David Gray / Reuters An Australian police official inspecting a pile of about 4,500 prohibited firearms that had been handed in over the past month under the Australian government's buyback scheme in in Sydney on July 28, 1997

Gun-control advocates in the U.S. are hoping 2012 marks a turning point in the country’s struggle with gun violence. The massacre at Sandy Hook Elementary — where most of the 26 victims were killed with an assault rifle similar to the M-16 rifle issued to U.S. soldiers — might spur Washington lawmakers into action following a year of grisly, tragic mass shootings. There are now calls to reinstate a federal ban on assault weapons; the weeks ahead may see a heated debate over the long-enshrined place of guns in American society.

In other words, 2012 may be the watershed moment 1996 was for two countries that have shared histories and bonds with the United States. Separate mass shootings 16 years ago in the U.K. and Australia prompted soul-searching, anger and a rapid political response in both London and Canberra. Anti-gun legislation passed then, say many experts, has had a lasting, positive impact in both countries.

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In an attack not dissimilar to what took place at Sandy Hook, a shooter burst into a gymnasium of a school in the Scottish town of Dunblane on March 13, 1996, and turned his four handguns on a group of unsuspecting 5- and 6-year-olds assembled there. Sixteen children and one teacher were killed; the gunman, a deranged unemployed shopkeeper, then turned his weapon on himself. Among the dazed pupils forced to take cover during the assault was British tennis champ Andy Murray, then 8 years old. The outcry in the U.K. was immense. “We must take this as a warning that we are becoming like America and act before it is too late,” said one governing Conservative Party legislator, quoted by TIME.

What followed was a drastic overhaul of existing British gun laws by the sitting Tory government. The Christian Science Monitor sums up the changes:

a ban on handguns and automatic weapons, as well as an onerous system of ownership rules involving hours of paperwork, criminal reference checks, and mandatory references designed to reduce as far as possible the likelihood of guns falling in the wrong hands.

Despite a surge in gun-related offenses in the early 2000s, the past seven years in the U.K. have seen successive drops in gun crimes — a consequence, some argue, of the country’s tougher laws on gun ownership. Of course, such measures aren’t enough to wholly prevent mass killings. In 2010, a taxi driver with a shotgun and a rifle cruised around the idyllic Lake District of Cumbria, northern England, killing a dozen people in a shooting spree that shocked the country. The shooter had no history of mental problems and his guns were legally owned and licensed.

On the other side of the world, just a month after the 1996 Dunblane attack, a shooter in the town of Port Arthur, Tasmania, went on a rampage, killing 35 people in what is the worst single episode of such slaughter in Australian history. The then months-old old government of conservative Prime Minister John Howard — who would go on to rule for over a decade — initiated a sweeping set of reforms, even in the face of opposition from allies in Australia’s right wing. The new measures banned the sale and possession of all automatic and semiautomatic rifles and shotguns. Moreover, the government instituted a mandatory buyback scheme that compensated owners of newly illegal weapons. Between 1996 and ’98, some 700,000 guns were retrieved by the government and destroyed. The results have been tangible: A widely cited 2010 study in the American Journal of Law & Economics showed that gun-related homicides in Australia dropped 59% between 1995 and 2006. The firearm-suicide rate dropped 65%. There has been no mass shooting in Australia since the Port Arthur attack.

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Americans often argue that their country’s unique political culture and ubiquity of gun ownership make similar anti-gun measures unthinkable. The 700,000 firearms Howard’s government retrieved from its citizenry was a fifth of the total possessed by Australians at the time — in the U.S., that equivalent figure would mean confiscating some 40 million to 50 million guns.

Yet while the scale is vastly different, the politics ought not be. Like the U.S., Australia is a frontier society built on a rugged, pioneering individualism. It has its own mythic Wild West gunmen. The rhetoric of freedom and liberty is as often voiced by an Australian politico as it is by an American one. And Howard, a close friend of President George W. Bush and a cheerleader of the much maligned invasion of Iraq, was no socialist peacenik.

But, in the wake of the mass shooting in Aurora, Colo., earlier this year, Howard, a staunch conservative, voiced a criticism seemingly still too subversive for Washington. Writing in the Age, he took issue with the American devotion to the Second Amendment:

The Second Amendment, crafted in the immediate post-revolutionary years, is more than 200 years old and was designed to protect the right of local communities to raise and maintain militia for use against external threats (including the newly formed national government!). It bears no relationship at all to the circumstances of everyday life in America today. Yet there is a near religious fervour about protecting the right of Americans to have their guns — and plenty of them.

It remains to be seen what lasting change emerges out of the tears and heartbreak in Newtown, Conn., but at the very least the tragedy ought prompt a real conversation — as it did in these two other Anglophone nations — about how much carnage a society is willing to take.

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