printer and publisher of a newspaper in which such advertisement is published, shall be liable to punishment.” Furthermore, Section S.11-A of the Emigration Rules 1979 restricts the establishment of OEP regional offices, stating that an OEP “shall not shift his office or open more than two branch offices or shift the same except with the prior permission of the Federal Government and on payment of a fee of five thousand rupees.” The restrictions on official, legally established branches results in many OEPs, regardless of involvement in criminal activities, using subagents to facilitate their work. All the interviewed OEPs confirmed that they relied on subagents or other unregistered actors to connect them with workers. The indispensable nature of the work of subagents and the inevitability of their use by OEPs means that current rules ignoring the role of subagents pushes an integral part of the migration procedure into the realm of illegality, black markets and zero accountability, opening up possibilities of human trafficking and drug smuggling. Recruitment chains, especially for semi and unskilled migrant workers, have multiple, complex steps that often levy high financial and personal costs on workers. The use of subagents and ineffective enforcement of regulations makes it difficult to identify the individual or organisation that is responsible for misleading and exploiting workers. This informal way of practising recruitment allows official institutions to devolve responsibility for fraudulent practices onto OEPs, and OEPs to devolve responsibility onto notoriously difficult to locate subagents. In cases where families of migrant workers imprisoned abroad did try to initiate legal proceedings against subagents, the subagent either disappeared or the family was unable to move beyond the initial stages of inquiry and investigation. In addition to subagents, migrants may often take help from friends and relatives or returnee migrants who have knowledge about the migration regime. Therefore, in regions with concentrated migration, such as Punjab and Khyber Pakhtunkhwa provinces, friends and relatives, abroad and at home, play a significant role in relaying their experiences to intending migrants, forming networks that provide job opportunities and visas for others in their town/ village/area. The involvement of friends and relatives in fraudulent practices is difficult to ascertain but claims by detainees have hinted at the involvement of such actors in their ordeal and their involvement with OEPs. While the regulation of personal networks is a complex task, the lack of regulation around OEP’s use of unauthorised actors and the processes of direct recruitment has exacerbated the problem significantly. This direct recruitment or recruitment through private OEPs (often via subagents or friends and relatives) is the most commonly used recruitment channel. In 2017, only 2-3 percent of workers going abroad for employment used the Overseas Employment Corporation, a public body which exists to facilitate recruitment.33 This is indicative of the country’s reliance on private (sparsely regulated) or personal networks to migrate; a reliance that allows corrupt individuals to take advantage of innocent and vulnerable citizens. The OEPs interviewed for the report acknowledged the widespread problem of narcotics smuggling and the deception and coercion of migrant workers into smuggling prohibited 14