drugs. However, they denied any responsibility and claimed unlicensed actors in rural areas were responsible for running the smuggling rings. Despite public knowledge of the use of subagents, the BEOE has not made any moves to formalise this sector. While a small number of complaints have been registered against the use of subagents, holistic steps to streamline the procedure have not been taken, leaving the use of subagents not only prevalent but also unregulated. Informal conversations with employees at the BEOE suggested that the institution’s role was limited to oversight only over licenced OEPs who are seldom the first (arguably the most crucial) point of contact for an intending migrant worker. Six of the interviewed OEPs claimed the oversight was only limited to extorting fines from these OEPs and no meaningful efforts at resolving real issues were taken. Four of the interviewed OEPs claimed it was unclear whether any money ever reached the complainant migrant worker. In these interviews, OEPs refused to take responsibility for facilitating or directly participating in the exploitation of vulnerable migrant workers claiming that “the responsibility does not lie with [the recruiter]. How is there any [proof of my] involvement because my job is simply to produce the appropriate paperwork for migration.”34 They further stated that it was seemingly a friend or a relative that brought the passports of the workers and that an OEP cannot be expected to tell the difference between a drug trafficker or a relative. According to another OEP, the migrants claimed that the person that was accompanying them or sent on their behalf was a trustworthy person. In cases where “a worker, who has gone through our agency, gets into trouble,” the OEP informed JPP, “we are usually told to pay a bribe to the Protector of Emigrants office or detained for a few days after the initial investigation and then we are free to continue our work.”35 Hence, there are little to no consequences for OEPs for not performing their duty. The Emigration Ordinance states “When, in the course of any proceeding in connection with emigration in which an Overseas Employment Promoter is concerned, a breach of the provisions of this Ordinance or of the rules is committed, such person shall be liable to the punishment provided by subsection (2) unless he proved that he was not responsible for and could not have prevented the commission of the breach.” In this way then, subagents, while undeniably playing a significant role in the trafficking of victims, easily avoid liability by shifting responsibility onto subagents. Three hundred and sixteen complaints about OEPs were filed from May 2016 to June 2018. However, the majority of these were marked as settled by the complainant or closed because of non-pursuance by the complainant. Only 28 licences were “suspended until settlement”, four were restored after settlements were awarded and three were marked as closed. Two of those closed found the OEP to be not guilty and one was said to have been “amicably settled and the parties being informed accordingly.” One of the closed complaints involved the case of a subagent which was then recommended to be referred to the FIA (Figure 1.3 on page 18). Despite the involvement and use of subagents, the licence of the OEP was not affected nor was any penalty charged. The BEOE was named as one of the four respondents on the public interest litigation filed on behalf of the detainees. To date, they have not issued a response. 15