How Do Levels of Consent Shape Different Forms of Human Trafficking In Southeast Asia?

Human trafficking is one of the most tragic features of present-day global migration, with an estimated 2 million people being trafficked annually.[1] Although combating human trafficking is a growing priority for many governments, information on the magnitude of the problem remains limited. The lack of consensus regarding the number of trafficked victims is largely attributed to the inability to isolate the jurisprudential and practical distinctions between who is, in fact, a victim of human trafficking or a smuggled migrant.[2] One might think that the effectiveness and legality of consent that distinguishes human trafficking from smuggled migrants rests on the presence or absence of coercion. Indeed, human trafficking legislation, to some degree, reflects this position. According to the UN, “Trafficking in persons shall mean the recruitment, transportation, transfer, harboring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability… for the purpose of exploitation.”[3] However, when these interferences to the individual’s autonomy are absent, the individual is deemed a consenting participant and thus is branded a criminal. This essay critiques such a view and challenges existing approaches to identifying trafficked victims, in particular, for sex labor. This essay will argue that consent may be viable despite the absence of agreeable alternatives. In so doing, this essay questions whether individuals can be neatly placed into two categories—migrant smuggling and human trafficking—and instead points to different levels of consent within a continuous spectrum. As a result, these levels of consent will play a significant role when assessing each case of human trafficking.

I will use a comparative method on a range of real-life stories to demonstrate how a close reading of single events can yield a better understanding of the complex phenomenon of human trafficking. Since human trafficking is a transnational problem, regional approaches offer an appropriate variability across cultures. This paper will focus on Southeast Asia, where human trafficking is ardently denounced, but still endemically entrenched across the region.[4] The reference to real experiences of women from Indonesia, the Philippines, Thailand, Burma and Laos, provides variability in terms of religious beliefs, ideology and socio-economic status. Firstly, this essay will evaluate the relevance of consent and coercion on measures to distinguish trafficked victims from smuggled migrants. The concept of agency helps to illustrate women’s capacity to make choices about their own lives. Thenceforth, this essay suggests the “spectrum of consent” as a descriptive device to measure the nature of the women’s consent. Finally, even though it is beyond the scope of this paper to evaluate the impact of policy intervention, a few implications of anti-trafficking policy in Southeast Asia will be considered.

Sex worker rights advocates and feminist legal theorists have devoted attention to the conceptualizing of issues on sex work and trafficking.[5] The essence of their ideological divide lies on the relationship between trafficking in women and the crucial notion of consent. According to the Oxford Dictionary of Law, the legal definition of consent is “an act of reason and deliberation” and assumes the individual “possesses and exercises sufficient mental capacity.”[6] Even though international policies are based on the legal notion of consent to differentiate between trafficking and migrant smuggling, the presence or absence of consent as a moral and acceptable contribution to the definition of trafficking victims is still highly contested. Supporters of the feminist theory perceive sex work as inherently exploitative and reject the idea of consent as a relevant indicator of trafficking.[7] On the other hand, the sex worker rights advocates place the voluntary nature of the individuals’ actions at the center of their practical approach.[8]

Distinguished scholars, such as American sociologist Kathleen Barry and professor of criminal justice Ekaterina Osipova, argue that consent of the victim should be irrelevant to any proposed definition and scope of trafficking. They believe consent is inaccurate and oversimplified and would allow most traffickers to escape prosecution. Any legislation that allows traffickers to use consent as a defense would not protect most victims of trafficking. Not only do traffickers control the trafficking, but they can also control the evidence.[9] Many traffickers often require women to feign consent, for instance, they can make their victims pose smilingly for pornography. According to Dr. Osipova, “Some trafficking victims initially give their consent to be transported in search of legal employment. However, once force, fraud, or coercion are introduced, the individual is now referred to as ‘trafficked,’ having not agreed to exploitative circumstances.”[10] For this situation, exploitation rather than coercion should be the operative concept in any definition of trafficking. Dr. Barry claims, “No women can choose to do the work of prostitution.”[11] The logic of her claim follows two arguments: first, sex work involves a level of self-harm to which no woman could ever consent; second, no other meaningful labor option exists, which renders choice impossible. The sum of Barry’s propositions also supports a universalized approach to prostitution and trafficking.[12] Since sex work is inherently a form of violence against women, it does not matter how they entered the sex trade. This position asserts that all women involved in sex work are coerced; they are powerless victims.

Contrary to the gendered approach, which underestimates the role of voluntary undertakings and characterizes consent as irrelevant, the liberal approach measures the individual’s moral culpability based on consent and his/her deliberate actions.[13] This approach argues that the trafficking of autonomous individuals is rarely something thrust upon them by a coercive agent, but is instead a consequence of their deliberate conduct.[14] Therefore, it creates, to some degree, moral symmetry[15] between the consenting agents. The consent or lack thereof, is subsequently significant as a basis for apportioning blame in the case of consent, and to weaken any claim to victim status. A UN report in 2000 stated that: “[it] is the non-consensual nature of trafficking that distinguishes it from other forms of migration.”[16] In other words, each person is entitled to have a natural right to determine [for themselves] the direction of their lives without interference; individuals are not only entitled to the rewards produced by their decisions, but they are also responsible for any negative outcomes of their choices.[17] As a result, individuals’ right to form and execute agreements without interference, supersedes any judgment of others who might disagree with the outcome of an actor’s voluntary conduct.

In contrast to the polarized opinions regarding consent as the legitimate basis for human trafficking analysis, there is almost no controversy in the case of individuals who are innocent of their own trafficking and are referred to as “deserving victims” in the sex-work realm. Unlike smuggled migrants, human trafficking victims do not willingly violate the law; they have no reasonable alternative to obeying the commands of the trafficker.[18] While smuggled migrants are generally treated as business allies by their smugglers, trafficking victims are subjected to threats, forced isolation, and other forms of coercion, fraud, deception, or abuse in order to guarantee obedience.[19]

The testimony of Memey, a 28-year-old Indonesian woman who was trafficked and forcibly recruited into commercial sex work, better illustrates the case of many other non-consenting trafficked victims. Memey was born in Temanggung Central Java, Indonesia. When her husband died and left her with a small child to feed, she saw no other option but to try finding a better paying job abroad. “A neighbor told me that there was an opportunity to work in Malaysia as a waitress,” she explained.[20] Since she had worked in Singapore before, she thought this would be a similar, if not better, opportunity. However, criminal networks quickly took advantage of her situation and illegal status as soon as she arrived in Malaysia. Middlemen held her captive for four months. “We were watched closely, there was no opportunity to escape. Our passports were taken away, and we did not have access to a phone either,”[21] She described. When Memey finally escaped, she found that she was infected with HIV. She returned home but did not tell her family about the work she had been forced to do in Malaysia. What is undeniably revealed in the story of Memey is that her daily life was characterized by anxiety, fear, torture, poverty, and social isolation. In short, because of the lack of consent, coercive means, and forced exploitation involved in her case, Memey cannot be referred to as a migrant labor in Malaysia, but as a victim of human trafficking in Indonesia.

Memey’s story portrays her as a victim of forced labor. However, her story is just one amongst countless other unique cases. There are others that, instead, confront the argument that sex work is inherently degrading and violent and recognize sex work as a form of labor. From an anthropological perspective, sex work is the performance of a service rather than the selling of the “self.”[22] It is explained as an assertion of female sexual autonomy and subversion of patriarchy. With the story of the Angel Club Filipinas, Dr. Sealing Cheng provides an illustration of the recognition of migrant women as cultural and social actors in her book: On The Moon For Love. The purpose of her ethnography is to show how migrants Filipinas make their deployment to South Korea “their own,” not as commoditized labor or sex objects, but as individuals motivated by their “capacity to aspire.”[23] Moving away from the presumed framework of sexual victimhood, Cheng studies the Filipina migrant workers as “laboring and erotic subjects;”and their migration is understood as their voluntary pursuit of a better future. [24] A brief summary of their story is narrated below to demonstrate that women’s victimhood in sex work is not a universal truth.

In August 1999, Winnie and six other Filipina entertainers ran away from the Angel Club in Dongducheon, the largest US military camp town (gijichon) in South Korea. Upon arriving at Dongducheon, Seoul police interrogated the club owner, Aunt Lee. After a night of negotiations between the Filipinas and the club owner, the Filipinas decided they wanted to retrieve their personal belongings from the Club. Rather than returning to the shelter assigned to them, they decided to make the trip back to Dongducheon with Aunt Lee. Sealing Cheng describes how she could not understand why they would want to leave with Aunt Lee; only when she met with the Filipinas a week later did she find out that they had all been eager to meet their American boyfriends that same night. In fact, for most of the rest of their stay in South Korea they were put up in motel rooms by their boyfriends. Two of them, over the next two years, married them. After a few days, the Filipinas were not eager to return home since they were looking forward to hanging out with their boyfriends and finding jobs in other clubs in the area.[25]

Cheng takes this experience to reveal the logic of these migrant women’s actions, motivations and struggles. Her ethnography makes sense of their lives as migrant women in gijichon,where they are marginalized and stigmatized, yet hopeful and agentive. Similarly,anthropology professor Mahdavi Pardis uses the concept of agency to refer to the women’s capacity, desire, and potential to make choices about their own lives. While this line of argument does not mean to minimize the abuse that some women indeed face, many women do in fact choose to migrate into sex work. The paradigm that portrays women like the Angel Club Filipinas as innocent, by assuming they are tricked or kidnapped into transnational sex work, denies their agency and courage. Nonetheless, these women should be seen as agents of change because they are making deliberate choices and seeking to improve their own circumstances.[26]

There is, however, little understanding that most women fall somewhere in between these two poles of non-consenting trafficked victims and willing migrants for sex work. In reality, most women fall within the “spectrum of consent,” also referred to as the “human trafficking-smuggled migrant spectrum.”[27] This spectrum is a descriptive device to clarify the range of considerations that might determine whether or not any decision—of the victim—might be said to be autonomous. One might ask if the prosecution has truly shown there was no consent. Even though in the current legal system there can be no spectrum of convictions, only guilty or not guilty, the following analysis treats consent and coercion as a continuum, as opposed to a dichotomous approach. There are many levels of consent, however, and the total complexities and levels of consent cannot be completely encapsulated in this essay. Therefore, with the following real world demonstrations, this essay will discuss two levels of consent: informed and uninformed. These two levels will be discussed in order to measure the women’s capacity to make an intelligent and deliberate decision unaffected by fraud, pressure, or sometimes even by mistake.

Tolerance and agreement to the actual sex work may stem in some cases from religious beliefs and the absence of a strong social stigma.[28] A large number of Thailand’s population is Buddhist. The Buddhist beliefs, especially in northern Thailand, contribute to community acceptance of prostitution and sex trafficking because it allows women to earn enough money to send to their families.[29] According to Siriporn Skrobanek, nearly 300 million dollars are transferred yearly between trafficked women engaged in prostitution and their families in Thailand.[30] Thai Buddhists hold that “each person’s soul inhabits many physical bodies over time, with the quality of each life influenced by the soul’s store of merit.”[31] Merit can be earned by providing aid to one’s parents, despite the nature of the work itself. Most villages believe that children owe a debt of merit (bun khun) to their parents for their having endured the hardships of childbearing.[32] The merit gained would bless the young women in their next life, negating the effects of having been a sex worker. In the journal Voice of Thai Women, Skrobanek tells the story of a twenty-year-old female sex worker, Nang, in Bangkok. When a European man tries to help Nang escape from the bar she works at, she expresses no plans to quit working there because the money she earns provides her with more than enough for the basic needs of her and her family. These reactions do not seem to be those of a forced or victimized woman, but rather the choice and informed decision of a sex worker to make money because her filial piety outweighs any stigma.

Like Nang, there are many other women in Thailand aware of the risks and reputation of the sex industry who still give their consent to migrate to Bangkok as sex workers, believing “that a good deed for one’s mother is equivalent in merit to a good deed for ten others.”[33] Some of them even describe that their sex work is a modern urban activity that young Thai women enjoy. In 2002 a former sex worker from Phayao village in her 30s stated, “I had a very good income, worked short hours, indoors, it wasn’t hot, I could shop with my friends during the day, and my skin stayed white. I don’t really think it was bad.”[34] The assertion of the former sex worker illustrates how some young women understand prostitution as a tradition and as a normal job in the city. The social stigma and reputation as a sex worker is weaker than in other non-Buddhist countries.

However, not all educated and informed women give their consent because of their religious beliefs; others have no other alternative. Many women in Southeast Asia become prostitutes out of economic desperation and lack of other job opportunities. In August of 2009 a Women’s Community Revitalization Project (WCRP) field reporter interviewed Ma Thit Thit, an eighteen-year-old woman from Burma working in Ye township. “Think about it, nobody enjoys working as a prostitute, but we have no money to survive,”[35] she said. Poverty disproportionately affects women, who consistently receive less pay than men for equal positions. Many women do not have the skills or education to find work outside of the house, yet daughters in Burma are often expected to provide for their parents. This vulnerable socio-economic status often leads women to enter the sex industry, but few of them tell their families how they earned the money. “My family doesn’t know what I am doing here. I lied to them and told them I worked at a normal job,” added Ma Thit Thit. As her experience reflects, a large number of sex workers in Burma are not tricked or forced into the trade; in fact, they are well aware of their situation. However, they do not become prostitutes out of their own volition but out of economic necessity to survive. Ma further explained, “Even though it is not a good job, I decided to work as a prostitute so that I could earn a higher income to send back to my family… We are poor and need the money.”

Burma is one of the world’s poorest countries and was ruled from 1988 until 2011 by a brutal military junta called the State Police and Development Council (SPDC).[36] The SPDC’s political mismanagement and isolationist policies led to a rising inflation and economic stagnation in the country. Moreover, in 1997 with the Asian financial crisis, Burma’s already weak economy sank even further leading to more job cuts and rising unemployment.[37] Many women who leave their country (or their villages) are cognizant of the kind of work that awaits them, but still migrate for employment in the sex industry, feeling it is their only alternative. The choice to migrate remains a free and autonomous one since the women are capable of making informed decisions for their own lives. Nevertheless, Ma’s experience demonstrates that she did not have the ability to maintain her autonomy. “Even though I know this is not a good job… we are poor and always face a shortage of money. Therefore, I must do it even though I don’t want to,” said Ma Thit Thit.[38] In the face of only unappealing options, a woman’s choice to engage in sex work cannot be deemed a truly autonomous one, although it may be the best option from the available array of life choices. A strict definition of coercion cannot always capture the levels of softly coercive elements within the lives of women who seemingly voluntarily choose to migrate for sex work.

Similarly, a strict definition of consent or non-consent cannot fully reflect the cases in which the trafficker induces the victim through deception and fraud, rather than coercion or force. Any consent given to a specified act cannot be considered informed and legitimate when important information for the decision-making process is withheld from the consenting agent.[39] The following story will reflect the shared experiences of ordinary women who hope to cross the border and find a lawful employment upon arrival, yet are instead subjected to illegal entry and forced to work as sex workers—a reality far from that which was promised.

Vahn[40] was sixteen years old when she was deceived into becoming a sex worker. She is from Champasak, a province in Laos. One day, a woman whom Vahn’s family knew very well came to visit and told Vahn about a job opportunity as a housekeeper at the border between Thailand and Malaysia. “You will be well paid, earning 4,500 Baht [140 USD] a month, in a good environment and it will be easy work,”[41] the woman said. But this woman was a trafficker. In total there were four families who agreed to send four of their young daughters to the border, including Vahn, with the promise that they would be safe and well paid. When they arrived at their final destination they did not see a home but instead a karaoke bar/massage/beauty salon. The next day they received massage training, and then they were informed that they also had to provide sexual services. At first the girls refused, but then the trafficker told them they would have to pay back all the expenses that they had previously been told were covered. Since it was impossible for them to pay this amount, and they did not have the documentation to leave, they were forced to work as sex workers. As Vahn’s story demonstrates, such deception can render a situation of facilitated migration one of human trafficking. Regardless of the original arrangement to accept the job, the presence of fraud means there was no valid agreement to sex work—the original consent has been nullified and no longer applicable.

All in all, one can determine that the ability to distinguish between victims of human trafficking and willing participants is informed by social notions about human dignity and moral culpability, and how each situates consent. While the liberal approach maintains the importance of consent and respect for human dignity and voluntary undertakings, the gendered approach, on the contrary, discounts the connection between human dignity and the exercise of personal autonomy. To be effective, however, it is also necessary to evaluate the sequence of choice that gave rise to the lack of agreeable alternatives.[42] Regardless of whether or not one is inclined to agree with the gendered or liberal approach, what appears undeniable is that each view is supported by an anti-trafficking construct. Hence, confusion and injustices regarding victim identification is likely to continue—and probably increase—so long as one tries to narrow down each case to either side of the line. The testimonies of different former sex workers around Southeast Asia demonstrate that in the real world, most women fall within the spectrum of consent or the grey area between a fully informed decision and a forced act of trafficking. Though placing consent and coercion within a continuum will make it more difficult to implement policy within the legal framework, treating consent and coercion as binaries ignores the complexities of a human trafficking victim’s situation and regresses to a retrograde understanding of human trafficking.[43]

Savitri Restrepo Alvarez (’16) attends Wellesley University.



Works Cited

Asian Development Bank. “Facilitating Safe Labor Migration in the Greater Mekong Sub-region.” Issues, Challenges and Forward-Looking Interventions, 2013.

Aung, Maung Htin. “Government and History of Myanmar.” Encyclopædia Britannica, 2013.

Barry, Kathleen. Female Sexual Slavery. Englewood Cliffs, NJ: Prentice Hall, 1979.

Cavalieri, Shelley. “Between Victim and Agent: A Third-Way Feminist Account of Trafficking for Sex Work.” Indiana Law Journal 86:1409 (2010).

Cheng, Sealing. On the Move for Love: Migrant Entertainers and the U.S. Military in South Korea. Philadelphia: University of Pennsylvania Press, 2010.

Dewaraja, L.S. The Position of Women in Buddhism. Kandy: Buddhist Publication Society, 1981.

Doezema, Jo. “Now You See Her, Now You Don’t: Sex Workers At The UN Trafficking Protocol Negotiations.” Social and Legal Studies 14:61 (2005).

Elliott, Jessica Christine. “The Role of Consent In The Trafficking of Women For Sexual Exploitation: Establishing Who The Victims Are, and How They Should be Treated.” PhD Diss., University of Birmingham College of Arts and Law, 2011.

Jha, Lalit K. “Report: Why Burmese Women Become Sex Workers.” The Official Website of Human Rights Foundation of Monland, November 2009. <>.

Jones, Samuel Vincent. “Human Trafficking Victim Identification: Should Consent Matter?” Indiana Law Review 45:2 (2012).

Law, Jonathan and Elizabeth A. Martin. A Dictionary of Law. 7th ed. Oxford: Oxford University Press, 2014.

Mensendiek, Martha. “Women, Migration and Prostitution in Thailand.” International Social Work 40:2 (1997): 163-176.

Osipova, Ekaterina. “Human Trafficking and Ways to Battle it During the World Economic Crisis.” Internal Security: Police Academy in Szczytno 3:7 (2012).

Pardis, Mahdavi. Gridlock Labor, Migration, and Human Trafficking in Dubai. Palo Alto: Stanford University Press, 2011.

Raymond, Janice G. “When It Comes to Human Trafficking, Consent Is Irrelevant.” Coalition Against Trafficking in Women, July 2009.

Reece, Rick. “A Survivor of Human Trafficking.” Village Focus International, 2013.

Siriphō̜n, Sakhro banēk, Nataya Boonpakdee, and Chutimā Čhanthathīrō. The Traffic in Women: Human Realities of the International Sex Trade. London: Palgrave Macmillan, 1997

Taylor, Lisa Rende. “Dangerous Trade-offs: The Behavioral Ecology of Child Labor and Prostitution in Rural Northern Thailand.” Current Anthropology 46:3 (2005).

Thanenthiran, Sivananthi, and Sai Jyothirmai Racherla. “Reclaiming & Redefining Rights: Status of Sexual and Reproductive Health and Rights in Asia Pacific.” Asian-Pacific Resource & Research Centre for Women (ARROW), 2013. <>.

United Nations. “Protocol to Prevent, Suppress and Punish Trafficking in Persons, especially Women and Children, supplementing the United Nations Convention against Transnational Organized Crime”. United Nations Treaty Series vol. 2237 no. 39574. New York. November 15, 2000. <>.

United Nations Office on Drugs and Crime. “‘Put yourself in my shoes’: a human trafficking victim speaks out.” November 28, 2012. <>.

Victims of Trafficking and Violence Protection Act, 2000.Public Law No. 106-386. 106th Congress, 2nd Session (October 28, 2000).

Vilchez, Andréa. “Human Sex Trafficking in Thailand.”Aquinas Group, May 8, 2011.



[1] Victims of Trafficking and Violence Protection Act, 2000,P.L. No. 106-386, 106th Congress, 2nd Sess. (October 28, 2000).

[2] Shelley Cavalieri, “Between Victim and Agent: A Third-Way Feminist Account of Trafficking for Sex Work.” Indiana Law Journal 86:1409 (2010): 18-20.

[3] United Nations, “Protocol to Prevent, Suppress and Punish Trafficking in Persons, especially Women and Children, supplementing the United Nations Convention against Transnational Organized Crime”, United Nations Treaty Series vol. 2237 no. 39574, New York, Nov. 15, 2000. <>.

[4] Jo Doezema, “Now You See Her, Now You Don’t: Sex Workers At The UN Trafficking Protocol Negotiations,” Social and Legal Studies 14:61 (2005): 62-63.

[5] Jessica Christine Elliott, “The Role of Consent In The Trafficking of Women For Sexual Exploitation: Establishing Who The Victims Are, and How They Should be Treated,” Ph.D diss, University of Birmingham College of Arts and Law, 2011, 19.

[6] Jonathan Law and Elizabeth A. Martin, A Dictionary of Law, 7th ed., (Oxford: Oxford University Press, 2014), 103.

[7] Samuel Vincent Jones, “Human Trafficking Victim Identification: Should Consent Matter?” Indiana Law Review 45:2 (2012): 485.

[8] Ibid., 490

[9] Janice G. Raymond, “When It Comes to Human Trafficking, Consent Is Irrelevant,” Coalition Against Trafficking in Women, Jul. 2009, 1-2.

[10] Ekaterina Osipova, “Human Trafficking and Ways to Battle it During the World Economic Crisis,” International Security: Police Academy in Szczytno 3:7 (2012): 4.

[11] Kathleen Barry, Female Sexual Slavery, (Englewood Cliffs, NJ: Prentice Hall, 1979), 46.

[12] Ibid., 50.

[13] Jones, 492.

[14] Ibid., 493

[15] Tooley’s moral symmetry principle states that there is no moral difference between refraining from stopping an action and performing the action itself if motivations are the same.

[16] United Nations, “Protocol to Prevent, Suppress and Punish Trafficking in Persons”, 5.

[17] Jones, 495.

[18] Mahdavi Pardis, Gridlock Labor, Migration, and Human Trafficking in Dubai, (Palo Alto: Stanford University Press, 2011), 17.

[19] Ibid., 21

[20] United Nations Office on Drugs and Crime, “‘Put yourself in my shoes’: a human trafficking victim speaks out,” Nov. 28, 2012, <>.

[21] Ibid.

[22] Sealing Cheng, On the Move for Love: Migrant Entertainers and the U.S. Military in South Korea, (Philadelphia: University of Pennsylvania Press, 2010), 23.

[23] Ibid., 10.

[24] Ibid., 27.

[25] Cheng, 1-5.

[26] Pardis, 68.

[27] Jones, 449.

[28] L. S. Dewaraja, The Position of Women in Buddhism, (Kandy: Buddhist Publication Society, 1981), 8.

[29] Andréa Vilchez, “Human Sex Trafficking in Thailand,” Aquinas Group, May 2011, <>.

[30] Sakhro banēk Siriphō̜n and Nataya Boonpakdee and Chutimā Čhanthathīrō, The Traffic in Women: Human Realities of the International Sex Trade, (London: Palgrave Macmillan, 1997), 20.

[31] Mensendiek, “Women, Migration and Prostitution in Thailand,” International Social Work 40:2 (1997): 163.

[32] Ibid., 164.

[33] Ibid., 26.

[34] Lisa Rende Taylor, “The Behavioral Ecology of Child Labor and Prostitution in Rural Northern Thailand,” Current Anthropology 46:3 (2005): 4-6.

[35] Lalit K. Jha, “Report: Why Burmese Women Become Sex Workers,” The Official Website of Human Rights Foundation of Monland, Nov. 2009, <>.

[36] Maung Htin Aung, “Government and History of Myanmar,” Encyclopædia Britannica, 2013.

[37] Jha, “Report: Why Burmese Women Become Sex Workers,” 2009.

[38] Ibid.

[39] United Nations, “Protocol to Prevent, Suppress and Punish Trafficking in Persons”, 2.

[40] Vahn is not her real name.

[41] Rick Reece, “A Survivor of Human Trafficking,” Village Focus International, 2013, 1.

[42] Asian Development Bank, “Facilitating Safe Labor Migration in the Greater Mekong Sub-region,” Issues, Challenges and Forward-Looking Interventions, 2013, 14.

[43] Sivananthi Thanenthiran, and Sai Jyothirmai Racherla, “Reclaiming & Redefining Rights: Status of Sexual and Reproductive Health and Rights in Asia Pacific,” Asian-Pacific Resource & Research Centre for Women (ARROW), 2013, <>.