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Criminological Policy Mobilities and Sex Work: Understanding the Movement of the ‘Swedish Model’ to Northern Ireland



Ideas, policies and models related to criminal justice often travel between places. How, then, should we make sense of this movement? We make the case for drawing on the policy mobilities literature, which originates in human geography. It is only recently that criminological studies have drawn on small parts of this literature. This article argues for a more expansive engagement with the policy mobilities literature, so that criminal justice researchers focus on concepts such as mobilities, mutation, assemblages, learning, educating and showcasing when studying the movement of criminal justice ideas, policies and models. To illustrate our argument, we will draw on a case study of the adaptation of the 'Swedish model' of governing sex work by policymakers in Northern Ireland.
Criminological policy mobilities and sex work:
Understanding the movement of the ‘Swedish model’ to Northern Ireland
Laura McMenzie, Ian R. Cook and Mary Laing
Northumbria University
Forthcoming in The British Journal of Criminology
Ideas, policies and models related to criminal justice often travel between places. How, then,
should we make sense of this movement? We make the case for drawing on the policy
mobilities literature, which originates in human geography. It is only recently that criminological
studies have drawn on small parts of this literature. This article argues for a more expansive
engagement with the policy mobilities literature, so that criminal justice researchers focus on
concepts such as mobilities, mutation, assemblages, learning, educating and showcasing
when studying the movement of criminal justice ideas, policies and models. To illustrate our
argument, we will draw on a case study of the adaptation of the ‘Swedish model’ of governing
sex work by policymakers in Northern Ireland.
Keywords: sex work; policy transfer; policy mobilities; Sweden; Northern Ireland
Between 2012 and 2014 Maurice Morrow, a Democratic Unionist Party (DUP) peer, led a
campaign to criminalise the buyers of sexual services in Northern Ireland. An important and
intriguing element of Morrow’s campaign was his regular use of Sweden the first country to
criminalise those buying but not selling sex as a reference point. Morrow, like many of his
supporters, would often talk of Sweden as a source of inspiration, and a place that must be
learnt from and emulated. Even after the Assembly voted to introduce Morrow’s plan in
October 2014 as part of a wider package of measures targeting sex work and human
trafficking Morrow was still keen to stress the links to Sweden. For instance, several weeks
after the vote, he stated in a speech to the Northern Ireland Assembly that:
“[T]he evidence clearly suggests that the approach modelled by Sweden is the best
available. It recognises the abuses involved in the prostitution industry and seeks to
reduce the core driver for prostitution the demand for paid sex.” (Northern Ireland
Assembly, 2014a, n.p.)
Later that day, Morrow reasoned that having visited criminal justice officials and policymakers
in Sweden a year prior he was confident of its success in Northern Ireland. “If it is as effective
in Northern Ireland as the equivalent is in Sweden”, Morrow argued, the Assembly will have
done everyone a favour, particularly victims of human trafficking” (Northern Ireland Assembly,
2014a, n.p.). Morrow, of course, is not the only person to have campaigned for the ‘Swedish
model’ to be emulated in other countries. In fact, several other jurisdictions including Norway,
Iceland, France, Canada and the Republic of Ireland have all followed Sweden in
criminalising the buying of sex without criminalising the selling of sex. So while many
worldwide have criticised the Swedish model (e.g. Scoular, 2004; Levy and Jakobsson, 2014;
Vuolajärvi, 2018), it has been heavily promoted and highly influential.
By exploring the movement and mutation of the Swedish model into Northern Ireland,
the paper has two purposes. The first is that it illustrates and enhances some of the ideas
mooted in a recent article in Theoretical Criminology by Newburn et al. (2017) who call for a
re-imagining of policy transfer within criminological research. In short, they make the case for
drawing ideas from the geographical literature on policy mobilities. We strongly support this
but also argue that there are other ideas in the policy mobilities literature, not mentioned by
Newburn et al. (2017), which can enhance our understanding of the mobilisation of criminal
justice ideas and policies. In particular, we make the case for a focus within criminological
policy mobilities studies on learning, educating and what we call extrospective showcasing.
The second purpose is that it provides an insight into the so far unexplored
international circulation of sex work policy models. This is important because debates about
sex work and its regulation in different parts of the world often reference other places and
mobile models. It is not just Sweden or the Swedish model that is widely discussed; Aotearoa
New Zealand, for instance, is regularly framed as a model for decriminalisation while the
Netherlands and Nevada are positioned as models for legalisation. All these places and
others are strategically used in debates; they are held up as being successful or
unsuccessful, good practice or bad practice, and policies that should or should not be
emulated. So, given the prevalence and implications of drawing on examples from elsewhere
in sex work policymaking and advocacy, it is somewhat perplexing why the sex work literature
has not closely examined the transnational movement of sex work policy models. In this paper,
we begin to address this gap.
The structure of this paper is as follows. It begins by considering the ways in which
criminological work has sought to understand the movement of policies, ideas and models,
and then it draws on the policy mobilities literature to set up a framework for understanding
this phenomenon. This is followed by a brief methodological note, after which there is an in-
depth exploration of the adaptation of the Swedish model by policymakers in Northern Ireland.
Let’s turn our attention now to the criminological literature.
Towards criminological policy mobilities
As noted previously, a small and varied body of criminological research has steadily emerged
providing insights into the movement of selected policies, ideas and models. These include
probation (Canton, 2006; Vanstone, 2008; McFarlane and Canton, 2014), victim impact
statements (Wemmers, 2005), preventive orders (Ogg, 2015), football banning orders
(Hamilton-Smith and Hopkins, 2012), electronic tagging (Nellis, 2000; Jones and Newburn,
2007) and policies targeting violence against women (Walklate and Fitz-Gibbon, 2018). Early
work on the movement of policies from the USA and the UK (Nellis, 2000; Jones and Newburn,
2007) has been complimented by studies exploring a variety of places and routes of travel.
Historically, the work has concentrated on the movement of policies in recent decades,
although Vanstone (2008) provides an exception with their exploration of the international
emergence and circulation of probation in the late nineteenth century and early twentieth
century. There are of course gaps in this literature, not least on the issue of sex work and on
the role of the Nordic countries as “sites of policy import and export” (Geddie 2014, p. 242).
Criminologists, of course, are not the only academics interested in the movement of
policies. There is a long history within political science of research into policy diffusion, policy
learning and, most noticeably, policy transfer (e.g. Dolowitz and Marsh, 2000; Benson and
Jordan, 2011). Scholars outside of political science have also explored such issues with, most
noticeably, a large body of work in and around human geography emerging since the mid-
2000s on what McCann (2008) has coined ‘policy mobilities’ (e.g. McCann and Ward, 2013;
Peck and Theodore, 2015; Temenos et al., 2018). There are several links between the
criminological and political science literature on mobile policies, the most noticeable is the
shared use of the term ‘policy transfer’, a term developed by the political scientists Dolowitz
and Marsh (2000, p. 5) who define it as “the process by which knowledge about policies,
administrative arrangements, institutions and ideas in one political system (past or present) is
used in the development of policies, administrative arrangements, institutions and ideas in
another political system”.
While a significant number of the criminological articles on policy transfer are
empirically focused and cite little or none of the political science policy transfer literature, a
smaller number of criminological studies have drawn explicitly and substantially on the
conceptual tools developed by Dolowitz and Marsh as well as other political scientists (e.g.
Newburn and Jones, 2002; Canton, 2006; Canton, 2014; Jones and Newburn, 2007; Ogg,
2015). An important example is Trevor Jones and Tim Newburn’s (2007) monograph Policy
Transfer and Criminal Justice which explores criminal justice policy transfer from the USA to
the UK, critically examining the apparent movement of ‘zero tolerance’ policing, two and three
strike sentencing, electronic tagging and the privatisation of prisons. Jones and Newburn draw
especially on the work of Evans and Davies (1999) and Smith (2004) to identify whether policy
transfer has occurred or not, as well as Dolowitz and Marsh (2000) to consider what is
transferred, where lessons are drawn from, what degrees of transfer occur, what constrains
or facilitates the transfer, the success or failure of the transfer, who is involved in transfer, and
why they get involved.
A decade after the publication of Policy Transfer and Criminal Justice, Jones and
Newburn have teamed up with Jarrett Blaustein to advocate a noticeably different way of
viewing the movement of criminal justice policies (Newburn et al., 2017). Their inspiration this
time is not the political science work on policy transfer, instead it is the geography-led work on
policy mobilities. For them, a policy mobilities approach is more nuanced as it avoids the
literalism of the ‘policy transfer’ label, embracing at the same time the geographical messiness
and social construction of policy formation (cf. Dolowitz and Marsh, 2012; Marsh and Evans,
Newburn et al. (2017) usefully single out two aspects of the policy mobilities approach
that can enhance our understanding of travelling criminal justice policies (and are downplayed
in the political science and criminological policy transfer literature). The first is the focus on
mobilities. Indeed, the policy mobilities literature focuses on the qualitative mobility and
immobility of policy knowledge. As part of this, it repeatedly stresses that policy knowledge
mutates as it moves, and that it is influenced by and influencing the landscapes through which
it travels (Peck and Theodore, 2015). Here the policy mobilities literature takes its cues from
the wider mobilities literature which focuses on the qualitative experiences and ramifications
of mobility and immobility (see, for instance, the collection edited by Adey et al. 2014). The
second aspect of the policy mobilities highlighted by Newburn et al. (2017) is the concept of
assemblage, which was first developed by Deleuze and Guattari (1987) and points to the
process of temporarily bringing something such as a policy into coherence. While it is not
used in all policy mobilities accounts, the concept of assemblage offers a useful lens through
which to view policy mobilisation (Prince, 2010; McCann, 2011; Baker and McGuirk, 2017).
This is illustrated by McCann and Ward (2013, p. 8) when they say:
“Policies… are not only local constructions; neither are they entirely extra-local
impositions on a locality. Rather, policies and governance practices are gatherings, or
relational assemblages of elements and resources fixed and mobile pieces of
expertise, regulation, institutional capacities, etc. from close by and far away. They
are assembled in particular ways and for particular interests and purposes… This
concept [of assemblage] is helpful as a frame for policy studies because it
emphasises… that policies are not internally coherent, stable ‘things’ but must be
understood as social processes.”
For Newburn et al. (2017) the policy mobilities approach with its emphasis on mobilities
and assemblages can be enhanced through a careful consideration of what they call policy
levels. Expanding on ideas developed a decade earlier in Jones and Newburn (2007),
Newburn et al. (2017) argue that there needs to be clarity in what we mean by policy and what
exactly is and is not being mobilised and assembled (see also Lovell, 2017a). For them, it is
important to differentiate the softer elements of policy in terms of (a) policy ideas, symbols and
rhetoric from (b) “the more concrete manifestations of policy in terms of policy content and
instruments as well as (c) “the more practical applications of policy in terms of its
implementation by practitioners and professionals” (Jones and Newburn, 2007, p. 23,
emphasis in original). We concur with Newburn and colleagues that attention to mobilities,
assemblage and policy levels are particularly useful in understanding criminological policy
mobilities. Nevertheless, Newburn et al.’s (2017) favourable, amended and brief interpretation
of the policy mobilities approach overlooks two issues that are being grappled within the policy
mobilities literature which would provide a useful supplement to the focus on mobilities,
assemblages, policy levels and policy mobilisation agents. The first is learning and educating,
and the second is extrospective showcasing.
The circulation of policy knowledge is intimately connected with, and dependent on,
forms of learning and educating. By learning, we echo Dunlop (2009, p. 296) in viewing it as
“a knowledge acquisition process” and by educating we use de Oliveira and Ahenakew’s
(2013, p. 233) definition of it as “the steering of learning towards particular desirable ends,
which are defined differently in different societies, cultures and contexts”. Learning and
educating are every-day, power-infused practices (McFarlane, 2011). They take multiple
forms, take place in person or at a distance, occur at various sites and occasions (formal and
informal), and shape the collection, interpretation and use of mobile policy knowledge.
An important concept within the policy mobilities literature that speaks to the
relationship between learning, educating and policy mobilisation is informational
infrastructures. These, McCann (2008, p. 12) notes, are assemblages of institutions, events
and technologies that “frame and package knowledge about best policy practices, successful
cities, and cutting-edge ideas and then present that information to specific audiences”. Here
McCann’s definition of informational infrastructures strongly echoes de Oliveira and
Ahenakew’s (2013) understanding of educating. Informational infrastructures are therefore
focused on educating audiences such as policymakers and shaping their learning. It is
important, then, to think about the role of informational infrastructures and how they influence
policy mobilisation. A central task in exploring the relationship between policy mobilities,
learning and educating is to consider how learning and education are performed at
informational infrastructure events such as study tours, conferences and award ceremonies
and with what effects, something that has received attention within the existing policy
mobilities literature (Cook and Ward, 2012; Wood 2014; Cook et al., 2015; Temenos, 2016;
Montero 2017).
Turning to extrospective showcasing, this term speaks to the ways in which local policy
actors showcase their work and locality to audiences elsewhere, often drawing on wider
informational infrastructures to do so. As McCann (2013) notes, policymakers often act
extrospectively through drawing ideas from elsewhere and, just as importantly, actively
promoting their policies to audiences elsewhere. Such promotional practices are akin to
education, and would include, for instance, writing about their policies in trade magazines or
newspapers, speaking at conferences, providing materials for exhibitions and hosting study
tours (Cook 2018). Work by McCann (2013) and Cook (2018) encourages us to critically
examine the ‘supply-side’ of mobile policy knowledge, and challenges us to consider how and
why local policy actors engage in extrospective showcasing, how such practices are
embedded within wider informational infrastructures, and how they influence policy
In summary, then, the policy mobilities approach can facilitate a nuanced
understanding of the geographical circulation of criminal justice policy knowledge and
especially sex work policy models. We will demonstrate our argument through an analysis of
the movement of the Swedish model to Northern Ireland. As part of this we will pay close
attention to five aspects of policy mobilisation: (1) mobilities, (2) assemblages, (3) policy levels,
(4) learning and educating, and (5) extrospective showcasing. First though, we will provide a
brief reflection on the methodology.
As part of wider debates on the methodological challenges of doing policy mobilities research
(e.g. Peck and Theodore, 2015; Wood, 2016; Baker and McGuirk, 2017), McCann and Ward
(2012) have suggested a useful methodological approach in studying the complexities of
policy mobilisation: the ‘following’ of policy mobility. Here McCann and Ward speak of the need
to follow policies, people and places as they travel as well as the requirement to closely
examine the connective sites through which policies are mobilised and mutated. Such a
methodological focus on mobility, of course, needs to run alongside an emphasis on the less
mobile and more inward-looking aspects of policy formation (Lovell, 2017b; Weller, 2017), in
addition to a pragmatic acknowledgement that access restrictions, time demands and
spiralling costs can prohibit all-compassing following.
In ‘following’ the Swedish model to Northern Ireland, the research project utilised two
key methods. The first is semi-structured interviewing with those involved in policymaking,
advocacy and the mobilisation of the Swedish model in Northern Ireland (n=7) and in Sweden
(n=5). The interviews were conducted either in-person or via telephone or Skype, and the
interviewees have been anonymised in this paper. The second is narrative analysis of a variety
of texts. These include newspaper articles, governmental and non-governmental policy
documents, advocacy reports, information packs, conference presentations, academic
literature and social media feeds. Particularly important sources were the Hansard reports of
proceedings in the Northern Ireland Assembly as well as texts (such as the meeting minutes
and written evidence) relating to the Committee Stage through which Morrow’s Bill the
Human Trafficking and Exploitation (Further Provisions and Support for Victims) Bill had to
pass through. As with the interview transcripts, narrative analysis was used to reveal the
arrangement of these textual ‘stories’ and the characterisation of policies, people and places
within them (Moore, 2014). By using a combination of semi-structured interviews and texts, it
is possible to offer an insight albeit a partial one into the mobile and less-mobile policies,
people and places involved as well as some of the important connective sites through which
policy mobilisation was shaped, such as the public debates and meetings in the Parliament
Buildings in Belfast known as Stormont.
Introducing the Swedish model
On January 1st 1999 it became illegal to buy sex in Sweden. Initially it was an offence
punishable by a fine or up to six months’ imprisonment with the maximum sentence revised to
one year in 2010. Those selling sex were not criminalised. Prior to the legislative change in
1999, there were no laws in place criminalising on-street sex work with off-street sex work
subject to few criminal laws (Hubbard et al., 2008). The ‘sex purchase law’ (sexköpslagen)
was brought in as part of the Women’s Peace (Kvinnofrid) Bill voted in under the Social
Democratic government (see Holmström and Skilbrei, 2017 for an overview of its introduction).
As well as reflecting some of the paternalistic underpinnings of Swedish welfarism,
sexköpslagen was also influenced by radical feminism within Sweden (Scoular, 2004).
Echoing radical feminist ideas (see, for instance, Jeffreys, 1997; Raymond, 2013), prostitution
has been positioned in Sweden as an inherently violent form of patriarchal oppression that,
irrespective of the circumstances in which it takes place, is harmful for women both inside and
outside the sex industry (Ekberg, 2004). It was argued that sexköpslagen was introduced to
not only abolish prostitution but also to improve gender equality in Sweden. To achieve both
goals, it is believed that the law must target those who are deemed to possess power and
choice: the clients as well as those profiting from the sex industry. Sex workers would not be
criminalised but offered support and advice on how to exit the industry. As Levy (2015)
describes in detail, much of this support has been funnelled through ‘prostitution units’ in the
three major cities in Sweden: Stockholm, Malmö and Gothenburg. These units are funded by
local councils and provide a variety of services for sex workers often focused around issues
such as welfare, alternative employment and health. Notable though is that Malmö focuses on
harm reduction while Stockholm and Gothenburg focus on facilitating service users to leave
sex work (Levy, 2015).
On June 1st 2015 it became illegal to buy sex in Northern Ireland, sixteen years and
five months after its introduction in Sweden. Under section 15 of the Human Trafficking and
Exploitation (Criminal Justice and Support for Victims) Act (Northern Ireland) 2015 it became
a crime punishable by a fine and potentially up to one year’s imprisonment. This replaced
existing laws criminalising kerb crawling and the purchase of sex from someone subject to
force. It also repealed the acts of soliciting and loitering, while keeping a brothel used for
prostitution would remain illegal. Section 19 of the 2015 Act also required a programme of
support for those exiting prostitution. As we will detail, the measures under the 2015 Act and
the rationale for them were clearly informed by Sweden, but they have mutated as the policy
was mobilised and implemented in Northern Ireland.
During the campaigns for and against the new laws in Northern Ireland, Sweden was
positioned as a model: ‘the Swedish model’. Indeed, the Swedish model has become a much-
used term within debates on sex work worldwide. It is important to unpack this phrase. Drawing
on the work of Peck and Theodore (2010) we should view the Swedish model, like all policy
models, as a socially constructed, stripped-down abstraction of a messy and prosaic reality.
We should avoid seeing the Swedish model as one that has only been ‘made in Sweden’ and
one whose component parts are fixed; instead it is co-produced by numerous actors in
different places and it mutates as it moves.
A central aspect of the Swedish model is, to use Peck and Theodore’s (2010) words,
its metonymic tagging of a policy to a place a metonym being a linguistic device “where a
name is used for something with which it is somehow culturally or spatially associated” (Brown,
2006, p. 317). With its symbolic association to a particular nation state, the Swedish model
“evokes a grounded form of authenticity, implies feasibility, and signals an ideologically
palatable origin story” (Peck and Theodore, 2010, p. 170). The metonymic tagging of the
Swedish model has become more complex as it has been emulated elsewhere, with
policymakers and advocates also referencing the ‘Nordic model’. The Nordic model is mostly
used as a synonym for the Swedish model. Nevertheless, those who use the Nordic model
terminology often do so to suggest a common approach in the Nordic countries; this is despite
the fact that Denmark has not criminalised the purchase of sex and Finland has only partially
criminalised this, with clients who purchase sex from trafficked victims or someone controlled
by a pimp being targeted (see Skilbrei and Holmström, 2013). The Nordic model terminology
is used to demonstrate a transnational transferability of Swedish policies. The emulation of
Sweden in Canada, France, the Republic of Ireland and Northern Ireland has further
complicated this metonymic tagging. Despite all this, in Northern Ireland and elsewhere
Sweden remains the dominant reference point within the movement of the Swedish/Nordic
Showcasing, educating and learning
A sizable informational infrastructure has developed since the late 1990s that seeks to educate
people in different parts of the world about what has become known as the Swedish model.
Many of the educators have not been directly involved in the development and implementation
of prostitution policy in Sweden. Furthermore, much of this education occurs at a distance,
disseminated, for instance, via newspaper articles, journal articles, books, blogs and other
social media. The experiences of Sweden have been commented on at length by Swedish
and non-Swedish activists and journalists (e.g. Demsteader, 2012; Meredith, 2013). One such
UK-based activist is Julie Bindel (2016, p. 1) who has argued that the “Nordic model is the
best way towards a society where women are not saleable objects”. Many Swedish and non-
Swedish academics, too, have been vocal on the sex purchase law in Sweden. As with
journalists and activists, the Swedish model has proved extremely divisive among academics;
some have criticised the Swedish model (e.g. Levy and Jakobsson, 2014; Vuolajärvi, 2018)
and some have been supportive of it (e.g. Coy, 2016; Raymond, 2013). Others, meanwhile,
have broadly supported it while recommending changes to its modus operandi (e.g. Johnson
and Mathews, 2016). Those academics and activists who are vocal in their support of the
Swedish model are often, but not always, linked to a wider transnational neo-abolitionist
movement. This is a movement that includes but is not limited to radical feminism and seeks
to abolish prostitution through the punishment of clients and third parties. As Ward and Wylie
(2017) note, for many within the neo-abolitionist movement, the Swedish model is the
exemplary model.
Of course, much of this education has also involved those working within or alongside
the Swedish state. This is unsurprising given that the Swedish state has actively funded the
external promotion of the Swedish model (Ward and Wylie, 2017) and that at its inception the
sex purchase law was intended to make a statement internationally. There is a desire from
within the Swedish state to stop sex work occurring outside of Sweden; one interviewee in
Sweden who promotes the model internationally reasoned that “we do not want to have a
world where it is OK to buy other people”. This extrospective showcasing has occurred not
only at a distance but also face-to-face with curious onlookers from abroad. This has often
involved Swedish representatives participating at informational infrastructure events such as
conferences, workshops and study tours (we will return to the latter further on). There are
numerous showcasers in Sweden who have regularly and proactively promoted the Swedish
model to international audiences as well as responded to requests from curious policymakers
and practitioners from abroad. Two of the most prominent Sweden-based showcasers are
Kajsa Wahlberg (the Swedish National Rapporteur on Trafficking in Human Beings) and
Simon Häggström (who works in the Prostitution Unit within Stockholm’s Police). Much of
Wahlberg and Häggström’s showcasing focuses on their experiences of delivering the
Swedish model; they can give the ‘inside story’ of how it works. This partly explains the
international interest in Häggström’s book, Shadow’s Law: The True Story of a Swedish
Detective Inspector Fighting Prostitution (2016). It is a book that the American radical feminist
Melissa Farley (2017, p. 1) has praised, calling it “a much-needed tool for confronting
prostitution-harm-denial and for making the links between prostitution, trafficking, and
pornography”. In addition to Wahlberg and Häggström, another prominent Swedish showcaser
is Per-Anders Sunesson, the Swedish Ambassador at Large for Combating Trafficking in
Persons, who has spent considerable time travelling abroad in this capacity promoting the
Swedish model, as his twitter account @PASunesson illustrates.
Whether it is conducted at a distance or face-to-face, by those in Sweden or outside
Sweden, most of the pro-Swedish model educators and their educating materials are adamant
that the model is (a) successful, (b) morally right and (c) transferable. Although their claims
have often been rebuked by critics, these positive and digestible messages have accompanied
the Swedish model on its travels. The words and actions of one showcaser, Gunilla Ekberg,
are important to note here primarily because she played an important role in bringing the
Swedish model to Northern Ireland. Ekberg worked as a Special Advisor on Trafficking in
Human Beings in Sweden between 1998 and 2006. She continues to write academic articles
and briefings on the model (e.g. Ekberg, 2004; Ekberg and Werkman, 2017). In short, she has
become very closely associated with the Swedish model and a travelling advocate for it. In
what Ellison (2017, p. 207) describes as “one of the most unlikely pairings in recent political
history”, Ekberg a radical feminist worked for Morrow and the DUP as an advisor, and
helped to facilitate the adoption of the Swedish model in Northern Ireland. Among other things,
Ekberg helped draft Morrow’s Bill and gave oral evidence at length during a Committee Stage
meeting at Stormont in September 2013. Ekberg’s close links with the Swedish model
encouraged Morrow to work with her. As one DUP Member of the Legislative Assembly (MLA)
interviewed (#1) reasoned, Ekberg is “an absolute world authority… on this issue; she has
walked the walk, as they say, in legislation and studies [of] other countries, and we listened
intently and closely to what Gunilla Ekberg was saying in relation to the Swedish model”.
In Ekberg’s writing and public speaking – before, during and after her involvement in
Northern Ireland she has repeatedly stated that prostitution is in almost every case
exploitative and abhorrent, dismissed the idea that many sex workers have the capacity to
exercise choice, and reasoned that sex work is inseparable from trafficking (Ekberg and
Werkman, 2017). Ekberg has also repeatedly praised the measures put in place in Sweden
and the sex purchase law in particular which she argues has been a considerable success.
Like many advocates for the Swedish model, Ekberg has frequently stressed that there has
been a reduction in sex work and trafficking in Sweden. For instance, when Ekberg gave
evidence at the Committee Stage of the Bill, and was asked whether prostitution had been
abolished in Sweden, Ekberg responded:
“No, of course not. Any social change takes more than 15 years, but what I can say
with some conviction is that Sweden is a country where prostitution is much less
prevalent and is a country that is not attractive for traffickers… [I]f you look at, for
example, Finland, you see that they had 15,000 victims of trafficking per year, whereas
we have maybe 200 or 300 at the most. Again, that is because it is not attractive. Think
about it. If you were a trafficker, where would you go? Where would I go? I would not
go to a place where you risk getting caught.” (Northern Ireland Assembly, 2013, n.p.)
As we suggest later, the reported ability of the Swedish model to deter trafficking rather than
its ability to reduce gender inequality has become its most seductive ‘sales pitch’ to audiences
abroad, especially those in Northern Ireland. Ekberg was not the only person giving oral
evidence at the Bill’s Committee Stage who spoke about the success or otherwise of the
Swedish model. In fact, the majority who gave evidence referenced Sweden and the impact
of the sex purchase law. Their views were often justified by claims to have read reports about
Sweden, visited Sweden or spoken to people from Sweden connected to sex work. Most of
those giving oral evidence were from Northern Ireland with several from the Irish Republic and
Britain; Ekberg, however, was the only person from Sweden.
Prior to receiving written and oral evidence, it was decided that six members of the
Committee for Justice would attend a two-day study tour to Stockholm on Ekberg’s
recommendation. They were accompanied by Morrow who participated at his own expense
(Committee for Justice, 2013). Taking place in December 2013, the trip was an important
means through which those in Northern Ireland learnt about Sweden. Its itinerary centred on
the delegation meeting and hearing presentations from ten professionals whose work focuses
on sex work or trafficking, including Kajsa Wahlberg, Simon Häggström, the academic Petra
Östergren and co-ordinator of the NGO Rose Alliance, Pye Jakobsson. The tour report makes
it clear that while many of the Swedish ‘hosts’ presented policy and practice in Sweden as
working successfully, some such as Östergren and Jakobsson spoke critically about it
(Committee for Justice, 2013). Echoing study tours elsewhere, this visit was a way of learning
face-to-face from those deemed to have experience and expertise on the issue. For Morrow,
the trip also offered him a means of convincing the Committee of Justice to support his
proposals some of whom had spoken publicly about their reservations about clause 6 which
criminalised the buying of sex (clause 6 would later become clause 15). The trip would also
be regularly namechecked by Morrow when speaking to the media and other audiences about
his ‘tried-and-tested’ proposals.
For some of the other delegates, the tour confirmed the success and transferability of
Morrow’s proposal. One such delegate was the Chair of the Committee of Justice and DUP
MLA, Paul Givan who in a Committee Stage meeting said:
“The Swedish police service said — and I have no reason to suggest why they would
tell me different that the deterrent value in clause 6 would reduce things by
approximately half. That was the deterrent value that allowed them to put their
resources into the harder cases. The deterrent value would reduce it by about half.
Why would we not have that same kind of deterrent value?” (Northern Ireland
Assembly, 2014b, n.p.)
Others delegates, however, took more critical lessons from the visit to Stockholm. Sinn Féin
MLA Rosaleen McCorley, for instance, reasoned at another Committee Stage meeting:
“I was in Sweden and was told by people who work in the sex industry there that they
have seen no significant reduction. There is also evidence that it has increased. In fact,
there is Eurostat evidence to suggest that convictions for trafficking in Sweden have
quadrupled and that trafficking is increasing more there than in other countries in the
area. What the women said this is very concerning was that life had got more
dangerous and that they felt more stigmatised.” (Northern Ireland Assembly, 2014c,
The visit to Sweden would go on to shape the ways in which Morrow’s Bill was framed and
how it was received by policymakers. The trip, however, was not a ‘tick-box exercise’ as it did
offer an opportunity for some critical voices in Sweden to speak directly to the delegation. That
said, important questions have been asked about the lack of interest by Morrow and his
supporters in learning from academic research on sex work in Northern Ireland, particularly
research which presents empirical data that runs contrary to the image of sex work in Northern
Ireland as sizeable, exploitative and inherently linked to trafficking (e.g. Huscke et al., 2014;
Ellison, 2015).
One such author, Graham Ellison (2017) who submitted written and oral evidence to
the Committee reasoned that the DUP saw little interest in engaging with such research.
“Empirical evidence from research into commercial sex”, Ellison argues, “was either ignored
or treated as inferior to that conducted by a number of advocacy groups which was based
normatively on feelings, emotions and particularistic moral stances” (Ellison 2017, p. 309).
Academic research was met with resistance from some Committee members such as Paul
Givan who reasoned that “some of us do not need any research or any evidence. For some
of us, the principle of purchasing sex from a woman is sexual violence, full stop” (Northern
Ireland Assembly, 2014d: n.p.). Many Committee members, however, were receptive to
evidence given by those also with a neo-abolitionist standpoint such as Women’s Aid and
CARE (Christian Aid Research and Education). Ellison’s sentiments are echoed by Huscke
and Ward (2017) who bemoan the way in which their own research (Huscke et al., 2014),
commissioned by the Department of Justice into the demographics and experiences of sex
workers and their clients, was treated. They reason that it was ignored and dismissed by some
MLAs as unnecessary, biased and a rouse by the Justice Minister to delay the Bill. One
wonders how academic research informed by a neo-abolitionist philosophy would have fared
with Morrow and the Committee.
Policy assemblages, levels and mutations
In Stormont during December 2014, Morrow’s Bill was passed by 81 votes to 10, gaining
support from DUP MLAs as well as many MLAs from other parties. It is a Bill that should be
understood as an assemblage, bringing together into temporary coherence three couplings:
(1) sex work and trafficking, (2) radical feminism and the Christian right, and (3) Sweden and
Northern Ireland. Let’s explore each of the couplings in turn. A central tenet of neo-abolitionist
thinking is that sex work and human trafficking are closely connected to the point where sex
work cannot exist without human trafficking (Raymond, 2013). Many from a neo-abolitionist
perspective would concur with a Swedish police official interviewed who suggested that “if
there was no demand for women and girls in the sex industry, in prostitution, we wouldn’t have
trafficking for sexual exploitation”. Tackling the demand for paid sex, therefore, is viewed as a
necessary tool to reduce trafficking. Although the ways that neo-abolitionists connect
trafficking and sex work have been vehemently disputed (e.g. Agustín, 2007), these linkages
became a repeatedly used justification for the criminalisation of buying sex in Northern Ireland.
So much so that prior to the vote, Jim Wells, a DUP MLA and supporter of the Bill, said in
Stormont that “[w]ithout clause 15 the Bill is meaningless” (Northern Ireland Assembly, 2014a,
n.p.). These linkages are not exclusively Swedish in origin, but they have become closely
associated with the Swedish model. As Svanström (2017) has detailed, although sexköplagen
was not originally conceived as a tool to reduce trafficking an important difference from the
2015 Act in Northern Ireland it has become increasingly framed as being so within Sweden
and showcased internationally as such also.
This leads onto the second coupling: the bringing together of secular radical feminism
with the Christian right. While many from these two groups would strongly disagree on several
issues such as abortion many within them would agree that sex work is problematic and
should be abolished (Ellison, 2015, 2017). For instance, many radical feminists would share
the sentiments of one DUP MLA interviewed (#2) who argued that “prostitution is a nasty, evil
activity that causes huge hurt to the women concerned”. This coupling most clearly manifested
itself in the way in which Morrow worked closely with both Gunilla Ekberg and members of
CARE in drafting the Bill (Ellison, 2017). In contrast to the introduction of sexköplagen in
Sweden, the Christian right have been central to the reforms in Northern Ireland. Indeed,
Morrow stated in Stormont before the vote that “taking action was very much motivated by my
Christian faith and principles” (Northern Ireland Assembly, 2014a, n.p.) and his party, the DUP
(who are a socially conservative right-wing party), have strong connections to the Free
Presbyterian Church. This coalescence between the Christian right and radical feminism has
been strategic, selective and, for some commentators, unequal. Huschke (2017, p. 201), for
instance, has made the case that “[i]n Northern Ireland, the feminist rhetoric is merely used as
a way of packaging sex-negative, repressive policy measures based on conservative Christian
values, thereby rendering them more appealing”. It is a coupling that Ellison (2017) argues is
much more likely to benefit the religious right than feminists or women in general.
The third coupling is the linking of Northern Ireland and Sweden whereby Sweden has
had a significant influence on policymaking in Northern Ireland. Other countries who have
adopted the Nordic model played a limited role in policy development in Northern Ireland, the
exception being the Irish Republic whose development of similar laws and the appeal of an
‘all-Ireland’ approach gave Morrow’s Bill further impetus. Thinking about the role of Sweden,
then, it is beneficial to bring in Jones and Newburn’s (2007) notion of policy levels as discussed
earlier. We can identify a clear transfer of certain policy content and instruments from Sweden
to Northern Ireland. Certainly, the adoption of the criminalisation of buying sex, the non-
criminalisation of soliciting and loitering, and the one year maximum sentence closely reflect
the Swedish approach. The use of fines as punishment travelled too, however their positioning
and calculation morphed. Indeed, while a fine can be used as an alternative to imprisonment
in both jurisdictions, a client can be sentenced to both imprisonment and a fine for a singular
offence in Northern Ireland but not in Sweden. Furthermore, the calculation of the fine in
Northern Ireland does not take into account the daily income of the client as it has does in
Sweden; instead it is based solely on the perceived seriousness of the offence (in line with
sentencing guidelines in Northern Ireland).
The influence of Sweden becomes more blurry when considering the incorporation of
exiting services in the Act. The original Bill did not include such services but Morrow has stated
publicly that this was revised following lobbying by campaign groups in the UK and Ireland:
Let me be very clear: on reflection, it was not properly catered for in my Bill. It was as
a result of listening to what people were telling me about an exit strategy that we
decided that it was important, and we needed to introduce it. It was emphasised by
[groups…] including Women’s Aid and Ruhama. Other groups said that if the Bill did
not have an exit strategy, there would be a fundamental weakness in the whole
strategy… This [revised] strategy is designed to try to steer them away from that and
to give them the support, self-esteem and confidence that they really need” (Northern
Ireland Assembly, 2014e, n. p.)
Every so often those lobbying for exiting services in Northern Ireland would point to similar
services in Sweden. Yet Sweden did not seem to act as a blueprint in Northern Ireland. One
reason perhaps is that Sweden’s exiting services have a different legal and political setting:
they have not been written into law but are embedded within a far more comprehensive welfare
state (Levy, 2015). In Northern Ireland, where the welfare state has been increasingly eroded,
lobbyists successfully sought to guarantee such services through the inclusion of a section in
the 2015 Act that requires the Department of Health to work with other departments to develop
exiting services. The Act goes on to state that exiting services are not compulsory for sex
workers and that acting as a witness in criminal proceedings is not an entry requirement.
Conversely in Sweden although its approach is supposed to enable better access to state
services, Levy (2015) suggests that some of those who refuse to stop sex work (despite it not
being criminal to sell sex) have had access to support services withheld, while some will not
seek these services because of fear of judgement and discrimination.
Some aspects of Northern Ireland’s new laws, therefore, emulated or echoed those in
Sweden but other policy content and instruments did not make the move west. One example
is the powers available to the police in Northern Ireland to follow their Swedish counterparts
in engaging in covert surveillance such as phone-tapping to catch those paying for sex (see
Häggström, 2016). As suggested by representatives of the Police Service of Northern Ireland
at a Committee Stage meeting in Stormont, the payment of sex between two consenting adults
would not be deemed serious enough to meet the threshold that allows convert surveillance
under the UK-wide Regulation of Investigatory Powers Act 2000 (Northern Ireland Assembly,
Moving onto policy ideas, symbols and rhetoric (Jones and Newburn’s second policy
level), there are similarities in the way in which sex work and trafficking as well as sex workers
and clients have been imagined and represented in Northern Ireland and Sweden. It is also
possible to identify an argument used against critics by policymakers in Northern Ireland that
was ‘borrowed’ from Sweden (and explicitly so): that criminalisation of buying sex cannot drive
sex work underground where it cannot be policed because it needs to be advertised in
some way. Yet this example aside, it has not been possible to identify a stream of policy ideas,
symbols and rhetoric flowing from Sweden to Northern Ireland. Indeed, many of these
discursive tools seem to have originated in neo-abolitionist networks that stretch far beyond
In terms of implementation by practitioners and professionals (Jones and Newburn’s
third policy level) more research is required into whether those at the front-end of service
provision and policing in different parts of Northern Ireland have taken inspiration from
Sweden. That said, the relatively low arrest rates for buying sex in Northern Ireland hint that,
unlike in Sweden, arresting clients has not become a policing priority (McClafferty, 2016; cf.
Häggström, 2016). In sum, then, it appears that the movement of the Swedish model to
Northern Ireland have centred on the selective borrowing and reworking of bits and pieces of
policy content and instruments more than anything else.
This article has made the case for an alternative way of understanding the circulation of
criminal justice ideas, policies and models. It has called for a more expansive engagement
with the policy mobilities literature that originates in human geography. Ideas and concepts
that emerge out of human geography do not receive as much attention in criminological
studies as they should (for notable exceptions, see Hayward, 2012 and contributions in Moran
and Schliehe, 2017). Acknowledging the value of engaging with human geography, we have
supported Newburn et al.’s (2017) call for criminological policy mobilities studies to utilise three
policy mobilities concepts (mobilities, mutations and assemblages) alongside Jones and
Newburn’s (2007) concept of policy levels. This, we have argued, does not go far enough.
Here we have called for these issues to be explored alongside other concepts used in the
policy mobilities literature (namely learning, educating and extrospective showcasing).
By drawing more expansively on the policy mobilities literature we are better equipped
to understand the circulation of sex work policy models, an issue that has received surprisingly
little attention in the academic literature on sex work. By paying close attention to practices of
learning, educating and showcasing, for instance, we can see that these practices which are
often ignored in academic studies of policy formation significantly influence the mobilisation
of policies, ideas and models. The making of the Human Trafficking and Exploitation (Criminal
Justice and Support for Victims) Act (Northern Ireland) 2015, for instance, was the result of
policymakers and advocates learning from Sweden, primarily through working with the
consultant Gunilla Ekberg and attendance on a study tour to Stockholm. The Act was also
influenced by a transnational informational infrastructure comprising of actors, events and
technologies that sought to showcase the Swedish model and educate onlookers. Ignoring all
this means only revealing a small part of the story. That said, a focus on mobilities, mutations,
assemblages and policy levels provides a complimentary insight into the geographies of policy
formation and circulation. These conceptual tools has enabled us to understand that while the
Swedish model is often presented as being a coherent package ‘made in Sweden’, it has
actually been transformed on its travels, adapted to local contexts, and brought into wider
assemblages when it ‘lands’. So, in Northern Ireland, there are clear Swedish resonances in
the Human Trafficking and Exploitation (Criminal Justice and Support for Victims) Act
(Northern Ireland) 2015, particularly so in the case of policy content and instruments to use
the terminology of Jones and Newburn (2007). Yet there is a distinctive Northern Ireland
‘flavour’ to its take on the Swedish model that also incorporates influences from the UK and
Ireland as well as wider ideas (such as those in radical feminism) whose geographical origins
are difficult to pinpoint.
There is much more to explore in regards to the movement and mutation of criminal
justice ideas, policies and models, with those related to sex work in particular need of further
research. There are many stories to tell here, of models that are mobile in varied ways and
those that are not. This research should continue to draw on the policy mobilities literature.
More importantly, criminologists can and should play an important role in shaping the future
of this literature.
Adey, P., Bissell, D., Hannam, K., Merriman, P. and Sheller, M. (2014), The Routledge
Handbook of Mobilities. Routledge.
Agustín, L. (2007), Sex at the Margins: Migration, Labour Markets and the Rescue Industry.
Zed Books.
Baker, T. and McGuirk, P. (2017), ‘Assemblage Thinking as Methodology: Commitments and
Practices for Critical Policy Research’, Territory, Politics, Governance, 5/4: 425-442.
Benson, D. and Jordan, A. (2011), ‘What Have We Learned from Policy Transfer Research?
Dolowitz and Marsh Revisited’, Political Studies Review, 9/3: 366-378.
Bindel, J. (2016), ‘Decriminalising the Sex Trade Will Not Protect Its Workers from Abuse’.
The Guardian, 13th July.
Brown, M. (2006), ‘A Geographer Reads Geography Club: Spatial Metaphor and Metonym in
Textual/Sexual Space’, Cultural Geographies, 13/3: 313-339.
Canton, R. (2006), ‘Penal Policy Transfer: A Case Study from Ukraine’, The Howard Journal,
45/5: 502-520.
Canton, R. (2014), ‘Transfer of Policies and Practices to Other Countries’, in G. Bruinsma and
D. Weisburd, eds., Encyclopedia of Criminology and Criminal Justice, 2623-2632. Springer.
Committee for Justice (2013), ‘Report on the Committee for Justice Visit to Stockholm,
Sweden to View the Workings of the Swedish Model that Prohibits the Purchase of Sexual
Services’, in ‘Report on the Human Trafficking and Exploitation (Further Provisions and
Support for Victims) Bill (NIA 26/11-15)’, 1270-1275.
Cook, I.R. (2018), ‘Showcasing Vällingby to the World: Post-War Suburban Development,
Informational Infrastructures and the Extrospective City’, Planning Perspectives, 33/3: 315-
Cook, I.R. and Ward, K. (2012), ‘Conferences, Informational Infrastructures and Mobile
Policies: The Process of Getting Sweden ‘BID Ready’’, European Urban and Regional Studies,
19/2: 137-152.
Cook, I.R., Ward, S.V. and Ward, K. (2015), ‘Post-war Planning and Policy Tourism: The
International Study Tours of the Town and Country Planning Association 1947-61’, Planning
Theory and Practice, 16/2: 184-205.
Coy, M. (2016), ‘Joining the Dots on Sexual Exploitation of Children and Women: A Way
Forward for UK Policy Responses’, Critical Social Policy, 36/4: 572-591.
Deleuze, G. and Guattari, F. (1987), A Thousand Plateaus: Capitalism and Schizophrenia.
University of Minnesota Press.
de Oliveira, V. and Ahenakew, C. (2013), “Educating.” In S. Matthewman, C. Lane West-
Newman and B. Curtis, eds., Being Sociological, 2nd edition, 233-250. Palgrave Macmillan.
Dolowitz, D. and Marsh, D. (2000), ‘Learning from Abroad: The Role of Policy Transfer in
Contemporary Policy-Making’, Governance, 13/1: 5-24.
Dolowitz, D. and Marsh, D. (2012), ‘The Future of Policy Transfer Research’, Political Studies
Review, 10/3: 339-345.
Demsteader, C. (2012), ‘The Swedish Sex Law that Shook the World’, The Local, 16th
November, (accessed 16/08/18).
Dunlop, C. (2009), ‘Policy Transfer as Learning: Capturing Variation in What Decision-makers
Learn from Epistemic Communities”, Policy Studies, 30/3: 289-311.
Ekberg, G.S. (2004), ‘The Swedish Law that Prohibits the Purchase of Sexual Services: Best
Practices for Prevention of Prostitution and Trafficking in Human Beings’, Violence Against
Women, 36/4: 572-591.
Ekberg, G.S. and Werkman, K. (2017), ‘Swedish Laws, Polices and Interventions on
Prostitution and the Trafficking in Human Beings: A Comprehensive Overview’, available at:
policies-thb-gunilla-s-ekberg-171122-2.pdf (accessed 16/08/18).
Ellison, G. (2015), ‘Criminalising the Payment for Sex in Northern Ireland: Sketching the
Contours of a Moral Panic’, British Journal of Criminology, 57/1: 194-214.
Ellison, G. (2017), ‘Who Needs Evidence? Radical Feminism, the Christian Right and Sex
Work Research in Northern Ireland’, in S. Armstrong, J. Blaustein and A. Henry, ed, Reflexivity
and Criminal Justice: Intersections of Policy, Practice and Research, 289-314. Palgrave
Evans, M. and Davies, J. (1999), ‘Understanding Policy Transfer: A Multi-Level, Multi-
Disciplinary Perspective’, Public Administration, 77/2: 361-385.
Farley, M. (2017), Book Review of Shadow’s Law: The True Story of a Swedish Detective
Inspector Fighting Prostitution. Dignity, 2/2: 1-3.
Geddie, K. (2015), ‘Policy Mobilities in the Race for Talent: Competitive State Strategies in
International Student Mobility’, Transactions of the Institute of British Geographers, 40/2: 235-
Hamilton-Smith, N. and Hopkins, M. (2012), ‘The Transfer of English Legislation to the Scottish
Context: Lessons from the Implementation of the Football Banning Order in Scotland’,
Criminology and Criminal Justice, 13/3: 279-297.
Hayward, K. (2012), ‘Five Spaces of Cultural Criminology’, The British Journal of Criminology,
3/1: 441-462.
Holmström, C. and Skilbrei, M.-L. (2017), ‘Swedish Prostitution Policy in Context’, in E. U.
Savona, M.A.R. Kleiman and F. Calderoni, eds, Dual Markets: Comparative Approaches to
Regulation, 353-364. Springer.
Hubbard, P., Matthews, R. and Scoular, J. (2008), ‘Regulating Sex Work in the EU: Prostitute
Women and the New Spaces of Exclusion’, Gender, Place and Culture, 15/2: 137-152.
Huschke, S., Shirlow, P., Schubotz, D., Ward, E., Probst, U. and Dhónaill, C. (2014),
Research into Prostitution in Northern Ireland. Department of Justice.
Huschke, S. (2017), ‘Victims Without a Choice? A Critical View on the Debate About Sex Work
in Northern Ireland’, Sexuality Research and Social Policy, 14/2: 192-205.
Häggström, S. (2016), Shadow’s Law: The True Story of a Swedish Detective Inspector
Fighting Prostitution. Bullet Point.
Jeffreys, S. (1997), The Idea of Prostitution. Spinifex.
Johnson, H. and Mathews, R. (2016) ‘Addressing Prostitution: The Nordic Model and Beyond’,
in R. Matthews, ed, What is to Be Done about Crime and Punishment? Towards a Public
Criminology, 281-308. Palgrave Macmillan.
Jones, T. and Newburn, T. (2002), ‘Learning from Uncle Sam? Exploring U.S. Influences on
British Crime Control Policy’, Governance, 15/1: 97-119.
Jones, T. and Newburn, T. (2007), Policy Transfer and Criminal Justice: Exploring US
Influence on British Crime Control Policy. Open University Press.
Levy, J. (2015), Criminalising the Purchase of Sex: Lessons from Sweden. Routledge.
Levy, J. and Jakobsson, P. (2014), ‘Sweden’s Abolitionist Discourse and Law: Effects on the
Dynamics of Swedish Sex Work and on the Lives of Sweden’s Sex Workers’, Criminology and
Criminal Justice, 14/5: 593-607.
Lovell, H. (2017a), “Are Policy Failures Mobile? An Investigation of the Advanced Metering
Infrastructure Program in the State of Victoria, Australia’, Environment and Planning A, 49/2:
Lovell, H. (2017b), Policy Failure Mobilities’, Progress in Human Geography, doi:
Marsh, D. and Evans, M. (2012) ‘Policy Transfer: Coming of Age and Learning from the
Experience’, Policy Studies, 33/6: 477-481.
McCann, E. (2008), ‘Expertise, Truth, and Urban Policy Mobilities: Global Circuits of
Knowledge in the Development of Vancouver, Canada’s ‘Four Pillar’ Drug Strategy’,
Environment and Planning A, 40/4: 885-904.
McCann, E. (2011), ‘Veritable Inventions: Cities, Policies and Assemblage’, Area, 43/2: 143-
McCann, E. (2013), ‘Policy Boosterism, Policy Mobilities, and the Extrospective City’, Urban
Geography, 34/1: 5-29.
McCann, E. and Ward, K. (2012), ‘Assembling Urbanism: Following Policies and ‘Studying
Through’ the Sites and Situations of Policy Making’. Environment and Planning A, 44/1: 42-
McCann, E. and Ward, K. (2013), ‘A Multi-Disciplinary Approach to Policy Transfer Research:
Geographies, Assemblages, Mobilities and Mutations’, Policy Studies, 34/1: 2-18.
McClafferty, E. (2016), ‘‘No Prosecutions’ for Paying for Sex in NI Despite New Law’, BBC,10th
August, available at (accessed
McFarlane, C. (2011), Learning the City: Knowledge and Translocal Assemblage. Wiley-
McFarlane, M. A. and Canton, R. (2014), Policy Transfer in Criminal Justice: Crossing
Cultures, Breaking Barriers. Palgrave Macmillan.
Meredith, F. (2013), ‘Sweden’s Sex Laws Do We Really Want Them in Northern Ireland?’
Belfast Telegraph, 9th December.
Montero, S. (2017), ‘Study Tours and Inter-city Policy Learning: Mobilizing Bogotá’s
Transportation Policies in Guadalajara’, Environment and Planning A, 42/2: 332-350.
Moore, S. (2014), Crime and the Media. Palgrave Macmillan.
Moran, D. and Schliehe, A. K. (2017), eds, Carceral Spatiality: Dialogues between Geography
and Criminology. Palgrave Macmillan.
Nellis, M. (2000), ‘Law and Order: The Electronic Monitoring of Offenders’, in D. Dolowitz, ed,
Policy Transfer and British Social Policy: Learning from the USA? 98-117. Open University
Newburn, T., Jones, T. and Blaustein, J. (2017), ‘Policy Mobilities and Comparative Penality’,
Theoretical Criminology, early online.
Northern Ireland Assembly (2013), Official Report, 12th September.
Northern Ireland Assembly (2014a), Official Report, 9th December.
Northern Ireland Assembly (2014b), Official Report, 20th February.
Northern Ireland Assembly (2014c), Official Report, 13th February.
Northern Ireland Assembly (2014d), Official Report, 9th January.
Northern Ireland Assembly (2014e), Official Report, 20th March.
Ogg, J.T. (2015), Preventive Justice and the Power of Policy Transfer. Palgrave Macmillan.
Peck, J. and Theodore, N. (2010), ‘Mobilizing Policy: Models, Methods, and Mutations’,
Geoforum, 41/2: 169-174.
Peck, J. and Theodore, N. (2015), Fast Policy: Experimental Statecraft at the Thresholds of
Neoliberalism. University of Minnesota Press.
Prince, R. (2010), ‘Policy Transfer as Policy Assemblage: Making Policy for the Creative
Industries in New Zealand’, Environment and Planning A, 42/1: 169-186.
Raymond, J. (2013), Not a Choice, not a Job: Exposing the Myths about Prostitution and the
Global Sex Trade. Potomac.
Scoular, J. (2004), ‘‘Criminalising Punters’: Evaluating the Swedish Position on Prostitution’.
Journal of Social Welfare and Family Law, 26/2: 195-210.
Smith, A. (2004), ‘Policy Transfer in the Development of UK Climate Policy’, Policy and
Politics, 32/1: 79-93.
Skilbrei, M.-L. and Holmström, C. (2013), Prostitution Policy in the Nordic Region: Ambiguous
Sympathies. Ashgate.
Svanström, Y. (2017), ‘From Contested to Consensus: Swedish Politics on Prostitution and
Trafficking’, in E. Ward and G. Wylie, eds, Feminism, Prostitution and the State: The Politics
of Neo-Abolitionism, 29-45. Routledge.
Temenos, C. (2016), ‘Mobilizing Drug Policy Activism: Conferences, Convergence Spaces
and Ephemeral Fixtures in Social Movement Mobilization’, Space and Polity, 20/1: 124-141.
Temenos, C., Baker, T. and Cook I.R. (2018), ‘Inside Mobile Urbanism: Cities and Policy
Mobilities’, in T. Schwanen, ed., Handbook of Urban Geography. Edward Elgar, forthcoming.
Vanstone, M. (2008), ‘The International Origins and Initial Development of Probation’, The
British Journal of Criminology, 48/6: 735-755.
Vuolajärvi, N. (2018), ‘Governing in the Name of Caring – the Nordic Model of Prostitution and
its Punitive Consequences for Migrants who Sell Sex’. Sexuality Research and Social Policy,
doi: 10.1007/s13178-018-0338-9.
Walklate, S. and Fitz-Gibbon, K. (2018), ‘Criminology and the Violence(s) of Northern
Theorizing: A Critical Examinsation of Policy Transfer in Relation to Violence Against Women
from the Global North to the Global South’, in K. Carrington, R. Hogg, J. Scott and M. Sozzo,
eds, The Palgrave Handbook of Criminology and the Global South, 847-866. Palgrave
Ward, E. and Wylie, G. (2017), ‘Introduction’, in E. Ward and G. Wylie, eds, Feminism,
Prostitution and the State: The Politics of Neo-Abolitionism, 1-12. Routledge.
Weller, S. (2017), ‘Fast Parallels? Contesting Mobile Policy Technologies’, International
Journal of Urban and Regional Research, 41/5: 821-837.
Wemmers, J.-A. (2005), ‘Victim Policy Transfer: Learning from Each Other’, European Journal
on Criminal Policy and Research, 11/1: 121-133.
Wood, A. (2014), ‘Learning through Policy Tourism: Circulating Bus Rapid Transit from South
America to South Africa’, Environment and Planning A, 46/11: 2654-2669.
Wood, A. (2016), ‘Tracing Policy Movements: Methods for Studying Learning and Policy
Circulation’, Environment and Planning A, 48/2: 391-406.
... The Swedish Model criminalizes purchasing sex but refrains from taking punitive measures against the sellers. This model has recently gained traction and has now been adopted by, for example, Ireland (McGarry & FitzGerald, 2019), Northern Ireland (McMenzie et al., 2019), Canada (Krüsi et al., 2014), Israel (Levy-Aronovic et al., 2020) and France (St. Denny, 2017). ...
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Researchers have conducted a lot of research into policies regulating commercial sex. This study is a scoping review aiming to characterize the research field as well as finding research gaps and suggest directions for future research. Nine electronic databases and a key journal (Sexuality Research and Social Policy) were searched using Boolean operators to identify studies containing “prostitution AND policy” or “sex work AND policy” in the title and/or abstract. A total of 3663 studies were identified, and of them, 351 were deemed eligible after duplicates were removed and the title and abstract had been assessed according to the study’s inclusion criteria. The studies on sex work policy were often conducted in English-speaking countries, the majority of which were about streetwalkers, criminalization of sex work, and trafficking policies. Interestingly, few empirical studies were conducted and stigmatization was frequently mentioned. There is an unmet need for studies addressing the lived experiences of sex workers under the Swedish Model, as well as studies about migrant sex workers and studies from Africa, Asia, and Latin America. Researchers should direct additional efforts into understanding the lived experiences of sex workers under the Swedish Model as well as into studies covering Africa, Asia, and Latin America.
... It demands that the governance and regulation of prostitution should adopt an abolitionist position with the stated intention of suppressing demand and ultimately eliminating the 'prostitution' of women. There has been strong criticism of this model from the academic and professional quarters which have questioned the legitimacy of the approach, based on the appeal of an ideological position rather than evidence (Kulick, 2003;McMenzie et al., 2019;Weitzer, 2013). The rise of abolitionist sex work policies is seen as part of broader neoliberal framing of crime and policing, immigration and border control (Jahnsen & Skilbrei, 2018;Ward & Wylie, 2017) morality, social order and social engineering (Jordan, 2012). ...
Full-text available
IntroductionVisible spaces of sex work are controversial and contested spaces. This paper explores the relationship between the legal framing of sex work and local policy and how this impacts upon the health and safety of sex workers who use those spaces.Methods This paper is based on data collected from a Winston Churchill Memorial Trust Travel Fellowship in 2016. WCMT Travel Fellowships are granted to front-line practitioners to further develop their area of expertise and integrate best practice findings into the UK. The mission of the WCMT is “go to learn, return to inspire”. Findings are based on observations and ethnographic methods during my travels, which included conducting semi-structured interviews with key informants, attending practitioners group discussions, participating in activist-led conferences and completing observations and journal notes. Using grounded theory data was organised into emerging themes.ResultsThis paper focus on a key finding from the research; the systematic reduction of visible spaces of sex work across Europe. I use the examples and illustration from different cities across Europe to demonstrate how this affects service delivery to sex workers, and I explore some of the impacts on the lived realities of sex workers working in those spaces.DiscussionFindings reveal increasing divisions between those who can work legally and those who cannot. This has resulted in the creation of sex work spaces that are outside of legality, research, health and social support provision.
... Other offences include controlling offences such as 'keeping a brothel, causing or inciting prostitution for gain, controlling prostitution for gain' (Release, 2017: 19). Scotland has a similar approach to England and Wales, but Northern Ireland differs as during the 2010s its Assembly emulated aspects of the 'Swedish model' by criminalising all instances of sex buying, while soliciting and loitering are not directly criminalized (McMenzie et al., 2019). ...
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With the intensification of calls for social 'impact' from research, there is renewed emphasis on academic-activism as a means to realize social change. But what 'counts' as activism in these visions of academic-activist impact? Drawing on interviews with sex work scholars in the United Kingdom and Aotearoa New Zealand, we examine the borders-and the disruption of borders-between 'traditional' forms of activism and a wider array of more 'minor' practices frequently perceived as too 'ordinary' to claim that label. In doing this, we explore quiet, implicit and everyday forms of activism, arguing that activism is embodied, frequently undertaken by those who do not self-identify as activists, and sits ambivalently within broader institutional drives for research-based 'impact'.
... This may explain why this perspective has only recently gained purchase within criminology and related examinations of crime policy transfer (Newburn et al. 2017, though see McCann 2008 for an exception). Some recent work on crime policy mobilities has, attempted to combine the political science-inspired analysis of different 'policy levels' with mobilitiesrelated concepts of policy assemblages in order to interrogate the dynamic processes of knowledge formation and exchange that drive crime policy mobilisation (McMenzie et al. 2019). Although not identifying explicitly as 'mobilities' scholarship (and certainly not attempting the ambitious goal of 'multi-site ethnography) there have been a small number of studies within the field of crime control policy transfer that have adopted generally interpretivist approaches. ...
Cross-national policy movement in crime control has only recently become the focus of scholarly attention. Research findings suggest, despite appearances to the contrary, that fully fledged policy transfers are rare. In practice, soft transfer (in terms of symbolic dimensions of policy) appears more prevalent than harder manifestations (e.g., the travel of institutions, instruments, and practices). Soft transfers are usually associated with penal policies that have emotive political appeal. Hard transfers are more likely to occur when policies have a strong technical flavor. A number of mechanisms influence policy transfer, ranging from purposive and self-conscious lesson drawing to more imposed forms of policy adoption. A number of factors facilitate or constrain the degree to which policies travel and how they take shape during and after the process, from matters of cultural and political attraction to the activities of policy and moral entrepreneurs. This field of research was once dominated by a focus on the Global North as the site of policy transfer or the source of policy influence, but increasing attention is now paid to circulation and spread of policy models within the Global South and from South to North.
... A concrete example of this approach to policy is what has become known as the Nordic or Swedish model whereby buyers of sex are criminalised while sex workers themselves are encouraged to engage with social services (Vuolajärvi, 2019;McMenzie et al., 2019). The aim of this approach is to 'end demand' as it is argued that it is the preferences of men to use sexual services that drive the development of the sector. ...
... A concrete example of this approach to policy is what has become known as the Nordic or Swedish model whereby buyers of sex are criminalised while sex workers themselves are encouraged to engage with social services (Vuolajärvi, 2019;McMenzie et al., 2019). The aim of this approach is to 'end demand' as it is argued that it is the preferences of men to use sexual services that drive the development of the sector. ...
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Purpose: Assess the impact of online platforms on the sex industry, focussing specifically on direct sex work, and evaluate what approaches to platform regulation is likely to align with the interests of sex workers. Design/methodology/approach: A review of interdisciplinary conceptual and empirical literature on sex work combined with analysis of key issues using a transaction cost framework. Findings: Online platforms generally make sex work safer. Regulation aimed at preventing platforms from serving sex workers is likely to harm their welfare. Research limitations/implications: Regulation of online platforms should take great care to differentiate coercive sex from consensual sex work, and allow sex workers to experiment with governance mechanisms provided by entrepreneurs. Originality/value: The paper demonstrates how a transactions costs approach to market behavior as applied to personal services like ridesharing can also shed light on the challenges that sex workers face, partly as a result of criminalisation, and the dangers of over-regulation.
The recent reform of Irish prostitution law introduced in Part 4 of the Criminal Law (Sexual Offences) Act 2017, which criminalised the purchase of sexual services, is based upon 1999 Swedish legislation in accordance with an approach termed ‘the Nordic model’. The Nordic approach has been subject to criticism from those who argue that laws criminalising sex purchase offend against personal autonomy. This article challenges that criticism, and offers feminist arguments for the reform, which represented a significant turn in the focus of Irish law from a framework based upon prohibition of public nuisance, towards an approach which views prostitution as an inherently exploitative transaction within a gendered context. The author argues that feminist arguments in support of the new Irish law are based upon reconsideration of consent as a legal concept, informed by insights gained through the work of the #MeToo movement on the need to take account of social and economic contexts within which consent is given and choices made.
This paper explores the current approach to the interaction between policing and sex work in England and Wales. It reviews the legal and policy context and outlines current policing guidance and priorities, introducing the Harm Reduction Compass as a mechanism to advance policing policy and optimise operational decision-making. Through critical discussion of occupational culture and reforms in policing, it also assesses how continuity, reliability, and transferability can be achieved across police forces within the existing hostile and outdated statutory framework. The Harm Reduction Compass (HRC) aims to focus policing resources on adult sexual exploitation and crimes experienced by sex workers by decoding the complexities of different individuals’ personal circumstances. This paper proposes a new framework as a model to aid operational policing by triaging different scenarios to reach the most appropriate response. This new model, which identifies autonomy and harm as the most significant indicators, addresses harm and vulnerability holistically and combines policing with public health and community-based approaches; this ensures the pathway to assistance and intervention is an integrated multi-partnership. The HRC is a step forward in progressing police culture around the use of language and in dealing with crimes against sex workers in the most appropriate way.
In the context of on-going debates regarding sex work laws, in most jurisdictions forms of criminalisation continue to dominate. Despite decades of sex workers calling for the decriminalisation of sex work and collectively organising against repressive laws, decriminalisation remains uncommon. New Zealand was the first full country to decriminalise sex work with the passing of the Prostitution Reform Act in 2003, which aimed to improve occupational health and safety. Several empirical studies have documented positive impacts of this framework. However, despite this, neo-abolitionists persistently describe the New Zealand model as a failed approach. This article examines neo-abolitionist knowledge claims regarding the New Zealand model and in doing so unpacks the strategic stories told about this approach, considering the implications for sex work policy making.
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This article examines the so-called “Nordic model” in action. Using feminist argumentation, the model aims to abolish commercial sex by criminalizing the buying of sexual services while not criminalizing the selling, as the aim is to protect, rather than punish, women. Utilizing over 2 years of ethnographic fieldwork and 195 interviews in Sweden, Norway, and Finland, this article argues that in a situation where the majority of people who sell sex in the region are migrants, the regulation of commercial sex has shifted from prostitution to immigration policies, resulting in a double standard in the governance of national and foreign sellers of sexual services. Client criminalization has a minor role in the regulation of commercial sex in the area, and instead, migrants become targets of punitive regulation executed through immigration and third-party laws. Nationals are provided social welfare policies to assist exit from commercial sex such as therapeutic counseling, whereas foreigners are excluded from state services and targeted with punitive measures, like deportations and evictions. My fieldwork reveals a tension between the stated feminist-humanitarian aims of the model, to protect and save women, and the punitivist governance of commercial sex that in practice leads to control, deportations, and women’s conditions becoming more difficult. The article concludes that when examined in action, the Nordic model is a form of humanitarian governance that I call punitivist humanitarianism, or governing in the name of caring. © 2018 Springer Science+Business Media, LLC, part of Springer Nature
Technical Report
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New and expanded overview of the Swedish approach to the prevention and elimination of prostitution and trafficking in human beings. Updated February 24, 2018.
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This paper concerns the movement of negative lessons and worst practice in public policy. It focuses on a relatively new branch of scholarship – policy mobilities – which explores the global movement of policies. Within policy mobilities research there is concern about an empirical bias towards successful policies: there has been insufficient attention to whether policy failures might also be mobile. Ideas and concepts about policy failure from political science, economic geography, and science and technology studies are used to illuminate what is missing from policy mobilities scholarship, why it might be important, and to offer some ways forward.
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This edited volume focuses on charting the rise of neo-abolitionism and offering a critique of the idea, its logics and consequences. A model of state policy which aims to abolish prostitution through legislation, Neo-abolitionism criminalises the buyer of sex but not the seller. It is currently law in Sweden and other Nordic states and dominates the framing of policy debates in many other Western liberal contexts. Pressure for adoption of this policy has come from radical feminists who understand prostitution and sex trafficking as a form of violence against women. This volume argues that this convergence between radical feminism and state’s interests arises from the emergence of, on the one hand, ‘governance feminism’ which seeks to have its ideals implemented through ‘top-down sovereigntist means’, and on the other hand, state’s interests in legitimising stricter border controls and law enforcement responses in relation to transnational organised criminality, ‘illegal’ migration, and security. Based around a series of country case studies each chapter will explore the politics surrounding the emergence of neo-abolitionism and its trajectory through those polities, whether the paradigm has been adopted, rejected or is still under debate. The volume will be of great interest to students and scholars of Social and Public Policy, Gender and Women’s Studies, Politics and International Relations and Critical Legal Studies/Criminology.
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The study of ‘policy transfer’ has been subject to sustained criticism, in particular by critical policy studies scholars. This critique - together with the rather marginal role that policy transfer research has played in criminological debates to date - raises questions about the continued utility of such research in scholarly discussions of crime control and penal policy-making. However, we argue here that such studies can enhance our understanding of the local, national and global influences over crime control policy formation. In particular, the developing interest in comparative criminology, in the political economy of punishment, and in the ‘proximate causes’ of penal change, are all areas to which this work can make a useful contribution. Although we feel that some elements of the critique are over-stated, the critical policy studies notions of ‘mobilities’ and ‘assemblages’ offer important advances that capture more fully the complexities of the processes involved in the cross-national movement of penal policy.
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Vällingby – one of the first post-war suburbs in Stockholm – became a well-known and much visited development, a prominent place in the geographical imaginations of many planners and architects during the 1950s and 1960s. This article will consider the ways in which Vällingby was ‘showcased’ to planners and architects outside of Sweden during this period. It will demonstrate how this was achieved through three practices in particular: (1) the hosting of visitors to Vällingby; (2) the promotion of Vällingby by those governing and marketing the development; and (3) the reporting of the development in English language planning and architect journals. In so doing, the article will speak to the academic literature on policy mobilities and two important concepts within it: informational infrastructures and the extrospective city. Keywords: suburbs, post-war planning, policy mobilities, study tours, exhibitions, Stockholm
Deleuze and Guattari discuss the rhizome as being "absolutely different from roots and radicles" 6. The rhizome is explained via principles. 1 and 2: connection and heterogeneity.: "any point of a rhizome can be connected to anything other, and must be". Principle 3: "Principle of multiplicity" "There are no points or positions in a rhizome, such as those found in a structure, tree, or root. There are only lines". Principle 4: "Principle of asignifying rupture" "There is a rupture in the rhizome whenever segmentary lines explode into a line of flight, but the line of flight is part of the rhizome." Principles 5 and 6: Principle of cartography and decalcomania: Where traditional thought is 'tracing', a rhizome is a map. Tracing involves laying onto reality the pattern of structure, itself a construct. "The map does not reproduce an unconscious closed in upon itself; it constructs the unconscious". They take the term plateau from Gregory Bateson, it refers to a sustained intensity. "We call a 'plateau' any multiplicity connected to other multiplicities by superficial underground stems in such a way as to form or extend a rhizome". "Write with slogans: Make rhizomes, not roots, never plant!"
This chapter considers the implications of the violence done by the criminological embrace of Northern theorizing for the questions of policy transfer deemed to address violence against women. This focus is adopted in recognition of the significant policy activity introduced in this area in recent years, both within and beyond the global South. Australia, a key criminal justice jurisdiction within the global South, has looked largely beyond its own borders to interventions introduced in the North when determining new directions for policy targeted at the prevention of and responses to violence against women. This chapter examines the consequences of this gaze with a specific focus on pro-arrest policies and domestic violence disclosure schemes.
The Swedish Sex Purchase Act has sparked considerable interest and debate internationally since it was introduced in 1999. This chapter describes and contextualizes the political process preceding the introduction of the Swedish Sex Purchase Act. We then describe its implementation and existing knowledge and assessments of its consequences. One key point is that analyses of legislation in the field of prostitution must consider the relationship between the expressed intentions of the law, the formulation of the law, and how the law is implemented. Legal measures are taken based on specific agendas, but their symbolic value and implications are transformed by the way in which the criminal law interacts with other policy domains. With the Swedish Sex Purchase Act, there has been an interaction between the feminist abolitionist agenda, which was the original basis for the policy, and other agendas. Laws are not made once and for all but are continually revised and readily appropriated by new aims, agendas, and actors.
This article extends recent examinations of incomplete or disrupted policy mobility by examining the politically volatile case of policies to manage the regional impacts of decarbonization in Australia. The article's extended case study shows how political interests differently incorporated figments of circulating policy into longstanding debates and how more-than-local political networks defeated an antipolitical, technocratic exercise in ‘new regional’ governance. ‘Follow the policy’ methods could not have revealed the complexities of this case. The article concludes that mobilities approaches need to be more attentive to institutional arrangements, to the contested politics of policy formation and to the ambiguities of perceived policy likenesses. This case highlights the importance of considering how antipolitical institutional architectures facilitating policy mobility relate to established political power networks.