Looking for Victims, Finding Migrants: The Realities of the Nordic Model

The so-called 'Nordic Model', which criminalises the purchase of sex, is often mooted as a solution to women's oppression. But does it work? Anastasia Diatlova offers a view from the Nordic countries.

10 min read

Another one joins the fray. Not content with her Private Members’ Bill on Sexual Exploitation (currently awaiting its second reading), Diana Johnson MP has called for an amendment to the reactionary Police, Crime, Sentencing and Courts Bill. Her aim? To bring the so-called ‘Nordic Model’ approach to sex work to Britain (a version of the model is already operational in the North of Ireland).

According to Johnson, the UK is just too appealing as a destination for traffickers. Apparently, all those anti-trafficking and anti-exploitation laws already on the books—with some of the harshest maximum and actual sentences in Europe—are just not enough to stem the tide. Trafficking, she claims, takes place in the UK “on an industrial scale” (Hansard col.887), and the Nordic Model is the only way “to bust the business model of sex trafficking” (Hansard col.888).

The fact that the Sex Worker Advocacy and Resistance Movement (SWARM) and Amnesty International, as well as sex workers and their allies across the UK all oppose the Nordic Model does not seem to be enough to dissuade its advocates from their mission. For them, it is quite simply the best and most humane way to support and protect sex workers, and women more broadly.

But my research, conducted in Finland (where I live) between 2014 and 2016, suggests otherwise. During my PhD, I interviewed a number of Russian-speaking women engaged in commercial sex, and conducted fieldwork in various clubs where sex workers looked for clients. My findings, particularly when brought together with similar research from Norway and Sweden, strongly suggest that the Nordic Model causes actual harm to those it claims to protect. Here, I draw on my research to offer a perspective from the Nordic countries—one that is informed not by government commissions, but by the actual experiences of sex workers.

What is the Nordic Model?

The Nordic Model, also known as the Swedish Model, criminalises the purchase of sex (and by extension, the client) while, at the same time, decriminalising the sale of sex. At the time of writing, the model has been implemented in full in Sweden (where it originated in 1999), Norway, Iceland, France, Ireland (including the North), and Canada. Here in Finland, its implementation is partial: the purchase of sex from those who have been pimped or trafficked is illegal, but ‘private’ transactions between individuals remain legal.

Usually, the stated goal of the legislation is to end demand and eventually eradicate commercial sex altogether, which would purportedly have a positive effect on gender equality. The idea behind this approach is that sex work is harmful to women. It is harmful to women who sell sex, because commercial sex is a supposedly a form of sexual abuse (in her speech presenting the Sexual Exploitation Bill, for example, Diana Johnson repeatedly equates all commercial sex with trafficking and rape). And it is harmful to women who do not sell sex, because, supposedly, it contributes to objectification and devaluation of all women. I use the word “women” here quite deliberately, as proponents of the Nordic Model hardly ever acknowledge that anyone other than cis women might be engaged in sex work (with trans women occasionally blipping in and out of their conversation).

Let us get the obvious question out of the way. The criminalisation of clients supposedly reduces the levels of sex work. But is this actually the case? The answer is far from simple: it’s hard to say; but probably not. Evaluating levels of increase and decrease in something as diverse and as amorphous as sex work is difficult at the best of times, and much harder when legality and personal safety are thrown into the mix. The results from Sweden are inconclusive,1 suggesting only that it does not seem like the levels of commercial sex have increased since the passing of the law.

The ‘decriminalisation’ part of the model is nothing more than a legal fiction.

So there isn’t much evidence to bear out the assertions of NM advocates, and what evidence there is seems questionable. We do, however, have ample evidence that the law has caused serious and substantial harm to those it purports to protect. We do, however, have ample evidence that the law has caused serious and substantial harm to those it purports to protect.

First of all, the ‘decriminalisation’ part of the model is nothing more than a legal fiction. In the countries that have implemented the Nordic Model, the act of selling sex may itself be decriminalised, but all the surrounding activities— renting spaces, soliciting, advertising, living with other sex workers, offering support for sex work—are still illegal. So, while it may technically be legal to sell, it is impossible to do so in practice without falling foul of the law. In the Nordic countries, this has led to sex workers having difficulties renting flats,2 being forced into exploitative rental arrangements,3 being evicted,4 and being unable to work together.5

One of the women I interviewed for my research told me of her experiences of being “rescued” while working in a Nordic country. The police arrived at her hotel room, announced that she was a “victim”, paraded her in front of the hotel staff, and promptly left her, alone and unsupported, on the streets of an unfamiliar city at night. Needless to say, the money she had paid for that hotel room was not returned to her. In the North of Ireland, sex workers who choose to live and work together for safety have been arrested on suspicion of ‘brothel-keeping’, and even accused of being one another’s ‘pimps’.6 This approach is not dissimilar to how some states in the US deal with the question of abortion: rather than criminalising it outright, they instead impose more and more restrictions, making it virtually impossible, and therefore de facto illegal.

The anti-migrant realities of the Nordic Model

For all the proponents of the Nordic Model like to invoke the image of the exploited, vulnerable migrant woman, the model’s supposed decriminalisation does not extend to migrant sex workers. In fact, anti-purchasing laws often work in tandem with anti-immigration laws, allowing authorities to deport migrants for selling sex. Sex work is often one of the few jobs open to migrants; it is also one of the better ones, in terms of pay. In Sweden, Norway, and Finland, non-EU/EEA citizens face deportation and denial of entry if they are suspected of selling (or intending to sell) sex. These laws effectively give the police more power to surveil and harass sex workers, all while claiming that this surveillance is ‘protection’. In Finland, this has led to police going after women whom they perceive to be migrants, regardless of their citizenship status. And the threat of harassment and deportation has made sex workers from migrant backgrounds even more wary of the police; many now try to avoid encountering them at all costs.

One worker told me of how she was detained while working in a Nordic country and sent to a detention centre as an “illegal migrant”—despite being an EU citizen. She was held there for a week before being deported. The perceived dangers of commercial sex seem to easily trump citizenship rights. This is hardly surprising, as the campaign against trafficking is often just a campaign against migration by another name. In fact, the Swedish cultural anthropologist Don Kulick has argued that the introduction of the Nordic Model in Sweden was driven by anxieties over the expansion of the European Union and the migration from the former Soviet Union:

During the two years leading up to the country’s referendum in 1994, the press was filled with reports warning that eastern European women were poised to invade the country. ‘A new form of prostitution is spreading in Europe’ announced an article in Dagens Nyheter, the country’s largest daily newspaper (circulation c. 380,000 daily), in early 1993.7

Similar arguments have been made regarding the enactment of the Nordic Model in Norway,8 and the expanding regulation of commercial sex in Finland.9 A legal model rooted in moral panics over migration cannot protect migrant workers.

The campaign against trafficking is often just a campaign against migration. A legal model rooted in moral panics over migration cannot protect migrant workers.

Criminalisation doesn’t work

A mounting body of research is showing that the criminalisation of clients makes sex workers less safe.10 Sex workers have to worry about protecting the clients from the police, instead of focusing on their own safety. This leads to hurried negotiations, inability to run background checks, and work in unsafe locations. “The law [in Sweden] has failed,” write Jay Levy and Pye Jakobsson; “Furthermore… the law has resulted in increased dangers.”11 In my own research, the workers with whom I spoke repeatedly said that they preferred working in Finland over other countries because the clients were notably more polite, respectful, and law-abiding. The quality of clients has a direct effect on how safe and comfortable sex workers feel, and how well they can negotiate prices, services, and boundaries.

A key claim of the Nordic Model Now campaign is that criminalising the purchase of sex will lead to a decrease in violence against women. While there is no clear evidence that criminalising demand has any positive effect on societal attitudes towards women, there is evidence that it has a negative and stigmatising effect on attitudes towards sex workers.12 The stigma associated with commercial sex negatively affects the physical and mental wellbeing of sex workers. Criminalisation of demand exacerbates this stigma, not only by continually framing paid sex as something criminal and shameful, but also by forcing sex workers to constantly work on convincing their clients that they are not victims.

Either you always love your job, or you're a victim. Under the conditions of capitalism, this seems like a high bar for any form of work.

During my research, one worker related, with some bitterness, how angry she felt when clients asked her whether she had been trafficked. She did not think she looked like a victim at all—and certainly she didn’t feel like one. This puts enormous amount of pressure on sex workers to appear happy and content with their work in order to distance themselves from the stigma of victimhood. An experience as simple as a bad day at work becomes impossible under these conditions: either you always love your job, or you’re a victim. Under the conditions of capitalism, this seems like a high bar for any form of work, let alone one subject to these sorts of pressures.

The Nordic Model creates conditions which make building worker solidarity difficult, if not impossible.

Client criminalisation also has a negative effect on worker solidarity. When demand is driven down, sex workers are forced to compete for scarce clientele, and may feel less empowered to refuse work for safety reasons. This leads not only to pressure to put oneself in danger in order to secure a client,13 but also increases competition and erodes unity and solidarity. This erosion of unity may hamper collective struggle towards actually improved living and working conditions. Solidarity is a crucial component of any liberatory workers’ movement—the Nordic Model creates conditions which make building solidarity difficult, if not impossible.

As for Johnson’s call for “provision for support services for victims of sexual exploitation”—such legal provisions exist in Norway, Sweden, and Finland, and yet there is no indication that they work in any meaningful way. This is primarily because the majority of the people selling sex in these countries are migrants, and are thus not eligible for state support. Yes, the support exists in theory, but most people who may want it cannot claim it. In many cases, migrant sex workers who ask for state assistance can expect nothing more than a one-way ticket “back home”.14 Furthermore, it is not clear why providing this support needs to be conditional upon client criminalisation. If the state is keen to provide support services for sex workers, and exit strategies to those who wish to leave commercial sex, surely it can do so without any additional caveats or conditions.

Finally, and crucially, the enactment of the Nordic Model would be particularly callous in the midst of a pandemic. Sex workers have already been hit hard by lockdown restrictions. Client criminalisation would do nothing but push people further into poverty and precarity, even as the already-remote possibility of other forms of income is severely limited.

It is not clear why providing support for sex workers needs to be conditional upon client criminalisation.

People, not symbols

So, what does all this tell us? A growing body of research from the Nordic countries, where client criminalisation has been in effect for a while, clearly shows that the Nordic Model has an adverse effect on the lives of sex workers, especially migrant sex workers. While the symbolic value of this legislation may win some political points for its proponents, it will do real harm to real people, many of whom are already in precarious situations. Moreover, if it is indeed tabled as an amendment to the PCSC Bill, it risks ‘purplewashing’ one of the most authoritarian and repressive pieces of proposed legislation in recent memory.

The Nordic Model simply isn’t worth it.

  1. Jay Levy, Pye Jakobsson. 2014. ‘Sweden’s abolitionist discourse and law: Effects on the dynamics of Swedish sex work and on the lives of Sweden’s sex workers’. In Criminology & Criminal Justice 14(5): 593–607. 

  2. Anastasia Diatlova. 2018. ‘Conceptualisation of home among Russian-speaking women engaged in commercial sex in Finland’. In Gender, Place & Culture 25:1, 61-79. 

  3. Niina Vuolajärvi. 2019. ‘Governing in the Name of Caring—the Nordic Model of Prostitution and its Punitive Consequences for Migrants Who Sell Sex’. In Sexuality Research and Social Policy 16: 151–65. 

  4. Levy & Jakobsson (2014). 

  5. Levy & Jakobsson (2014). 

  6. Susann Huschke. 2017. ‘Victims Without a Choice? A Critical View on the Debate About Sex Work in Northern Ireland’. In Sexuality Research and Social Policy 14: 192–205. 

  7. Don Kulick. 2003. ‘Sex in the New Europe’. In Anthropological Theory 3(2): 199–218. 

  8. May-Len Skilbrei. 2012. ‘The Development of Norwegian Prostitution Policies: A Marriage of Convenience Between Pragmatism and Principles’. In Sexuality Research and Social Policy 9: 244–57. 

  9. Sirpa Tani. 2002. ‘Whose Place is This Space? Life in the Street Prostitution Area of Helsinki, Finland’. In International Journal of Urban and Regional Research 26: 343–59. 

  10. Vuolajärvi (2019). 

  11. Levy & Jakobsson (2014). 

  12. Jari Kuosmanen. 2011. ‘Attitudes and perceptions about legislation prohibiting the purchase of sexual services in Sweden’. In European Journal of Social Work 14(2): 247-63. 

  13. Levy & Jakobsson (2014). 

  14. Vuolajärvi (2019). 


Anastasia Diatlova (@AnastasDiatlova)

Anastasia Diatlova is a postdoctoral researcher at the University of Helsinki. She is currently working on a project on Finnish and migrant men and gender-nonconforming people selling sex in Finland. Her PhD was a multi-sited ethnographic research on Russian-speaking women engaged in commercial sex in Finland. She was part of Dr. Lena Näre’s Insecure Lives: Irregular Migration and Precarious Labour in Finland (INSECURE) project. Her research interests include migration studies, gender and sexuality, sex work, and sex workers’ labour rights.