The Government of the United Arab Emirates (UAE) does not fully meet the minimum standards for the elimination of trafficking but is making significant efforts to do so. The government demonstrated overall increasing efforts compared with the previous reporting period, considering the impact of the COVID-19 pandemic on its anti-trafficking capacity; therefore the United Arab Emirates remained on Tier 2. These efforts included convicting more traffickers overall, reporting a forced labor prosecution for the first time since 2018, and identifying a victim of forced labor for the first time in five years. However, the government did not meet the minimum standards in several key areas. The government did not convict any traffickers for the forced labor of a migrant worker during the year and has not ever done so; it also did not report the number of trafficking cases authorities investigated for the 10th consecutive year. Officials did not regularly investigate labor law violations that exhibited trafficking indicators—such as cases of unpaid or withheld wages, passport retention, restriction of movement, and related abuses—as potential trafficking crimes, addressing them administratively instead of through criminal proceedings, which undercut efforts to hold traffickers accountable and weakened deterrence. Finally, the government did not consistently screen vulnerable populations for trafficking indicators, which may have penalized some victims for unlawful acts traffickers compelled them to commit, such as immigration or “prostitution” violations, and the deportation of other unidentified victims. This contributed to the lowest number of victims the government identified in five years.
Significantly increase efforts to investigate, prosecute, and convict traffickers of forced labor crimes, specifically of migrant workers, including domestic servitude, under the anti-trafficking law.
Increase efforts to identify and provide protective services for labor trafficking victims.
Expand trainings to officials across all emirates to better identify potential trafficking cases that originate as labor violations.
Strengthen efforts to punish potential forced labor crimes criminally instead of administratively and refer cases with trafficking indicators, such as complaints of non-payment of wages, passport confiscation, and restriction of movement, for investigation as potential trafficking crimes.
Regularly employ standard procedures for victim identification and referral to quality care among foreign workers, particularly women in commercial sex, domestic workers who have fled their employers, and other vulnerable documented and undocumented migrants, to ensure authorities do not penalize victims.
Report the number of trafficking investigations and the number of identified victims that were not involved in active court proceedings.
Report the number of labor law violations—such as passport retention, withholding of wages, and other complaints of abuse reported by workers, employers, and recruitment agencies, and identified from inspections.
Continue to expand use of the Wage Protection System (WPS) pilot program for domestic workers to ensure all workers are covered under the system.
Execute implementing regulations for and strengthen enforcement of the domestic worker law that expands legal protections for domestic workers.
Strictly enforce prohibitions on withholding workers’ passports.
The government demonstrated uneven law enforcement efforts; it convicted more traffickers and prosecuted an alleged labor trafficker for the first time since 2018, but it continued to focus efforts overwhelmingly on sex trafficking and has not historically reported forced labor convictions. Federal Law No. 51 of 2006 and its amendments in Federal Law No. 1 of 2015 criminalized sex trafficking and labor trafficking and prescribed penalties ranging from five years to life in prison, as well as fines and deportation for non-citizens. These penalties were sufficiently stringent and, with respect to sex trafficking, commensurate with those prescribed for other serious crimes, such as rape.
The government did not report statistics on investigations of suspected trafficking cases for the 10th consecutive year. During the reporting year, the government prosecuted 40 alleged traffickers in 19 cases, including 34 individuals in 15 sex trafficking cases, two individuals in two forced begging cases, and three individuals in one case for “selling” victims across the seven emirates. This was a decrease compared with the prosecution of 57 alleged traffickers in 20 cases during the previous year: 54 individuals in 19 sex trafficking cases and three individuals in one child forced begging case. For the first time since 2018, the government reported prosecuting one individual for forced labor during the year. Of the prosecutions, 14 alleged perpetrators in five sex trafficking cases and one alleged perpetrator in one forced labor case remained pending verdicts at the close of the reporting period. Courts convicted 23 traffickers, including 18 sex traffickers, two individuals for forced begging, and three individuals for “selling victims,” and sentenced them to between six months and life imprisonment, with the majority of perpetrators receiving three years or more with additional fines. While the government did not report the nationalities of traffickers, the vast majority were foreign nationals subject to deportation at the conclusion of their sentences. In 2020, courts convicted 15 sex traffickers under trafficking laws and handed down similar punishments, while in 2019, courts convicted 67 sex traffickers under the trafficking law. The government has not ever reported convictions for the forced labor of migrant workers—the largest trafficking problem in the UAE. In one specific case during the year, the Dubai Court of Appeals convicted six individuals for trafficking, forging documents, and abusing a child; the perpetrators deceived a 16-year-old female into coming to the UAE with a false job offer as a domestic worker and forged her documents to facilitate her entry into the country, where she was sexually assaulted by the traffickers and then forced into domestic work, where her salary was withheld and provided to one of the six traffickers as a means of coercing her into commercial sex to receive payment. The court sentenced three of the traffickers to 10 years’ imprisonment, two traffickers to seven years’ imprisonment, and one trafficker to six months’ imprisonment.
Observers noted Emirati institutions had limited understanding of how to differentiate between labor trafficking crimes and labor violations. The government did not routinely investigate as possible trafficking crimes labor law violations that exhibited trafficking indicators, such as passport confiscation, delayed or nonpayment of wages, fraud, and contract switching; generally, the government settled these cases by levying administrative fines or canceling business licenses in lieu of criminal proceedings. Labor violations, including those involving forced labor, continued to be addressed by Ministry of Human Resources and Emiratization (MOHRE) through administrative dispute resolution processes and labor courts. The government did not report any investigations, prosecutions, or convictions of officials complicit in trafficking crimes during the reporting year. Police, judges, prison officials, and immigration authorities continued to receive training to identify trafficking victims; the specialized anti-trafficking units within local police headquarters and public prosecution offices at the federal and local level throughout the Emirates routinely facilitated trainings for staff on handling trafficking cases. For example, the Abu Dhabi Police trained more than 1,300 judges and prosecution staff through 34 different courses and training programs focused on anti-trafficking; the Dubai Police provided the same training to more than 400 police officers through 10 courses during the year. In addition, the Ministry of Interior (MOI) provided at least 38 different courses and training programs for police officers throughout the Emirates, training more than 3,000 police staff on topics including victim-centered approaches to investigating trafficking cases. In October 2021, the National Committee to Combat Human Trafficking (NCCHT) and Dubai Police inaugurated the seventh iteration of the “Human Trafficking Specialist” program at the Dubai Judicial Institute (DJI) in collaboration with an international organization; this was a five-week diploma program on ways to detect and prevent trafficking, protect victims, and raise societal awareness of the problem. The program was expanded in 2021 to include 101 virtual participants representing national police authorities, human rights associations, shelters, and federal and national government bodies, as well as participants from across the Gulf Cooperation Council countries. Employees of Abu Dhabi and Dubai airports continued to receive training on trafficking awareness and reporting processes, including identifying potential cases and victims upon arrival at the airports or on flights. Additionally, the Federal Authority for Identity and Citizenship provided multiple anti-trafficking trainings to staff employed at UAE entry points—including customs, border, and port security officials—on topics such as forgery detection, human rights, and uncovering signs of trafficking. Finally, MOHRE provided training to more than 300 labor inspectors on understanding anti-trafficking legislation. However, observers noted Emirati officials would benefit from additional targeted training on effective implementation of the anti-trafficking law, victim-centered approaches to law enforcement efforts, and identifying potential labor trafficking cases from labor violations that exhibit trafficking indicators.
The government made uneven efforts to protect trafficking victims; for the first time since 2016, the government identified one forced labor victim, but it did not increase any other protection efforts, nor did it consistently screen vulnerable populations for trafficking indicators, which may have resulted in the penalization of some victims for unlawful acts traffickers compelled them to commit. Consistent with prior years, the government reported the number of trafficking victims it identified as the number of victims involved in active court cases and did not otherwise track potential victims or those victims whose cases did not go to trial. It reported identifying the lowest number of victims in the last five years. The government identified and referred to care 25 victims, including 21 of sex trafficking, two of forced begging, one of “selling,” and—for the first time since 2016—one victim of forced labor. This was compared with 33 sex trafficking victims and one child forced begging victim identified and referred to care during the previous reporting period.
While the government had standard procedures for victim identification, officials did not regularly employ these procedures proactively and continued to rely predominantly on third-party referrals to identify victims, including from foreign embassies, religious institutions, or tips received through government hotlines, smartphone applications, and the internet. Authorities continued to implement a formal referral process to transfer potential trafficking victims from detention centers, hospitals, houses of worship, and facilities run by source country embassies or consulates, as well as those identified from shelter-operated hotlines, to government shelters. Government shelter staff reported that although police were supposed to refer all potential trafficking victims to government shelters, in some cases, police only referred individuals that law enforcement had already officially determined to be trafficking victims. Shelter staff also assessed all individuals referred to the shelter upon arrival using an international organization-issued screening questionnaire to better assess victims’ needs. While this assessment was shared with law enforcement, authorities did not always consider the shelter’s determination and instead came to a separate conclusion on whether the individual was officially a trafficking victim. However, shelter staff reported all potential victims had access to shelter and services regardless of law enforcement’s determination. Authorities also sometimes held potential victims who encountered law enforcement first at a transitional center until they could make an official determination of their trafficking victim status. At times, female or male police officers in plain clothes—intended to allay victims’ anxieties—escorted officially identified victims from a government-run detention center to a shelter. In previous reporting periods, some diplomatic contacts and community leaders reported they were hesitant to refer victims of forced labor to shelters, as authorities did not always recognize these crimes as trafficking and rather considered them labor violations.
The shelters were largely funded through individual donations, notably from the ruling family of Abu Dhabi emirate, as well as contributions from public and private companies and religious institutions. The government maintained oversight and funding for shelters in four of the seven emirates (Dubai, Abu Dhabi, Ras Al Khaimah, and Sharjah), offering housing and assistance for all female and child sex trafficking and abuse victims across the country. The government operated one shelter for men in Abu Dhabi and served one male victim during the year. Protective services included medical, psychological, legal, educational, rehabilitation and reintegration, vocational training and certificates, and voluntary repatriation with follow-up care after the victim returned home. Child trafficking victims and dependents of trafficking victims received services tailored to their needs, including separate living sections and case managers, as well as teachers who provided age-appropriate educational and psycho-social support. All police departments had a special room for interviewing children and other vulnerable victims. The Philippine, Indian, and Sri Lankan embassies in Abu Dhabi and the Philippine, Indonesian, and Sri Lankan consulates in Dubai provided shelter and other protective services to an unspecified number of their nationals who had been subjected to trafficking during the reporting period. In 2021, the Ugandan embassy in Abu Dhabi began providing shelter to its nationals on an ad-hoc basis, and the Bangladeshi embassy also provided shelter and services to an unknown number of female domestic workers during the year. Other consulates used “foster families” of the same nationality to host victims until their cases were resolved. During the reporting year, officials distributed 191,000 Emirati dirhams ($52,000) through the Victims Support Fund to trafficking victims residing at government shelters across the Emirates, which financially supported victims by providing housing and education services, and covering medical expenses, repatriation, or resettlement.
Independent observers alleged authorities jailed some potential victims for “prostitution” offenses, consensual sex outside marriage, or “absconding” from their employers. Reports also persisted that some potential victims were unwilling to approach law enforcement officials due to fear of being sent to prison for immigration or other violations, such as “absconding” from their employer, rather than being accepted into a shelter. MOHRE could reject an “absconding” charge on several grounds, including if the charge was filed for vexatious or fictitious reasons or if the worker already had a pending claim against their employer with the government, and it also did not force the employee to return to his or her former place of employment. MOHRE did not report how many absconding claims it received nor the number it rejected. In September 2021, an NGO alleged the government arrested at least 800 African migrants based on their race and national origin and deported them without charge. Rights groups alleged the migrants were detained for approximately five weeks, with some experiencing abuses amounting to torture and were forcibly deported despite most possessing valid documentation and visas. The government did not report screening the African migrants for trafficking indicators prior to deportation despite the vulnerability of this population. Furthermore, because the government did not routinely use victim identification procedures or screen for potential trafficking crimes among vulnerable populations, it may have penalized some unidentified victims during the year. During the previous reporting period, the Dubai Public Prosecution announced an initiative to encourage employers to report their “absconded” domestic workers to authorities to prevent employers from hiring illegal workers and reduce losses incurred by employers whose workers flee. Employers could be fined for hiring a worker illegally and could be compensated for filing “absconding” charges against a worker; employers had 10 days to report “absconding” workers or risk being fined. This policy continued in 2021 and may have exacerbated vulnerabilities of some workers attempting to leave exploitative situations; to this end, officials may have penalized potential trafficking victims whose employers filed malicious “absconding” charges during the year.
The government reported it exempted from fines trafficking victims who had overstayed their visas, but it did not report how many benefitted from this exemption during the reporting period. The government did not provide permanent or formal temporary residency status to victims; however, it permitted victims to stay in shelters and participate in court proceedings and worked with international organizations to resettle (in third countries) victims who could not return to their countries of origin. MOI officials could amend the status of victims to assist them in seeking follow-on job opportunities in the UAE. Migrant workers whose employer had not paid them for 60 days were entitled to legally remain in country and search for a new employer. The government reported it provided repatriation assistance to trafficking victims who wished to return to their home countries but did not report the number of victims that were repatriated during the reporting period. Shelter staff noted they assisted an unknown number of trafficking victims in finding new employment or sponsors on an ad-hoc basis. The government encouraged victims to assist in the investigation and prosecution of traffickers and provided victim-witness protective services, including private interview rooms, free legal counseling, and safe transportation to court hearings. Police took measures to prevent communication between the victim and suspect. Police also enforced two governmental decrees aimed at ensuring the media adhered to victims’ right to privacy and that shelters adequately protected victims. According to the NCCHT, victims were informed and assured of their rights when giving testimony. Shelter staff reported courts attempted to accommodate victims’ desire to leave the country and most victims were able to depart the UAE with a letter from the presiding judge after the first court hearing. Both police and shelter representatives reported victims often chose immediate repatriation at the UAE’s expense rather than remaining in country to testify against alleged traffickers or see a case through to final adjudication. In 2021, remote court trials continued to be utilized due to the pandemic; observers noted the use of remote courts eased the burden on trafficking victims from appearing in the courtroom and made trials move more quickly while keeping the victims’ safety and wellbeing protected. However, the government did not report how many trafficking victims had their court proceedings conducted remotely. During the previous reporting period, the government established a Witness Protection Program by expanding Federal Law No. 14 of 2020, which gave judicial officials the authority to enroll witnesses in the protection program to keep their identities confidential during legal proceedings; the government did not report if any trafficking victims were enrolled in the program during the year. The government reported victims could file civil suits seeking damages from traffickers but did not report if any victims did so during the reporting period.
The government maintained efforts to prevent trafficking. It continued to carry out its national action plan to address trafficking, driven chiefly by the NCCHT; the plan focused on prevention, protection, prosecution, punishment, promotion of international cooperation, redress, rehabilitation, reintegration, and capacity building. The NCCHT met four times during the year. In January, the government restructured the NCCHT under the leadership of the Minister of Justice. The government made efforts to prevent forced labor primarily through labor regulatory and monitoring mechanisms, including labor inspection programs that incorporated routine and unannounced inspections of company housing and work sites by a team of full-time labor inspectors and seven dedicated anti-trafficking inspectors. If a company was found to have violated the labor law following an inspection, the government could fine the company or curtail its ability to operate or hire additional workers. Furthermore, the government reported individuals found to have engaged in fraud that led to forced labor could face jail time. During the year, the NCCHT reported MOHRE conducted 354,902 inspection visits but, as in previous years, did not report how many labor law violations were identified or if any were referred for further investigation or criminal prosecution as a potential trafficking case. MOHRE also continued to oversee, regulate, and enforce labor-related complaints; however, authorities generally dealt with labor law violations administratively and did not report investigating such cases for trafficking indicators or referring any for criminal prosecution. Workplace grievances routinely resulted in fines, suspended permits to hire new workers, or the cancellation of business licenses; for example, in July 2021, MOHRE’s Supreme Arbitration Committee for Collective Labor Disputes settled 22 collective labor disputes for 18,670 workers amounting to 300.6 million Emirati dirhams ($81.84 million). The government did not report how many complaints it received from workers, employers, or recruitment agencies during the year or the nature of those complaints.
The government’s WPS required and monitored electronic salary payments for private sector workers via vetted banks, currency exchanges, and financial institutions for all onshore companies employing more than 100 workers (95 percent of the private sector workforce). The WPS automatically alerted officials to delayed salary payments of more than 60 days or payments that were less than contractually agreed upon, and after a period of 15 days, authorities administered fines and other enforcement actions. MOHRE reported that letters were issued to companies and sent to the Public Prosecutor for WPS violations; MOHRE also reported that cases were only dropped when the missing wages were paid and the company was up to date with all salary payments. Although the NCCHT reported the government fined 3,050 companies that failed to provide payments to workers via the WPS in 2021, for the 14th consecutive year, the government did not report the number of complaints of unpaid wages it investigated as a result of its dispute resolution process or the WPS or if any such complaints were criminally investigated as potential trafficking crimes. However, Ministerial Resolution No. 43 of 2022 introduced new penalties on non-compliant companies and employers, including suspending their ability to issue new work permits, increased inspections, and a 1,000 Emirati dirham ($270) fine imposed for each worker. The government reported that through this resolution, continued violations resulted in referral to the Public Prosecutor’s Office; during 2021, 2,051 non-compliant companies were referred to judicial authorities for violating the WPS. Media and diplomatic sources continued to report that some companies retained workers’ bank cards or accompanied workers to withdraw cash, coercively shortchanging the employees even though the WPS showed the proper amount paid. Such cases were difficult to prove in labor courts, given the WPS documented accurate payments via designated bank accounts. Furthermore, domestic worker salaries were not required to be paid via the WPS; this, coupled with the lack of legal provisions requiring inspections of domestic worker accommodations, wage payment, and work hours, heightened domestic workers’ vulnerability to exploitation. The government continued its pilot program from a previous reporting period through MOHRE’s agreement with First Abu Dhabi Bank to incorporate domestic workers into the WPS. The NCCHT reported that the pilot program integrated 16,771 domestic workers at the close of the reporting period, a significant increase compared with 423 domestic workers enrolled at the close of the previous reporting period. The NCCHT reported that although the enrollment of domestic workers under the WPS was currently voluntary, the renewal of domestic worker permits will make enrollment mandatory, with the intent that all domestic workers will be integrated under the WPS in 2022.
Since 2017, the government has issued Tadbeer licenses to private recruitment agencies to recruit domestic workers to the Emirates. Agencies with Tadbeer licenses were mandated to provide training to recruited workers, educate them on their legal rights, resolve employee-employer disputes, and verify worker accommodations for compliance with domestic worker law minimum standards. Each licensed agency was equipped with a room solely for grievance mediation with a video connection to MOHRE for official oversight. Officials also reported when a dispute occurred between a domestic worker and employer, the worker could approach the Tadbeer-licensed agency for assistance instead of fleeing their employer, which rendered a worker undocumented and vulnerable to exploitation. However, Tadbeer-licensed agencies could not enter or inspect private homes, which made verification of worker accommodations and other protections outlined in the law difficult to obtain. Since 2019, MOHRE had mandated licensed agencies cover the cost of employer recruitment fees for domestic workers through an insurance policy with a two-year warranty; this policy aimed at ensuring recruitment fees would not be transferred to domestic workers from employers once they arrived in the UAE. In certain circumstances where a domestic worker terminated employment, employers were entitled to a full refund of the recruitment fees, which the licensed agency would cover. However, observers noted this insurance policy did not protect workers from fees they incurred from both legal and unregulated recruiters in their home country. Despite the expansion of agencies with Tadbeer licenses, the expensive costs to obtain a license—coupled with mandated insurance requirements to cover recruitment costs—disincentivized some private recruitment agencies from obtaining a Tadbeer certification. Furthermore, non-Tadbeer-licensed recruitment agencies remained popular as their services were viewed as cheaper and more flexible and accessible compared with Tadbeer-licensed agencies. However, as these agencies were not strictly regulated, many continued to be accused of violating labor and immigration laws and failing to guarantee the rights of workers and employers.
NGOs continued to raise concerns about the ease with which tourist visas could be converted into work visas for domestic workers looking to circumvent their home countries’ recruitment ban in the UAE—a practice that exacerbated the risk of trafficking for these workers, as they often paid fees to recruitment agencies in both their home countries and in the UAE and had no protection under UAE law when they arrived on tourist visas. Furthermore, some workers were unable to switch their visas to employment visas and so continued to work illegally, heightening their vulnerability to exploitation. In the previous reporting period, in a purported effort to address this practice and solely use Tadbeer-licensed agencies for the recruitment and regulation of all domestic workers, MOHRE mandated the closure of 250 non-Tadbeer-licensed recruitment agencies in January 2021; agencies had the option to obtain a Tadbeer license, switch to another sector or shut down by March 2021. MOHRE reported, as of March 2021, citizens and residents would be required to hire domestic workers only through Tadbeer-licensed agencies. At the close of the reporting period, 68 Tadbeer-licensed agencies were operational across the Emirates, an increase from the 56 agencies that were operational at the end of the previous reporting period. Nonetheless, despite authorities mandating all hiring be conducted through the Tadbeer system, many UAE households continued to employ domestic workers directly or through other recruitment agencies, further increasing the vulnerability of domestic workers to exploitation and trafficking without protection under the law.
Federal Law No. 10 of 2017 provided additional protections for domestic workers, as well as regulations for recruitment agencies and employers of such workers, including those pertaining to hiring practices, working conditions, and employment contracts. Federal Law No. 10 also protected domestic workers’ rights to retain their own identity documents but did not stipulate penalties for employers who confiscated workers’ passports. Cabinet Resolution No. 22 of 2019 granted domestic workers the right to terminate their employment if an employer failed to meet contractual obligations, such as payment of wages, or if the employee was subject to sexual harassment or physical or verbal abuse by the employer; in these cases, a Tadbeer-licensed recruitment agency was required to provide shelter to the domestic worker. The government did not strengthen regulatory enforcement of in-home inspections and workplace grievance resolutions. In addition, legal barriers against government interference with private households continued to hamper monitoring and enforcement efforts of these laws relevant to domestic workers. Cabinet Resolution No. 22 included the right for employees to retain personal documents, sign standardized contracts with designated working conditions, access specialized tribunals for settling workplace grievances, and observe mandatory time off. It also stipulated in-home inspections on the basis of complaints or reasonable evidence of violations. Under the law’s provisions, a recruitment agency or person who hindered law enforcement, anyone who disclosed information unveiled in an investigation, or anyone who facilitated the abandonment of a domestic worker may be jailed for a minimum of six months and ordered to pay a fine between 10,000 and 100,000 Emirati dirhams ($2,720 to $27,230).
Private sector workers were granted the freedom to leave and switch employers at any time without employer approval through Ministerial Decrees No. 765 and 766 of 2015; however, this decision included the requirement that the worker had to provide between one month and three-months’ notice, depending on the initial contract terms, to leave an employer. In addition, workers had to physically possess their passport to leave the country or switch employers. Because the government did not enforce a prohibition on employers confiscating workers’ passports, this practice remained pervasive and may have left some workers vulnerable to exploitation and potentially trafficking. The government reported that if an employer withheld a worker’s passport, the worker could contact MOHRE’s hotline where a legal advisor would speak to both parties and explain the worker’s legal rights—including the prohibition of retention of identity documents; if the problem could not be resolved through arbitration, the case was referred to the labor courts. According to the NCCHT, 465,557 workers changed employers during 2021. As with domestic workers, in instances where a private sector worker faced physical or verbal abuse or sexual harassment, the worker had the freedom to leave the employer without notice. All workers were able to terminate employment at any time in the absence of abuse or a contractual breach but may be required to forego certain benefits including end of service gratuity and a return ticket to their home country. In those instances, a domestic worker may have had to pay their employer compensation equal to one month’s wages and other entitlements deemed necessary by a court. In such instances, MOHRE could issue the domestic worker a new work permit to move to a new employer, and the worker was not subject to immediate deportation to ensure the worker had sufficient time to find a new job. Most workers chose to remain in the UAE to work for another employer under a new work permit or contract after terminating their previous employment. In February 2022, the government passed a revised private sector labor law under Federal Law No. 33 of 2021 that replaced Federal Law No. 8 of 1980, the previous private sector law, in its entirety. This law does not apply to domestic workers; however, it does outline new requirements for termination of a contract for both the employer and employee during and after the probationary period concludes. For example, if a worker wants to terminate a contract during the probationary period, the worker must give one month’s notice if they want to change employers in the UAE or 14 days’ notice if the worker wants to leave the country; the employer must also provide 14 days’ notice to the worker if they plan to terminate the contract during that period. Notably, if a worker or employer terminated the contract, under the new law, the worker has 180 days to find a new job, compared with 30 days under the previous labor law, without incurring overstay fines or becoming undocumented. Furthermore, the new law prohibited discrimination of any form in the workplace, provided new flexible employment options, and introduced explicit prohibitions against forced labor, which previously only existed in the anti-trafficking law.
The government continued to post informational anti-trafficking notices at airports, implement training courses for high-risk groups, and disseminate publications in various languages directed at the most at-risk communities, reaching almost two million individuals during the year. The campaigns also raised awareness of penalties for trafficking and publicized hotlines. Airport banners specifically targeted terminals based on nationalities with high workforce numbers in the UAE. Relevant authorities, including the MOI, Dubai Police, and MOHRE, held a series of lectures and training programs in workers’ residences and in recruiting offices to raise awareness on the types of trafficking crimes and ways to communicate with law enforcement authorities and shelters. The MOI conducted four different campaigns aimed at approximately 300 domestic workers and hotel workers; domestic-worker campaigns focused on raising awareness of their rights and the anti-trafficking law while the campaign for hotel workers explained indicators of trafficking. MOHRE continued to conduct lectures on the labor law and trainings on human rights and human trafficking issues to workers; it also began publishing a magazine aimed in part at raising awareness for workers on different labor issues. The PPO led a public campaign on social media on the anti-trafficking law and further explained “force” as an element of the crime, specifically in the context of forced begging.
During the reporting period, the Dubai Foundation for Women and Children (DFWAC) provided information on human trafficking in five different languages through lectures, leaflets, and podcasts aimed at employees in the retail sector and for staff and students at local universities; in addition, it provided lectures and trainings to foreign embassies on trafficking and services available for victims. The Aman Shelter for Women and Children continued its campaign titled “No to Human Trafficking,” scheduled to continue through 2025; the campaign used leaflets and public meetings to raise awareness of the crime. The shelter also targeted workers in beauty salons and spas to raise awareness of labor rights and trafficking indicators. In December 2021, shelter staff launched an interactive art display at the Dubai Expo; artists worked with two trafficking survivors to develop the installation, which featured audio commentary narrating the victims’ experiences. Additionally, the Abu Dhabi Police worked with media outlets to warn job seekers about fraudulent internet employment ads that emerged as a result of increased unemployment due to the pandemic and cautioned laid-off workers to be cognizant of fraudulent job offers that charged recruitment fees, an illegal practice in UAE. The government funded and ran a 24-hour toll-free hotline for reporting cases of trafficking, delayed wage payments, or other labor violations, which operated in Arabic, English, Russian, and Urdu. Calls were categorized and automatically alerted police in suspected trafficking cases. Additionally, MOHRE, MOI, and DFWAC had dedicated multilingual toll-free hotlines; MOI continued to host a mobile phone application that allowed users to access certain police services on their phones, and victims of trafficking or witnesses to the crime could use the application to file reports as well. In Dubai, law enforcement authorities ran a separate line, and UAE-wide there remained a 24-hour toll-free number for migrant workers to vocalize complaints or general inquiries. Analogous to previous years, the government did not report how many trafficking or trafficking-related calls any hotline received, how many victims were identified, or how many investigations were initiated during the reporting year.
In November 2021, in coordination with an international organization, the government hosted the “Inter-regional Meeting on Combating Trafficking by Air” to discuss challenges in detecting, investigating, and prosecuting trafficking cases where victims traveled to their destination and location of exploitation through commercial airlines; representatives from the region and East Africa participated, including airport law enforcement officers and staff from specialized trafficking police and prosecutions units. In the previous reporting period, the government announced a partnership between the UAE, Saudi Arabia, and the African Union to pilot and implement an orientation program for Gulf-bound workers from Africa; however, during the current reporting period, the government reported that all three stakeholders placed the program on hold due to the pandemic. The government continued to utilize its trafficking-related memoranda of understanding with Armenia, Australia, Azerbaijan, Bangladesh, The Gambia, India, Indonesia, Nepal, Pakistan, the Philippines, Sierra Leone, Thailand, Uganda, and Vietnam to regulate recruitment mechanisms and prevent contract switching. The government did not take measures to reduce the demand for commercial sex acts in the UAE. The Ministry of Foreign Affairs maintained provision of workshops and awareness programs on human trafficking for its diplomatic personnel.
As reported over the past five years, human traffickers exploit foreign victims in the UAE. Foreign workers comprise nearly 90 percent of the UAE’s population and are recruited globally. Lower wage labor, including most manual labor and a significant portion of the service sector, is provided almost entirely by migrant workers predominantly from South and Southeast Asia and the Middle East, with a growing percentage from East and West Africa. It is not uncommon for employers to subject some of these workers to conditions indicative of forced labor, such as passport retention, non-payment of wages and unpaid overtime, restrictions on movement, contract switching, fraudulent employment promises, substandard food and housing provisions, or a failure to meet other contractual agreements. Adults from some of these countries travel willingly to the UAE to work as domestic workers, security guards, drivers, gardeners, massage therapists, beauticians, hotel cleaners, or elsewhere in the service sector, but traffickers subject some of them to forced labor or sex trafficking after arrival. During the year, one human rights group reported migrant workers employed to support the Dubai Expo—held between September 2021 and March 2022—were allegedly subjected to conditions indicative of forced labor, including being charged recruitment fees, non-payment or delayed payment of wages, passport confiscation, and other abuses, including racial discrimination. Workers were also reportedly reluctant to access available grievance mechanisms for fear of reprisal by employers or authorities.
Observers continue to report the UAE serves as a trafficking hub where recruiters sell migrants to families who subsequently illegally transport them to other countries in the Gulf. As reported in the previous year, the UAE has in recent years become a primary destination for Ugandans seeking employment as domestic workers and security guards. Many Pakistanis are reportedly hired on promises they will receive handsome salaries, medical benefits, and accommodations, but after reaching the UAE, the promises go unfulfilled, with some Pakistanis discovering that the companies that hired them are fraudulent and workers are instead forced to obtain unregulated work due to their legal status, rendering them at increased vulnerability of exploitation and trafficking. For expatriate workers and domestic workers especially, the kafala or visa sponsorship system in the UAE restricts their ability to leave a position without prior notice. Despite legal measures allowing workers to change sponsors or terminate their employment, some employers continue to exercise unilateral power over foreign workers’ movements, deny laborers working illegally the ability to change employers, restrict permission for them to leave the country, and threaten employees with abuse of immigration processes, which heightens their vulnerability to trafficking. Traffickers subject some women, predominantly from Central Asia, South and Southeast Asia, East Africa, Eastern Europe, Iraq, Iran, and Morocco, to sex trafficking in the UAE, and most trafficking cases registered in the UAE are classified as sexual exploitation despite significant labor trafficking concerns. Anecdotal reports alleged an increase of traffickers in Laos recruiting young women through social media for commercial sex in Dubai. Anecdotal reports also alleged Mongolian nationals were subjected to labor trafficking in the UAE for herding, domestic work, and in circus performances during the year. Per media sources, some cases of child sex trafficking involve traffickers forging ages on passports to facilitate undetected entry into the UAE. Recruiters in some source countries work as individual agents rather than for regulated companies, complicating law enforcement and monitoring efforts.
Many source-country labor recruiters charge workers exorbitant fees in their home countries, causing workers to commence employment in the UAE owing debts in their respective countries of origin, increasing their vulnerability to trafficking through debt-based coercion. Reports of employers engaging in the practice of contract-switching persist, leading to less desirable and lower paying jobs for migrant workers post-arrival in the UAE. Traffickers often recruit victims from the large foreign national population already in the country. Some migrant workers enter the UAE on tourist visas and work for an employer who does not apply to exchange the worker’s tourist visa for the required work visa in order for the worker to have legal residency; this subsequently can be used as coercion to exploit the worker. As pandemic-related border closures and travel restrictions eased by mid-2021, the use of tourist visas as a method to circumvent immigration and labor laws increased; migrants, especially from Africa, sought entry in the UAE via this method during the year. However, as in the previous reporting period, due to pandemic-related restrictions and the subsequent decrease in new workers entering the UAE, traffickers reportedly continued to use illegal online markets on social media to advertise and sell domestic workers already residing in the country. During the reporting period, workers continued to experience pandemic-related job loss, non-payment of wages, or forced leave without pay, which heightened their vulnerability to trafficking and trafficker’s recruitment pitches; during the year, traffickers continued to target workers already residing in the country who had experienced pandemic-related job loss with false promises of better jobs through online platforms. In the previous reporting period, pandemic-related lockdown measures increased the vulnerability of domestic workers to trafficking by reinforcing their isolation and restricting their movement. In June 2021, media sources reported the government denied the renewal of work permits or issuance of new work permits for Nigerian nationals in certain employment categories working in the Emirates; one media source reported, as of October 2021, more than 700 Nigerians experienced job loss and therefore became undocumented in the country; some migrants traveled back to Nigeria, while others remained stranded due to their inability to pay for travel home, increasing their vulnerability to exploitation, including trafficking. Many UAE households continued to employ domestic workers directly or through private recruitment agencies instead of through Tadbeer-licensed agencies that had additional government oversight, further increasing the vulnerability of domestic workers to exploitation and trafficking without protection under the law. Furthermore, some employers sponsoring domestic workers continued to use online platforms to advertise the selling of domestic workers. According to UAE shelter staff, migrant workers will sometimes start with one employer and for various reasons, including abuse or exploitation, low salary, or simple dissatisfaction with the job, will follow alternate employment opportunities that ultimately prove fictitious, as traffickers in the UAE are adept at using manipulation to entice laborers with fraudulent higher salaries. Cuban nationals working in the UAE may have been forced to work by the Cuban government.
During the reporting period, there were no allegations the UAE unlawfully recruited or used child soldiers. In September 2019, the UAE reportedly ceased providing direct support to Security Belt Forces in Yemen, which allegedly unlawfully recruited or used child soldiers. In June 2020, the UN Secretary-General delisted the Saudi-led Coalition in Yemen from the annexes of the UN report on Children and Armed Conflict. During a previous reporting period, an international organization alleged the government, as a member of a multi-nation coalition that commenced military operations against Houthi rebel forces in Yemen in 2015, provided training and coordinated operations with the Security Belt Forces, Hadhrami Elite Forces, and Shabwani Elite Forces—proxy militias fighting Houthi forces and terrorists in Yemen that allegedly unlawfully recruited or used child soldiers. Media also previously reported officers associated with Sudan’s Rapid Support Force took bribes from families to unlawfully recruit children to serve as combatants in Yemen during that same period. Emirati officers allegedly trained and commanded some Sudanese combatants during the previous reporting period. While the UAE did not directly commission those forces, the Saudi-led Coalition fighting with Emirati and Yemeni government forces coordinated with Sudanese units that allegedly unlawfully recruited or used child soldiers during those years.