Turkey has long been a transit site for irregular migration, and policy makers and advocates have stressed the vulnerability of many of these irregular migrants to human trafficking. The Turkish government increased its anti-trafficking efforts in the early 2000s, but these efforts may in fact be increasing immigrants’ vulnerability to trafficking. Using data from fieldwork among NGOs and government officials and analyses of laws and policy reports, we analyze the changing legal terrain and shifting migration flows into Turkey. We argue that recent counter-trafficking policies designed to curb human trafficking may in fact be making immigrants more vulnerable to traffickers. Our findings inform the labor exploitation theoretical framework of human trafficking that we proposed in earlier research.