Do a state’s human rights obligations extend beyond its territory? Do they apply to the conduct of private persons? If so, how can the state be held responsible for potential violations? The present chapter addresses these questions in the context of EU immigration control. It introduces the case of immigration liaison ofﬁcers (ILOs) as a prime example of the increasing extraterritorialisation and privatisation of immigration control, which is often deplored on the grounds that it produces ‘legal black holes’. This chapter argues, against this common perception, that despite these trends, states generally retain substantial means of inﬂuence that trigger obligations under human rights and refugee law. By drawing on three different legal concepts, the chapter defends the basic idea that states cannot offshore and delegate immigration control without keeping a corresponding level of legal responsibility.