They often arrive willingly, but subsequently face conditions that the U.S. State Department says is indicative of forced labor -- the withholdingof passports, restrictions on movement, nonpayment ofwages for work up to 20 hours a day, threats, deprivation of food and sleep, and physical or sexual abuse.
The purpose of the subsection, the court logically concluded, was to include SUB payments within the purview of those items of income that require withholding, even though they are not wages.