Citizens generally are free to practice the religion of their choice; however, police are normally ineffective in upholding law and order and are often slow to assist members of religious minorities who have been victims of crimes. Although the Government states that acts of violence against members of religious minority groups are politically or economically motivated and cannot be solely attributed to religion, human rights activists reported an increase in religiously-motivated violence.
The generally amicable relationships among religions in society contributed to religious freedom; however, the number of Hindu, Christian, and Buddhist minorities who experienced discrimination by the Muslim majority increased. During the period covered by this report, the Government was led by the centrist Bangladesh Nationalist Party (BNP), which heads a four-party coalition that includes two Islamic parties, Jamaat Islami and the Islami Okiyya Jote. The majority of Hindus traditionally vote for the opposition Awami League (AL). In the 300-seat Parliament, religious minorities hold 7 seats--4 for the AL and 3 for BNP. Six non-Muslims hold deputy or state minister or equivalent positions in the Government. In 2002 the newly elected BNP Government arrested and intimidated AL leaders and repealed key legislation passed by the previous AL administration. The acute animosity between the two mainstream political parties often leads to politically motivated violence and sometimes heightened societal tensions between Muslims and Hindus.
The U.S. Government discusses religious freedom issues with the Government as part of its overall policy to promote human rights.
Section I. Religious Demography
The country has a total area of approximately 53,000 square miles, and it has a population of nearly 140 million. Sunni Muslims constitute 88 percent of the population. Approximately 10 percent of the population is Hindu. The remainder of the population is mainly Christian (mostly Catholic) and Buddhist. Members of these faiths are found predominantly in the tribal (non-Bengali) populations of the Chittagong Hill Tracts, although many other indigenous groups in various parts of the country are Christian. There also are small populations of Shi'a Muslims, Sikhs, Baha'is, animists, and Ahmadis. Estimates of their populations vary from a few hundred to 100,000 adherents for each faith. Religion is an important part of community identity for citizens, including those who do not participate actively in religious prayers or services.
A national survey in late 2003 confirmed that religion is the first choice by a citizen for self-identification; atheism is extremely rare.
There is no reliable estimate of the number of missionaries, but several Christian denominations operate schools, orphanages, or other social programs throughout the country. Several dozen missionaries, primarily based in Dhaka and Chittagong, are engaged in social-development projects. Ethnic and religious minority communities often overlap and are concentrated in the Chittagong Hill Tracts and northern regions of the country.
Section II. Status of Religious Freedom
The Constitution establishes Islam as the state religion but provides for the right to practice--subject to law, public order, and morality--the religion of one's choice. The Government generally respects this provision in practice; however, some members of the Hindu, Christian, Buddhist, and Ahmadiya communities experience discrimination.
Religious organizations are not required to register with the Government; however, all nongovernmental organizations (NGOs), including religious organizations, are required to register with the Government's NGO Affairs Bureau if they receive foreign financial assistance for social development projects. The Government has the legal authority to cancel the registration of an NGO determined or suspected to be in breach of its legal or fiduciary obligations and to take other actions, such as blocking foreign funds transfers, to hinder its operation. During the period covered by this report, the Government took action in a nontransparent manner against six NGO's perceived as anti-Government or pro-opposition. In September 2003, one such NGO was closed temporarily after a government official claimed it had too many Hindus on its board of directors; however, it subsequently reopened. Another prominent NGO had its outside grants blocked after its director in 2001 wrote to the head of Government and the diplomatic community to express concern over attacks on minorities during the election then underway.Ultimately, the grants given in 2001 expired early this year and have not been renewed. Members of targeted NGOs reported harassment and intimidation, including pressure against traveling abroad to participate in religious freedom events, by law enforcement and intelligence officials.
Family laws concerning marriage, divorce, and adoption differ slightly depending on the religion of the person involved. There are no legal restrictions on marriage between members of different faiths.
Religion exerts a powerful influence on politics, and the Government is sensitive to the Muslim consciousness of its political allies, Jamaat Islami and the Islami Okiyya Jote, as well as the majority of its citizens.
The Government provides some monetary support for the development of Muslim mosques, Hindu and Buddhist temples, and Christian churches.
Major religious festivals and holy days of the Muslim, Hindu, Buddhist, and Christian faiths are celebrated as national holidays. The Bangladesh Christian Association has lobbied unsuccessfully for the inclusion of Easter as a national holiday.
Religion is taught in government schools, and parents have the right to have their children taught in their own religion; however, some claim that many government-employed religious teachers of minority religions are neither members of the religion they teach nor qualified to teach it. Although transportation may not always be available for children to attend religion classes away from school, in practice schools with few religious minority students often work out arrangements with local churches or temples, which then direct religious studies outside of school hours.
The Government has taken some steps to promote interfaith understanding.For example, Government leaders issued statements on the eve of religious holidays calling for peace and warning that action would be taken against those attempting to disrupt the celebrations.Through additional security deployments and public statements, the Government promoted the peaceful celebration of Durga Purja, a major Hindu holiday in October2003, as well as supporting peaceful activities during Ramadan and before Eid-Ul-Azha.
Restrictions on Religious Freedom
In 2001 the High Court ruled illegal all fatwa's, or expert opinions on Islamic law. Fatwa's include decisions as to when holidays begin based upon the sightings of the moon, matters of marriage and divorce, the meting out of punishments for perceived moral transgressions, and other religious issues. Islamic tradition dictates that only those Muftis (religious scholars) who have expertise in Islamic law are authorized to declare a fatwa. However, in practice village religious leaders sometimes make declarations in individual cases and call the declaration a fatwa. Sometimes this results in extrajudicial punishments, often against women for their perceived moral transgressions. In deeming all fatwa's illegal, the High Court intended to end the extrajudicial enforcement of fatwa's or other declarations by religious leaders. The pronouncement resulted in violent public protests (see Section III). Several weeks later, the Appellate Court stayed the High Court's ruling, and subsequently no action has been taken. Given the heavy Appellate Court case load, it is unclear when the appeal will be determined.
Foreign missionaries were allowed to work in the country; however, their right to proselytize is not protected by the Constitution. The Constitution provides for the right to profess, practice, or propagate any religion; however, the right to proselytize is not discussed in the Constitution. Proselytization is neither permitted nor prohibited by law.As is the case for other foreign residents, missionaries often face delays of several months in obtaining or renewing visas. In the past, some missionaries who were perceived to be converting Muslims to other faiths subsequently were unable to renew their visas, which must be renewed annually. In mid-2001 the Department of Immigration and Passports began to issue regularly a new visa category for foreign missionaries working in the country. The processing of the new visas apparently created complications initially; however, there were no recent reports of any current problems with receiving these visas. Some foreign missionaries reported that internal security forces and others closely monitored their activities.
There are no financial penalties imposed on the basis of religious beliefs; however, religious minorities are disadvantaged in practice in such areas as access to jobs in government or the military, and in political office. The Government has appointed some Hindus to senior civil service positions. Non-Muslims are not barred legally from any government position. However, religious minorities remain underrepresented in most government jobs, especially at the higher levels of the civil and foreign services. Selection boards in the government services often lacked minority group representation. The government-owned Bangladesh Bank employs approximately 10 percent non-Muslims in its upper ranks. Hindus dominate the teaching profession, particularly at the high school and university levels. Some Hindus report that Muslims tend to favor Hindus in some professions, such as doctors, lawyers, and accountants. They attribute this circumstance to the education that the British offered during the 19th century, which Muslims boycotted but Hindus embraced. Employees are not required to disclose their religion, but religion generally can be determined by a person's name.
Many Hindus have been unable to recover landholdings lost because of discrimination in the application of the law, especially under the now-defunct Vested Property Act. The act was a Pakistan-era law that allowed "enemy" (in practice Hindu) lands to be expropriated by the Government. Approximately 2.5 million acres of land were seized from Hindus, and almost all of the 10 million Hindus in the country were affected. Property ownership, particularly among Hindus, has been a contentious issue since partition in 1947. However, in April 2001, Parliament passed the Vested Property Return Act. This law stipulated that land remaining under government control that was seized under the Vested Property Act be returned to its original owners, provided that the original owners or their heirs remain resident citizens. Hindus who fled to India and resettled there are not eligible to have their land returned, and the act does not provide for compensation for or return of properties that the Government has sold. By law the Government was required to prepare a list of vested property holdings by October 2001, and claims were to have been filed within 90 days of the publication date. No further claims were to be accepted after that period expired. At the end of the period covered by this report, the Government had not published the list of vested properties; the reasons for the extended delay could not be determined.
In 2002, the Parliament passed an amendment to the Vested Property Return Act, allowing the Government unlimited time to return the vested properties. The properties are to remain under the control of deputy commissioners until a tribunal settles ownership. The amendment also gives the deputy commissioners the right to lease such properties until they are returned to their owners. The Government claimed that this provision would prevent the properties from being stolen.
In 2001 the Forestry Department inaugurated an eco-park on the lands inhabited by the predominantly Christian Khasi tribesin Moulvibazar. Although indigenous Khasis had lived on these lands for generations, the Government did not recognize their ownership. The Government claimed ownership and stated that the Khasis were occupying the land illegally. On January 3, a member of the Garo tribe died and several others sustained injuries when police and forestry officials fired on Garos attempting to obstruct the construction of a wall in Madhupur forest in the northern Tangail district as part of a forest conservation and eco-park project. Rather than go to the police, the victim's family filed a petition with the magistrate accusing nine government officials of the crime. The magistrate court initiated a judicial inquiry, but by the end of the period covered by this report, there was no action. In July 2002, Forest Department guards killed a Khasi member, Abinash, and injured 10 others in an attempt to evict the Khasis. Police had not arrested anyone in connection with the killing by the end of the period covered by this report.
Under the Muslim Family Ordinance, female heirs inherit less than male relatives, and wives have fewer divorce rights than husbands. Men are permitted to have up to four wives, although society stronglydiscourages polygyny, and it is practiced rarely.Laws provide some protection for women against arbitrary divorce and the taking of additional wives by husbands without the first wife's consent, but the protections generally apply only to registered marriages. Marriage is governed by family law of the respective religions.In rural areas, marriages sometimes are not registered because of ignorance of the law. Under the law, a Muslim husband is required to pay his former wife alimony for 3 months, but this law is not always enforced.
In December 2003, anti-Ahmadi activists killed a prominent Ahmadi leader in Jessore and announced a January 23 deadline for the Government to declare Ahmadis to be non-Muslims. On January 8, the Government announced a ban on all Ahmadiya publications. The ban has not been formalized, but police detained a boy for 3 days for possession of Ahmadiya books, and during demonstrations in April and May, police entered and seized documents from two Ahmadiya mosques. The Government has opposed court challenges to the ban on the grounds the ban has not been promulgated officially and is, therefore, beyond judicial scrutiny. With a few exceptions, the police are not enforcing the ban.
Abuses of Religious Freedom
Reports of harassment by BNP supporters of Hindus, who traditionally vote for the AL, preceded and followed the 2001 election. Reported incidents included killings, rape, looting, and torture. The BNP acknowledged reports of atrocities committed between Muslims and Hindus; however, the BNP claimed that they were exaggerated. The Home Minister was unable to confirm reports that Hindus had fled the country and insisted that there was no link between religion and the violence. He also dismissed allegations that the BNP was linked to the perpetrators. In 2001, the High Court ordered the Government to investigate and report on attacks on religious minorities and to demonstrate that it was taking adequate steps to protect minorities. The Government submitted its report to the High Court in 2002. The report claimed that some of the incidents of post-election violence were not connected to communal relations. It also alleged that some of the reports of violence were fabricated or exaggerated. Since the submission of the report, neither the High Court nor the Government has taken further action.
Since the 2001 elections, religious minorities reportedly have continued to be targeted for attacks. An NGO claimed that in the first 4 months of the period covered by this report, there were approximately 200 incidences of discrimination or violence against religious minorities. Reportedly, incidents include killings, rape, torture, attacks on places of worship, destruction of homes, forced evictions, and desecration of items of worship. However, many such reports have not been verified independently. The Government sometimes has failed to investigate the crimes and prosecute the perpetrators, who are often local gang leaders.
On February 27, Humayun Azad, a Dhaka University professor and writer, sustained serious injuries when unidentified assailants stabbed him near campus. Azad, known for his criticism of Islamic fundamentalism, publicly blamed the attack on Muslim extremists. The Government provided Azad with medical treatment in Dhaka and later, at its expense, in Thailand, but at the end of the period covered by this report, the police investigation into the attack had not identified the assailants.
In January a Hindu temple and three houses belonging to Hindus in Chittagong were burned. According to a prominent human rights NGO, the temple was on disputed ground, and the temple priest sought to expand temple lands. Subsequently, there was conflict between the police, the local fire brigade, and Hindu devotees, who accused the police of destroying the temple. They attacked the police and fire brigade personnel with stones and incendiary devices. There has been no subsequent legal action.
In November 2003, 11 members of a Hindu family burned to death after assailants set fire to their home near the port city of Chittagong. BDG officials ascribed the crime to robbers following a failed robbery attempt, but the opposition Awami League alleged that BNP members attacked the family as part of a local Hindu cleansing effort. Local human rights NGO Odhikar claimed that the attack was a planned assault on the family because of its Hindu faith. Government ministers visited the home within a few days of the incident and promised action against the perpetrators. Subsequently, within a month of theattack,police arrested 5 persons, 3 of whom confessed to the magistrate and claimed that 14 people were involved in what they said was an attempted robbery.At the conclusion of the period covered by this report, police had completed their investigation and prepared a criminal complaint for submission to the court.
Using a compilation of newspaper reports, Ain-O-Shalish Kendra (The Law and Mediation Center), a human rights NGO, filed in 2001 a writ petition with the High Court asking that the Government be ordered to investigate the reported incidents of post-election violence against minorities and submit its findings to the court. The Government submitted its report to the court in 2002, stating that it had taken action against perpetrators of violence against members of the minority communities wherever such incidents took place. The government report said investigations revealed that many of the reports were false or exaggerated. During the period covered by the report, the High Court took no further action in response to the Government's report.
In 2002, a Buddhist monk, Ganojyoti Mohasthobir, was killed at a Buddhist temple and orphanage at Rauzan in Chittagong. According to media reports, his killing was related to a land dispute. Then Home Minister Altaf Hossain Chowdhury and Foreign Minister Morshed Khan visited the temple after the killing. They assured the public that the incident would be investigated properly and that those involved would be brought to trial. Police subsequently apprehended three of the seven accused in the killing. Their trial opened in district court on May 16, with the judge saying that he would depose witnesses intensively until May 23;at the end of the period covered by this report, the case was continuing.
One human rights activist claimed that, especially after the 2001 elections, religious minority groups have been targeted for acts of violence, which has led to the requirement for guards to be present at church and temple ceremonies. These claims continued during the period covered by this report; however, there also has been violence during important Muslim holidays.
In June 2001, in Baniarchar, Gopalganj District, a bomb exploded inside a Catholic church during Sunday Mass, killing 10 persons and injuring 20 others. The army arrived to investigate approximately 10 hours after the blast. Police detained various persons for questioning, but by the end of the period covered by this report, the police reported no progress on the case. A judicial commission was formed in December 2001 to investigate the Baniachar bombing. In September 2002, the commission submitted its report to the Government. The commission's final report blamed Sheikh Hasina and other AL party members for six of the seven bomb attacks that occurred in 1999, 2000, and 2001, including the June 2001 attack. However, two of the three commission members dissented, alleging that the head of the commission, Judge Abdul Bari Sarkar, had inserted his personal views in the final report. During the period covered by this report, the Government took no further action on the basis of the 2002 commission report, and the police are not pursuing the case actively.
Feminist author Taslima Nasreen remained abroad during the period covered by this report, while criminal charges were pending against her for insulting the religious beliefs of the country's Muslims. In May 2002, the Government banned her subsequent book, a sequel to an earlier novel that also was banned for being "anti-Islamic." In October 2002, a court sentenced Nasreen, in absentia, to a year in jail for her "derogatory remarks about Islam," in a case filed by a local Jamaat-e-Islami leader in 1999. In November 2003, a Dhaka court banned the sale or distribution of Nasreen's latest book, "Ka," an account of Nasreen's relationships with Bangladeshi intellectuals, in response to a defamation suit filed by a Bangladeshi writer; "Ka" was sold openly on street corners after the ban.
There were no reports of religious prisoners or detainees.
Forced Religious Conversion
There were no reports of forced religious conversion, including of minor U.S. citizens who had been abducted or illegally removed from the United States, or of the refusal to allow such citizens to be returned to the United States.
Abuses by Terrorist Organizations
There were no reported abuses targeted at specific religions by terrorist organizations during the period covered by this report.
Improvement and Positive Developments in Respect for Religious Freedom
Following demands by the IOJ, an Islamist coalition partner of the ruling BNP, that Ahmadiyya publications be banned and that Ahmadis be declared non-Muslims, the BDG announced such a ban on January 8. However, several days after senior-level visits by the U.S. Embassy and a Congressional delegation on January 11 to 14, the Prime Minister announced the Government would not declare Ahmadis to be non-Muslims.
After the U.S. Embassy and several human rights organizations expressed concerns, the Government in March deferred proposed legislation by a BNP parliamentarian that would have created a blasphemy law based on the Pakistani model.
Section III. Societal Attitudes
Relations between the religious communities generally are amicable. Persons who practice different religions often join each other's festivals and celebrations, such as weddings. Shi'a Muslims practice their faith without interference from Sunnis. Nevertheless, clashes between religious groups occasionally occur. Violence directed against religious minority communities continues to result in the loss of lives and property, but the motives--religious animosity, criminal, or property rights--are often unclear. Religious minorities are vulnerable and often have even less access to justice than other citizens. Police, who generally are ineffective in upholding law and order, are normally slow to assist members of the religious minority community, thereby perpetuating an atmosphere of impunity for acts of violence (see Section II).
Intercommunal violence caused many Hindus to emigrate to India between 1947 and 1971 and continued on a smaller scale throughout the 1980s. Since the 1991 return to democracy, emigration of Hindus has decreased significantly, which generally can be attributed to the significant reduction in the Hindu population over the last 30 years. In recent years, emigration has been primarily motivated by economic and family reasons. Nevertheless, incidents of communal violence continue to occur.
Newspapers reported attacks on Hindu homes and rapes of Hindu women at several places in the country soon after the October 2001 election. According to a human rights organization, at least 10 Hindu women were raped and a number of Hindu homes were looted by low-level BNP workers a few days before the BNP took power from the nonpartisan caretaker government that supervised the election. Some incidents of rape and looting also took place in the southwestern district of Bagerhat. The situation improved after the new government members visited the areas and deployed additional police to troubled locations. In February 2002, an AL-backed Convention on Crimes Against Humanity alleged "systematic persecution" of religious minorities and called for the perpetrators to be brought to trial under local and international laws. In two cases, courts convicted the perpetrators. On September 10, 2003, a Speedy Trial Court in Barisal sentenced Ibrahim Khali and Dulal to life in prison (in practice 22� years) for raping a Hindu woman at Annoda Proshad in Lord Hardinge Union of lal Monhon subdistrict of Bhola district. The court also fined each convict approximately $165 (Taka 10,000) or alternatively to spend an additional 6 months in prison. Both convicts are serving their terms. On October 23, 2003, a Speedy Trial Court sentenced six persons to life in prison and acquitted a seventh person accused of raping a Hindu woman after the 2001 parliament election in the Sadar sub-district of Bhola. The convicts have appealed the verdict to the High Court; the appeal was pending at the end of the period covered by this report.
Human rights groups and press reports indicated that vigilantism against women accused of moral transgressions occurred in rural areas, often under a fatwa, and included punishments such as whipping. During 2003 36 fatwa cases occurred in which 5 persons were lashed, and others faced punishments ranging from physical assault to shunning of families by their communities. One human rights organization recorded 32 fatwa cases in 2002 in which 19 persons were lashed, and others faced punishments ranging from physical assault to shunning of families by their communities.
There are approximately 100,000 Ahmadis concentrated in Dhaka and several other locales. In the latter part of 2003, they were the targets of attacks and harassment prompted by clerics and the rhetoric of leaders of the Islami Okkiya Jote, an Islamic party and coalition partner of the ruling BNP. Many mainstream Muslims view Ahmadis as heretics. In October 2003, 17 Ahmadiya families in Kushtia were barricaded in their homes for several days. In November 2003, police stopped a mob of about 5,000 attempting to destroy an Ahmadiya mosque in Tejgaon, Dhaka. In December 2003, anti-Ahmadi activists killed a prominent Ahmadi leader in Jessore; however, there were no results from the subsequent police investigations in any of these cases. On January 8, the Government announced a ban on all Ahmadiya publications; the ban has not been promulgated officially, but in April and May, police entered and seized documents from Ahmadiya mosques (See Section II).
Reportedly, at the end of May, the Khatme Nabuwat Andolan, a group of anti-Ahmadiya Islamic clerics, threatened to evict thousands of Ahmadiyas from their homes in Patuakhali, Rangpur, and Chittagong. The same group also threatened to attack Ahmadiya mosques in those districts. Many Ahmadiyas appealed to the administration for protection and security. In April allegedly 12 Ahmadiya houses were destroyed; 15 Ahmadiya men and women in Rangpur reportedly were held against their will and pressed to renounce their faith. They were released after hoursof verbal harassment; no legal action has been taken against their assailants.
Public reaction to the High Court's 2001 ruling that fatwas were illegal resulted in violence. Following the court's decision, a number of NGOs organized a rally in Dhaka and transported busloads of persons, mostly women, from different parts of the country to express support for the ruling, which they said was a victory for women and for all who suffered abuses in the name of fatwa. However, Muslim groups contended that fatwas were an integral part of a Muslim's daily life and called the ruling an attack on their religious freedom. Islamist parties and the then-opposition BNP cited the ruling as an example of the Awami League government's "anti-Islam" attitude. Islamic groups organized blockades to prevent buses from entering Dhaka for the rally and protested the ruling and the NGO rally. In the ensuing violence, a police officer was killed inside a mosque, and an NGO office was ransacked. Subsequently, a case was filed and several persons were arrested for the murder. One of the accused was a well-known Islamic scholar and the chairman of a faction within the IOJ; the high court dismissed all charges against him.
The law neither permits citizens to proselytize nor prohibits proselytization; however, local authorities and communities often object to efforts to convert persons from Islam to other religions. Moreover, strong social resistance to conversion from Islam means that most missionary efforts by Christian groups are aimed at serving communities that have been Christian for several generations or longer.
There is no known indigenous Jewish community. Anti-Semitic attitudes are widespread among Islamist activists and are sometimes evident in commentaries, particularly on the Middle East, in mainstream newspapers.
In general citizens do not perceive Christians as Western society surrogates, and Christians are not targeted or harassed in response to the widespread perception by citizens that the U.S.-led war on global terrorism is "anti-Muslim. "
Section IV. U.S. Government Policy
The U.S. Government routinely discusses general and specific religious freedom issues with officials at all levels of the Government as well as with political party leaders and representatives of religious and minority communities. The U.S. Embassy twice encouraged Jamaat Islami to reiterate publicly its position that it supports tolerance and minority rights in the context of an attack on a religious minority member. Both times Jammat Islami demurred. Democracy and governance projects supported by the U.S. Agency for International Development (USAID) include tolerance and minority rights components. The Embassy successfully encouraged the leader of a major political party to condemn attacks on Ahmadis. An article that the Ambassador wrote for local newspapers on Human Rights Day on December 10, 2003, stressed the importance of religious tolerance and other basic rights.
Due to the increased attacks on Ahmadis, the U.S. Government made religious freedom a central point of discussion in most meetings with the Prime Minister, the Foreign Minister, the Law Minister, the Home Minister, and several other ministers beginning in December 2003. The Embassy expressed its views on this matter to the media and public forums related to democracy and governance. In February the Ambassador was the ranking guest at a religious freedom conference organized by a national human rights group.
Embassy and visiting U.S. Government officials regularly visited members of minority communities to hear their concerns and demonstrate public support.
Following demands for the ban of Ahmadiyya publications and that Ahmadis be declared non-Muslims, the Government announced such a ban on January 8. However, several days later, after senior-level representations by the Embassyand a visiting Congressional delegation, the Prime Minister announced that the Government would not declare Ahmadis to be non-Muslims. After the Embassy and several human rights organizations expressed concerns, the Government in March deferred proposed legislation by a BNP parliamentarian that would have created a blasphemy law based on the Pakistani model.
The Embassy assisted U.S. Christian-affiliated relief organizations in guiding paperwork for schools and other projects through government channels. The Government has been receptive to discussion of such subjects and generally helpful in resolving problems. The Embassy has also acted as an advocate in the Home Ministry for these organizations in resolving problems with visas.
The Embassy encouraged the Government through the Ministry for Religious Affairs to develop and expand its training program for Islamic religious leaders. After an initial pilot program, USAID provides, among other topics, course work for religious leaders on human rights, HIV/AIDS, gender equality, and trafficking in persons.