By J. Smith
Introduction
In discussions on prostitution policy, advocates for full decriminalization often cite endorsements from powerful organizations such as UNAIDS, Amnesty International, Human Rights Watch, and The Lancet without providing evidence of any observed reduction in violence or improved safety after full decriminalization, which in fact has not been seen. Such endorsements seem to end any debate, as audiences assume that such strong support from “the experts” must be underpinned by extensive, rigorously conducted research. This assumption can cause individuals, institutions, and politicians to overlook the research that these organizations based their endorsements on in the first place.
In anticipation of a 2023 EU Parliament vote favoring the Nordic Model, world renowned medical journal, The Lancet, published a critique of the Nordic Model, advocating for full decriminalization instead (i.e. decriminalization of pimping, brothel-keeping, buying sex, and selling sex) (The Lancet, 2023). They claimed that the Nordic Model may lead to deportations of migrant people in prostitution and that, “The EU is proposing a policy that risks increasing violence against sex workers” (The Lancet, 2023).
The Lancet’s endorsement has been used as conclusive evidence that full decriminalization promotes public health and safety and that the Nordic Model undermines it. However, with millions of vulnerable people at risk of exploitation, we have a responsibility to evaluate these claims further.
The primary document used to support these claims in the editorial is, Criminalising the Sex Buyer: Experiences from the Nordic Region, a policy brief authored by Niina Vuolajärvi (2022), published by London School of Economics (LSE), which will be reviewed in this article. The author claims the Nordic Model causes “stigma,” and “marginalization” and that to protect the “safety, integrity and rights of people in the sex trade” the purchase of sex and “third-parties” must be completely decriminalized (Vuolajärvi, 2022, p. 17).
Download
Summary
The Shaky Basis for the LSE Report
- Claims of benefits from full decriminalization vs. the harms of the Nordic Model are supported by a policy report, published by the London School of Economics, which was based on the author’s graduate school dissertation.
Deportation: An Abolitionist Tool?
- The dissertation claims that policies exist that lead to deportation of migrant women in prostitution under all prostitution frameworks, including fully decriminalized and legalized prostitution. The LSE report, cited by The Lancet, omits this, rather labeling deportation as an “abolitionist tool” used in Nordic countries.
- For suspected intention to engage in prostitution in New Zealand, after full decriminalization:
- 481 migrant women were denied entry from 2015 to 2019.
- 43 were stopped from boarding flights to NZ 2015 to 2019.
- 19 migrant women received deportation notices from 2019 to 2021.
- Sweden and Norway lack explicit laws against migrants selling sex, however, obtaining work permits is extremely difficult irrespective of occupation, with deportation as a possible consequence of non-compliance.
The Nordic Model: Exit Services, Safety, and Earning Potential
- Contrary to claims of increased violence under the Nordic Model, New Zealand (since decriminalization in 2003) has seen more prostitution-related murders (nine) than Norway and Sweden combined (one murder since their models began in 1999 and 2007, respectively).
- Almost all countries that have adopted the Nordic Model provide exit services or support services regardless of immigration status.
- The LSE report claims the Nordic Model causes “economic marginalization,” and yet women in Sweden make around seven times as much money per client than in Germany, where sex buying is legal.
The Shaky Basis for the LSE Report
While the LSE report states that the conclusions are “based on ethnographic research undertaken over a three-year period in the Nordic region (Sweden, Norway, Finland)…”,[1] the “ethnographic research” in question was simply the author’s own dissertation she wrote while in graduate school only one year prior to the publication of the LSE report (Vuolajärvi, 2022, p. 4).
The LSE report argues that the Nordic Model de facto criminalizes the sale of sex through the regulation of immigration, pimping, and “third-parties,” and that it harms women in prostitution by increasing “stigma” and “economic disenfranchisement.” She contends: “…Only a small minority of those interviewed – 6 per cent – considered themselves to have been trafficked or forced by someone else to sell sex” (Vuolajärvi, 2022, p. 5).
This figure, cited in her dissertation, was not from her own “ethnographic research,” but originally from interviews from Mai, N. (2009), author of such works as “The Fractal Queerness of Non-Heternormative Migrants Working in the UK Sex Industry” (2013) and “Tampering with the sex of ‘angels’: Migrant male minors and young adults selling sex in the EU” (2011).
While I couldn’t find the original paper claiming only 6% of women are trafficked, there is indication from his other published work that he does not consider cases of human trafficking (as defined under international law) to be trafficking. Shockingly, he claims:
“…I use the expression ‘minors’ rather than ‘children’ because this latter term is increasingly used to homogenise—along ‘infantilising’ and North-centric lines—experiences characterised by very different local definitions of autonomy, responsibility for survival and entitlement to protection. The juxtaposition of the expression ‘and young adults’ underlines the continuity of subjects’ experiences across the coming-of-age passage and the legal rather than ‘essential’ difference between older minors and young adults. Finally, I choose to use the expressions ‘selling sex’ and ‘sex worker’ to underline the possibility of a voluntary engagement in sex work, even when minors are involved…The analyses presented here highlight how there is nothing inherently pathological, abusive and victimizing in the independent migration of male minors and young adults, or in their involvement in sex work, and that their potential vulnerability is rooted in their histories of psychological detachment from ‘home’. For many, as we have seen, selling sex was a way to find a better answer to their economic, social and psychological needs than that provided by ‘protectionist’ initiatives of social intervention in the North….The representation of migrant male minors selling sex exclusively as ‘exploited children’, whether they are 5 or 17 years old, or whether they enjoy selling sex or not, is complicit with the attempt to recreated a lost ‘moral virginity’ in the North of the world, at a time in which its moral and economic bankruptcy are most evident. By addressing the individual vulnerabilities and resilience of migrant minors and young adults through ‘one fits all’ notions of exploitation and fetishised understandings of ‘angelic’ childhood what is concealed is the North’s responsibility in promoting the commodified and precarised moral and libidinal economies encompassing us all. The alternative, following O’Connor Davidson (2005: 23) … would also mean devising strategies of social intervention responding to their actual needs and priorities rather than to the North’s need to protect its perception of moral superiority and purity.”
Mai, N., 2011. [Emphasis my own]
Of note, this professor is supportive of full decriminalization of prostitution (Mai, N., 2019) and was also on the advisory board of the baseline assessment for the Nordic Model in Northern Ireland (Huschke, et al., 2014, p. 240), which similarly concluded few women were trafficking victims.
Evidence of a high degree of human trafficking and coercion in the legal sex trade is overwhelming. Dutch prosecutors estimate that up to 70% of women in prostitution in the Netherlands were forced into prostitution either by coercion, force, or the loverboy method of human trafficking (EU Parliament, 2023). According to the 2013 US Trafficking in Person report, up to “90% of women in prostitution in Spain could be under the control of organized crime networks” (U.S. Department of State, 2013). A 2021 European Parliament commissioned study found the majority of men who buy a migrant woman for sex in the EU have bought sex from a sex trafficking victim (Di Nicola, A., 2021, p. 28) – and the vast majority of women in prostitution in the EU are migrant women (EU Parliament, 2023, p. 18; Schulze, E., et al., 2014, p. 27).
Deportation: An Abolitionist Tool?
The LSE report claims that: “Even though the Nordic countries have decriminalised the sale of sex, it is still a ground for deportation in their immigration laws” (Vuolajärvi, 2022, p. 5). The sale of sex alone is not grounds for deportation in Nordic Model countries. Working anywhere in the European Union without a work permit, regardless of the job type, can result in detention and deportation for migrants (FRA[2], 2021). The EU Directive 2009/52/EC “…requires EU countries to prohibit the employment of non-EU nationals staying in the EU illegally” (EUR-Lex, 2016).
Before 2023, Sweden required work permit applicants to have an employment contract ensuring income above the minimum (SEK 13,000 per month) to prevent reliance on social support (European Website in Integration, 2023). The 2023 update to the Aliens Act mandates that work permits are granted only to those earning at least 80% of the median Swedish salary (European Website on Integration, 2023). In Norway, permits are issued only if the applicant has specific training and skills for the job and if the role cannot be filled by Norwegian, EEA,[3] or EFTA[4] citizens (Norwegian Directorate of Immigration UDI, n.d.).
Reading the LSE policy report, one would clearly think there is a policy of targeted deportation of women in prostitution under the Nordic Model (deportation being referred to dramatically as an “abolitionist tool”, Vuolajärvi, 2022, p. 14). However, buried within her over 330 page dissertation she notes:
“…Also, countries that legalize or decriminalize commercial sex, such as Austria, Netherlands, Singapore, or New Zealand, exclude sex working migrants from obtaining work permits and/or these permits are complicated and challenging to obtain. In countries where sex work is legalized as well as in countries where sex work is decriminalized, migrants may face deportation and visa cancellation if they engage in sex work… For example, in the Netherlands, where sex work is legal, migrant sex workers are the only category of employees excluded from getting work permits (both EU and non-EU citizens). The Netherlands violates the right to be free from discrimination, as, for all other types of work, non-nationals can obtain a work permit (ICRSE 2005). New Zealand that has decriminalized sex work, may deport and cancel visas of migrants who engage in sex work. In Singapore, sex workers may be refused entry (NSWP Global Network of Sex Worker Projects 2017).”
Vuolajärvi, 2021, p. 100. [Emphasis my own]
Why did “the experts,” whose job is to give good public health recommendations, withhold this essential information that proves that the Nordic Model is not a policy that uniquely targets women in prostitution from the LSE report, conclude the opposite is true, and recommend full decriminalization of pimping, brothel-keeping, and buying sex based on incomplete information?
While Vuolajärvi claims migrants in New Zealand “may” be deported for engaging in prostitution – this is not some remote possibility – it seems every week women are denied entry, prevented from flying to New Zealand, or deported for this reason:
“…Between July 2015 and May this year [2019], 481 suspected or known foreign sex workers were refused entry to New Zealand. Another 43 were stopped from boarding or offloaded from aircraft before heading here. Immigration NZ says it’s cracking down to protect vulnerable women, often coming from Hong Kong, China and Brazil.”
NZhub, 2019
Not only are hundreds of women denied entry into the country, but 19 women have been served deportation notices in New Zealand in only three years (2019-2021) for engaging in prostitution (NZ Herald, 2022). New Zealand authorities were concerned these strict measures were necessary so that “…New Zealand wouldn’t become a haven for sex-trafficking…” and they were likely right.
Swiss Federal police – who are both remarkably transparent on their failure to curtail human trafficking and completely resistant to change – have reported that victim identification is prevented due to migrant women from EU/EFTA member states being legally permitted to enter Switzerland to work on 90-day visas, including for the purpose of prostitution. These women frequently overstay these visas and “work” illegally (Biberstein & Killias, 2015, p. 98):
“Identifying victims at the border is difficult for two reasons: first, crossing the border and entering Switzerland for the purpose of working as a prostitute is legal; second, at the point in time when potential victims cross the border they have not yet been exploited or do not suspect their future exploitation. Therefore, border guard officers are hardly in a position to refuse entry, stop and check people or identify victims if there is no indication of exploitation.”
FEDPOL, 2016, p. 25
Due to the high risk of exploitation faced by migrant women in the sex trade, including debt bondage, many countries proactively restrict entry and deny work permits for those suspected of engaging in prostitution to prevent such abuses. These policies reflect a broad consensus across countries with varying prostitution laws (including legalized and fully decriminalized prostitution), that migrant women are at significant risk for sex trafficking.
The dissertation notes that like Norway, where an EU citizen in prostitution has never actually been deported, “…in Sweden, deporting EU citizens did not seem to be a common practice either….” (Vuolajärvi, 2021. p. 115).
“In the Nordic countries, the protection of victims of trafficking (VoT) is tied to the criminal process and cooperation with law enforcement. In case they do not cooperate, or the police do not have enough evidence to pursue the investigation, they will not be offered protection and can be deported.”
Vuolajärvi, 2022, p. 10. [Emphasis my own]
This policy is common in most countries, including those with legal prostitution such as Germany and the Netherlands (Walby et al., 2016. p. 100, 101). Deportation does not, in fact, seem to be an “abolitionist tool.” While prostitution and trafficking are not automatic reasons for asylum approvals in Sweden, in accordance with international law, victims can qualify for asylum if they are unsafe in their home country or if there is an aggravating circumstance (NSPM[5], 2024a).
Despite outlandish suggestions from The Lancet that the Nordic Model could indirectly lead to death sentences for “queer or transgender sex workers” (The Lancet, 2023), Sweden explicitly provides asylum status based on discrimination due to sexual orientation or gender identity (Migrationsverket, 2024). In 2020, Norway began prioritizing LBGTQ people seeking asylum above other groups and individuals. According to Euronews, “Under previous guidelines, vulnerable women and children were given priority” (EuroNews, 2020).
Sweden and Norway both collaborate with the International Organization for Migration (IOM) Return Program to offer support services to migrant women involved in commercial sex, both before and after their return home. The goal is to enable them to achieve independence, “reduce human suffering,” and enhance security. Sustainable reintegration is marked by financial independence, social stability, and psychological well-being. Services provided include airport reception, housing, medical and psychological care, education, work training, small business startup aid, and ongoing follow-up for at least a year, which can be extended if necessary (NSPM, 2024b).
The Nordic Model: Exit Services, Safety, and Earning Potential
Vuolajärvi suggests the Nordic Model’s aim to offer exit support for women in prostitution is ineffective for undocumented women, who can’t access state services. Although the model is implemented differently across countries, it often involves funding NGOs to help women in prostitution, who then serve them without regard to immigration status. A quick search finds numerous programs funded by governments in Nordic Model countries which explicitly serve migrant women in prostitution. Programs can include a wide range of free services, such as counseling, medical care, legal assistance, housing, and job training, which are available in at least Ireland, France, Sweden, Norway, and Iceland. France even provides monthly stipends and residence permits for up to two years to women leaving prostitution, with no requirement for proving trafficking and no required police involvement (see appendix for details).
While many services exist for women affected by the sex trade regardless of immigration status, the main benefit of decriminalization / legalization would be to provide women with labor rights, which are significantly impacted by immigration status. When the demand for prostitution increases, the sex trade expands, the number of migrant women in prostitution further increases, saturates the market, and lowers the cost of sex, making the “job” not attractive for nationals (Biberstein & Killias, 2015, p. 94).
This phenomenon is evident in the higher proportion of migrant women in prostitution in countries where the industry is legalized: Austria, 90-95% (EU parliament 2023, p. 18); Switzerland, 95% (Wüst, A., 2020, p. 29); Spain, 90% (Schulze, E., et al., 2014, p. 49); compared to Nordic regions (around 70%) (Vuolajärv, 2022, p. 3). In Germany, only 23,700 (EU Parliament 2023, p. 18) of the 400,000 women in prostitution are registered (or 5%). Of these women, only 4,500 are German nationals (~1% of the total in prostitution) (Destatis, 2022).
In contrast, criminalizing the purchase of sex can significantly reduce the scale of the sex trade, the number of vulnerable migrants in prostitution, and the overall degree of exploitation. The increased vulnerability in legalized countries vs. Nordic Model countries is made most obvious by the zero murders due to prostitution committed in Sweden (population of 10.6 million) since the implementation of the Nordic Model in 1999, compared to the 21 murders (Sex Industry Kills project)[6] in Switzerland (population of 8.8 million) and 30 murders in Netherlands (17.8 million population) due to prostitution at the same time[7] despite Sweden having around twice the homicide rate per 100,000 in the general population (1.1 in Sweden vs. 0.5 in Switzerland vs. 0.6 in Netherlands) (World Bank data). Those advocating “harm reduction” are condemning the most effective policy for actually reducing harm.
The LSE report notes[8] that criminalization of sex buyers can negatively impact the safety practices and bargaining power of women in prostitution. However, if the Nordic Model really “…reduces the bargaining position with clients…” and increases “economic marginalization” as claimed, why are women in prostitution successfully demanding around seven times the amount of money in Nordic Model countries vs. legalized countries such as Germany for sex (€200 vs. €30, Vuolajärv, 2021, p. 15, DW news, 2018), and why does empirical evidence show the cost of sex decreases dramatically when sex purchasing is decriminalized (Cunningham, S., & Shah, M., 2018)?
So what is the answer? Should we give visas to women from poverty-stricken countries for the express purpose of working in the sex trade in the hopes of providing labor protections? Look at what happened in Switzerland when cabaret dancers (also called “striptease artists”) were given specialized short-term visas for this exact reason (the “L Visa”). Extensive measures were in place to detect and prevent the abuse of migrant women, including personally interviewing applicants at embassies to ensure consent and explaining that no one could legally force them into prostitution or debt indenture – even offering counseling (FEDPOL, 2016 p. 25). However 20 years later:
“…working conditions for striptease artists with the special permits were very precarious, with huge potential for exploitation both inside and outside Switzerland. The women were frequently obliged to make illegal payments to intermediaries for work contracts drawn up in their countries of origin. To pay their debts the women often became dependent on employment agencies or their bosses in Switzerland, and were forced into prostitution. ‘The statute was originally created to protect women from exploitation. Various police and cantonal studies have shown that the statute does not or no longer fulfills its protective effect,” Justice Minister Simonetta Sommaruga told a news conference in October 2014 to explain the decision to repeal the law. “On the contrary, the statute favours exploitative situations and human trafficking.’”
SwissInfo, 2015
This led to the abolishment of the specialized visa in 2015. The caseload of one organization that provides services to trafficking victims reduced by 10% the year the visa was abolished (FIZ, 2016, p. 5). It seems when liberal idealism collides with reality – people suffer – and the people who suffer are invariably not gender studies majors who opine about “stigma.” No matter what regulations or “harm reduction” is implemented, if there is easy money to be made in a country – and with the normalization of prostitution, there is – traffickers will find a way to exploit that.
The LSE report notes: “This study demonstrates how the wide adaptation of the understanding of commercial sex as a form of violence in Swedish society contributes to heightened experiences of stigma, marginalization, and discrimination” (Vuolajärv, 2022, p. 11). Her dissertation indeed tells us more about the horrible stigma-inducing measures that Sweden has taken which marginalize women in prostitution including:
- “…a comprehensive campaign to educate the Swedish public, especially men and youth, about the radical feminist understandings of commercial sex as a form of men’s violence.”
- Offering sex buyers social counseling services which include a “support phone line and a special social work unit[9] that can help them to stop buying sex…”
- Information campaigns that “are incorporated into the national school program, reaching all Swedish students through schools’ feminist and gender equality work, anti-violence work targeting destructive masculinity norms, and sexual education programs.” (all from Vuolajärv, 2021, p. 170)
She then admits this method “has proven effective” and that “There is strong consensus in Sweden that commercial sex constitutes exploitation and a hindrance to gender equality…” (Vuolajärv, 2021, p. 170). The LSE report also outlines the efficacy of this approach: 32% of Swedes supported criminalizing the purchase of sex prior to the law (1996) vs. 65% after (2012). However, this clear evidence of the success of the Nordic Model is portrayed as being negative: “Moreover, Sweden’s normative campaigns against commercial sex have increased the view of sex workers as victims and mentally damaged” (Vuolajärv, 2022, p. 11).
This statement appears to be based on a study that claims “… 82 per cent believe that sex work is harmful for persons who engage in” (Vuolajärv, 2022, p. 11). It doesn’t seem that any reasonable person would associate that statement with a perception of “mental damage.” However, the LSE report makes it apparent that the concern might not necessarily be for women in prostitution – but for men who purchase sex:
“In other words, even if the law and discourses related to commercial sex as violence created a new stigmatised group – sex buyers – it did not shift stigma away from people in the sex trade but rather increased it.”
Vuolajärv, 2022, p. 12. [Emphasis my own]
In this view, rather than “…the Nordic model’s discourse of prostitution as violence that pins the problem of exploitation on individual buyers…” violence is instead seen as a product of punitive policies and stigma related to “sex work” (Vuolajärv, 2022, p. 5). The author claims research documented a decrease in stigma after full decriminalization in New Zealand:
“In New Zealand where sex workers were at the center of the decriminalization effort and sex work is understood as labor, studies have documented a decrease in stigma and violence among sex workers.” (Abel, Fitzgerald, and Brunton 2009).
Vuolajärv, 2021, p. 275
However, the cited paper (Abel, Fitzgerald, and Brunton, 2009) explicitly states there was not a decrease in stigma:
“Although the industry is now decriminalised in New Zealand, preliminary research with sex workers and staff, volunteers and outreach workers from the New Zealand Prostitutes’ Collective (NZPC) found that there were still suggestions of continuing stigmatisation of sex workers…”
Abel, Fitzgerald, and Brunton, 2009
Contrary to claims that the paper proves that decriminalization reduced violence, the cited paper doesn’t mention violence at all, and from the Prostitution Reform Act assessment[10] – we know there was in fact no reduction in violence (Mayhew, P., Mossman, E., 2007, p. 10, 11; Abel, G., et al., 2007, p. 161, 162). The author advocates for the complete decriminalization of buyers and “non-exploitative third parties.” However, we clearly have a different definition of “non-exploitative,” as she defines third-party as “…people who in some way organize or facilitate commercial sex” (Vuolajärv, 2022, p. 8) – seemingly describing a pimp or brothel-keeper.
She highlights a scenario in Sweden where landlords, fearing legal repercussions of being seen as profiting from prostitution (a criminal offense under pimping laws), might evict tenants engaging in prostitution. While it’s essential to ensure this does not occur, instead of decriminalizing pimping and brothel-keeping, why not simply clarify the law to explicitly exclude standard leasing agreements from being considered pimping?
Concluding Thoughts
In summary, the LSE report affirms the Nordic Model’s normative effectiveness and shows that the interplay between migration and the sex industry renders any theoretical benefits from legalization/decriminalization ineffective. However, the main goal of the Nordic Model, to reduce the overall scale of the sex trade and exploitation is unaffected. While in theory it seems impossible to provide support services to undocumented migrants in prostitution, in practice most Nordic Model countries have done this successfully (see appendix), further demonstrating that most claims that have been used to promote the full decriminalization of prostitution and undermine the Nordic Model are based on assumptions – not observed outcomes.
Sadly, the LSE report ignores several key points, such as most Nordic Model countries’ immigration policies are consistent with those across the entire EU, and the extensive denial of entry to women in prostitution in places where prostitution is legal or fully decriminalized. While the author focuses on potential evictions in Sweden, New Zealand nationals have also been evicted from their homes due to engaging in prostitution under full decriminalization of prostitution (NZ Herald, 2023).
If The Lancet and the London School of Economics object to the Nordic Model based on claims it will cause deportation and violence, why do they urge full decriminalization (The Lancet citing the “success” of New Zealand), a policy which appears to have resulted in more deportations and been associated with more murders of women in prostitution than in Sweden and Norway combined?[11] These contradictions underscore the need to rigorously evaluate claims made by “the experts” instead of viewing their conclusions as the undisputed truth.
Strict immigration policies, such as those prohibiting work visas for the purpose of prostitution, have been criticized by those who advocate full decriminalization as harsh, discriminatory, patronizing, and some claim that removing all restrictions would reduce stigma. However, such restrictions are based on extensive on-the-ground experience and observations from numerous countries across all major prostitution frameworks. Criticisms of protective measures overlook the observed outcomes under less restrictive frameworks.
Switzerland presents a clear case where the negative impact of lax prostitution laws on migrant women were directly amplified by lax immigration restrictions for the purpose of “sex work.” These policies encouraged human trafficking and prevented victim identification. Such instances highlight the unintended consequences of often well-meaning policies aimed at harm-reduction and underscore the critical need for basing public policy on robust, well-documented outcomes.
In contrast, despite the protective intentions behind immigration restrictions, the reality in New Zealand demonstrates the complexity of the issue. Brothel-keepers report that migrant women engage in prostitution regularly, despite its illegality (NZhub, 2019), and the police report migrant women have been often held in debt bondage within brothels (PLRC, 2005).
The inability for the police to intervene are due to legal constraints under the Prostitution Reform Act, which highlights a critical challenge: while immigration policies aimed at reducing exploitation are necessary and effective, they must be part of a broader strategy to reduce exploitation. Effective measures include: work collaboratively with police rather than prevent their investigations, provide exit services and social support rather than deny their necessity, punish those who exploit the most vulnerable in society rather than treat exploiters as respected business owners and managers, and create the cultural change to target the root cause of sexual exploitation (demand for prostitution) rather than normalize abuse as a social reality. Only a holistic approach can address the multifaceted nature of exploitation.
Citations
Abel, G., Brunton, C., and Fitzgerald, L. (2007), The Impact of The Prostitution Reform Act on The Health and Safety Practices of Sex Workers: Report to the Prostitution Law Review Committee, Christchurch, Christchurch School of Medicine.
Abel, G., M., Fitzgerald, L., and Brunton, C. (2009). “The Impact of Decriminalisation on the Number of Sex Workers in New Zealand.” Journal of Social Policy 38(3):515–31.
Addiction Center Stockholm. (n.d.). Mika Health. Accessed 2/2/2024.
Biberstein & Killias (2015) Erotikbetriebe als Einfallstor für Menschenhandel?
Causette. (2023). Isabelle Lonvis-Rome : « Je souhaite porter une nouvelle stratégie nationale de lutte contre la prostitution à la rentrée » Accessed: 2/4/2024.
City of Stockholm. (2023). Social and Financial Support: Sex for Compensation. Accessed 2/2/2024.
Cunningham, S., & Shah, M. (2018). Decriminalizing indoor prostitution: Implications for sexual violence and public health. The Review of Economic Studies, 85(3), 1683-1715.
Destatis – Federal Statistical Office of Germany. (2023). Press release No. 277 of 1. July 2022 Accessed 1/28/2024
Di Nicola, A. (2021). ‘The differing EU Member States’ regulations on prostitution and their cross-border implications on women’s rights’, European Parliament, Directorate- General for Internal Policies, Policy Department for Citizens’ Rights and Constitutional Affairs, 27
DW News (2018) Inside the ‘battery cage’: Prostitution in Germany 1/28/2024
Euronews. (2020). Norway will prioritise lesbian, gay, bisexual and transgender refugees Accessed 2/7/2024
European Parliament. (2023). Regulation of prostitution in the EU: its cross-border implications and impact on gender equality and women’s rights.
European Website in Immigration. (2023). Sweden: New rules for labour migrants
EUR-Lex. (2016). Illegal immigration – penalties for employers. Accessed 2/6/2024
FEDPOL (Federal Office of Police) (2016) Swiss National Action Plan to Fight Human Trafficking 2017-2020
FIZ. (2016). Annual Report 2016. Accessed 1/28/2024
FRA. (2021). Employer Sanctions Against Exploitation. Accessed 2/6/2024
Hela Manniskan. (n.d.) Annual Report 2022.
Huschke, S., Shirlow, P., Schubotz, D., Ward., E, Probst, U., Dhónaill, C. Research into Prostitution in Northern Ireland. (2014). Commissioned from Queen’s University Belfast by the Departement of Justice
Kirkens Bymisjon. (2022). Annual Report 2022.
The Lancet (2023) Editorial: Protecting the health of sex workers in the EU. Accessed: 1/28/2024
Mai, N. (2019, Feb, 26). Tweet: “Let us all sign this important petition: Decriminalise prostitution to promote safety petition.parliament.uk/petitions/2413…”
Mai, Nicola. (2009). Migrant Workers in the UK Sex Industry. Final Policy-Relevant Report.
Mai, N. (2012). ‘The Fractal Queerness of Non-Heteronormative Migrants Working in the UK Sex Industry’, Sexualities, 15(5-6): 570-585.
Mai, N. (2011). ‘Tampering with the Sex of “Angels”: Migrant Male Minors and Young Adults Selling Sex in the EU’, Journal of Ethnic and Migration Studies, 37(8): 1237-1252. Accessed 1/29/2024
Mayhew, P., Mossman, E., (2007) Key Informant Interviews: Review of the Prostitution Reform Act 2003. Wellington, Ministry of Justice.
Migrationsverket. (2024). If you are an LGBTQ person who is seeking asylum.
Mouvement du Nid. (2023). Annual Report 2023. Accessed: 2/2/24
Mouvement du Nid. (n.d.) Nos Actions.
Norwegian Directorate of Immigration UDI. (n.d.). Laws and Regulations.
NSPM. (2024a). The return program for persons exposed to human trafficking and prostitution.
NSPM. (2024b). Long-term support. Accessed 2/2/24
NZ Herald (Oct. 16, 2022) ‘Lives can be overturned’: Is deporting migrant sex workers causing more harm than good? Accessed 1/28/2024
NZ Herald. (2023, September 6). Adults only: Tenant evicted after failing to mention her “home-based business” involved sex work. NZ Herald. Accessed Sep 5, 2023.
Newshub NZ. (2019). Revealed: Hundreds of suspected sex workers stopped at NZ border. Accessed 1/28/2024
NSWP. (n.d.). Criminalisation of Third Parties and its Impact on Sex Worker Human Rights Accessed 1/28/2024
PCLR. (Prostitution Law Review Committee, 2005). “The nature and extent of the sex industry in New Zealand: an estimation”, Wellington, Ministry of Justice.
ROSA. (n.d.) Other aid measures and resources: Relief measures in Norway. Accessed 2/2/2024.
Ruhama. (n.d.a). About Ruhama. Accessed 2/2/2024.
Ruhama. (n.d.b.). Our Services. Accessed 2/2/2024.
Ruhama. (n.d.c.). Legal and Immigration Support. Accessed 2/2/2024.
Swissinfo.ch. (December 29, 2015). Permits ended for foreign workers in strip clubs. Accessed 1/28/2024.
Sweden Gender Equality Agency. (2023). Prostitution and Human Trafficking: Final Report.
Schulze, E., et al. (2014). Sexual exploitation and prostitution and its impact on gender equality.
Stígamót. (2023). Annual Report 2022.
Stígamót. (n.d.). Free counselling services for survivors of sexual violence.
Talita (n.d). Our work. Accessed 2/2/24.
Terrafem. (2023). Annual Report 2022.
UNHCR. (2012). GUIDELINES ON INTERNATIONAL PROTECTION NO. 9.
U.S. Department of State. (2013). Trafficking in Persons Report 2013, Country Narratives.
U.S. Department of State. (2022). Trafficking in Persons Report. Accessed: 2/2/2024
Walby et al. (2016). Study on the gender dimension of trafficking in human beings. European Commision final report
Wüst, A. (2020). Piff,Paff, Puff. Prostitution in der Schweiz. Basel: Echtzeit
Vuolajärvi, N. (2022). Criminalising the Sex Buyer: Experiences from the Nordic Region Policy Brief.
Vuolajärvi, N. (2021). “Governing in the Name of Caring: Migration, Sex Work and the ‘Nordic Model’” (Rutgers University – School of Graduate Studies, 2021)
[Data] World Bank. (2021). Intentional Homicides (per 100,000) Accessed: 2/3/2024
Appendix
Examples of services migrant women in prostitution can benefit from in Nordic Model countries.
Ireland: Ruhama, is an NGO in Ireland that provides housing, mental health and substance use counseling, employment support, health services, and outreach to women affected by the commercial sex trade (Ruhama, n.d.b). They claim, “You do not need to speak English, have a visa or want to exit prostitution to use our services.” (Ruhama, n.d.a). Additionally, they can provide legal counsel to migrants during immigration proceedings and if they are victims of crime (Ruhama, n.d.c).
France: The state-sponsored Parcours de Sortie de la Prostitution (PSP)[12] exit service programs provide a €343 per month allowance, housing accommodation, support in finding employment, and a provisional residence permit (up to two years) for people in prostitution. Around 90% of the women in the program are migrants and 95% of participants in the programs leave prostitution (Causette, 2023). Additionally, NGOs such as Mouvement du Nid “…offer our unconditional help to every person, whether or not from trafficking, French or foreigner, regardless of their sex or gender identity” (Mouvement du Nid, 2023, p. 12; Google translation). Services provided include language courses (Mouvement du Nid, 2023, p. 16; Google translation), exit services, as well as “…daily support in all areas, and, if they wish, aid to look for alternatives.” (Mouvement du Nid, n.d.; Google translation).
Sweden: The Swedish government directly offers free, confidential, support services to women affected by commercial sex in their Mika clinics (City of Stockholm, 2023). Services include advice as well as health services, (i.e. STD testing and treatment, contraceptives, pregnancy care, abortion), and mental health treatment (Addiction Center Stockholm, n.d.). NGOs funded privately and publicly provide housing, food, and work training for trafficking victims (Hela Manniskan, n.d.) and for women in prostitution (Talita, n.d.). Terrafem, a publicly and privately funded NGO, provides services specifically to migrant women. Services include: housing, emergency hotlines, and legal counsel (for family, criminal or asylum cases; Terrafem, 2023).
Norway: There are numerous services provided to women in prostitution in Norway (ROSA, n.d.). Kirkens Bymisjon offers health services, work training, social services, legal advice, provided regardless of nationality or residence status (Kirkens Bymisjon, 2022, p. 6). Like Sweden, Norway utilizes the IOM Return Program and provides services to migrant women both in Norway and in the victim’s home country.
Iceland: Free services include counseling, group classes (on self-confidence, well-being, and social integration; Stígamót, 2023, p. 9), and grants to support people exit prostitution and/or human trafficking situations which are offered through Stígamót. The program serves women as well as “…men, disabled people, queer people and people of foreign origin” (Stígamót, 2023, p. 7). There are free translation services for migrants who do not speak Icelandic or English (Stígamót, n.d.).
Acknowledgements
Thank you to Anna Fisher for advice and guidance.
Download
[1] Finland is included as a Nordic country in the report. The purchase of consensual sex is decriminalized in Finland (Vuolajärvi, 2021, p. 22) However, knowingly purchasing women in exploitation/pimping is criminalized.
[2] EU Agency for Fundamental Rights
[3] European Economic Area (EEA), which includes EU countries and also Iceland, Liechtenstein, and Norway
[4] European Free Trade Association (EFTA), a free trade organization including Iceland, Liechtenstein, Norway, and Switzerland.
[5] Swedish National Coordination Against Prostitution and Human Trafficking
[6] Website currently under maintenance.
[7] Netherlands since 2000
[8] Vuolajärvi (2021) notes that women she interviewed migrated from the Netherlands to Norway for prostitution due to recommendations from others in prostitution that they could make more money and could work independently (Vuolajärv, 2021, p. 52). The interviewee claimed that she paid “600 Euros every week for the window space [in Netherlands], whether she had clients or not and at the club, half of her earnings went to the owner.” Moreover, she claimed “if you want to make a lot of money [in the Netherlands], you must take cocaine….” (Vuolajärv, 2021, p. 52).
[9] Additionally, throughout Sweden, treatment services are provided to men who purchase sex through the Buyers of Sexual Service (BOSS) clinics (Sweden Gender Equality Agency, 2023, p. 10).
[10] The law which decriminalized prostitution in New Zealand in 2003
[11] New Zealand (population 5.1 million) had 9 murders of women due to prostitution since full decriminalization in 2003 and Norway and Sweden combined (combined population of 15.8 million), only 1 murder of women due to prostitution since their models began in 1999 and 2007 respectively (data from Sex Industry Kills project).
[12] “Pathway out of Prostitution”