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Viewing cable 06SINGAPORE630, SINGAPORE'S SUBMISSION FOR THE 2006 TIP REPORT:

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Reference ID Created Released Classification Origin
06SINGAPORE630 2006-03-01 09:20 2011-08-25 00:00 UNCLASSIFIED//FOR OFFICIAL USE ONLY Embassy Singapore
VZCZCXRO2927
RR RUEHCHI RUEHDT RUEHHM RUEHNH
DE RUEHGP #0630/01 0600920
ZNR UUUUU ZZH
R 010920Z MAR 06
FM AMEMBASSY SINGAPORE
TO RUEHC/SECSTATE WASHDC 8961
INFO RUCNASE/ASEAN MEMBER COLLECTIVE
RUEHBJ/AMEMBASSY BEIJING 2083
RUEHLM/AMEMBASSY COLOMBO 0504
UNCLAS SECTION 01 OF 07 SINGAPORE 000630 
 
SIPDIS 
 
SENSITIVE 
SIPDIS 
 
STATE FOR G/TIP 
STATE FOR INL/HSTC 
STATE PASS AID 
 
E.O. 12958: N/A 
TAGS: KCRM PHUM KWMN ELAB SMIG ASEC KFRD PREF SN
SUBJECT: SINGAPORE'S SUBMISSION FOR THE 2006 TIP REPORT: 
PART I 
 
REF: A. STATE 3836 
 
     B. SINGAPORE 470 
     C. SINGAPORE 139 
     D. 05 SINGAPORE 3614 
 
1. This is the first of three messages relaying Embassy 
Singapore's 2006 TIP submission.  Due to the length of our 
submission, we have split it into three cables.  Part I 
covers the overview of Singapore's trafficking problem and 
prevention efforts.  The Embassy point of contact for this 
report is Colin Willett, phone: (65) 6476-9492; fax: (65) 
6476-9389; email: willettc@state.gov.  Per the request in 
para 17 of Ref B, to date the 
Embassy has spent the following time on the TIP report: 
 
COM: 3 hours; FE-MC: 5 hours; FS-1: 50 hours; FS-5: 150 hours. 
 
Summary 
------- 
 
2. (SBU) Overall, the trafficking situation in Singapore 
improved in 2006.  The nature of the trafficking problem in 
Singapore has not changed dramatically since last year's 
report, but the Singapore government is now more aware of and 
proactive against trafficking, and is working with local NGOs 
and other groups to combat the trade.  A variety of sources 
indicate that the number of trafficking cases in Singapore 
has declined, due to a decrease in the number of women 
working in the sex trade following a police crackdown on 
vice-related activities in late 2004 and early 2005.  On 
labor issues, particularly those related to foreign maids, 
the Ministry of Manpower has continued to refine its 
regulations, enforce the laws, and raise public awareness of 
the consequences of exploiting domestic workers. 
 
3. (SBU) In November 2004, ASEAN leaders made combating 
trafficking a priority.  Since that time, the government of 
Singapore has been more actively discussing and working on 
the issue with its ASEAN neighbors and local NGOs.  NGOs 
report a significant improvement in their working 
relationship with the government.  Not only are NGOs given 
more latitude to conduct their own programs, including media 
campaigns and school-based programs, but the police, 
immigration authorities, and the Ministry of Community 
Development, Youth and Sports are now reaching out to local 
civil society to solicit advice and input as well as to offer 
a more cooperative working relationship on investigations and 
public outreach campaigns.  Singapore is also preparing 
important legislative changes that will address key USG 
concerns: it plans to raise the age of consent for commercial 
sex from 16 to 18 and to make laws against sex with minors 
enforceable extraterritorially.  We expect Singapore to enact 
these changes in the first half of 2006. End Summary. 
 
Overview 
-------- 
 
4. (SBU) A.  Is the country a country of origin, transit or 
destination for international trafficked men, women, or 
children?  Specify numbers for each group; how they were 
trafficked, to where, and for what purpose.  Does the 
trafficking occur within the country's borders?  Does it 
occur in territory outside of the government's control (e.g. 
in a civil war situation)?  Are any estimates or reliable 
numbers available as to the extent or magnitude of the 
problem?  Please include any numbers of victims.  What is 
(are) the source(s) of available information on trafficking 
in persons?  How reliable are the numbers and these sources? 
Are certain groups of persons more at risk of being 
trafficked (e.g. women and children, boys versus girls, 
certain ethnic groups, refugees, etc.)? 
 
Singapore is a destination country for a limited number of 
women and girls trafficked for the purpose of prostitution 
and, in rare instances, foreign domestic workers who 
voluntarily come to Singapore to work but are subsequently 
subjected to conditions that may rise to the level of 
trafficking.  Singapore is not a country of origin for 
trafficked persons, either for sex or labor.  There is no 
internal trafficking in persons.  Post is not aware of any 
cases of trafficking victims transiting through Singapore, 
Singapore authorities do not consistently screen the several 
million transit passengers who pass through the transit 
lounge at Changi Airport each year. (There was one 
prosecution for trafficking involving a person transiting 
 
SINGAPORE 00000630  002 OF 007 
 
 
Changi in 2005, but the woman was later exonerated. See 
section II.F for details.)  U.S. Immigrations and Customs 
Enforcement (ICE) officials at post do not believe Singapore 
is a major hub for people smuggling, a circumstance that 
further reduces the likelihood that there are a large number 
of undetected trafficking victims in transit. 
 
There are no numerical estimates of the magnitude of 
trafficking in Singapore.  The number of cases that the 
Embassy has identified through discussions with the 
government, NGOs, and foreign Embassy consular contacts is 
well under 100; however, given that Singapore has a sizable 
sex industry, it is possible that the total number of victims 
exceeds 100. 
 
Estimates of the numbers of women who may have been 
trafficked are based primarily on police interviews with 
women involved in the sex trade and anecdotal evidence of 
local NGOs.  While these organizations are reliable, they 
rely heavily on voluntary disclosure by victims, and may 
therefore underestimate the number of persons trafficked. 
Most NGOs, government contacts, source country consular 
officials, and U.S. law enforcement officials working in 
Singapore agree that the overall number of trafficking 
victims is probably small. 
 
B. Please provide a general overview of the trafficking 
situation in the country and any changes since the last TIP 
Report (e.g. changes in direction).  Also briefly explain the 
political will to address trafficking in persons.  Other 
items to address may include: What kind of conditions are the 
victims trafficked into?  Which populations are targeted by 
the traffickers?  Who are the traffickers?  What methods are 
used to approach victims?  (Are they offered lucrative jobs, 
sold by their families, approached by friends of friends, 
etc.?)  What methods are used to move the victims (e.g., are 
false documents used?). 
 
The number of trafficking victims in 2005 was down slightly 
from 2004, probably due to a crackdown on the sex trade in 
Singapore (which began in late 2004) that has substantially 
reduced the number of foreign prostitutes working here. 
Local NGOs say that they have been coordinating with the 
Police and providing their observations on the patterns of 
behavior by foreign prostitutes and their pimps or vice 
abettors.  As a result, the NGOs say, immigration authorities 
are allowing fewer foreign prostitutes to enter Singapore, 
and Police have closed down many of the establishments, such 
as karaoke bars, where prostitutes and pimps had gathered. 
NGOs say the Police are also more frequently and more 
aggressively patrolling known "red light" areas.  Police 
detained approximately 1,700 women from January to June 2005, 
down from over 2,600 in the same period of 2004.  (Note: Post 
expects full-year, detailed data from MHA by the end of the 
week, and will send an update cable upon receipt.) 
 
Nearly all of the known or suspected cases in 2005 involved 
sex trafficking, in part because of vigorous government 
efforts in recent years to better protect domestic workers. 
None appears to have been confined by the traffickers or 
subjected to physical violence.  Consular officials from 
Embassies of source countries report that the cases they 
encounter usually involve women who come to Singapore 
voluntarily to work in the sex trade or elsewhere who then 
face some sort of coercion, usually psychological, not 
physical, by agents or pimps.  Typical stories involve women 
who were told they could find jobs here in a restaurant or 
bar, but arrived to find that legitimate work was not 
available or paid very poorly.  Now alone in Singapore, and 
often having borrowed money for their travel expenses, they 
do not want to or cannot go home empty handed, and enter the 
sex trade either of their own volition or at the urging of a 
recruiter.  Consular officers and NGOs report that few such 
women are physically threatened or abused.  For the few maids 
who face severe abuse that may rise to the level of 
trafficking, all come to Singapore willingly to work but are 
ultimately exploited by their employers -- through nonpayment 
of wages, illegal confinement, and physical or psychological 
abuse. 
 
The Government of Singapore is committed to combating 
trafficking in persons, as it is committed to stamping out 
all kinds of organized crime and corruption.  Singapore 
leaders place great stress on achieving a very low crime rate 
and maintaining extremely tight immigration controls. 
 
SINGAPORE 00000630  003 OF 007 
 
 
High-level commitment to combating trafficking appears to 
have strengthened since Prime Minister Lee Hsien Loong 
attended the 2004 ASEAN Summit, at which trafficking in 
persons was a primary topic of discussion. 
 
Singapore emphasizes tight control of immigration, effected 
through very tough laws, and has strengthened controls 
further since 2001.  While it adopted these controls 
primarily for security reasons and to prevent a large influx 
of undocumented workers, the controls also effectively serve 
to prevent large-scale trafficking in persons into Singapore. 
 Singapore also has allowed employers to legally bring in 
large numbers of domestic and unskilled workers, and at 
relatively low wages (Singapore does not impose a minimum 
wage); with ready access to inexpensive foreign labor through 
legal channels, few employers wish to risk draconian 
penalties by hiring illegal employees or exploiting 
trafficking victims. 
 
Local NGOs report that the police, the Ministry of Community 
Development, Youth and Sports (MCYS), and the Ministry of 
Manpower have in the past year dramatically increased their 
efforts to work in concert with NGOs and other civic groups 
both to promote public education about trafficking (through 
school programs and publicity campaigns, for example) and to 
improve enforcement efforts. (See Sections II.C and II.F.) 
 
Law enforcement agencies routinely monitor all red-light 
districts using formal police checks, informants and 
electronic surveillance, and NGO representatives say they 
have stepped up efforts to police red light districts in the 
past year.  NGO contacts and consular officials here say the 
authorities fully investigate any allegations of trafficking 
and are anxious to prosecute traffickers -- in fact a common 
complaint is that investigations are so thorough that they 
often take months, requiring witnesses and victims to remain 
in Singapore.  The consensus among Embassy contacts in civil 
society and diplomatic circles is that Singapore is willing 
to devote whatever resources are necessary to combating these 
crimes. 
 
C.  What are the limitations on the government's ability to 
address this problem in practice?  For example, is funding 
for police or other institutions inadequate?  Is overall 
corruption a problem?  Does the government lack the resources 
to aid victims? 
 
The government has both the will and the resources to combat 
trafficking in persons; the largest limitations on its 
ability to address the problem are the generally 
uncooperative nature of the victims and the difficulty of 
obtaining evidence.  Overall, police, NGOs, and 
source-country embassies tell us that the women involved do 
not often allege force or coercion.  The vast majority of the 
women do not face any criminal or immigration charges, and 
generally choose to tell the police they were acting of their 
own free will in order to be allowed to return home 
immediately rather than remain in Singapore for months.  When 
women do allege trafficking, they are often not able to 
provide many details about their traffickers, and police and 
NGOs tell us that their stories are often difficult to 
verify, particularly when contradicted by their coworkers. 
Also, the trafficking rings themselves do not appear to be 
physically present in Singapore, but operate out of source 
countries with (at most) a few low-level agents or pimps 
present in Singapore.  As a result, the actual traffickers 
are generally beyond the reach of the Singapore Police. Some 
embassies remove victims from Singapore to pursue an 
investigation in the source country rather than press charges 
in Singapore. 
 
D.  To what extent does the government systematically monitor 
its anti-trafficking efforts (on all fronts -- prosecution, 
prevention and victim protection) and periodically make 
available, publicly or privately and directly or through 
regional/international organizations, its assessments of 
these anti-trafficking efforts? 
 
The Ministry of Home Affairs keeps extensive records on 
persons passing through border checkpoints, as well as 
records on all detentions, arrests, investigations, 
prosecutions and convictions, and publishes an annual report 
on crime in the first quarter of each year.  More detailed 
information on crime statistics is available upon request; 
local NGOs tell us that MHA has been forthcoming in response 
 
SINGAPORE 00000630  004 OF 007 
 
 
to their requests for such information.  The Ministry of 
Manpower keeps records on all allegations of maid abuse and 
the outcomes of their investigations, as well as other 
violations of the regulations governing employment of foreign 
workers.  MOM makes information on abuse allegations and 
prosecutions as well as violations by employment agencies 
available on its website.  The Ministry of Community 
Development, Youth and Sports keeps records on all cases 
where it has provided access to shelter or medical or 
psychological care. 
 
PREVENTION 
---------- 
 
5. (SBU) A.  Does the government acknowledge that trafficking 
is a problem in that country?  If no, why not? 
 
The government of Singapore acknowledges that a small number 
of the foreign prostitutes in Singapore have probably been 
forced or coerced into the sex trade.  The government also 
acknowledges that it continues to have a maid-abuse problem, 
but although it prosecutes all cases of abuse, it does not 
classify severe cases of abuse as trafficking.  The GOS's 
assessment -- shared by this Embassy -- is, however, that 
trafficking in persons is not widespread.  Authorities remain 
vigilant, and continue to take actions that directly or 
indirectly reduce the likelihood of trafficking. 
 
The government also does not describe as "trafficking" some 
cases that we would so classify: these cases include 16- and 
17-year olds wittingly and willingly engaged in prostitution, 
and "work disputes" involving women who entered Singapore for 
the purpose of prostitution.  Despite these definitional 
differences, the government prosecutes the vice operators 
involved in these cases, when it has prosecution witnesses. 
The GOS will raise the age of consent for commercial sex to 
18 in 2006.  Victims in these categories are few, as 
described in Section I.B. 
 
B.  Which government agencies are involved in 
anti-trafficking efforts and which agency, if any, has the 
lead? 
 
-- Singapore's Immigration and Checkpoints Authority controls 
the borders and looks for illegal immigrants, including 
trafficking victims, and for persons who employ or harbor 
illegal immigrants. 
 
-- The police monitor the sex industry, including through the 
use of informants, street patrols (uniformed and undercover), 
and electronic surveillance.  They interview women detained 
for public solicitation and pimps (both public solicitation 
and pimping are illegal), and look for coercion.  Police also 
investigate allegations or suspicions of maid abuse.  Until 
shortly before trial, police are responsible for law 
enforcement-related interaction with witnesses in criminal 
cases, including trafficking-related ones. 
 
-- The Attorney General's Chambers prosecutes both 
trafficking and domestic abuse cases. 
 
-- The Ministry of Manpower investigates complaints by 
foreign workers about pay or working conditions, attempts to 
resolve problems through mediation or enforcement action, 
works with employment agencies to improve business practices 
and encourage the industry to police itself, and carries out 
education efforts among both employers and employees. 
 
-- The Ministry of Community Development, Youth, and Sports 
(MCYS) assists victims with counseling and obtaining 
temporary shelter, if required, and is involved in public 
education campaigns to raise awareness of trafficking crimes 
such as child prostitution. 
 
 
C.  Are there or have there been government-run 
anti-trafficking information or education campaigns?  If so, 
briefly describe the campaign(s), including their objectives 
and effectiveness.  Do these campaigns target potential 
trafficking victims and/or the demand for trafficking (e.g. 
"clients" of prostitutes or beneficiaries of forced labor)? 
 
In February 2006, the Ministry of Manpower and 
government-linked telecommunications company Singtel launched 
a information campaign that aims to raise awareness among 
 
SINGAPORE 00000630  005 OF 007 
 
 
foreign workers, including maids, of their rights and the 
resources available to them by printing such information and 
maid and police hotline numbers on prepaid phone cards 
(popular with foreign workers). 
 
Local NGOs have sponsored a number of anti-trafficking 
awareness programs in the Singapore school system in 2006, 
including a recent conference on child prostitution for 
secondary school students organized by students from Raffles 
Girls School.  Singapore's two largest national universities, 
the National University of Singapore and Nanyang 
Technological University, have run a variety of seminars and 
information sessions (open to the public) on a range of 
trafficking-related issues. 
 
NGO contacts report that the Ministry of Community 
Development, Youth and Sports will launch a campaign against 
child sex tourism in March 2006 in accordance with an 
ASEAN-wide awareness program initiated at the ASEAN Summit in 
November, 2004 in Vientiane. 
 
In addition to these specific programs, the government runs 
an on-going public campaign to raise awareness among 
employers and employees about the rights of foreign workers, 
who comprise nearly 30 percent of Singapore's labor force. 
These publicity efforts include highlighting Singapore's 
tough laws against abuse of domestics or harboring illegal 
immigrants.  Government-linked media run regular features on 
domestic worker abuse and exploitation, and the 
government-linked press widely publicizes convictions. 
Public shaming is considered a significant part of the 
justice system's punishment and deterrence efforts; NGO 
contacts say that press coverage given to abuse cases and 
other foreign worker issues, combined with Singapore's new 
regulations and improved efforts to publicize those 
regulations, has had a positive impact on the welfare of the 
foreign workers here. 
 
In 2005, the government-linked media has taken up the cause 
of sex-trafficking as well, with a particular focus on child 
prostitution and child-sex tourism.  A local television 
program on the government-owned Channel News Asia, for 
example, has run a series of episodes on victims of sex 
trafficking, and local newspapers run occasional "victims' 
stories" to highlight the human cost of trafficking and 
exploitation. 
 
D.  Does the government support other programs to prevent 
trafficking? (e.g., to promote women's participation in 
economic decision-making or efforts to keep children in 
school.)  Please explain. 
 
This question seems addressed to countries that are origin 
countries for trafficking victims; Singapore is not a victim 
origin country.  Singapore has a first world economy and has 
legally protected women's equal rights to education, 
employment and independence since 1961.  Education is 
compulsory, and there are a number of programs designed to 
make sure all children have access to education at all 
levels.  Nearly all Singaporeans go to secondary school, and 
half pursue a post-secondary education. 
 
F.  What is the relationship between government officials, 
NGOs, other relevant organizations and other elements of 
civil society on the trafficking issue? 
 
Civil society leaders involved in combating trafficking in 
persons report a dramatically improved working relationship 
with the government over the past 18 months.  Multiple NGOs 
have reported that they now have frequent contact with both 
the police and the Ministry of Manpower (MOM), and in many 
cases have individual officers' and supervisors' personal 
mobile phone numbers to facilitate communication.  One NGO 
said that even very high-level officials are "remarkably 
accessible," and noted that all email requests from their 
organization to the Senior Minister of State for Home Affairs 
Ho Peng Kee have received a response within the same working 
day (MHA includes both the Police and Immigration).  Another 
organization noted that Police acted on any tips passed from 
that group "immediately."  Several NGOs told us that the 
Police now call them for advice on difficult investigations, 
and expressed satisfaction with how the police are handling 
cases referred to them. 
 
NGOs that work with sex-trafficking victims say that the 
 
SINGAPORE 00000630  006 OF 007 
 
 
Police have also consulted with them on several issues, 
including ways to improve police interviewing techniques and 
interaction with women who may have been victimized. They 
report that the Police hav successfully used NGOs information 
on how pimps and prostitutes operate to crack down on the 
vice trade.  The Police have also given the NGOs advice on 
Singapore laws and guidance on the types of information and 
evidence that are most helpful in police investigations, so 
that the NGO workers can ask the right questions when they 
encounter potential victims.  NGOs working with domestic 
workers say that MOM's Foreign Manpower Management Division 
routinely consults them on policy changes and takes any 
suggestion for new regulations or policies seriously, and has 
implemented NGO suggestions it found to be workable. 
 
The government also has excellent relations with the 
embassies of the various source countries.  All but one 
(which does not report such crimes to the Singapore Police) 
say that the authorities actively investigate allegations 
they bring to the government's attention, whether of 
sex-trafficking, maid abuse or work permit violations.  Most 
say that the new regulations regarding foreign workers have 
been helpful in securing their welfare, although there is 
some concern that education requirements may disadvantage 
their nationals, many of whom cannot meet the literacy 
requirements. 
 
G.  Does it monitor immigration and emigration patterns for 
evidence of trafficking?  Do law enforcement agencies screen 
for potential trafficking victims along borders? 
 
Singapore closely monitors its borders for any suspicious 
behavior or evidence of criminal activities.  Singapore has 
one of the world's toughest immigration regimes, and the 
Government further stepped up controls after September 11, 
2001.  These measures act as substantial barriers to illegal 
immigration and to trafficking in persons as a subset of this 
problem. 
 
Singapore maintains a record of all travelers who enter and 
exit Singapore, including information on persons they were 
traveling with and the vehicles they were in.  It checks all 
travelers' information against government-wide lists of 
prohibited travelers, suspicious persons, and immigration 
offenders before clearing them.  The GOS is currently 
addressing the technical changes needed to participate in 
Interpol's database of lost and stolen travel documents 
(which became available to member countries at the end of 
2005) to allow it to better target transnational crime.  The 
GOS anticipates completing the arrangements by mid-2006. 
 
NGOs and source-country consular officials say the Singapore 
government is attentive to all indications of trafficking and 
thoroughly investigates when there is evidence of such 
crimes.  For example, in 2005, although transit passengers 
are not specifically screened, the Immigration and 
Checkpoints Authority arrested a woman in the transit lounge 
after an alert airport employee noticed she did not speak the 
same language as the children traveling with her.  She was 
charged and tried for trafficking but was ultimately 
exonerated when the children's parents were located and told 
police the woman was a family friend who had agreed, with the 
consent of both parents, to bring the children to their 
mother in Paris. 
 
The Ministry of Manpower (MOM) also maintains a record of 
offenses (ranging from minor technical infractions up to 
serious crimes) committed by employers of foreign workers and 
can and does bar persons from employing foreign domestics 
based on past abuse.  From January to September 2004, the 
Ministry blacklisted 54 employers for abusing their maids, 
and between 2001 and June 2003 jailed 22 employers for abuse. 
(Note: Post expects to receive updated statistics by 
mid-March, and will file revised text at that time. End 
Note.)  MOM also revoked the licenses of six employment 
agencies for violating the Employment of Foreign Workers Act 
in 2005.  In February 2006, MOM adopted a demerit system for 
employment agencies, with infractions earning 3, 6, or 12 
demerits depending on the severity; 12 cumulative demerits 
will result in revocation of the company's license.  The 
tally of all employment agencies demerits is available for 
public viewing on the Ministry's website (www.mom.gov.sg). 
The Ministry also bars some employers of other foreign 
workers from obtaining work permits based on patterns of 
misconduct (e.g., nonpayment of wages or inadequate housing); 
 
SINGAPORE 00000630  007 OF 007 
 
 
in industries heavily dependent on foreign workers, such as 
construction, the prospect of being so barred acts as a 
strong incentive for employers not to mistreat their workers. 
 
 
H.  Is there a mechanism for coordination and communication 
between various agencies, internal, international, and 
multilateral on trafficking-related matters, such as a 
multi-agency working group or task force?  Does the 
government have a trafficking in persons working group or a 
single point of contact?  Does the government have a public 
corruption task force? 
 
There is an independent anti-corruption agency with broad 
powers, which aggressively pursues cases of possible 
corruption against government officials and private citizens. 
 
There is not a formal anti-trafficking task force; however, 
Singapore is an efficiently run municipality of 4 million, 
and interagency coordination within its small government is 
generally excellent.  In addition, government agencies 
cooperate well with foreign diplomatic representatives and 
NGOs in dealing with the rare cases of trafficking, and in 
implementing measures that prevent trafficking from occurring. 
 
J.  Does the government have a national plan of action to 
address trafficking in persons?  If so, which agencies were 
involved in developing it?  Were NGOs consulted in the 
process?  What steps has the government taken to disseminate 
the action plan? 
 
The government does not have a specific national plan of 
action to address trafficking in persons per se, given the 
small number of cases and diverse nature of the crimes here. 
Instead, it gives full authority to various agencies to 
implement available laws and regulatory tools to combat the 
various crimes that comprise "trafficking in persons."  MHA's 
Criminal Investigative Department is the primary agency for 
combating sex trafficking, in close coordination with MHA's 
Immigration and Checkpoint Authority, the Ministry of 
Community Development, Youth and Sports, and local NGOs.  The 
Ministry of Manpower is the primary agency for addressing 
labor trafficking, and works closely with source country 
consular officials, MHA's Immigration and Checkpoints 
Authority, Criminal Investigative Department, MCYS, and local 
NGOs.  Ministries have broad authority to adjust implementing 
regulations to make them more effective without formal 
approval from Parliament or a central body, although such 
changes are usually coordinated with other relevant 
government agencies as well as local NGOs before they are 
finalized.  Regulatory changes are frequently made in this 
manner -- several times a year, in the case of MOM. The 
changes are published in the government's gazette (available 
online) and on the relevant ministry's website, publicized in 
the media through ministry press releases, and in many cases 
distributed to subscribers to ministry mailing lists. 
 
HERBOLD