Anti-scam questions every employer should ask a foreign-worker agency

Cross-border recruitment has a long history of fee extraction, contract substitution, and broker-chain opacity. The buyer's exposure to that history is now structural. CSDDD (the EU Corporate Sustainability Due Diligence Directive) takes effect from 2027, and IOM IRIS certification audits are tightening their evidence requirements. The buyer's protection is the question set below. None of these questions is rhetorical; each one has an artefact that either exists or does not.

Question 1, What is the worker paying for, and what is the agency paying for?

The hard line on ethical recruitment is that the worker pays nothing. The IOM IRIS framework, the ILO General Principles and Operational Guidelines for Fair Recruitment, and every credible cross-border recruitment standard place every recruitment-related cost on the employer side. The agency that operates ethically can answer the line-item question without hedging.

The line items the worker should never pay:

• Placement or recruitment fee (the headline test).
• Medical examination, including the destination-specific panel (GAMCA for GCC, GCC Approved Medical Centres).
• Trade test before deployment.
• Document attestation and apostille fees.
• Embassy stamping fees and consular charges.
• Pre-Departure Orientation Seminar (PDOS) costs where applicable.
• Pre-arrival flight costs.
• Training programmes the agency or employer mandates.
• Accommodation deposits at the destination.
• Passport processing or renewal where the deployment requires it.

An agency that says "we don't charge placement fees" but cannot answer "what about the medical?" has not actually adopted the no-fee policy. The follow-up question is whether the agency will put the line-item commitment in the master services agreement as an explicit clause, with worker-paid-receipt audit rights for the buyer's CSR team. An agency that pushes back on this is selling a different product.

Question 2, Can you walk me through one recent worker's pre-departure receipts?

The strongest anti-scam check is the case-by-case audit. The buyer asks for one specific recent worker's pre-departure receipt set, anonymised, showing every line item the worker encountered between recruitment and flight. The receipts should show zero worker-side payments for any of the line items in Question 1.

This test catches the corridor where the headquarters operates ethically but the broker chain at the village level extracts fees outside the agency's audit window. An agency that runs in-country branches with direct candidate intake can produce the receipts. An agency that runs through a sub-agent or village-level broker chain cannot.

Question 3, How do you prevent contract substitution?

Contract substitution is the practice of changing the worker's contract terms between source-country signing and destination-country arrival. The worker signs a contract in Kathmandu for $1,500 monthly; the worker arrives in Riyadh and is presented with a different contract for $900. This is the second-most-common harm in cross-border recruitment after fee extraction, and the prevention is procedural.

The strongest prevention pattern is the source-country regulator's pre-departure contract verification, the DMW Verified Contract in the Philippines, the DOFE-attested contract in Nepal, the eMigrate-cleared offer in India. The worker carries the regulator-stamped contract, and contract substitution at the destination becomes a regulator violation, not just a private grievance.

The follow-up question is whether the agency runs the regulator-verified contract pathway on every deployment, or whether some corridors run "informal" routes without source-country contract verification. The honest agency answers explicitly and does not run informal routes.

Question 4, Who is the worker's first point of contact in the destination country?

The post-arrival accountability question. The worker has just landed in a country they do not know, in a language they may not speak, with paperwork they may not fully understand. Who meets them at the airport? Who delivers the post-arrival induction? Who do they call if the contract presented at the destination differs from the one signed at home?

The strong answer names the destination-country team, the Dubai mobilisation desk, the EU corridor lead, the local welfare officer. The weak answer is "the employer's HR team", because the employer is the counterparty to the worker's potential grievance, not a neutral first point of contact.

Question 5, How do you run the three-touchpoint post-deployment survey?

The corpus's strongest trust pattern is the three-touchpoint independent worker survey: origin community pre-departure, on-site at 30 days, and contract-end or post-return. The methodology is the operator-grade signal that the agency takes welfare seriously after the placement is made.

The buyer's follow-up: can you send a sample three-touchpoint report from a recent corridor, anonymised? An agency that runs the methodology has the artefact. An agency that "plans to start" has not yet earned this test.

Question 6, What is the documented scam pattern for your corridor, and how do you protect against it?

Every corridor has its specific predation pattern. The medical-fee-on-non-selected-applicants scam, where applicants pay for medicals and documentation before being told they were never selected, is the specific fraud pattern Filipino jobseekers have to navigate.

The buyer's question is whether the agency can name the specific scam patterns active in the source-country market and how the agency's procedures shut them down. Welder corridors out of Kathmandu carry training-fee scams. Caregiver corridors out of Mumbai carry passport-confiscation scams. Hospitality corridors out of Manila carry document-fee scams. An agency that cannot name the specific patterns active in its own corridors is not running the corridors directly.

Question 7, Who do you partner with, and where does the broker chain end?

The strong line on this question is to refuse third-party recruiters and run local relationships and offices in the source countries directly, with dedicated teams of experienced workers ready to deploy.

The buyer's audit question is to trace the chain from the village or town where the worker is recruited to the agency's headquarters. How many intermediaries sit in that chain? Are they paid by the agency or by the worker? Can the agency name every step and provide audit receipts for each?

A direct corridor has the agency's own branch in the source country, with named recruiters, named addresses, named in-country trade-test facilities. A broker chain has a sub-agent in the source country who works for a sub-sub-agent in the village, with the agency at the destination end taking the placement fee from the employer and passing some portion through the chain. The broker chain may work; the broker chain is not auditable end to end; and the broker chain is the structural source of fee extraction and contract substitution.

Question 8, What is your replacement guarantee, and what happens to the original worker?

The buyer protection of the replacement guarantee is well-covered. The worker protection is less often discussed. If a worker is "replaced" inside the probation window, what happens to that worker? Are they repatriated at the employer's cost or the worker's? Are they redeployed to another corridor inside the same agency? Are they written off?

The ethical answer names the replacement-with-redeployment pathway as the default, the original worker, if not at fault for the placement failure, is offered another corridor and another opportunity inside the agency's network at no additional cost. The agency that treats the worker as a sunk cost has the wrong incentive.

Question 9, What is your regulator escalation pathway for grievances?

Every cross-border agency operating ethically has a documented grievance pathway. The pathway names the regulator (DMW, DOFE, PoE, MOHRE, HZZ, NSZ), the contact details, and the timeline within which a worker's grievance is escalated if the agency cannot resolve it internally.

The strong pattern is a "Report a Concern" function as a top-level navigation item, not hidden in a footer, not behind a contact form, surfaced as a visible trust signal. The buyer's question is whether the agency makes the grievance pathway visible on the worker-facing side of the site and whether the destination-country embassy contact is named as a backstop.

Question 10, What is your IOM IRIS, ILO, or equivalent ethical-recruitment audit status?

The international frameworks for ethical recruitment are the IOM International Recruitment Integrity System (IRIS), the ILO General Principles and Operational Guidelines for Fair Recruitment, and various sector-specific protocols. An agency operating ethically references one or more of these frameworks and can name its specific audit or certification status.

The follow-up question is for the audit number or certification, not the framework reference alone. An agency that "operates under IRIS principles" without a specific audit or certification has named the framework as positioning rather than as compliance. The honest agency either holds the certification or can name the timeline within which it is pursuing certification.

Question 11, Where do you fail?

The disarming question. Every operator with real corridor mileage has a corridor that did not work, a deployment that fell short, a trade the agency does not run well. The agency that says "we deliver excellence across all corridors" has rejected the question and the buyer should treat the rejection as a signal.

The honest agency names a specific corridor or trade where the volumes are low, the cycle times are long, or the retention is harder than the agency would like. The honest answer earns trust because the buyer can read between the corridors and shortlist the ones where the agency operates at strength.

Question 12, Can I speak to a recent client?

The closing reference check. The buyer asks for one named client (with consent), recent (within 12 months), in a corridor similar to the buyer's intended corridor. The buyer calls the reference and asks two questions: did the agency deliver against the demand letter, and did the workers arrive without paying anything they were not supposed to pay?

The agency that can produce the reference inside one business day has the relationship. The agency that promises "we'll set up the call" and then loses momentum has not earned the reference.

The frame that ties the questions together

The 12 questions above are not a quiz. They are the working frame for the second scoping call with any cross-border recruitment agency the buyer is considering. The agency that answers all 12 from memory, in operator vocabulary, with named artefacts available on follow-up, is shortlistable. The agency that struggles on three or more is selling.

For Werklist's approach to the 12 questions, see the cross-border recruitment agency selection guide for the longer framework, or see /contact-companies to brief a corridor directly. Send the role, the headcount, and the destination, and we come back inside one business day with a corridor fit, whether you sign with us or not.