A/HRC/7/3 page 19 55. UNHCR has stated that “FGM, which causes severe pain as well as permanent physical harm, amounts to a violation of human rights, including the rights of the child, and can be regarded as persecution. The toleration of these acts by the authorities, or the unwillingness of the authorities to provide protection against them, amounts to official acquiescence. Therefore, a woman can be considered as a refugee if she or her daughters fear being compelled to undergo FGM against their will; or, she fears persecution for refusing to undergo or to allow her daughters to undergo the practice.”69 In the refugee context it has also been found that FGM amounts to “continuing and permanent persecution”.70 (c) Human trafficking 56. Although all human trafficking cases have their individual characteristics, most follow the same stages: victims are abducted or recruited in the country of origin, transferred and then exploited in the destination country, where they are forced into sexual or labour servitude or other forms of exploitation. Victims of human trafficking are very often kept in forced confinement.71 Women working in brothels often undergo constant surveillance through the use of video cameras and may be forced to use drugs or stimulants by their traffickers as a means of control. A recent study on trafficking in women from Romania to Germany shows that the level of psychological control held by the traffickers over their victims is generally so high that most of the victims are not able to act on any opportunity to escape.72 During the exploitation phase victims are often forced to work up to 18-24 hours per day and subjected to severe forms of physical and mental violence, including beatings, sexual abuse, humiliations and threats that may amount to torture or at least cruel, inhuman and degrading treatment.73 Psychological problems observed in victims of trafficking include post-traumatic stress disorder, depression, overwhelming shame, loss of self-esteem, loss of sense of safety, dissociation, anxiety and 69 Office of the United Nations High Commissioner for Refugees (UNHCR), Memorandum on female genital mutilation, 10 May 1994, para. 7. 70 United States Court of Appeals of the Ninth Circuit, Mohamed v. Gonzales, Nos. 03-70803 and 03-72265, March 2005; see also “Report and analysis of immigration and nationality law”, Thomson West: Interpreter Releases, vol. 83, No. 9, 27 February 2006, pp. 385-391. Ditto. Ed. 71 With respect to the situation of domestic workers, see for example the report of the Special Rapporteur on trafficking in persons, especially women and children regarding her mission to Bahrain, Oman and Qatar, A/HRC/4/23/Add.2, paras. 69-75. For information regarding forced marriage in the context of trafficking, see A/HRC/4/23, paras. 13-60. 72 United Nations Interregional Crime and Justice Research Institute (UNICRI), Trafficking in Women from Romania into Germany, March 2005, p. 46, available at: http://www.gtz.de/de/dokumente/en-svbf-unicri-trafficking-romania.pdf. 73 See article 3 (a) of the Protocol to Prevent, Suppress and Punish Trafficking in Persons, especially Women and Children.