• Expand legal protections for domestic workers that are equal to those of private sector workers.
• Ensure all front-line officials adequately and consistently use screening protocols during law enforcement action, labor inspections and prior to deportations, specifically when encountering vulnerable groups, such as individuals in commercial sex, domestic workers who left their employer, migrant workers, and deportees.
• Fully implement the WPS, including by holding accountable violators with deterrent penalties, and ensure officials screen all wage theft cases for other trafficking indicators and refer such cases for criminal prosecution.
• Expand the WPS to include domestic workers.
• Prohibit passport confiscation with deterrent penalties that apply to all workers, address concerns of employers “losing” worker’s passports, and train officials to consider passport confiscation as a trafficking indicator.
• Provide targeted training to law enforcement and prosecutors on trauma-informed and victim-centered practices during law enforcement and court proceedings and when engaging with victims.
• Fully implement screening procedures for domestic workers upon arrival to Bahrain and ensure domestic workers sign a contract in their own language and in the presence of a labor official to improve oversight of contract switching.
• Continue to conduct national anti-trafficking awareness campaigns, strategically targeting migrants, domestic workers, and employers.
• Use orientation programming to ensure workers have not paid recruitment fees and are not subject to contract switching prior to traveling to Bahrain.

The government increased anti-trafficking law enforcement efforts.

The anti-trafficking law, No. 1 of 2008, criminalized sex trafficking and labor trafficking and prescribed penalties ranging from three to 15 years’ imprisonment, plus a fine between 2,000 and 10,000 Bahraini dinar (BD) ($5,315-$26,525) and the cost of repatriating the victim(s). These penalties were sufficiently stringent and, with respect to sex trafficking, commensurate with penalties prescribed for other grave crimes, such as rape.

During the reporting period, the Ministry of Interior (MOI) investigated 44 cases involving 101 alleged traffickers – 12 for sex trafficking and 32 for labor trafficking – compared with 54 investigations in the previous reporting period. Investigations of four alleged labor trafficking cases involving seven defendants (including two companies) initiated in previous reporting periods remained ongoing. Officials prosecuted 48 perpetrators, including 39 alleged sex traffickers in nine cases and nine alleged labor traffickers in five cases, compared with 38 prosecutions in the previous reporting period. Courts convicted 55 traffickers, including 46 for sex trafficking and nine for labor trafficking, a significant increase compared with 24 convictions in the previous reporting period. Officials sentenced all traffickers to between one- and 10-years’ imprisonment plus a fine. Upon appeal, four sex traffickers were acquitted of trafficking charges, while 19 sex traffickers’ convictions and five labor traffickers’ convictions were upheld. The government required convicted traffickers to pay costs associated with the repatriation of victims and planned to deport all non-Bahraini traffickers upon completion of their sentences. The government did not report any investigations, prosecutions, or convictions of government employees complicit in human trafficking crimes. MOI’s Directorate of Criminal Investigation and Forensic Science (CID) maintained a police unit dedicated to trafficking investigations. The Public Prosecution Office (PPO)’s Trafficking in Persons Unit prosecuted all trafficking crimes under the 2008 anti-trafficking law and ensured victims had access to legal recourse and adequate protection services and assistance. The First High Criminal Court remained dedicated to handling trafficking cases exclusively through specialized judges and staff.

Although observers reported government officials and frontline authorities sometimes handled labor law violations administratively rather than investigating indicators of trafficking, labor-focused authorities continued to refer suspected labor trafficking cases to law enforcement for criminal proceedings. The Labor Market Regulatory Authority (LMRA)’s Protective Inspection Directorate (PID) and Grievances and Protections Directorate (GPD) continued to identify and refer labor trafficking cases for criminal prosecution, specifically those that originated as labor violations and continued to be incorporated into the government’s broader NRM. PID’s investigators could refer potential trafficking cases (either referred by GPD or identified through PID inspections) directly to the PPO, which often forwarded the cases to CID to conduct a follow-up investigation for additional information to aid in prosecution. During the reporting period, PID referred an unknown number of alleged labor trafficking cases involving 38 potential trafficking victims to the PPO through this process; GPD also referred three potential trafficking victims to the PPO for further investigation after screening them upon arrival at the LMRA’s Expatriate Protection Center (EPC). Officials reported prosecutors had sole authority to determine and confirm trafficking cases and led in the investigatory phase of cases, directing law enforcement to execute warrants and arrest alleged traffickers. Observers reported prosecutors often prioritized pursuing cases they anticipated would result in successful prosecutions, sometimes resulting in the denial of more complex cases, including alleged labor trafficking cases. Of the cases referred to the PPO by the LMRA involving 41 potential trafficking victims, officials prosecuted at least one labor trafficking case. Separately, seven of the 32 alleged labor trafficking cases criminally investigated by law enforcement were referred for prosecution during the reporting period. In 2024, the government established a taskforce with relevant stakeholders to exchange knowledge and align understanding of the definition of labor trafficking, elements of the crime, and evidence thresholds between authorities.

The government trained – directly and in partnership with an international organization – law enforcement, judges, prosecutors, LMRA staff, NRM personnel, diplomatic staff, labor inspectors, shelter staff, medical staff, airline personnel, hotline operators, and media representatives on various anti-trafficking topics, including proactive identification and screening, trafficking indicators, applying the anti-trafficking law, and NRM procedures. The government continued its training of trainers program for labor inspectors, prosecutors, NRM personnel, law enforcement, medical and airline personnel, and shelter staff to enable them to share expertise on victim identification and trauma-informed practices in Bahrain. Investigators from CID’s anti-trafficking unit trained on screening and identifying trafficking indicators often accompanied immigration officials during law enforcement action and immigration inspections to provide victim identification expertise. During the reporting period, law enforcement and LMRA staff conducted a separate training session on recently implemented screening tools employed in “prostitution” cases and in deportation centers to improve prospects of victim identification. Experts reported both law enforcement and prosecutors would benefit from additional training on trauma-informed and victim-centered practices during law enforcement and court proceedings.

The government increased victim protection efforts.

The government identified 32 trafficking victims, compared with 37 victims in the previous reporting period. The 32 victims identified included 19 female sex trafficking victims and 13 labor trafficking victims (seven women, four men and two girls). The government referred all 32 victims to care; two victims declined shelter but received other services, and officials referred the two child victims to the government shelter and specialized care in coordination with the Ministry of Social Development’s Child Protection Center. The government also provided assistance, including shelter, to 51 potential trafficking victims. The government continued to utilize its NRM to proactively identify victims, ensure proper documentation of cases, refer cases to the MOI and PPO for an official determination, and provide protection services to victims until case resolution or voluntary repatriation. Officials provided English and Arabic NRM booklets to all relevant ministries, labor-source country embassies, and NGO stakeholders. Police stations, other government entities, NGOs, religious organizations, and foreign embassies directly referred victims to the LMRA.

The LMRA’s EPC provided services to workers regardless of sex or legal status in the country, including shelter for potential trafficking victims, persons who experienced severe labor exploitation, and persons vulnerable to exploitation. The EPC provided separate spaces for men, women, and children with a maximum capacity of 400 individuals. The government allocated 255,606 BD ($678,000) for direct victim protection and assistance, an increase from 197,191 BD ($523,054) in the previous reporting period. The EPC provided victims and potential victims with shelter, food, clothing, medical care, religious support, psycho-social care, transportation, employment assistance, assistance with remittances, familial reunification, translation services, reintegration and repatriation support and legal counsel.

Observers reported the PPO was inconsistent in determining a trafficking crime had occurred. Access to the EPC was not contingent on this determination, but an official determination by the PPO was necessary for victims to be eligible for the Victim Assistance Fund. The government provided 27 trafficking victims 1,131 BD ($3,000) to support their reintegration upon confirmation of their victim status by the PPO. The government offered job placement in Bahrain to victims who desired to remain in the country to work and provided a new work permit to one labor trafficking victim. The government reported trafficking victims were eligible to sponsor their own work visas through the Labor Registration Program (LRP), and the government could use victim assistance funds to pay the registration fees for a victim’s work permit. LMRA provided funding for repatriations and financed GPD operational expenses. Embassies of labor-source countries also provided housing on a temporary basis for potential victims who decided not to go to the EPC.

Due to inconsistent screening among vulnerable populations, including migrant workers, deportees, workers who fled abusive employers and individuals in commercial sex, the government did not take effective measures to prevent the inappropriate penalization of potential victims solely for unlawful acts committed as a direct result of being trafficked. Observers reported officials periodically arrested potential victims of domestic servitude who fled abusive sponsors for immigration violations, sometimes immediately deporting such workers without screening for trafficking indicators. The government implemented a screening form when interviewing individuals in detention centers pending deportation to identify trafficking victims among this population. However, officials reported no victims were identified as potential victims via this screening tool. The government continued to conduct joint-ministry inspections through an LMRA-MOI taskforce – which intended to identify non-compliant employers, potential trafficking victims, and workers in violation of labor and residency laws and enhance ministerial coordination on victim referral, particularly for labor trafficking cases. As a result of over 28,000 inspections, officials identified 84 potential trafficking victims, referred 38 potential victims to the PPO and deported over 5,000 foreign workers; this suggested ongoing gaps in officials’ use of screening tools, particularly in deportation centers and during joint inspections. Observers continued to report some migrant workers who fled abusive visa sponsors chose not to report abuse to authorities out of fear of deportation. The government generally did not proactively monitor establishments known for commercial sex and instead only investigated such cases if an individual filed a report with authorities. However, officials continued to implement, though infrequently, a screening tool to identify sex trafficking victims during law enforcement action; officials identified 40 potential sex trafficking victims these actions, of which the PPO confirmed 19 as victims.

Bahraini officials provided comprehensive protective assistance to all official victims regardless of their willingness to participate in criminal justice proceedings and relieved them from all legal and financial penalties related to acts committed as a direct result of being trafficked. The government shared a full evaluation of their case with the victim and their legal right to restitution in the event of a conviction. The law provided victim-witness assistance to anyone providing information during criminal justice proceedings, and the government reported it kept confidential the identities of all persons through the stages of the NRM. The LMRA continued to utilize a specialized office responsible for liaising with victims, law enforcement, and prosecutors to ensure adequate victim-witness assistance during criminal justice proceedings. The government reported victims could testify via written correspondence, video recording, a closed-circuit live video, or in private; however, the government reported no victims required or requested to testify through these methods. Victims could speak in their native language in court proceedings with the assistance of an interpreter. The government reported all 28 identified victims, and 43 potential victims participated in law enforcement investigations; the government has not reported a victim declining to participate in law enforcement investigations in the last five years. Experts expressed concern that high rates of participation indicated victims were not given a choice to participate, felt they could not safely decline participation, or were ultimately not considered a victim if they chose not to participate. No victims participated in court proceedings due to requests for immediate repatriation.

Observers reported concerns the requirement for all case-related documents to be translated into Arabic before being presented to judges created difficulties in seeking redress for some foreign victims. Observers also noted the process for submission of labor complaints was opaque, and reported situations where vulnerable workers, including potential trafficking victims, were not provided a copy of their submission, limiting their ability to access remedy. Some workers did not file complaints against employers due to distrust of the legal system, protracted court processes, inability to afford legal representation, lack of interpretation and translation services, concern over potential loss of residence permits during proceedings, and fear of additional mistreatment due to employer reprisal. The government reported it could award restitution during criminal proceedings, while victims could file civil suits to receive compensation; however, the government did not report awarding restitution or victims filing such civil suits.

The government maintained efforts to prevent trafficking.

The National Committee to Combat Trafficking in Persons (NCCTIP) – composed of government ministries and three civil society organizations – led government anti-trafficking efforts; it met four times as a full committee. The government drafted a national human trafficking strategy, which remained pending Cabinet and Prime Minister approval at the end of the reporting period. The government allocated 2,091,602 BD ($5,548,016) for prevention efforts, an increase compared with 1,582,404 BD ($4,197,360) in the previous reporting period. The government, in partnership with an international organization, conducted a national awareness campaign targeting foreign workers, employers, and the public on worker’s and employer’s rights and responsibilities, available grievance mechanisms and assistance, mental health resources, trafficking vulnerabilities and indicators, and contract and employment transfer regulations. The LMRA maintained a website with information on trafficking and resources for foreign workers; however, NGOs reported key information on the website was only available in English and Arabic. The LMRA continued to provide booklets outlining labor rights in languages common among expatriate and migrant worker populations and distributed them upon arrival at the airport and at the LMRA when applying for residence cards. Observers noted language barriers remained an obstacle for workers to access resources, particularly for domestic workers employed in private homes.

The EPC’s 24/7 anti-trafficking hotline collected reports and educated workers about their rights and available services in 11 languages. The government advertised the hotline’s number and mandate in pamphlets given to each migrant worker upon arrival in Bahrain and on the LMRA’s social media platforms and website. The government reported the LMRA’s trafficking hotline received 5,462 calls during the reporting period; hotline staff referred 189 individuals to the EPC. EPC staff did not identify any as potential trafficking victims but reported providing labor-related assistance to all individuals. The MOI’s hotline received 237 calls, investigated 18 for trafficking indicators and referred an unknown number to the PPO.

Article 23 of Bahraini Law No. 19 of 2006 prohibited worker-paid recruitment fees for all workers. However, observers noted migrant workers continued to report schemes in which prospective workers paid a recruiter in their home country, or more rarely, paid a recruiter in Bahrain, for employment or a work permit. Experts asserted the government did not adequately address this practice, provide support to workers who paid fees, or hold unscrupulous recruiters accountable. The LMRA reported handling six cases of worker-paid recruitment fees and referring the cases to the PPO for criminal investigation. The LMRA continued to oversee issuance of licenses and regulation of recruitment agencies through quarterly inspections, monitoring agencies for employment and immigration violations, and other measures. The government required employers provide workers with adequate accommodation and recruitment agencies to pay a one-time deposit equivalent to 10,000 BD ($26,530) to be forfeited if the company violated employees’ rights. PID inspections of recruitment agencies and employment offices resulted in the closure of one employment office that was referred for civil prosecution.

The government allowed all migrant workers, including domestic workers, freedom to change jobs without their employer’s consent after one year of employment, although the LMRA had to approve each transfer; the policy allowing workers to change employers may have reduced migrant workers’ vulnerability to trafficking. While the government did not previously publicize or announce the policy change allowing domestic workers to change jobs without their employers’ consent, it made efforts to raise awareness of the change in targeted LMRA locations frequented by domestic workers, their employers, and recruitment agents. All migrant workers remained able to terminate employment at any time, within the notice period specified in their contract, and leave the country permanently without employer consent.

The government continued to operate programs granting foreign workers the ability to work without a Bahraini visa sponsor, including the LRP, which allowed migrants to register at labor registration centers and obtain a work permit without a sponsor or contract. Such workers could register for a six-month, one-year, or two-year renewable permit; all permits included health insurance and departure flight ticket insurance. These programs allowed registered workers to hold multiple jobs concurrently with various employers and did not require technical certifications to register. Following registration, workers were auto-enrolled in a new service agreement portal to enable workers to document all employment agreements, which could be used as evidence in case of a civil dispute with their employer. The government required registered workers to attend orientation sessions to raise awareness of their rights as non-contract workers and available resources for grievances.

The LRP was available for workers with expired, cancelled or terminated contracts, regardless of their immigration status. In 2024, the government newly allowed workers with expired passports to update their status through registration without needing to renew their passport. However, migrants could not register with the LRP before arriving in Bahrain or after arriving on a tourist visa; this policy did not address workers’ vulnerability to trafficking upon first entering Bahrain – when they were still required to have a sponsor. Workers with legal charges filed against them, such as “absconding” or other criminal charges or contract violations, were not eligible to register. Domestic workers were eligible to register with the LRP following the expiration of their contract or in situations where their contract was cancelled or terminated due to a violation of their rights or abuse.

Observers continued to note registered workers were not entitled to rights and protections under the labor law (as they were not considered employees without a sponsor), increasing their vulnerability to trafficking. Authorities continued to provide administrative and technical support to registered workers in filing civil cases at the EPC; the government reported staff was trained to identify trafficking indicators during interviews with workers seeking to file complaints. Observers continued to report concerns registered workers lacked access to labor courts to specifically address disputes related to working conditions. The LMRA reported each registration center maintained a dedicated communication channel to receive inquiries and complaints from registered workers.

The government continued to make efforts to prevent trafficking and address wage theft, including through its WPS, which required employers to pay wages electronically to workers via financial institutions authorized by the Central Bank of Bahrain; the system encompassed private employers with one or more employees and automatically enrolled registered self-sponsoring workers. The government designed the system to alert the LMRA and MOL of non- or delayed-payment of wages with violators subject to penalties and legal action. However, officials reported participating banks had responsibility to report inconsistencies, as notification for delayed or underpayment of wages to the government was not automatic. Observers also noted not all workers had bank accounts and many received their salaries in cash, limiting the effectiveness of the system. The government began issuing all newly arrived workers IBANs and guidance on how to activate a bank account, which may improve employer compliance with WPS regulations and further prevent trafficking vulnerabilities. The government did not report penalizing employers for non-compliance and instead issued warnings, required a compliance plan and in some cases, suspended their ability to apply for new work permits. Observers and NGOs continued to report wage theft as a prominent issue for certain migrant and domestic workers in Bahrain, who, despite receiving IBANS upon arrival, were not required to be paid through the WPS. The LMRA also reported it received 4,740 claims of unpaid wages from workers during the year, referring 750 to labor courts for litigation. Separately, 505 cases of wage theft were referred to court; the government reported in several cases, employers were penalized – including through imposition of fines.

Articles 19 and 40 of the labor law established limited protections for individuals in the domestic work sector, requiring employers to provide a labor contract specifying annual leave and bonuses, and that such workers must be paid at least monthly. However, Article 22, which prohibited contract switching or changes to preset work conditions, was not applicable to domestic workers. Labor inspectors were unable to conduct unannounced inspections of domestic workers’ accommodations and had no other mechanism by which to investigate abuse allegations without an official complaint, increasing workers’ vulnerability to trafficking. Observers reported domestic workers frequently fled their employer’s home to remove themselves from abusive situations, further increasing their vulnerability to traffickers. As soon as employers reported a worker as “absconding,” they faced residency law violations and could be detained by officials. In other cases, domestic workers felt unable to leave exploitive working conditions due to abuse or threats of abuse, including nonpayment of wages in retaliation for seeking out new employment, physical abuse, threats of deportation or “selling” the worker to another employer without consent.

The LMRA continued to disseminate copies of the standard/tripartite labor contract to all registered recruitment agencies and private families seeking to recruit such workers in Bahrain, which required domestic workers to sign, prior to their arrival, a comprehensive work agreement outlining labor rights and employment obligations. The contract aimed to strengthen protections for domestic workers by requiring employers to disclose duties, hours of work, salary, rest hours, and weekly days off. Domestic workers brought to Bahrain by recruitment agencies and private families were able to accept or reject a contract in their respective countries of origin, and the LMRA maintained copies of signed contracts to assist in future labor disputes and mitigate contract switching, a key trafficking indicator. However, NGOs expressed concern that the standard contract lacked mandatory working conditions as it remained up to the employer to determine working hours, minimum wage, overtime pay, and rest time. In contrast, the labor law stipulated a maximum daily limit of eight working hours for other private sector workers. An executive regulation that would provide additional protections for domestic workers remained under review for the second consecutive reporting period. The government reported offering the standard contract in additional languages to ensure workers understood the contents of agreements. However, NGOs reported many domestic workers did not receive a copy of their contract or did not understand the contents. Observers reported instances of contract switching, particularly for workers who did not have embassy representation in Bahrain.

The government implemented a screening procedure for all domestic workers upon arrival at the airport through an electronic text to voice questionnaire regarding recruitment, employment, and their contract, conducted in the worker’s language. If discrepancies were found, officials allowed entry into Bahrain but also generated a case for the LMRA to verify the worker’s employment and prevent further exploitation, including trafficking. Officials reported screening 1,850 domestic workers using this tool and identified three domestic workers requiring additional employment verification. However, some domestic workers reported being unaware of LMRA’s screening procedures.

Bahraini law did not explicitly prohibit passport retention, and the practice remained pervasive. When cases of passport retention were reported, the LMRA reportedly screened the worker for trafficking indicators. In cases where employers refused to return a passport to the LMRA, officials imposed administrative penalties, including prohibiting issuance of new or renewing existing work permits and barring use of other LMRA services, and referred the case to law enforcement for legal action. Police generally did not consider passport retention to be a trafficking indicator, instead considering it stolen property if the employer refused to return it. The LMRA retrieved and returned 812 passports to migrant workers, a significant decrease from 1,719 in the previous reporting period; the government reported this reflected increased awareness among employers that passport confiscation was exploitive. Observers reported instances of employers losing workers’ passports or threatening workers for seeking government assistance, preventing potential trafficking victims from reporting abuse. The government reported a draft labor law amendment criminalizing passport confiscation was approved by the Cabinet but remained under review for the third consecutive year. Observers reported concerns the draft law allowed employers to keep worker’s passports with their consent and prescribed financial penalties would be an insufficient deterrent for future violators.

The government maintained MOUs with several labor source countries focused on recruitment agency oversight and migrant worker protections, and additional MOUs were in progress. Officials sought direct feedback from unofficial representatives of foreign communities on the conditions migrant workers experienced and facilitated workshops to increase awareness and utilization of government assistance. The LMRA launched an initiative to provide a physical space for foreign missions without embassies in Bahrain to provide consular services to their citizens, which may have prevented vulnerable populations from trafficking. The LMRA also conducted training sessions for labor-source embassy representatives on trafficking indicators experienced by migrant workers and protection services available at the EPC. In 2024, the government – in partnership with two international organizations – launched an orientation for employers of domestic workers. The government conducted an awareness session with prominent aluminum and oil companies in Bahrain, including its subcontractors, to emphasize ethical recruitment, indicators of labor trafficking, and clean supply chains. The government did not make efforts to reduce the demand for commercial sex acts.

Trafficking affects all communities. This section summarizes government and civil society reporting on the nature and scope of trafficking over the past five years. Human traffickers exploit foreign victims in Bahrain. Men and women, primarily from India, Bangladesh, Cameroon, Kenya, Pakistan, the Philippines, Nepal, Egypt, Sri Lanka, Jordan, Uganda, and Yemen, among other countries, migrate voluntarily to Bahrain to work as semi-skilled or unskilled laborers in the construction and service industries and domestic work sector – which includes agricultural workers, home security guards, nannies, drivers, and cooks. Men from India and Bangladesh account for the majority of Bahrain’s male domestic workers. The government reported there were approximately 78,900 domestic workers in Bahrain as of February 2024, 85 percent of whom were female, predominantly from the Philippines, Ethiopia, India, Indonesia, Kenya, Pakistan, and Sri Lanka. Domestic workers from African countries are increasingly at risk of labor trafficking and arrive in Bahrain via direct recruitment from local employers in which workers pay brokers or middlemen, including unlicensed recruiters, in their home country to match them with a visa sponsor in Bahrain. Reports increasingly indicate traffickers in countries of origin deceptively recruit skilled workers – including doctors and teachers, mostly from Africa – and upon arriving to Bahrain, force them into domestic work. Some employers subject migrant workers to labor trafficking in Bahrain; indicators include passport retention, confinement, contract substitution, denied overtime, non-payment of wages, debt bondage, excessive working hours, threats or intimidation, and physical or sexual abuse. NGOs and labor-source countries continue to report the prevalence of wage theft and debt bondage, especially among construction, security, hospitality, domestic workers and unskilled workers. Reports of unpaid overtime pay, end-of-service indemnity, and denied vacation time continue, particularly for workers employed by companies that declare bankruptcy or dissolve and domestic workers who are employed for several years, generating a large sum of end-of-service indemnity. Some migrant workers are not given or are not in possession of their employment contracts and are generally unfamiliar with the employment terms contained therein, increasing their vulnerability to trafficking. Passport confiscation – a key indicator of trafficking – remained pervasive, and observers reported increases in employers claiming they “lost” workers’ passports.

Nationals of countries without diplomatic or consular presence in Bahrain, most significantly from African countries, are particularly vulnerable to trafficking, as are domestic workers, who are only partially protected under Bahraini labor law and significantly isolated in their place of work. Government and NGO representatives report physical and sexual abuse of female domestic workers, controlled freedom of movement, withholding of workers’ identity cards and passports, restrictions on outside communication, and employer coercion to prevent employees from reporting exploitation remain significant problems. According to reports from the Cuban regime, there were Cuban regime-affiliated workers in Bahrain in 2022; however, government authorities confirm these workers departed the country. Any Cuban regime-affiliated workers who were present in Bahrain may have been forced to work by the Cuban regime. Traffickers recruit women to Bahrain via social media platforms or Bahrain-based acquaintances under false pretenses of high-paying jobs in the hospitality and domestic work sectors and subsequently force them into sex trafficking. Some unscrupulous employers bring migrant workers to Bahrain through visa trading or the “free visa” scheme – whereby workers pay an employer a recurring fee to sponsor their work visa while performing work for other employers in violation of local labor law – which can render them vulnerable to trafficking. Expatriates residing in Bahrain long-term reportedly can be complicit in the “free visa” scheme.