ENoMW Submission
ENoMW Submission on the EU Anti-Trafficking Strategy: Re-Centring Sex-Based Violence
The European Network of Migrant Women (ENoMW) has submitted its assessment of the current EU Anti-Trafficking Strategy, analysing it from a women’s rights perspective, with particular attention to migrant women and trafficking for sexual exploitation.
Across all pillars, ENoMW identifies a central weakness: trafficking continues to be framed as a sex-neutral crime and migration-management issue, rather than as a form of sex-based violence rooted in structural inequality, male demand, and the commodification of women’s bodies.
Prevention: Addressing Structural Inequality and Male Demand
Current prevention efforts remain focused on awareness-raising and procedural coordination, while failing to address the structural conditions exposing women to trafficking. The submission critically examines policy shifts that prioritise labour exploitation frameworks, warning that such approaches obscure the nature of sexual violence and the role of prostitution systems.
ENoMW recommends integrating demand reduction as a core pillar of the EU strategy and ensuring that the EU Anti-Trafficking Coordinator possesses demonstrated expertise in sex-based violence.
Protection of Victims: Ensuring Durable Safety
Access to protection and support remains fragmented, conditional and closely tied to criminal justice processes. As a result, many victims are left without durable safety or meaningful exit pathways. For migrant women, fear of immigration enforcement often deters disclosure and cooperation.
ENoMW calls for unconditional, long-term support, independent of criminal proceedings, and for the recognition of emerging forms of exploitation — including forced marriage and surrogacy — as trafficking.
Investigation and Prosecution: Moving Beyond Victim Testimony
A persistent gap remains between suspected trafficking cases and convictions, largely due to an over-reliance on victim testimony. The submission advocates for a shift toward evidence-led investigative models, including systematic financial investigations that target profit flows and the male-dominated nature of trafficking perpetration.
Cooperation: Prioritising Women’s Safety
Existing cooperation frameworks often prioritise security, border control and returns over women’s safety, thereby increasing the risk of re-trafficking. The strategy must embed sex-explicit analysis across all areas of cooperation and formally include independent women’s and migrant-led civil society organisations.
Private Sector Accountability
Cooperation with businesses and digital platforms remains compliance-driven and sex-neutral. ENoMW recommends addressing the role of digital infrastructures in facilitating sexual exploitation and ensuring that anti-trafficking decision-making is protected from conflicts of interest involving the commercial sex trade.