reparation such as compensation or satisfaction. Compensation is the most common form of reparation and should remedy the damage caused by the breach to the extent that this is possible with financial means. Compensation can include payment for medical treatment, costs for therapy or rehabilitation, lost income and payment also of non-material damages such as pain, suffering or emotional distress. Restitution should re-establish the situation prior to the violation as far as this is possible. In the context of trafficking in human beings restitution can also be problematic. In some cases, the situation prior to the trafficking act was the cause for being trafficked. Restoring this situation could place victims at risk of being re-trafficked. Rehabilitation such as medical and psychological care and legal services are especially important for trafficked persons. 177 Trafficked persons suffer harms similar to that of victims of torture due to physical and non-physical acts of the exploiters. A trafficked person may suffer from post-traumatic stress disorder (PTSD) or overwhelming shame resulting from brutal acts such as torture or rape, from depression, loss of self-esteem, anxiety and phobias.178 The harms of trafficking in human beings can be similar to torture. Consequently, rehabilitation has to take into account that longterm treatment encompassing psychological and medical care is necessary. Case Study 9 Report of the Special Rapporteur on torture and other cruel, inhuman or degrading treatment or punishment, Manfred Nowak Satisfaction is a non-monetary measure to show the trafficked person that the violation is being properly dealt with by the State. Measures of satisfaction include the prosecution or the verification of the facts. An official apology or declaration might not be an adequate means of satisfaction for trafficked persons due to the fear of stigma of being a ‘victim of trafficking in human beings’. A guarantee of nonrepetition in the context of trafficking in human beings can constitute an important measure of preventing future trafficking.179 In this context, the importance of ensuring residence of trafficked persons in the country of destination has to be stressed. Ensuring residence can be seen as a form of guarantee of non-repetition. Since re-trafficking is a very high risk, ensuring residence in the country of destination prevents re-trafficking and therefore supports non-repetition. The importance of allowing residence to trafficked persons is twofold in the context of receiving reparation for the violation of human rights. Concerning the right to remedy, it is essential that the trafficked person have a legal residence permit. As stressed in the context of the CoE Convention, it would be very difficult for the trafficked person to “obtain compensation if they were unable to remain in the country where the proceedings take place”. 180 The presence of the victim in the country where the remedy is being sought is an important co-requisite for realizing the right to a remedy.181 At the same time, safe residence in the country of destination can establish a form of reparation. Residence can be a guarantee of non-repetition if re-trafficking can be prevented. As shown above, the relevant legally-binding instruments concerning trafficking in human beings require States to offer trafficked persons the possibility of compensation. In practice, implementing this obligation is difficult and the number of trafficked persons actually receiving compensation is rather low. A study of the OSCE in eight countries showed that only a small minority of trafficked persons The International Law of Human Trafficking The International Law of Human Trafficking Report of the Special Rapporteur on torture and other cruel, inhuman or degrading treatment or punishment, , Convention on Action against Trafficking in Human Beings CETS No. 197, Explanatory Report The International Law of Human Trafficking 37