There's a warning that human traffickers are succeeding 'to a large extent' in keeping a step ahead of Irish authorities.
A recent report by the US State Department saw the Republic accused of not fully meeting minimum standards for the elimination of trafficking.
Brian Killoran, CEO, Immigrant Council of Ireland, told The Pat Kenny Show it's part of a downward trend for Ireland.
He said: "We were downgraded to tier two in 2017 and 2018, which effectively meant we were not meeting the minimum standards.
"We were downgraded further this year to the tier-two watchlist - which essentially means we are in threat of going even further again into tier three.
"If you look at tier three, there are countries such as Afghanistan and Syria there, which is definitely a place we do not want to be. Indeed tier two is a place we do not want to be.
"Really there's a concerted effort needed to improve our responses to trafficking in Ireland - and to date that hasn't happened."
Mr Killoran noted that the criticisms of the State's approach here have been around factors such as victim identification; accommodation and supports for victims of trafficking; and convicting traffickers.
He said trafficking, as opposed to smuggling, usually involves someone entering the country believing they are coming into the country legally, and enters using the usual procedure.
However, when they get here they found out the situation is 'much different' then promised - often owing the trafficker a large debt, and sometimes told they have to enter into prostitution to pay off that debt.
Of 42 cases discovered here last, 34 of the victims were in situations of sexual exploitation.
Brian said many victims are being controlled, threatened or intimidated that they do not want to interact with any authorities.
He explained: "By its very nature, trafficking and traffickers try to evade any detection - they move people around very frequently... sometimes in and out of the jurisdiction.
"We've come across instances where the woman in question didn't even know what country she was in when she came to the attention of the authorities.
"There's a huge effort by the traffickers to keep one step ahead of the authorities - and they're succeeding in doing so to a large extent."
He also said the belief that there are many more victims that have yet to be identified "is one very well backed by the evidence both nationally and internationally".