024
*Name changed to protect anonymity
324 According to information provided to UNODC by Permanent Mission of Poland to the United Nations Office and the International
Organisations in Vienna on 31 October 2024, there are options to access free legal aid in Poland, also for foreign citizens, which
is offered by various NGOs.
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Case Study 4 - Ukrainian family's experience of forced labour on a farm in
Switzerland
Helga* a widowed Swiss farm owner, was hosting Yulia*, a Ukrainian woman, and her three
children aged 16 and under. Helga showed Yulia and her children around the farm. She showed
them how to milk a cow and carry out other tasks. Helga then went away on holiday and left Yulia
and her children in charge, saying that they already knew how to milk the cows and run the farm,
so they could take care of everything.
Yulia and her children worked on the farm for a whole summer and were not paid for their work.
Helga told Yulia that since the family received social welfare payments, they would not receive
any wages. The working day was usually from 5am until the evening, sometimes until 9pm. Some
hired workers came during the summer to work on the farm, but mostly, Yulia and her children
were on their own.
Yulia was scared of being held liable in case there was any damage to the farm or if they did not
take care of it properly, so she felt like they had to work that summer. Eventually, Yulia found a way
of moving out of the farm. She was scared to be truthful about their experience. Host families give
recommendations about Ukrainian guest families, and this is then attached to each family's
dossier. Yulia did not want to receive a bad recommendation.
Case described by key informant who supported the victim, 2CH-K-03, Bern, January 2024
*Names changed to protect anonymity
82
Case Study 5 - Trafficking of IDPs for forced labour in Ukraine
The head of an NGO managing an accommodation centre for IDPs in Lviv oblast in western
Ukraine referred a Ukrainian IDP couple, Viktoria* and Yury* to his own farm for work. Viktoria is
alleged to have milked goats in harsh conditions, without proper protective clothing, leading to a
severe skin condition. Despite her deteriorating health, she received no medical support or
medication. Subsequently, Yury also began working on the farm, while they sent their children to
a boarding school due to the lack of local schools.
Because of their working hours, Viktoria and Yury lived on the farm, in a dilapidated space with no
shower, toilet or proper kitchen. Their belongings were damaged by moisture and rodents.
Besides tending to the goats, they looked after other animals on the farm, guarded the farm
premises, and secured fishponds from fishers who did not have a permit. Viktoria and Yury are
reported to have worked from dawn until dusk, often without holidays or days off on weekends,
for twelve months. They were alleged to not have been paid and received leftovers from a hotel
kitchen or took eggs and goat milk from the farm to sustain themselves.
This was allegedly justified as payment for the room that had to be kept for Viktoria and Yury's
children during their school breaks, though they were living at the boarding school. The situation
escalated when the couple demanded wages owed them and the return of Viktoria's bank card,
leading to a heated conflict. The family's circumstances finally came to the authorities' attention
after an altercation prompting the involvement of the police in August 2023, followed by a court
case in November 2023. As of June 2024, a criminal case was ongoing before a Lviv court.
Court records; additional information provided by key informant UA-K-02 in March 2024 325
*Names changed to protect anonymity
325 The account is based on key informant interview UA-K-02 and on court records for criminal case no. 1 20231 40000001 007 of 1
September 2023. See the original indictment in: Ukraine, Halych District Court in Lviv City, case no. 461/9758/23, 20 November
2023: https://reyestr.court.gov.Ua/Review/1 1 502381 0. The details of the case described in the interview match those of the court
proceedings.
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8. Methodological Annex
This UNODC research study applied a phased, mixed-methods approach to analyse the evolution
of trafficking in persons and smuggling of migrants since the beginning of the full-scale invasion
of Ukraine in February 2022. Field research was conducted in three cities - Berlin, Warsaw and
Bern. The approach combined collection and review of relevant statistics, data, official records
and literature, with a survey and two phases of in-depth interviews with key informants and
refugees, culminating in the triangulation and analysis of the data and information obtained
through the different methods.
Figure 1 3: Research methodology for the study
0 1 . Develop Methodology and Research Tools
MJ 2. Literature Review
3. Statistics, Data, Records
4. Survey in Berlin, Bern, Warsaw
5. Two Phases of Interviews
6. Analysis and Triangulation
1. The overall research methodology and approach, and the individual research tools: sampling
strategy, in-depth interview guidelines, focus group guidelines, code of conduct (research ethics)
and referral protocols in the case of protection issues, were co-developed by UNODC and the
implementing partner Mixed Migration Centre (MMC). The methodology and tools apply UNODC
quality standards for research, as well as ethical principles and actions for conducting research
with vulnerable groups.
84
2. UNODC conducted a comprehensive literature review of sources relevant to the research topic.
During the period March 2022 - September 2024, many organizations, institutions and
researchers published relevant research, which informs and contextualizes the analysis of
available statistics, and the field research data.
3. Data and information on Ukrainians identified as trafficked since 2022 were collected through
UNODC's regular global data collection exercise on trafficking in persons. Administrative data on
trafficking and smuggling were also obtained from regional and national statistical reports and
public databases. UNODC also collected data on trafficking inside Ukraine and on the national
anti-trafficking response, in cooperation with the specialized unit for the investigation and
prosecution of trafficking in persons cases at the Office of the Prosecutor General (OPG) of
Ukraine, set up in 2022.
Table 1: Field research overview
Bern/CH Berlin/DE Warsaw/PL Regional Ukraine Total
Ukrainian refugees
surveyed in 2023 584 332 507 - - 1414
Non-Ukrainians surveyed
in 2023 9 78 102 - - 188
Total survey respondents 593 400 609 - - 1602
Key informants 2023 16 14 13 4 - 47
Key informants 2024 9 11 7 4 5 36
Refugees interviewed
2024 3 1 2 - - 6
Total interviewees 28 26 22 8 5 89
4. For the survey conducted for this research, the implementing partner MMC used a
non-randomized, purposive sampling approach for quantitative data collection, monitoring for
gender and age. The sample was non-probabilistic and aimed to achieve diversity. Respondents
were identified primarily through social networks and access to targeted and diverse places of
residence such as hostels, shelters and private accommodation.
Surveys were conducted with 1,602 people in Germany, Poland and Switzerland. The surveys were
conducted face-to-face during the period 31 January - 26 April 2023 in Berlin, Germany (400),
Warsaw, Poland (609) and Bern, Switzerland (593) with people who left Ukraine after January
2022. 1 ,41 4 of the survey respondents (88%) are Ukrainian citizens, from various regions (oblasts
- oójiacTki) in Ukraine: Kyiv (city) (23%) and Kyiv Oblast (9%); Kharkiv (9%); Dnipropetrovsk (7%);
Odesa (5%); Zaporizhzhia (5%); Lviv (5%); and Vinnytsia (4%). 96 per cent of the Ukrainian citizens
surveyed identify ethnically as Ukrainian, six per cent as other ethnicities and one per cent as
Russian (multiple responses possible).
85
183 survey respondents are from other non-EU countries - nine in Bern, 99 in Warsaw and 75 in
Berlin. They were living in Ukraine prior to 2022 and comprise 1 03 Belarussians (mostly surveyed
in Warsaw), 1 7 Moldovans, 1 3 Azerbaijanis, 1 1 Armenians and seven Russians, and less than five
people from each of: Morocco, Georgia, Syrian Arab Republic, India, Islamic Republic of Iran,
Tiirkiye, Israel, Tajikistan, Turkmenistan, Nigeria, Iraq and Kyrgyzstan. An additional six
respondents, surveyed in Berlin and Warsaw, are EU citizens who had been living in Ukraine in
February 2022. They are from Romania, Hungary, Latvia and Czechia.
Survey respondents comprise 1,209 women (75%), 391 men (24%) and two other/NA/refused
(1%). Half the respondents are aged 25-44 years, with the remainder aged 45-64 (23%), 18-24
(19%) and over 65 (7%) years old. 37 per cent of respondents are married, while 48 per cent of
men and 36 per cent of women are single. 11 per cent (170/1,602) are separated or divorced,
seven per cent (106/1,602) are widowed and seven per cent (106/1,602) are in a domestic
partnership. Most respondents who answered the question identify as heterosexual (1 ,41 2/1 ,460
or 97%), while three per cent (42) identify as LGBTIQ+. 326 Just over half (53%) began their journey
within the first two months of the full-scale invasion.
The vast majority of respondents completed secondary school (96%) and the majority have a
university degree (60%), with the next largest group having completed vocational training (23%).
A higher percentage of women surveyed have a university degree compared to men (62% vs.
53%). Around one-third (30%) of survey respondents travelled from Ukraine to the country where
they were surveyed with their children; another one-third (30%) travelled alone; 24 per cent with
family members; 21 per cent with their partner; and 1 1 per cent with friends (multiple responses
possible). A slightly higher proportion of men travelled alone (34%) or with partners (35%). More
women (34%) than men travelled with their children. Women also accounted for the majority of
people travelling with other people's children (85% or 29/34).
5. Sixty-four key informant interviews were carried out with 78 individuals in the three cities of
study, in Ukraine, and at regional level (remotely), identified on the basis of their relevant expertise
and experience. The interviews were carried out in two phases, during December 2022 to May
2023 and January to June 2024. Key informants include representatives from national and local
government authorities, local, Ukrainian diaspora and international NGOs, UN agencies,
community leaders, researchers and journalists. Five key informants identified as having
significant expertise were interviewed twice, once in each phase, allowing for a deeper
exploration of key themes and how they evolved over time.
326 LGBTIQ+ refers to people who self-identify as lesbian, gay, bisexual, transgender, intersex, queer or other minority sexual
orientations or gender identities. See: www.un.org/en/lgbtiq-people.
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Figure 14: Key informant interviews
Interview Code Country of interview Type of key informant Date
of interview
1. 1CH-K-01 Switzerland Local authority 20.04.2023
2. 1CH-K-03 Accommodation centre 20.04.2023
3. 1CH-K-04 Civil society 19.04.2023
4. 1CH-K-05 Civil society 26.04.2023
5. 1CH-K-06 NGO 26.04.2023
6. 1CH-K-07 Accommodation centre 21 .04.2023
7. 1CH-K-08 NGO 21.04.2023
8. 1CH-K-09 NGO 24.04.2023
9. 1CH-K-10 Psychologist 21 .04.2023
10. 1CH-K-11 NGO 21.04.2023
11. 1CH-K-12 Federal authority 27.04.2023
12. 2CH-K-01 NGO 30.01.2024
13. 2CH-K-02 Ukrainian social worker 30.01.2024
14. 2CH-K-03 NGO 31.01.2024
15. 2CH-K-04 Ukrainian social worker 01 .02.2024
16. 2CH-K-05 NGO, repeat interview 21.02.2024
17. 2CH-K-06 NGO 29.02.2024
18. 2CH-K-07 NGO 27.03.2024
19. 2CH-K-08 Ukrainian community 20.03.2024
20. 1 PL-K-01 Poland Expert/analyst 03.05.2023
21. 1PL-K02 Academic 04.05.2023
22. 1PL-K-03 Journalists 24.04.2023
23. 1 PL-K-04 Research centre 06.12.2022
24. 1PL-K-05 NGO 27.06.2023
25. 1PL-K-06 NGO 05.05.2023
26. 1 PL-K-07 International organization 06.05.2023
27. 1PL-K-08 Independent stakeholder 05.05.2023
28. 1PL-K-09 Civil society 26.06.2023
29. 2PL-K-01 NGO 14.02.2024
30. 2PL-K-02 NGO, repeat interview 15.02.2024
31. 2PL-K-03 NGO 15.02.2024
32. 2PL-K-04 NGO 1 6.02.2024
33. 2PL-K-05 International NGO 20.02.2024
34. 2PL-K-06 Academic, repeat interview 27.02.2024
35. 1DE-K-01 Germany NGO 26.04.2023
36. 1DE-K-02 NGO 26.04.2023
37. 1 DE-K-03 NGO 27.04.2023
38. 1DE-K-04 NGO 28.04.2023
39. 1DE-K-05 Researcher 27.04.2023
40. 1DE-K-06 NGO 07.12.2022
41. 1DE-K-07 Local authority 28.04.2023
42. 1DE-K-08 Federal authority 04.05.2023
43. 1DE-K-09 NGO 25.04.2023
44. 1DE-K-10 Ukrainian community 31.03.2023
45. 1DE-K-11 NGO 18.05.2023
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Interview Code Country of interview Type of key informant Date
of interview
46. 2DE-K-01 NGO, repeat interview 06.03.2024
47. 2DE-K-02 NGO 12.03.2024
48. 2DE-K-03 Research centre 12.03.2024
49. 2DE-K-04 NGO 13.03.2024
50. 2DE-K-05 NGO, repeat interview 13.03.2024
51. 2DE-K-06 NGO 13.03.2024
52. 2DE-K-07 NGO 14.03.2024
53. 2DE-K-08 NGO 20.03.2024
54. 2DE-K-09 NGO 05.04.2024
55. 2DE-K-10 NGO 09.04.2024
56. UA-K-01 Ukraine NGO 17.03.2024
57. UA-K-02 NGO 27.03.2024
58. UA-K-03 Lawyer/human rights defender 06.06.2024
59. UA-K-04 National authority 20.05.2024
60. UA-K-05 International development project 20.06.2024
61. IN-K-01 Regional Journalists 03.05.2023
62. IN-K-02 International organization 16.05.2023
63. NL-K-01 Netherlands National authorities 13.06.2024
64. NL-K-02 NGO 14.06.2024
A total of 47 key informants participated in 34 interviews for this research during December 2022
to June 2023. The key informants are based in Bern (16), Berlin (14), Warsaw (13), and regional.
During the period February to June 2024, 36 key informants participated in 30 interviews (five of
which were repeat interviews of the same person interviewed in phase 1 ( carried out in Berlin (1 0),
Bern (7), Warsaw (6), Ukraine (Lviv and online) (5) and The Hague, Netherlands (2). The key
informants comprise 60 women and 18 men.
Six in-depth interviews were carried out with five Ukrainian women and one Ukrainian man in the
cities under study, who experienced situations that present indicators of potential trafficking in
persons cases (see Case Studies in Chapter 7).
While every effort was made to ensure that the research was as comprehensive, representative
and objective as possible, some limitations should be noted. The survey respondents were
selected non-probabilistically, as a convenience sample, which presents limitations in terms of
the extent to which the analysis can be generalized to the entire refugee population. Due to the
ethical and practical implications of such research, no children (anyone aged under 18 years)
were interviewed or surveyed. This means the information and analysis regarding children in this
study is at one remove from children themselves, and drawn from surveys and interviews with
adults, as well as from data and literature.
While around two-thirds of the population of adult refugees from Ukraine in Europe are women,
around three-quarters of the survey respondents are women, meaning that women are slightly
over-represented in the sample. In addition to Ukrainians, the research also covers the
experiences of non-Ukrainians who fled Ukraine since February 2022. In Berlin, diversity in this
sample was achieved, while in Warsaw, this group mainly comprised Belarusians and in Bern this
was not achieved. Efforts were also made to include the experiences of Ukrainian Roma people
who were displaced, directly through the survey and indirectly through key informant interviews,
but these cannot be taken as representative due to the low numbers involved.
88
The research methodology initially foresaw a higher number of interviews with people who
directly experienced trafficking in persons and/or smuggling of migrants, but significant
challenges were experienced in achieving this. This is due to a combination of the difficulty of
contacting a vulnerable and mobile population and the welcome fact that there are relatively few
people in the study countries who have experienced trafficking or smuggling.
Finally, the administrative and criminal justice data on trafficking in persons included and
analysed in the study mainly date from the year 2022. At the time of writing, data for 2023 and
2024 was not generally available. Indeed, some of the data reported for 2022 refer to trafficking
cases identified prior to that year and therefore do not relate to the experience of people who fled
the full-scale invasion. This means that data for 2023-2024, as and when they become available,
may indicate a different incidence of trafficking cases than is reflected in this analysis, based on
the sources available in late 2024.
In terms of the scope of this study, the research covers trafficking in persons and smuggling of
migrants outside Ukraine, and trafficking in persons inside Ukraine, in territories under the control
of the Ukrainian Government.
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9. Annex: Information provided to UNODC by the Government of Ukraine on actions
taken to combat trafficking in persons
- as of 5 December 2024 -
According to the National Police of Ukraine (NPU), the Migration Police Department has been
participating in the work of the European Multidisciplinary Platform against Criminal Threats
(EMPACT) 327 since 2022, which is a key EU tool in the fight against organized crime. As a result
of the full-scale military invasion of Ukraine by the Russian Federation, the implementation of the
EMPACT Operational Plans to combat human trafficking, illegal migration and child sexual
exploitation has become a priority area in combating these types of crime, protecting Ukrainian
citizens from falling victim to human trafficking and establishing inter-institutional and
international cooperation in these areas.
At the initiative of representatives of the NPU, in 2023, item 8.5 of the EMPACT Operational Plan
to Combat Human Trafficking for 2024-2025 328 included the collection of information regarding
the deportation of Ukrainian children to the Russian Federation. In 2023, the NPU participated in
the implementation of 20 out of 24 points of the Operational Plan, particularly on combating
human trafficking in the Eastern Partnership countries, 329 with an emphasis on Ukrainian citizens
who moved to other European countries due to the full-scale invasion of Ukraine, as well as on the
points of the Operational Plan providing for holding Joint Action Days: "global chain", "against
labour exploitation linked to agricultural sector" and "labour exploitation". In 2024, Ukraine
continued to ensure its participation in the implementation of the Operational Plan. During
2023-2024, NPU representatives continued to participate in monthly meetings of the UATF
taskforce, established in 2022 under the auspices of Europol to combat trafficking of Ukrainians
who fled to other European countries in connection with the full-scale invasion.
The Government of Ukraine has also put in place measures to provide administrative services and
issue passports to Ukrainian citizens outside the country, including a pilot project (Resolution No.
648 of the Cabinet of Ministers of Ukraine dated 4 June 2024, which entered into force on 30 June
2024 and was in effect until the entry into force of the Draft Law of Ukraine No. 3709-HX dated 9
May 2024 "On Amendments to Certain Laws of Ukraine Regarding the Provision of Certain
Administrative Services to Citizens of Ukraine, Including Abroad"). 330 The Ukrainian State
Migration Service has developed a draft Resolution of the Cabinet of Ministers of Ukraine to
implement the law ("Some issues of registration (including in place of a lost or stolen one) and
exchange of a passport of a citizen of Ukraine and a passport of a citizen of Ukraine for traveling
abroad, including those residing abroad"). The registration and issuance of a passport for a
citizen of Ukraine is carried out in accordance with the Procedure for registration, issuance,
exchange, transfer, seizure, return to the state, invalidation and destruction of a passport of a
citizen of Ukraine (Resolution of the Cabinet of Ministers of Ukraine No. 302 dated 25 March
2015).
327 See European Commission, "EMPACT Fighting Crime Together", (25 June 2024):
https://home-affairs.ec.europa.eu/policies/law-enforcement-cooperation/empact-fighting-crime-together_en.
328 Council of the EU, "Operational Action Plan 2024-2025: Trafficking in Human Beings", (23 November 2023):
https://data.consilium.europa.eu/doc/document/ST-14544-2023-REV-1/en/pdf.
329 The six countries participating in the EU’s Eastern Partnership are: Armenia, Azerbaijan, Belarus, Georgia, the Republic of
Moldova and Ukraine: www.eeas.europa.eu/eeas/eastern-partnership_en.
330 The Law is available in Ukrainian at: https://itd.rada.gov.ua/billlnfo/Bills/Card/43720.
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