Introduction

Within contemporary global debates on sex work laws, clients of sex workers are a central focus. While punitive legislation used to regulate the sex industry has a long history of targeting sex workers, policy makers are now increasingly directing their attention to clients as the targets of criminalisation. As Sanders (2008) explains, ‘there has been a repositioning of men who buy sex as the problem’ (p 135). That is, clients of sex workers are increasingly being depicted as sexual abusers, and the abolitionist feminist perspective that sex work is a form of male violence against women appears to have gained more support (Bernstein, 2007; Coy et al, 2019). As such, policy makers in many countries have opted to enact new laws which criminalise the purchase of sex, including Sweden in 1999, Norway and Iceland in 2009, Canada in 2014, France in 2016, Northern Ireland in 2015, and the Republic of Ireland in 2017 (Serughetti, 2012; Arisman, 2019; Calderaro and Giametta, 2019; Coy et al, 2019; McMenzie et al, 2019). This approach is often referred to as ‘the Swedish model’ – owing to its initial adoption in Sweden – and also ‘the Nordic model’ since versions of it have now been adopted in several countries in the Nordic region. As noted by McMenzie et al, (2019), between 2012 and 2014, Northern Ireland's Democratic Unionist Party campaigned to introduce client criminalisation through drawing on Sweden as a source of inspiration and as a country to be learnt from and emulated. Likewise, when sex work regulation was debated in France during 2011, a key report presented to the National Assembly for parliamentary debate argued that the onus for sex work should be located with clients, as their demand for paid sexual services fosters exploitation and trafficking (Calderaro and Giametta, 2019). Sanders and Campbell (2014) have further noted that the political agenda in the United Kingdom is beginning to mirror this trend, with some politicians clearly influenced by the Swedish model and the discourse of client criminalisation.

Sanders (2008) proposes that there are separate processes contributing to the increased popularity of client criminalisation.