[n2007 the POEA docketed 3,316 cases of recruitment violations which is a slight decline from the 3,81I in 2006. These resulted in969 orders of reprimand, suspension, fine, licence cancellation and preventive suspension issued and enforced for the year. In 2008, the POEA cancelled the licences of 64 agencies, 40 of which were due to charging exorbitant placement fees. However these numbers need to be qualified given the seeming scale of the problem of erring recruitment agencies and perceived weakness of the POEA in cracking down on these. Migrante has reports of agencies still being rated as of 'good standing'in the POEAs list of agencies even when they have failed to appear in hearings on complaints filed by victims of illegal recruitment. The sheer volume of migrants seeking desperately work abroad creates vastly profitable opportunities for trafficking syndicates that they would seek to protect by any means necessary. For instance it is alleged that Finardo Cabilao, a former director of the Department of Social Welfare and Development deployed to the Philippine Embassy in Kuala Lumpur, Malaysia as a social welfare attach6, was brutally murdered in by syndicates running a trade in humans and for sex that among other nationalities victimized Filipinos. The ease of travel to other ASEAN countries offers relatively easier prospects for undocumented work arrangements which perhaps partly explains the relatively high proportion of irregular workers in Malaysia, for instance working in large plantations. There are also accounts of recruitment agency exploitation and abuse even in the very early stages of application and outside of any actual processing ofjob applications. Agencies are perermially under pressure to show foreign employers that they have an updated and large stock ofprospective employees. To create this impression agencies have been known to artificially inflate their rosters with unqualified applicants who would never be hired - but where the unqualified job-seekers are nonetheless asked to come to the usually Manila-based agency at their expense and even if they come from the provinces. Oppressive contracts. The POEA in principle has a standard labor contract outlining bare minimums for migrants. This has been criticized for tending towards the low end of wages - especially insofar as low Philippine minimum wages set benchmarks - so as not to discourage employers and unduly constrain migration as well as not being sufficiently rigorously implemented. The DOLE for instance actually went so far as signing a Memorandum of Understanding (MOU) - called the Unified Contract with the Saudi National Recruitment Committee and the Council of Saudi Chamber of Commerce and Industry (SANARCOM) - that effectively prohibited OFWs from leaving their jobs even under objectionable working conditions. The report by the House Committee on Labor and Employment Report during the 13ft Congress found that it obligated OFW to "accept whatever work, salary and benefits is given, even if those are already in violation of the 30