Convention Annotation: The first two sections establish who can be prosecuted and the
scope of the crime. It is important to note that they do not cover trafficking by one or two
persons or internal trafficking that has no international aspect. For example, traffickers of
domestic workers are often a wife and husband who bring a worker from abroad and force
her to work in a foreign country with little or no pay or freedom. They would not be covered
by 2(a). Also not covered is trafficking that is done entirely within a country by nationals of
the country.
Domestic legislation should go further than the Trafficking Protocol and include all domestic
and cross-border trafficking and should punish individual traffickers as well as organized
criminal groups. Trafficking within some countries is as serious as, or more serious than,
cross-border trafficking. Furthermore, from the perspective of the victims, the harm can be
just as great no matter whether there are one or ten traffickers and whether the trafficking is
cross-border or internal. So the punishments for the traffickers and the protections for the
rights of trafficked persons should be the same regardless of whether the trafficking is
internal or across borders and whether there are one or twenty traffickers.