As reported by Kuwaiti media, authorities in Kuwait are cracking down on possible employment-based immigration schemes involving up to 3,000 sham companies that were set up and used as vehicles to obtain work permits for foreign companies.  This has led to 5,000 files of various companies being held and audited by Kuwaiti authorities.  It appears as though the focus of the investigation is on domestic workers following pressure on authorities to reduce this segment of foreign workers.  Authorities are also reviewing misuse of Kuwaiti immigration programs whereby foreign companies incorrectly use third-party entities to secure work permits rather than setting up local corporate entities.  Some foreign companies are willing to cut corners or are poorly guided by local representatives to secure work permits for their foreign workers quickly in an effort to get to a strategically important market as soon as possible.  Because Kuwait’s corporate, immigration and employment laws are challenging and require significant preparation and logistics planning, some foreign employers make rash decisions or don’t perform appropriate risk analysis and use unrelated corporate entities to secure work permits, thereby avoiding incorporating a local entity.  These so called “easy fixes” are often suggested by local “immigration providers” and, as is evidenced with this investigation, can create significant compliance concerns.  This is made worse as most foreign employers in this region do not have significant local resources and are, therefore, trying to manage the problem from the United States.  Bottom line: vet your service providers and conduct a thorough risk analysis on their processes and activities; in the global mobility field many entities are using sub-contractor networks to complete work which can create substantial hidden risk for employers.