The Government of Mongolia 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 to the previous reporting period; therefore, Mongolia remained on Tier 2. These efforts included investigating more trafficking cases, convicting more traffickers, and increasing the size of the National Police Agency’s (NPA) anti-trafficking unit. The government approved implementing regulations on amendments to the Child Protection Law related to the provision of services to trafficking victims. However, the government did not meet the minimum standards in several key areas. Authorities prosecuted fewer traffickers and identified fewer victims, and lack of government support resulted in the closure of both shelters for trafficking victims during the reporting period. Courts did not convict a labor trafficker for the fifth consecutive year, and officials did not identify any foreign victims. Overlapping and at times conflicting articles in the criminal code complicated anti-trafficking judicial processes and continued to incentivize prosecutions and convictions under charges with lesser penalties. The government lacked formal written procedures for proactive victim identification.
PRIORITIZED RECOMMENDATIONS:
Increase efforts to implement and train officials on Articles 12.3 and 13.1 of the criminal code to investigate and prosecute sex trafficking and forced labor crimes rather than under alternative administrative or criminal provisions that prescribe lesser penalties. * Develop and implement formal government-wide SOPs for victim identification and referral to protective services and train government officials – including law enforcement, border protection, prosecutors, and labor and child rights inspectors – on their use. * Improve coordination, information-sharing, and anti-trafficking data quality among anti-trafficking agencies, including police, prosecutors, the judiciary, and social services. * Ensure victims have access to protection services regardless of whether officials initiate formal criminal proceedings against the alleged traffickers. * Allocate resources for the Multidisciplinary Task Force (MDTF). * Amend Articles 16.1 and 16.4 of the criminal code to increase prescribed penalties so they are aligned with penalties for other child trafficking crimes. * Amend Article 8 of the Labor Law to align its definitions with preexisting anti-trafficking laws, including by eliminating exemptions for labor in basic landscaping and cleaning. * Allocate increased resources to support and expand shelters and other forms of victim assistance, including for male victims who identify as lesbian, gay, or bisexual. * Strengthen efforts to monitor the working conditions of child and foreign workers in Mongolia and screen them for labor trafficking indicators by increasing funding, resources, and training for labor inspectors and child rights inspectors, and facilitating unannounced inspections.
PROSECUTION
The government increased law enforcement efforts.
Article 13.1 of the criminal code criminalized sex trafficking and labor trafficking; it prescribed penalties of two to eight years’ imprisonment for offenses involving an adult victim and five to 12 years’ imprisonment for those involving a child victim. These penalties were sufficiently stringent and, with respect to sex trafficking, commensurate with those prescribed for other grave crimes, such as rape. Other provisions of the criminal code additionally criminalized some forms of labor and sex trafficking. Article 13.13 separately criminalized forced labor and prescribed fines, community service, probation, and/or one to five years’ imprisonment. Article 12.3 of the criminal code criminalized sexual exploitation offenses, including some forms of sex trafficking; penalties ranged from two to eight years’ imprisonment for trafficking offenses involving individuals older than the age of 14, and 12 to 20 years’ imprisonment for those involving children younger than the age of 14. As in prior years, authorities sometimes prosecuted trafficking crimes under statutes carrying lesser penalties. For example, the government reported prosecuting sex trafficking offenses under Article 12.6, which criminalized “organizing prostitution” involving adults and prescribed penalties of six months to three years’ imprisonment. Articles 16.1 and 16.4 criminalized “inducing a child to the committing of a crime” and “forcing a child into begging,” respectively; they both prescribed penalties of a travel ban for one to five years or one to five years’ imprisonment. Observers, including officials, noted complex case initiation and referral procedures; law enforcement, prosecutorial, and particularly judicial officials’ general unfamiliarity with anti-trafficking laws; rapid turnover of investigators; and criminal code articles with overlapping and often conflicting definitions and penalty provisions at times hindered investigations and prosecutions.
Authorities continued to categorize certain crimes as trafficking based on Mongolia’s more expansive legal definitions, resulting in law enforcement data that at times included cases involving child pornography, sexual extortion, and “organizing prostitution.” The government initiated 85 trafficking investigations, including 41 for sex trafficking involving at least 28 alleged perpetrators and six for labor trafficking – two of which involved forced child labor; this was compared with 42 investigations in 2023, including 36 for sex trafficking and six for labor trafficking. The government continued monitoring for sex solicitation on social media and reported 38 cases of unspecified forms of exploitation involving 36 alleged perpetrators from these efforts (62 cases and 36 perpetrators in 2023); the majority of these cases involved child pornography and it was unclear how many involved trafficking. Authorities initiated prosecutions of 35 defendants, including 29 for alleged sex trafficking crimes (four defendants under Article 12.3, 12 under Article 12.6, and 13 under 13.1), and two for alleged forced labor (under Articles 13.13 and 16.10); this was compared with initiating prosecutions of 41 traffickers in 2023 – 34 for alleged sex trafficking crimes and seven for forced labor. In addition, the Prosecutor General’s Office reported prosecuting four defendants under Article 16.8 (“Advertising and dissemination of pornography or prostitution, inducement to a child”), which carried lesser penalties, compared with 20 defendants the prior year; authorities did not provide sufficient detail to ascertain whether these cases featured trafficking elements according to the definition under international law. The government reported 38 ongoing sex trafficking prosecutions initiated in previous reporting periods compared with 25 reported ongoing prosecutions in 2023. Courts convicted 22 individuals for sex trafficking-related crimes in 2024, an increase from 10 in 2023. The courts convicted all 22 sex traffickers under anti-trafficking articles, including three individuals under Article 12.3, seven under Article 12.6 and 12 under Article 13.1, compared with 10 individuals (four under Article 12.3 and six under Article 13.1) in 2023. Courts did not convict any labor traffickers for the fifth consecutive year (three labor traffickers were convicted in 2019). The government did not provide sentencing data for convictions in 2024. Courts revised the charges in at least five cases initially investigated and prosecuted under Article 13.1 to Article 12.3; cases pursued under Article 12.3 often imposed lower sentences than those pursued under Article 13.1. The government did not report any investigations, prosecutions, or convictions of government employees complicit in human trafficking crimes; however, corruption and official complicity in trafficking crimes remained concerns.
In recent years, because of the misconception among many government officials that traffickers only exploit women and girls crossing borders, authorities rarely used Articles 12.3 or 13.1 to prosecute cases in which traffickers targeted male victims and instead used provisions with less stringent penalties. Civil society representatives reported various judicial entities often maintained conflicting or incomplete data on anti-trafficking case registration and history. A lack of sufficient training among police and prosecutors outside Ulaanbaatar on the overly complex legal codes led to inconsistent enforcement of the law, including local police dropping potential trafficking cases or misidentifying them under other criminal codes.
The NPA anti-trafficking unit’s jurisdiction to cover trafficking crimes was previously limited to Criminal Code Articles 12.3 and 13.1; in May 2024, the Prosecutor General’s Office amended this jurisdiction to include Article 12.6, 13.13, 16.6 (child trafficking), 16.8 and 16.9 in addition to articles of the criminal code prohibiting crimes such as kidnapping, forced disappearance, the illegal taking or transplantation of human blood and organs, and the spreading infectious diseases or viruses that may endanger the lives of others. The expansion of the unit’s responsibilities to cover crimes that may not involve trafficking as defined under international law potentially impacted its capacity to investigate sex and labor trafficking crimes. An NPA cyber-crime division was responsible for investigating crimes under Articles 16.8 and 16.9. Following an external assessment, Ministry of Justice and Home Affairs (MOJHA) expanded the capacity of the anti-trafficking unit from six to 13 officers in February 2025, to accommodate the unit’s expanded responsibilities; these new positions were in the process of being filled at the end of the reporting period. The Prosecutor General’s Office had a division assigned to specialize in supervising investigations of trafficking crimes and prosecuting trafficking cases. Officials reported improved interagency coordination among police, prosecutors, and civil society, although legal barriers remained an obstacle to successful prosecutions.
In partnership with international organizations and NGOs, the government continued training law enforcement officers, prosecutors, judges, state inspectors for child rights, and immigration officials on topics including new regulations for implementing anti-trafficking laws, conducting victim-centered and child-friendly investigations, investigating cyber-facilitated trafficking, forensic and trauma-informed interviewing, and identifying and referring trafficking victims to services. Observers and officials continued to describe an acute need for additional training, resources, and dedicated personnel to properly handle trafficking cases. It was unclear if training had resulted in increased use of victim-centered approaches in practice. Officials renewed an MOU on law enforcement coordination with local Chinese authorities from China’s Inner Mongolia Autonomous Region.
PROTECTION
The government decreased efforts to protect victims.
According to available data, police identified at least 28 Mongolian potential trafficking victims, including 15 adult and 10 child potential victims exploited in sex trafficking, and three potential labor trafficking victims; this was compared with 30 trafficking victims (20 women and nine girls exploited in sex trafficking, and one male labor trafficking victim) identified in 2023. Victims were only formally identified as trafficking victims after a prosecution was initiated, but authorities did recognize potential victims who could be referred to and receive services for trafficking victims; during 2024, authorities formally identified 19 victims of trafficking (eight women and 10 girls exploited in sex trafficking, one man exploited in labor trafficking. Authorities also initiated investigation of a case involving seven potential female victims of labor trafficking from Sierra Leone; however these victims had not been identified as trafficking victims as of the end of the reporting period. Authorities have not identified a foreign victim of trafficking since 2021. The government did not have formal written procedures for proactive victim identification. Instead, investigators and immigration officials had access to a victim identification checklist, although use was sporadic, especially in rural areas. District and provincial police either lacked training on the checklist or were unaware of its existence, which potentially resulted in cases dropped at the local level and fewer victims referred to NPA investigators. NGOs indicated victim identification and referral procedures were vague, not sufficiently systematic, and often depended largely on the awareness and initiative of individual officers. Due to inconsistent screening among vulnerable populations, a lack of formalized screening and identification procedures, as well as untrained officers, the government did not take effective measures to prevent the inappropriate penalization of potential victims – particularly girl sex trafficking victims – solely for unlawful acts committed as a direct result of being trafficked. In previous years, observers noted some victims did not self-report or testify because of fear they could face prosecution. In July the government organized a restructuring of multiple Ministries; the Ministry of Labor and Social Protection (MLSP) which oversaw most victims protection efforts was renamed the Ministry of Family, Labor and Social Protection (MFLSP), and the MLSP’s Family, Child, and Youth Development Agency (FCYDA) was changed as the General Authority for Child and Family Development and Protection (GACFDP) which took over FCYDA’s protection implementation responsibilities. Observers reported this restructuring resulted in significant turnover of staff and impacted the ministry’s ability to advocate for its work, particularly during budget negotiations.
Government officials lacked training on how to identify and refer to care child victims of forced labor. GACFDP also reported cases of local officials and law enforcement preventing child rights inspectors from accessing some worksites, such as race courses. Social and child protection workers used procedures for victim identification and referral to services but a continued lack of training for labor inspectors and social workers limited the referral system’s use. Officials reportedly identified two victims of child labor in hazardous work, which may have amounted to trafficking.
The government allocated 30 million MNT ($8,770) to NGOs to provide shelter, psycho-social and medical care, and legal assistance, the same amount allocated in the prior year. NGOs continued to provide the majority of Mongolia’s limited victim services, in some cases with government assistance. Observers have noted overlapping or conflicting victim services and referral data between different government agencies and government-assisted NGOs. In 2024, 16 adult sex trafficking victims were referred to services by NGOs, according to combined government and civil society estimates, compared with 77 adult and child sex trafficking victims and 16 forced labor victims referred to services by NGOs in 2023. The MDTF had five child-friendly spaces at police stations and court houses to allow children, including trafficking victims, to provide evidence in safe, less-traumatizing environments.
There were two NGO-run trafficking-specific shelters, however both shelters closed in June 2024 due to concerns the government had not approved accreditation standards for trafficking shelters as required by law. An NGO also operated a shelter for women in commercial sex and women and child sex trafficking victims. Officials reported the closure of trafficking-specific shelters had a serious impact on their ability to provide protection services to victims of trafficking, and some child sex trafficking victims were instead referred to the remaining NGO shelter. The government operated 39 low-capacity temporary shelters and one-stop service centers for women and child victims of domestic and sexual abuse, including one NPA-operated shelter for victims of sexual violence and one temporary shelter for children operated by the GACFDP, both of which could serve trafficking victims. Observers reported difficulty differentiating between these government shelters and one-stop service centers, and that some locations appeared to always be closed. Authorities did not report referring victims to NGOs for shelter or health services, partly due to shelter closures; in the past observers noted the referral process was inefficient and untimely. Long-term shelter services were not available for child trafficking victims, but in severe cases, GACFDP could provide shelter services for child victims for up to six months. GACFDP also maintained a rehabilitation center to help child victims with their recovery through long-term psychological care and other services. There were no shelters for men and few shelters, if any, were accessible for people with disabilities. In practice, victims who identified as lesbian, gay, or bisexual could receive shelter if they were minors, women, or did not explicitly reveal their sexual orientation or identity. An audit by the Capital City Audit Agency of the government’s child protection policy found a lack of coordination between agencies, insufficient involvement of officials, limited budget and human resources, and violations of temporary shelter standards posed a risk to the effectiveness of child protection efforts – including for child victims of human trafficking – during 2024.
The Law on Criminal Procedure and Law on Victim and Witness Protection provided protections for the physical security and privacy of victims and witnesses; however, the NPA anti-trafficking unit reported referred nine trafficking victims to witness and victim protection services in 2024. Article 8.1 of the Law on Criminal Procedure states that a victim must be formally recognized by the decision of an investigator, prosecutor, or the court; this language has reportedly been used to deny potential trafficking victims access to protective services. Some officials claimed victims could still access protection services regardless of whether relevant prosecutions had begun; nevertheless, the language represented a barrier to access for potential trafficking victims. Authorities did not provide victims with alternatives to speaking with law enforcement during investigations, and victims – including child victims – were regularly interviewed multiple times by law enforcement and prosecutors which observers reported led to the re-traumatization of victims. Victims could provide testimony via written statements and could obtain employment and move freely within Mongolia or leave the country pending trial proceedings. However, child victims’ testimony required a legal guardian’s verification and approval to be admitted as evidence, posing added risks to abandoned children or to children whose guardians were complicit in their child’s trafficking; in these cases, child victim advocates could request the government assign a social worker in place of complicit legal guardians. The government did not report if victims participated in investigations during the reporting period.
In September 2024, amendments to the Child Protection Law went into effect to formalize the MDTF, refine case management protocols, and ensure comprehensive delivery of protection services to vulnerable children, including trafficking victims. During the reporting period, the government approved some implementing regulations for these amendments on providing shelter, services, and employment and vocational training for trafficking victims, procedures for ensuring the dignity and safety of victims and requirements for testimony rooms. However, two implementing regulations on protection services to child trafficking victims and procedures for the MDTF to providing services were still pending at the end of the reporting period.
The anti-trafficking law entitled victims to legal counsel and representation, as well as to compensation from traffickers. However, inconsistencies between the criminal code and the civil code made the provision on restitution difficult to implement; for the second year the government did not report issuing court-ordered restitution to any trafficking victims, compared with 34 victims receiving court-ordered restitution in 2022. The government also did not report any trafficking victims receiving compensation from the government’s victim compensation fund, and observers noted that in practice, compensation was mainly provided to a victim’s family for burial expenses when victims died. Mongolia’s General Intelligence Agency, the General Authority for Border Protection (GABP), and the Consular Department within the Ministry of Foreign Affairs shared responsibility for handling cases involving Mongolian trafficking victims abroad. The latter maintained a fund to assist Mongolian victims, but it was only available in cases involving organized crime syndicates or “grave harm” – a distinction that was unclear in application. In 2024, authorities partnered with NGOs to repatriate one Mongolian victim from China, compared with 12 Mongolian victims repatriated from China, Laos, and Thailand in 2023. Authorities did not report repatriating foreign victims for the third consecutive year. Mongolian law did not provide legal alternatives to the removal of foreign victims to countries in which they could face retribution or hardship.
PREVENTION
The government increased efforts to prevent trafficking.
The National Sub-Council on Trafficking in Persons (“the council”) met three times in 2024. The MDTF worked to combat child trafficking at the working level and comprised 18 government and NGO representatives. The MDTF met at least quarterly and continued to implement its Strategic Action Plan to combat child trafficking, devoting more staff time across the interagency to facilitate collaboration in child services.
The government increased the MOJHA’s anti-trafficking budget to 244.9 million MNT ($71,610) in 2024 from 240 million MNT ($70,175) in 2023. It designated 30 million MNT ($8,770) of this budget for contracted services with at least one NGO; the remainder of this budget was used for awareness-raising activities and purchasing equipment and tools for the NPA, and National Forensics Agency. The Secretariat for the Coordinating Council for Crime Prevention oversaw implementation of 90 percent of the recommendations from a 2023 review of Mongolia’s anti-trafficking efforts; this included efforts such as submitting recommendations on standardizing sentencing to parliamentarians overseeing Criminal Code revisions; conducting studies on the use of Articles 12.3 and 13.1, best practices of other countries’ anti-trafficking efforts, and why labor exploitation cases in Mongolia do not reach courts. In partnership with NGOs, international organizations, local media, and foreign donors, the government conducted a national campaign to raise awareness of trafficking, which included social media outreach, radio broadcast spots, and awareness raising activities at schools, such as essay writing contests and distributing trafficking-related comic books. The Ministry of Education partnered with NGOs and foreign donors to provide afterschool programs on forced labor and sex trafficking prevention to high schoolers in high risk schools. MDFT also organized human trafficking awareness displays for travelers at two ports of entry, and the GABP and Immigration Agency distributed 50,000 trafficking awareness passport inserts at some border crossings. Municipal GACFDP offices and District Governors deployed 200 volunteers for a home visit program to engage and educate communities on child protection, domestic violence, school attendance, health and welfare, and human trafficking and victim identification.
A hotline maintained by an NGO identified at least two child victims, which were referred to authorities for criminal investigations. GACFDP operated another 24-hour hotline that coordinated referrals to special welfare and protection, emergency response, and shelter services for child victims. The GACFDP did not report how many calls this hotline received in 2024. Police confirmed that some calls to this hotline led to investigations for suspected trafficking crimes but for the second year the government did not report how many, compared with investigators following up with 317 children after receiving 251 calls on possible “hazardous child labor” in 2022.
The MFLSP’s General Agency for Labor and Social Welfare had the authority to monitor labor agreements for foreign nationals working in Mongolia, as well as those for Mongolians working in countries with which the government had bilateral work agreements. The government maintained such agreements with the ROK and Japan; observers noted authorities did not always sufficiently implement these agreements to prevent labor abuses, including trafficking. MFLSP employed 66 labor inspectors and GACFDP employed 54 child rights inspectors (who accompany labor inspectors for some inspections, particularly for horse jockeying cases); officials and NGOs noted the number of labor inspectors and child rights inspectors was insufficient for the monitoring of all workplaces and labor sectors where child labor occurs, and that funding and resources for the inspectors were insufficient to provide comprehensive oversight. The government did not report how many labor inspections it conducted in 2024, or if any resulted in the identification of cases of forced labor. Labor laws gave inspectors “unrestricted access to legal entities, organizations, and workplaces which are subject to inspection without prior notice;” however, a competing law still required inspectors to give employers two days’ advance notification before conducting an inspection, raising concerns employers could conceal violations in the interim. The government did not report conducting unannounced labor inspections, but it did conduct preventative assessments at workplaces and issued recommendations based on identified problems. Labor laws explicitly prohibited labor agents from charging workers recruitment fees, confiscating workers’ identity or travel documentation, switching their contracts without consent, or garnishing or withholding their wages as collateral; authorities did not report information on implementation of these provisions. The government did not make efforts to reduce the demand for commercial sex acts.
TRAFFICKING PROFILE:
Trafficking affects all communities. This section summarizes government and civil society reporting on the nature and scope of trafficking over the past five years. Human traffickers exploit domestic and foreign victims in Mongolia, and traffickers exploit victims from Mongolia abroad. Traffickers may also use Mongolia as a transit point to exploit foreign individuals in sex trafficking and forced labor in Russia and China. Most sex trafficking of Mongolian victims from rural and poor economic areas occurs in Ulaanbaatar, provincial centers, and border areas. Mongolian communities experiencing widespread unemployment – especially women and informal sector workers – were especially vulnerable to sex trafficking and forced labor. Observers report that individuals who identify as lesbian, gay, or bisexual are vulnerable to trafficking amid widespread discrimination that often jeopardizes their employment status and complicates their access to justice. Domestic violence continues to drive the vast majority of Mongolian trafficking victims to seek and accept unsafe employment opportunities on which traffickers target.
Traffickers continue exploiting women and girls in sex trafficking in Mongolian hotels, massage parlors, illegal brothels, bars, and karaoke clubs, as well as in outdoor urban areas, sometimes facilitated by a lack of enforcement of local police. Traffickers often utilize online platforms to lure, groom, or blackmail victims, including Mongolian children, into domestic sex trafficking. Japanese and ROK nationals reportedly engaged in extraterritorial commercial child sexual exploitation and abuse in Mongolia in prior years and some civil society groups believe this practice persists. Traffickers sometimes use drugs, fraudulent social networking, online job opportunities, or English-language programs to lure Mongolian victims into sex trafficking abroad. Some men in the predominantly ethnic Kazakh regions of western Mongolia subject local women and girls to abduction and forced marriage as part of a cultural practice known as Ala kachuu, or “grab and run”; some women and girls forced into marriages may be subjected to sex trafficking or forced labor.
The mining industry’s ongoing development in southern Mongolia drives growing internal migration, intensifying trafficking vulnerabilities. This was especially the case along the China-Mongolia border prior to 2020. Stringent border restrictions between January 2020 and January 2023 during the pandemic limited movement across the border, while creating new vulnerabilities. For example, women and girls in affected coal mining and trucking communities faced additional pandemic-induced economic hardships, increasing their vulnerability to trafficking, and truckers desperate to make deliveries across restricted borders were vulnerable to labor exploitation. Since the end of these border restrictions, new train lines and improved logistics management have mitigated some of these concerns. Nevertheless, individuals in mining and trucking communities near the border remain vulnerable to labor and sex trafficking due to poorer living conditions, itinerant work, and a lack of public services.
Children working in informal sectors of the Mongolian economy such as artisanal mining, horseracing, herding and animal husbandry, landfill scavenging, and construction are often younger than the country’s minimum age of employment and vulnerable to forced labor. In particular, Mongolian boys engaging in work as horse jockeys and circus performers are vulnerable to sex and labor trafficking, in part because of frequent travel domestically and abroad. Children living in poverty or who are abandoned by their families are often recruited into child labor, increasing their risk to forced labor. Some Mongolian families are complicit in exploiting children in sex trafficking and forced labor.
Traffickers exploit Mongolian men, women, and children in forced labor and sex trafficking in China, ROK, Türkiye, and the United States, as well as other countries in Asia, Europe, and the Middle East. Observers reported a high and increasing number of Mongolian children traveling abroad – particularly over the land border into China – for competitions; although these opportunities involve legitimate sports, music, and school competitions, children are sometimes taken abroad under the auspices of competitions and are instead subjected to labor trafficking working as horse jockeys, on farms, or performing other menial labor. Traffickers reportedly increasingly exploited Mongolian victims in Türkiye because of visa-free travel regimes, the availability of direct flights, and shifts in migration trends after the pandemic-related closure of the Chinese border. Chinese national workers employed in Mongolia are vulnerable to trafficking as contract laborers in construction, manufacturing, agriculture, forestry, fishing, hunting, wholesale and retail trade, automobile maintenance, and mining. As of September 2023, as many as 7,880 Chinese nationals were reportedly working in Mongolia. Observers report corruption among some Mongolian officials impedes the government’s anti-trafficking efforts.

Published Date:2025-09-30