Over the last 30 years, the governments of various Western democracies have made significant changes in their approach to managing prostitution. However, little consensus exists on the most appropriate legislative response. In various countries, attempts to adopt a new legislative approach (whether to enact or repeal criminal penalties) have sparked fierce controversy. Though the similarities between these legislative approaches are not always immediately apparent, all of them express the aims of both protecting the health and safety of sex workers, and preventing their exploitation by pimps or clients. This paper reviews the key legislative approaches to prostitution in a number of Western jurisdictions (Australia, New Zealand, the Netherlands, Sweden, United Kingdom and the United States). In particular, it examines the specific laws and/or regulations these countries and states have instituted, and it discusses how they appear to have fared in meeting their objectives.
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