Although it emerged out of anti-trafficking rhetoric, the end-demand campaign is actually a movement to change prostitution policy from our current legal framework — the criminalization of both buying and selling sex — to the “Swedish model,” in which selling sex is not illegal, but buying sex is a criminal offense. (Two other models exist: full legalization with government regulation and registration of sex workers, as in the Netherlands, and full decriminalization of both buying and selling sex with minimal state oversight, as in New Zealand.)

Based on an appealing, proactive vision of gender justice, the Swedish model has caught on in Iceland and Norway — even though it hasn’t panned out as planned in Sweden, where street-level prostitution dropped temporarily after the law took effect in 1999, only to climb again. Sweden’s sex workers say they are forced to rush negotiations and have to rely more on intermediaries to access wary clients. Prostitution hasn’t gone away; it’s simply gone underground.

Translating Swedish laws into an American context presents even more problems. America lacks the extensive services of Sweden’s social welfare state, which are vital to anyone leaving the sex trade. And American politicians don’t want to be seen as soft on crime or morally lax, making it unlikely that selling sex could ever be decriminalized here.

In this environment, any uptick in law-enforcement actions aimed at buyers inevitably results in increased criminalization of those selling sex. New York City’s “Operation Losing Proposition” earlier this year resulted in nearly 200 arrests; the operation allegedly targeted the demand side of prostitution, but it netted 10 individuals who sell sex as well. Attempting to implement the Swedish law in our punitive environment would most likely mean the criminalization of even more of those it’s intended to help — without a Scandinavian-style safety net for those leaving the life.

“You will see that in any country, when you criminalize both parts, the police go for the women,” said Kasja Wahlberg, a Swedish detective and the country’s rapporteur on human trafficking. According to Meagan Morris, a Colorado researcher who has studied law-enforcement approaches to prostitution, even so-called “victim-centered” approaches disproportionately hurt women, leaving them more vulnerable to trafficking and exploitation because they have criminal records, which limit their access to affordable housing and sustainable-wage jobs.

End-demand strategies could also lead to more pressure on sex workers from pimps and traffickers. “Pimps don’t accept the rationale that there’s a new law and fewer johns now,” said Paul Holmes, a counter-trafficking expert and former Scotland Yard official. “So if a girl is working 16 hours, she’ll have to work 20, and under more brutality. You’ll also drive the trade underground, which makes it more dangerous for them and more difficult for us.”