Criminological policy mobilities and sex work:
Understanding the movement of the ‘Swedish model’ to Northern Ireland
Laura McMenzie, Ian R. Cook and Mary Laing
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;
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
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;
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
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