Abstract
<jats:p>The aim of the study was to identify the similarities and differences of the legal and institutional frameworks for the response to trafficking in human beings in Europe and Central Asia. The use of a comparative legal analysis enabled the study to be conducted in a rigorous manner, and enabled rigorous comparisons both between national criminal law provisions, and both between legislation that was specialised, as well as institutional coordination and monitoring mechanisms. This ensured that differences between jurisdictions were found both in the harmonisation of international standards, as well as in the implementation of these standards in practice. The results indicated that in the majority of cases, international standards are incorporated more comprehensively into EU member State domestic legislations. There are established robust interagency cooperation mechanisms, there are well-developed monitoring and reporting mechanisms, and there is substantial engagement of civil society organisations, and comprehensive victim assistance that is provided by these organisations. These elements combine to form a model that has an unwavering focus on the victim-centred approach to addressing the problem of trafficking in human beings. In contrast, the study found systemic shortcomings with regard to Central Asian States in relation to their fragmented implementation of international commitments, their insufficient protection of victims of trafficking, and their lack of interagency cooperation and the insufficiently developed independent monitoring mechanisms. It is this which impact significantly upon the effective operation of domestic national anti-trafficking mechanisms. The differences also therefore point to directions for the adaptation of the most effective European practices in strengthening monitoring mechanisms and digital readiness, and also in relation to other Central Asian States</jats:p>