The Government of Zambia does not fully meet the minimum standards for the elimination of trafficking but is making significant efforts to do so.  The government demonstrated overall increasing efforts compared with the previous reporting period, considering the impact of the COVID-19 pandemic, if any, on its anti-trafficking capacity; therefore Zambia was upgraded to Tier 2.  These efforts included amending the anti-trafficking law to criminalize all forms of trafficking and creating a new department to implement the government’s anti-trafficking efforts.  The government increased victim identifications and investigations of alleged traffickers, including complicit officials.  The government mandated use of the NRM for referring trafficking victims to care by law enforcement, immigration officials, and other front-line officers.  The government increased training for law enforcement and front-line officials on victim identification and human trafficking investigations.  The government opened an additional shelter for trafficking victims and increased resources allocated to overall anti-trafficking efforts.  However, the government did not meet the minimum standards in several key areas.  Due to gaps in awareness of victim identification procedures and lack of resources, the government inappropriately penalized some trafficking victims solely for unlawful acts committed as a direct result of being trafficked.  Due to conflation between human trafficking and migrant smuggling in the anti-trafficking law, officials sometimes misidentified trafficking. crimes.