Living the law: An ecological analysis of NGO responses to sex work governance

Abstract

This article analyses the criminalisation of sex work as an ecological system of governance, sustained not only through statutory law but also through institutional mandates, funding logics, and cultural ideologies. Drawing on interviews with NGO practitioners in the United Kingdom and United States, and using ecological systems theory, we show how criminalisation operates through networked institutional relations. NGOs, as meso-level actors, mediate between sex-working clients and carceral systems, navigating data-sharing mandates, safeguarding protocols, and exclusionary eligibility rules. We introduce the concept of ‘cascading vulnerability’ to capture how these interactions can compound risk across ecological levels. Addressing structural exclusion requires engaging the broader architecture of governance, not statutory law alone.

Introduction: NGOs at the fault line of criminalisation

In both the United Kingdom and United States, sex work is criminalised to varying degrees – fully in most U.S. jurisdictions and partially in England, Scotland, and Wales, where selling sex is legal but related activities (e.g. brothel-keeping, soliciting) are not, and in Northern Ireland, which adopted the Nordic Model by criminalising clients in 2015 (Ellison, 2017). Here, we use the term ‘criminalisation’ to refer to regulatory systems that criminalise some or all aspects of sex work. NGOs and other intermediaries play a critical but under-theorised role in the governance of sex work. Often positioned between punitive legal regimes and vulnerable communities, these diverse organisations provide essential services, advocate for change, and mediate access to housing, healthcare, and justice. A substantial body of literature has examined the role of NGOs in reinforcing carceral approaches to sex work, particularly through anti-trafficking interventions that conflate protection with surveillance and control (Agustín, 2007; Bernstein, 2010, 2018; Chuang, 2014; Mai, 2009; Musto, 2016). In contrast, the organisations in our study engaged with sex workers through multiple frameworks rather than exclusively through an ‘anti-trafficking’ frame: some had a sex worker affirming focus, while others had more episodic engagement through adjacent issues such as intimate partner violence, substance use, health, housing insecurity, or criminal justice contact. Across this spectrum, NGOs were tasked with providing support while operating within structurally incoherent and often contradictory governance environments.

The aim of this article is to demonstrate that NGOs do not merely observe the effects of law; they live them. Criminalisation is experienced not only through statute, but through welfare eligibility criteria, safeguarding duties, data-sharing agreements, policing vagaries, funding mandates, and entrenched occupational stigma. In the discussion that follows we approach criminalisation as a socio-legal condition produced through dispersed institutional practices, rather than as a property of statute alone. Drawing on Ecological Systems Theory (EST) (Bronfenbrenner, 1979; Bronfenbrenner and Morris, 2006; Neal and Neal, 2013) we trace how criminalisation manifests across various points in the ecological system.

EST: Networked systems and the provision of care

EST, originally rooted in developmental psychology (Bronfenbrenner, 1979) has since been adapted across fields and disciplines including health, education, law, and organisational sociology (Doughty and Moore, 2021; Frohlich et al., 2018; Snyder and Duchschere, 2022; Tong and An, 2024). Graphically, EST is often depicted as a series of concentric circles, resembling a Russian matryoshka doll, in which each ecological system is nested within progressively broader contexts (Bronfenbrenner, 1979). In the discussion that follows, these systems are specified in organisational terms: the microsystem refers to frontline service encounters, the mesosystem to inter-organisational coordination, the exosystem to institutional and regulatory environments that shape practice indirectly, the macrosystem to dominant cultural and policy scripts, and the chronosystem to historically sedimented governance logics.

A major reconceptualisation of EST was proposed by Neal and Neal (2013), who replaced the idea of spatial nesting with a social network model. In their view, ecological systems should be understood as ‘networked, where systems at different levels relate to one another in an overlapping but non-nested way’ (p. 723). This reframing allows for a more dynamic reading of how institutional settings intersect, foregrounding social interaction as the connective tissue across ecological levels. Settings are the ‘building block’ of EST (Neal and Neal, p. 727). In the original model, they were physical spaces; in the networked version, they are defined by interaction itself (Neal and Neal, 2013: 727). This reformulation shifts emphasis from spatial proximity to relational patterning, allowing settings to traverse ecological levels. Micro-, meso-, and exosystemic processes can thus be understood as dynamic, intersecting networks rather than discrete physical containers. Applied to sex work governance, this model reveals how sex workers’ lives are shaped not by law or policy in isolation but through interlocking systems of interaction that entangle care, surveillance, and exclusion. NGOs operate across multiple ecological levels, with each level reflecting configurations of social interaction.

Methodology and ethics

This article draws on data collected between 2023 and 2024 as part of a broader cross-national project examining how legal frameworks shape the experiences of sex working populations (Sanders et al., 2025; Scoular et al., 2023). The project combined surveys and interviews with sex workers, police, prosecutors, and support practitioners in the United Kingdom and United States. The discussion here is based specifically on interviews with NGOs and non-profit organisations in both jurisdictions. Eligible organisations were limited to those with direct experience of sex work, either through service provision or through statutory partnership, which significantly reduced the potential pool. In total, 14 practitioners were interviewed across participating NGOs in the United Kingdom and six practitioners from non-profit organisations in the United States. In most cases a single practitioner represented each organisation, although some organisations were represented by more than one participant. Specific organisational counts are not reported in order to protect anonymity within a relatively small field.

U.K. respondents were drawn from organisations operating across multiple regions of the United Kingdom. U.S. respondents were based in a local jurisdiction where sex work was criminalised apart from that which occurred in licenced brothels. Most of their clients – though not all – were involved in criminalised sectors, and none of the interviewees worked exclusively within legalised zones. Both the U.K. and U.S. samples reflect the variety of roles performed by NGOs within this specialised sector. This is not a direct comparative study, though some examples from the United States are included to illustrate how similar pressures emerge in differently structured systems. The project received ethical approval from the relevant institutional review boards and university ethics committees. Interviews were conducted in person or via secure video, in accordance with university protocols. Each lasted 60 to 90 min and was recorded with consent. Some NGOs have quite fractured relationships with statutory authorities and for this reason all respondents are anonymised and identifying details such as city, region or job role are omitted. Quotations are drawn directly from transcripts and lightly edited for clarity. Participating organisations are identified using generic descriptors such as ‘U.K. NGO’ or ‘U.S.-based practitioner’.

Analysis proceeded in two stages. Interview transcripts were first coded inductively to identify recurring themes in practitioners’ accounts of service provision, institutional constraints, and interactions with other agencies. These themes were then organised through the analytic lens of EST, allowing patterns in the data to be examined across micro, meso, exo, macro and chronosystemic levels.

Findings: The ecological dimensions of sex work governance

This section presents the key empirical findings, organised through the ecological systems framework developed by Neal and Neal (2013). Drawing on interviews with NGO practitioners across the United Kingdom and United States, we examine how sex work governance is experienced and negotiated at five interconnected levels: the micro-, meso-, exo-, macro-, and chronosystems. These networked domains reveal how criminalisation is enacted not only through formal law, but through institutional logics, professional discretion, and inherited moral imaginaries. While each system is discussed individually for heuristic clarity, in practice – and consistent with the EST framework – they operate in overlapping and interacting ways.

Microsystem: The politics of frontline encounters

In EST, the microsystem refers to the immediate settings where individuals engage in direct, face-to-face interactions, which for sex workers may include outreach meetings with NGO practitioners, healthcare providers and law enforcement. These interactions are critical, constituting the first point through which broader systems of governance are experienced.

The cost of disclosure

NGO practitioners consistently reported that sex-working clients faced disbelief, judgement, or degraded care after disclosing their occupation to statutory agencies. These accounts echo prior research showing how healthcare providers often question sex workers’ credibility and reduce care quality once their occupational status is known (Lazarus et al., 2012). One U.K. respondent noted how trauma was treated as an expected consequence of sex work, with ‘exit’ framed as a prerequisite for healing:

Medical professionals such as nurses particularly in hospitals [are] saying to people it's their fault that they’re there because of the work that they do…. (003UK010)

A U.S.-based therapist described a pattern of informal exclusion whereby health practitioners quietly discontinue treatment or refer them to another practitioner:

And it's always the same thing. [The sex worker tells me], I was working with someone and then they ask me what I do, and I tell them, and then before you know it, within three days I have an email from them saying, “Hey, I’m going to refer you out to a specialist” … It's either because the provider themselves is insecure about it or doesn’t want to deal with it. (003US02)

A similar concern was raised by a U.K.-based support worker, who described how a male sex worker disclosed sexual violence during a therapy session, only to be met with the response: ‘I don’t know what to say to you, it is such a big thing’ – a moment that left him uncertain whether the therapist possessed the capacity or willingness to support him appropriately (004UK04).

Police encounters followed similar patterns. One U.S.-based NGO worker recounted accompanying a client to a police station to report an assault:

We waited in a room for hours and that guy, he was like, ‘So what were you doing?’ And she was in a parking lot of a strip club, and she had left work and then was assaulted in her car. And that guy goes, ‘Well, were you still technically on the clock?’ – like he didn’t even understand the difference between consent and coercion in that situation. And nothing happens. (004US02)

These responses go beyond individual prejudice to reflect institutional assumptions of sex workers as ‘out of place’, too visible, overly sexual, or insufficiently respectable to be recognised as legitimate victims (Estrich, 1987; Munro, 2008). Violence is reframed as a moral consequence, not a rights violation. NGOs often acted as buffers, advocating for clients, translating disclosures into institutional language, or accompanying them to appointments to bolster credibility. But their ability to intervene was limited. These dynamics illustrate how the macrosystemic narratives we discuss later are operationalised through microsystem interactions; what Gilliom and Monahan (2013) describe as the frontline enactment of ideological scripts.

In criminalised or semi-criminalised contexts NGO practitioners at the microsystem level described how even supportive engagements were shaped by institutional mandates and professional discretion, often foreshadowed by macrosystemic ideologies around gender, risk and victimhood (Scoular, 2010; Serisier, 2018). Yet the microsystem is not wholly determined by these forces. Some NGOs developed strategies to resist, reframe or circumvent external pressures, creating small zones of tactical autonomy within tightly constrained environments. As de Certeau (1984) suggests, everyday actors often engage in tactical resistance that pushes back against dominant structures without confronting them directly. Practitioners exercised discretion in how they recorded disclosures, interpreted safeguarding thresholds, or curated narratives to shield clients from institutional risk (discussed further below). While ‘care’ remained a central commitment of all the organisations in our study, they differed in how they responded to the pressures for disclosure and compliance generated elsewhere in the ecological system. The microsystem is thus not only a relational domain but a transmission point through which the wider ecology of criminalisation becomes tangible.

Mesosystem: Intersecting systems, surveillance and the carceral creep of care

In Neal and Neal's (2013) networked model of EST, the mesosystem comprises overlapping settings, such as outreach teams, multi-agency meetings, or support services where interactions occur between microsystem-level actors (e.g. clients, case workers) and exosystemic institutions (e.g. funders, police, statutory agencies).

Multi-agency coordination and cascading vulnerability

Safeguarding frameworks, intended to protect vulnerable people, may institutionalise surveillance when access to care is contingent (Brown et al., 2025; Gilliom and Monahan, 2013; Liberty, 2019). One U.K.-based practitioner explained:

Each week, we have tasking meetings, which involve the police and different agencies - like mental health, drug services. That's a chance for everybody to discuss women who are most at risk and who've been identified sex working on-street the week before … It means we can raise issues we’re concerned about and look at how to improve that support or make sure they're being supported the best way possible. (009UK04).

Although framed as supportive, these meetings reposition sex workers as institutional subjects. What we term cascading vulnerability refers to how disclosures in one system – housing, healthcare, legal services – suddenly spiral and activate scrutiny or sanction in others. Systems may appear discrete but act as a unified surveillance apparatus. A U.S.-based therapist shared clients’ fears:

If I tell my therapist I’m a stripper, are they going to call CPS [Child Protection Services] on me, you know, for leaving my kids all night with a babysitter? … Will they think I’m a bad parent? (001US02)

She added that such fears were not unfounded: ‘I’ve seen and heard of this happening’. Another, U.S. practitioner described the aftermath of a sexual assault disclosure:

[the assaulted sex worker said to me] … I need help because when I reported [a sexual assault] they arrested me as a prostitute, took over my child, placed them in foster care and now I’m trying to get her out of foster care. (004US01)

This pattern – where seeking support triggers punitive state intervention – is well documented in the literature (Lutnick and Cohan, 2009). One U.K. NGO recalled a Romanian woman referred to them due to concerns about sexual exploitation and trafficking. After cooperating with police, her child was removed. Nearly two years later, she gave another statement to police when her alleged trafficker was re-arrested. Her child was again removed, this time based on something she had said in her second statement. As an NGO support worker noted

As long as we continue to rely on women's, or anyone's statements, and as long as we then continue to interact with them as I have just outlined … we’re not going to get very far. (001UK05)

These examples reveal systemic contradiction: victims are expected to cooperate with authorities yet are punished when they do. Rather than isolated incidents, these are patterned effects of institutional entanglement in which care and surveillance are fused.

Immigration enforcement

For migrant sex workers, these dynamics intensify. NGO respondents described how immigration, policing, welfare, and safeguarding interact to amplify surveillance and exclusion. The persistent conflation of trafficking, sex work and irregular migration (Agustín, 2007; Mai, 2009; O’Connell Davidson, 2015) has only deepened as immigration issues have become increasingly politicised. Several U.K. NGOs referenced the ‘overspill effect’ where contact with housing or healthcare could trigger immigration scrutiny. As one U.K. legal advocate warned:

It is quite easy to do harm in this area … there is the fear of having children removed, there being no firewalls between immigration [authorities] and the police, and the perception that they will be treated as the criminal. (001UK05)

In one documented instance, the unexpected appearance of a U.K. immigration official at a sex worker outreach session led to significant organisational tensions, with a respondent noting the administrative fallout between the police and the NGO concerned (001UK02). While the presence of the official at the meeting was intended to explain the U.K. Border Agency's role in migrant sex work it nevertheless signalled how inter-agency collaboration can undermine the very trust relationships such partnerships are meant to strengthen.

Mistrust in institutions leads many migrants to avoid services altogether. As one U.K. outreach worker put it:

If you’re a migrant, are you going to be told to leave the country because of something that has happened to you? Are they [the police] going to get immigration involved? (005UK04)

Another NGO described a migrant sex worker whose baby was taken into care. She had lost residency and had no access to public funds. Because she did not claim to be trafficked, she was ineligible to access any support services. The NGO intervened to stop eviction:

Now she is required to be here because her three-week-old baby is in care, but she has no permission to be here anymore … Although she's not saying she's a victim of trafficking - she's not going to - but she has no access to public funds. (001UK05)

Here, carceral, welfare, and immigration systems converge to exclude those who fall outside recognisable victim narratives. The NGO prevented eviction, but broader support remained inaccessible. This reflects a meso–macro crossover: institutional interactions shaped by macrosystemic scripts of legitimacy, where support is conditioned on narrative conformity rather than need.

Structural disbelief and the governance of credibility

Disbelief in sex workers’ accounts reflects broader macrosystemic ideologies around gender, sexuality, and deviance. Yet its effects play out at the mesosystem level via courtrooms, service assessments, and NGO interactions. Practitioners noted how sex workers were treated as inherently unreliable, unless their accounts were externally validated (Serisier, 2018). As one U.S. advocate explained:

We end up working with the court systems … we’ll go to court and petition and advocate on behalf of the client and use whatever societal weight we have in order to help the client. (004US02)

Others described how sex workers’ disclosures of sexual violence were disbelieved:

I have seen two court cases where I believe that they have been judged and viewed as unreliable witnesses, even though all the evidence was really clear. (001UK05)

As Serisier (2018) argues, victims of sexual violence must conform to narrow scripts – passivity, innocence, pain. Those who do not perform these scripts are often dismissed. Even when sex workers engage through formal statements or risk disclosures, they are disbelieved. Disbelief thus becomes a filtering device: a way to exclude criminalised subjects from justice. NGOs are then tasked with mediating between institutional suspicion and client need. In this light, NGOs are not just intermediaries. Situated at the intersection of overlapping institutional demands, they navigate a dense terrain where care and control are deeply entangled. As Neal and Neal (2013) suggest, the mesosystem is not a neutral space of coordination but a relational zone of tension, where NGOs operate as nodal actors translating, amplifying, and sometimes resisting institutional logics.

NGOs do more than mediate mesosystemic domains; they are embedded in dynamic webs of influence, shaping how resources, expectations and obligations circulate (Doughty and Moore, 2021). Recent legal developments in both jurisdictions have fused social services provision with carceral systems, particularly in the name of combating sex trafficking (Agustín, 2007; Bernstein, 2010; O’Connell Davidson, 2015). In the United Kingdom, Engagement and Support Orders divert those charged with soliciting into behavioural programmes (Carline and Scoular, 2015); in the United States, trafficking courts offer services as an alternative to incarceration. Yet both approaches often reinforce penal-welfare logics, providing care in exchange for compliance (Brown et al., 2025; Carline and Scoular, 2015; Gruber et al., 2016; Sanders et al., 2009). Carceral creep extends through police, health, welfare, and immigration services, which routinely share information (Chuang, 2014; Gilliom and Monahan, 2013; Liberty, 2019). NGOs are not always outside this apparatus. Some respondents reported NGO staff present at police raids to identify trafficking victims or given advance notice of a raid to prepare beds for those ‘rescued’, blurring the distinctions between advocacy and coercion. Rather than neutral intermediaries, NGOs risk becoming conduits for carceral logic under the guise of care, producing a form of conditional care that is uneven, discretionary, and often inseparable from institutional control (Hanks, 2022).

Structured by market logics, NGOs mediate institutional access and provide services while subject to funding conditionalities, safeguarding mandates, and data-sharing obligations. In the United Kingdom, this reflects mixed public–voluntary sector coordination; in the United States, the weaker safety net and stronger police-NGO ties intensify dependency. Some NGOs resist by refusing police collaboration; others replicate exclusion through gatekeeping or alignment with anti-trafficking agendas. In housing, healthcare and social work, service delivery becomes conditional, diagnostic, and disciplinary (Bernstein, 2010, 2018; Musto, 2016). The governance of sex work reflects this trend. Whether rights-based, harm-reductive, or control-oriented, NGOs operate within carceral welfare ecologies.

The exosystem: Institutional design, conditional care and carceral governance

Following Neal and Neal's (2013: 728) networked reformulation, the exosystem comprises institutional settings that do not involve the sex worker directly but whose actors – police, funders, regulators – structure the conditions under which services are delivered. Exosystemic governance often tethers outreach and support services to criminal justice logics, particularly where cuts to welfare and health have pushed NGOs towards carceral state funding streams. These are frequently tied to anti-trafficking initiatives, embedding carceral priorities into service provision. These position clients within a reductive binary: as either criminals needing correction or victims needing rescue. Many practitioners in our study were committed to anti-violence principles; however, some organisations often functioned within or adjacent to carceral structures (Bernstein, 2010, 2018; Rice, 2013). One U.S. domestic violence NGO embedded staff directly within law enforcement:

We also have an advocate. It's our employee, but they’re stationed in the X Police Department … We also have an advocate that's stationed in the City Attorney's Office … they are in contact with a lot of victims that are involved with the legal system and then provide for referrals and information. (011US02)

Elsewhere, carceral entanglement was less direct but no less significant. The United Kingdom's Engagement and Support Orders just mentioned, compel those charged with soliciting for the purposes of prostitution to attend meetings with a court-ordered supervisor (Carline and Scoular, 2015). Participation in such programmes conditions support on compliance with dominant norms around desistance, motherhood, or victimhood; what Carline and Scoular term ‘forced welfarism’. In the United States, specialty courts often function as welfare referral agencies. As Gruber et al. (2016) note, programmes intended to support sex trafficking victims typically operate through prostitution courts, which divert charged sex workers into rehabilitation services, which are funded almost entirely through their ties to the criminal justice system.

In these contexts, NGO support – whether in court advocacy or child custody matters – often hinges on a client's conformity to dominant norms of domesticity, sobriety, and rehabilitation. One NGO representative described needing to vouch for clients’ moral reform to secure assistance, inadvertently reinforcing carceral narratives of redemption and risk (Hanks, 2022; Serisier, 2018; Shih, 2023). What begins as advocacy becomes a form of institutional gatekeeping where access to help depends less on rights than on perceived compliance.

Housing policy illustrates how this gatekeeping plays out. In the United States, one NGO described statutory exclusions:

So, there are laws, like we have a law in [state] that actually will stop you potentially from getting housing if you’ve been arrested for prostitution, so it's like what is your other choice at this point? (001US01)

These discretionary filters are a hallmark of exosystemic function: formal policy is interpreted through informal value systems, where ‘safeguarding’ is less a tool of protection than a moralising discourse that justifies exclusion.

Nevertheless, some NGOs developed internal strategies to either resist or work around exosystemic constraints. One U.K. organisation, for instance, ran a parallel unfunded outreach stream to preserve confidentiality and reduce bureaucratic exposure: ‘…with the unfunded work we don’t have a specific intake … it has been really handy for privacy and confidentiality, keeping that off the books’ (003UK01). While still subject to the organisation's data protection protocols, this structure allowed greater flexibility and client trust. Such adaptations reflect how NGOs navigate institutional demands while carving out pockets of discretion and care beyond formal surveillance.

Even modest objections can be easily overridden by institutional decisions. Some U.K. organisations reported being invited to provide input on official sex work interventions after fundamental decisions about approach and framing had already been finalised. In many ways this is standard government operating procedure and what appears as collaborative development often masks institutional closure, where statutory agencies seek legitimacy through consultation while maintaining predetermined outcomes (Burton, 2009). The resulting materials frequently reflected enforcement-oriented rather than support-focused approaches, suggesting that consultation was simply to validate existing institutional priorities rather than incorporate community expertise.

Surveillance and organisational logics

Many NGOs must share client data with external agencies, including details on immigration status, risk indicators, and criminal history – information that can trigger deportation, eviction, or child removal. As Brayne (2017) notes, once captured, data circulates across and between systems with little control or oversight. In the United Kingdom, for instance, the NHS is required to share immigration-related data with the Home Office, making NGO referrals fraught with risk (Liberty, 2019). As one respondent noted, practitioners must consider whether referring a client to medical care may lead to legal exposure: a stark example of how, at the exosystemic level, surveillance is embedded within ostensibly supportive practices.

Though the police in the United Kingdom have moved beyond the vice approach common in the United States (Matthews, 2005), prostitution remains low-status, discretionary work within the police occupational culture (Reiner, 2010). It offers limited enforcement capital and carries reputational risk, particularly amid safeguarding failures (Hanks, 2022). Exosystemic contradictions were evident in one U.K. case, where the police-designated Single Point of Contact (SPOC) for sex work – intended to facilitate support – was also responsible for issuing Anti-Social Behaviour Orders (ASBOs) against sex workers:

[It] is extremely difficult when they are the one, you know, sending them home for anti-social behaviour and they are also the SPOC. And we only found that out recently. (001UK02)

This contradiction reflects the institutional absurdity produced by fragmented governance logics. When roles designed for liaison are collapsed into those of enforcement, NGOs are left navigating incoherent systems that undermine the very partnerships intended to improve support. At the mesosystem level, this reflects a breakdown in communication; at the exosystem level, it illustrates the institutional logic of policing, which continues to operate through binaries of order/disorder rather than care/harm (Reiner, 2010). Assigning a beat sergeant to act as liaison may not be accidental, and may even be routine, but it reveals how the police prioritise territorial control and institutional shielding over relational trust. Lipsky's (1980) analysis of street-level bureaucracy applies in this situation, whereby discretionary front-line authority tends to reproduce systemic priorities unless actively restructured.

Policy narratives and strategic alignment

More generally, exosystemic pressures have reoriented police and multi-agency practice towards welfare-style interventions that are nonetheless structured through anti-trafficking logics. Yet as one U.K. respondent observed, the institutional embrace of trafficking discourse has not translated into better support. On the contrary, the growing strategic importance of trafficking has coincided with the erosion of victim-centred practice:

Trafficking prosecutions and sexual assaults - I don’t know where they’re going. The delays, the lack of engagement, just basically no one thinking about the victim in this. Five or six years ago we were better at this … I honestly don’t know what has changed, but we are also really struggling. The strong partnerships and collaborations that were there are not as strong, and that victim-centred focus is lessening. (001UK05)

In Neal and Neal's (2013) networked model, the exosystem comprises the indirect yet influential interactions between NGOs and statutory partners, forming a dynamic zone of institutional discretion. However, this discretion is often constrained, as trafficking discourse imposes symbolic alignment across systems, demanding rhetorical coherence even when it undermines material care. Carceral logics shape service provision through conditionality: support is frequently tied to legal compliance and moral reform, filtering access through norms of desistance, domesticity, or victimhood. Institutional gatekeeping is reinforced by mandatory data-sharing, exposing clients to immigration enforcement, eviction, or child removal. Contradictory governance logics further destabilise partnerships – NGOs may be required to liaise with officers who also issue ASBOs against their clients, collapsing support into enforcement. In this sense, policy is not the exosystem itself, but a structuring logic that configures exosystemic relations, embedding surveillance and punishment into care via contractual and administrative rule (Bernstein, 2010; Rice, 2013; Wacquant, 2009).

Macrosystemic scripts and institutional legibility

Neal and Neal (2013: 729) define the macrosystem as ‘the set of social patterns that govern the formation and dissolution of social interactions between individuals, and thus the relationship among ecological systems’. Macrosystem influences permeate governance systems at every level. They reshape police priorities (exosystem), narrow NGO–police cooperation (mesosystem) and determine what forms of victimhood become legible (microsystem). A majority of our NGO respondents indicated that in their opinion the single biggest macrosystem narrative that they had to navigate was that of human trafficking for sexual exploitation. NGOs often adopt trafficking narratives tactically to access funding, referrals, or institutional legitimacy. One U.K. NGO noted how anti-trafficking imperatives severely constrained their outreach efforts:

We all know what's important within the [police] organisation and that's trafficking, that's the only thing that's important and nothing else is of any importance, on a serious level … The trafficking work they do has the potential to undermine and conflict with the safety of sex workers. (004UK03)

Another U.K. practitioner explained how these macrosystemic priorities marginalised alternative voices:

…and there were lots of politicians that were pushing that agenda [anti-trafficking], and that's why we couldn’t get our voices heard, because that was the dominant voice and the dominant narrative. (001UK04)

Cultural stigma and funding logics

Macrosystemic forces also structure the NGO field through persistent cultural scripts about who counts as a ‘real’ victim. In Neal and Neal's (2013) ecological framework, the macrosystem comprises potent networks of meaning – ideologies, moral codes, institutional assumptions – that determine how experiences of violation are interpreted or rejected. Stigma operates not merely as background prejudice but as an active institutional filter, producing what can be called institutional illegibility: the systemic refusal to recognise certain identities as legitimate victims. As Stoler (2013) notes, moral logics sediment in institutions and persist as affective residues, shaping the contours of recognition long after their formal justifications have faded. These residues are especially visible where multiple stigmatised identities converge, compounding illegibility and constraining access to support:

I think, for male survivors to seek support, and I think if you add sex work into the mix, that's another barrier. But imagine if you’re a male escort, you went out, you took some drugs, you’re a migrant, you’re gay, and then you can't remember what happened, but you got raped. Are you just going to rock up to the nearest police station and say, “Guess what happened to me?” Probably not. (004UK04)

These intersecting identities – migrant, queer, drug-using, sex-working – compound barriers produce conditions in which disclosure becomes problematic. Similar cultural logics appeared in frontline policing responses, as another NGO practitioner recalled:

It was really shit … I won’t lie, and I’d had terrible things said to me [by police] when I’d tried to help women report before. So things like “Well a prostitute can’t be raped”, “What do you mean, like he didn’t pay her? Are you saying she didn’t get paid?”, “Well it's not the same as a regular rape is it? It's not like if it was a normal rape”. So all that kind of stuff. (001UK04)

What emerges here is a macrosystemic grammar in which perceived deviance disqualifies subjects from victimhood: an ideological filter that shapes exosystemic responses (policing), mesosystem strategies (NGO positioning), and microsystem choices (sex workers’ decisions on service engagement).

Structural exclusion in welfare, housing, and legal aid

Macrosystemic influences are evident in the exclusionary design of welfare, housing and legal aid systems. These policies embed moral judgements into bureaucratic forms, coding sex work, migration and criminalisation as markers of undeservingness. Neal and Neal's (2013) model frames such exclusions not as isolated acts but as active constraints structuring interactions at lower ecological levels. NGOs must navigate these exclusions reactively, withholding disclosures or managing narratives to avoid cascading vulnerability that can trigger exclusion across multiple institutional contexts. NGOs absorb this fallout, engaging in what one practitioner called ‘clever lawyering’ simply to maintain client eligibility. One U.K. NGO providing legal support to migrant women explained this balancing act:

And then if you’re trying to get help and trying to sort that out, you’re taking a risk in disclosing because there are risks and that has to be balanced and that takes clever lawyering in terms of what we need to know, when do we stop…. (001UK05)

What appears locally as a failure of access thus reflects national macrosystemic policy and mesosystemic cultural constraints – mediated through institutional routines and professional discretion – that limit the kinds of harm that can safely be disclosed. The dominance of anti-trafficking discourse has become a defining macrosystemic force in sex-work governance (Bernstein, 2010, 2018; Esslemont, 2019). Trafficking functions as a master-frame, recoding sex-work-related interventions through lenses of coercion, criminality, and rescue. Its ascendancy was not accidental. As commentators have acknowledged (Bernstein, 2010, 2018; Jackson et al., 2017) the global anti-trafficking agenda crystallised during the second Bush administration through alliances between evangelical conservatives, carceral feminists, and state actors. What emerged was a politically expedient and morally resonant narrative that expanded the state's punitive reach under the guise of humanitarian concern. In the United Kingdom, this alignment intersected with domestic anxieties around immigration, enabling border enforcement to be reframed as victim protection (Ellison, 2017; O’Connell Davidson, 2015).

Chronosystemic haunting and the historical residues of governance

The chronosystem draws attention to how past governance regimes continue to structure present institutional practice through inherited categories, routines, and moral assumptions (Neal and Neal, 2013: 729). To theorise this persistence, we draw on Stoler's (2013) work on historical sediment to foreground distinct mechanisms through which the past remains active in the present.

The origins of this historical sedimentation lie in nineteenth and early twentieth-century moral panics in the United States and United Kingdom, where campaigns against ‘white slavery’ and prostitution fused evangelical anxieties about national identity, female virtue, and racial order with the expanding reach of the modern state (Donovan, 2006; Freedman, 2003; O’Connell Davidson, 2015; Zimmerman, 2013). These campaigns positioned women's bodies as instruments of citizenship and moral regulation, enshrined in laws such as the Mann Act (1910) in the United States and the Criminal Law Amendment Act (1885) in the United Kingdom. The figure of the ‘white’ girl under sexual threat from foreign men mobilised nativist fears, drawing on Victorian tropes of virtue, contamination, and decline. These narratives closely tracked periods of intensified immigration (Jackson et al., 2017; Luker, 1998), embedding racialised and moralised logics of exclusion into state power. Anti-prostitution laws crystallised a binary between the innocent (typically white) victim and the racialised, oversexualised, immigrant ‘fallen woman’, legitimising invasive intervention under the guise of rescue or punishment (Bernstein, 2018; Zimmerman, 2013).

These earlier moral tropes have been rebranded into contemporary anti-trafficking initiatives, which reproduce the victim/criminal narratives, often for symbolic rather than protective ends. As one U.K. respondent reflected upon reviewing EU-funded anti-trafficking projects, the entire apparatus seemed performative rather than protective:

We got to evaluate 200 anti-trafficking projects, and I have to say, I’ve never seen so much money spent and so little impact. We couldn’t find victims. It's like pissing in the wind. It's millions … Nothing. No outcomes. Terrible. So, it's a nightmare. (001UKSB)

Although such initiatives claim neutrality, they repackage earlier racialised and classed carceral logics under the banner of protection (Bernstein, 2018; Jackson, 2024; Jackson and Brents, 2024). One U.S.-based NGO described how sex workers may be identified as trafficking victims yet still punished:

As it stands, “Why would I tell you who was trafficking me? You’re going to arrest me anyway”. The only person who might bail me out is the person who's my pimp. (001US01)

These accounts expose the disconnect between anti-trafficking rhetoric and on-the-ground outcomes. In both cases, the discourse of protection masks a system that either fails to find victims or punishes those who self-identify. Far from offering meaningful support, these initiatives often repackage punitive logics in therapeutic or humanitarian terms (Bernstein, 2010, 2018; Jackson, 2024).

A less explicitly acknowledged process is the persistence of institutional memory within local policing and welfare systems. In the United Kingdom, with its 45 separate territorial forces, and in the United States with its multi-tiered system, responses to sex work remain uneven, shaped by entrenched organisational cultures. While some police forces adopt trauma-informed rhetoric, many retain operational scripts drawn from older models of vice control. As Freedman (1987) notes, these do not simply disappear but resurface in new policy frameworks and frontline judgements about who is credible, deserving, or safe. Earlier we saw this in the police claim that sex workers could not be raped. Another U.K. NGO commented on the role of sedimented cultural scripts in police training:

I think we need to change the underlying attitude and stigma that's so ingrained in the police, from years and years and years. We [support organisation] should be there at the start, when they first become police officers, in the training, providing the information that they need. [Historically] the underlying rule was, sex workers shouldn’t be doing it, they are illegal, give them ASBOs. So that was that underlying tone. (005UK04)

This testimony underscores how past moral judgements continue to shape institutional conduct through routinised assumptions and inherited categories. Even when formal policies shift, their affective and classificatory residues often remain intact, circulating through training practices, discretionary policing, and the informal scripts of organisational life.

These three processes – moral inheritance, policy rebranding, and institutional memory – constitute the chronosystemic haunting of contemporary sex work governance. Chronosystemic haunting registers institutional change but it also exposes how policy reform is filtered through inherited anxieties and moral imaginaries. Stoler's (2013) historical debris foregrounds how repressed figures return, not as memory, but as structuring presence. In the governance of sex work, these are not abstract histories but sedimented institutional figures: the white slave, the pimp, the criminal migrant, the broken woman. They are animated by new vocabularies but perform familiar institutional work – shaping safeguarding protocols, determining who is seen as exploitable, and narrowing the field of recognition.

These figures do not simply circulate rhetorically; they become embedded in professional judgement, risk assessments, and frontline discretion. What appears novel is often a re-staging of older typologies, rendered intelligible through contemporary scripts of ‘harm’. NGOs operate on fragile terrain, navigating legal ambiguity and institutional architectures saturated with historical and moral logics. Support efforts must confront the genealogies of suspicion and control embedded within the systems they engage. Exclusion may appear rooted in present-day policy, but it is culturally sedimented and ideologically recycled. As Neal and Neal (2013) remind us, systems do not operate in isolation or in the present alone; the chronosystem is not a backdrop but an active force structuring care, control, and conditionality over time.

Conclusion

This article used Neal and Neal's (2013) ecological systems framework to analyse how NGOs engaged with sex workers navigate competing pressures within a complex and shifting institutional environment. Rather than focusing solely on discrete organisational practices, the analysis foregrounded how support and outreach work is shaped by tensions between care and control, recognition and exclusion, across interlocking systems.

Ecological systems theory is particularly well-suited to mapping the terrain of institutional dynamics because it illuminates how vulnerabilities are not confined to isolated institutional failures but emerge through the interaction of multiple, networked systems. It allows us to trace how chronosystemic imaginaries, macrosystemic discourses, exosystemic rules, mesosystemic partnerships, and microsystemic interactions combine to constrain both service providers and the sex workers who request their support. To capture the cumulative effects of these tensions, we introduced the concept of cascading vulnerability. This term helped explain how seeking support in one area can quickly trigger institutional spill-over across other domains, compounding risk rather than mitigating it.

The analysis identified three key challenges shaping the work of NGOs. First, the dominance of anti-trafficking discourse narrows the range of legitimate victimhood and restricts the terms of NGO–state cooperation. Second, cultural stigma filters who is seen as credible or deserving of support, especially where sex work intersects with queerness, migration, or drug use. Third, structural exclusions across housing, welfare, and legal aid systems force NGOs into tactical responses – managing disclosure, shielding clients, and engaging in ‘clever lawyering’ – to navigate bureaucracies not designed with sex-working populations in mind.

The policy implications of our discussion are stark. In the absence of structural attention to the ecological conditions that produce cascading vulnerability, NGOs remain tasked with compensating for systemic failure elsewhere in the governance ecology. Policies designed to expand access, and support must therefore contend with the institutionalised disbelief, exclusion, and risk logics that shape statutory provision. Rather than assuming that improved coordination can resolve these tensions, the analysis exposes how moral hierarchies and institutional architectures continue to displace responsibility onto NGOs while keeping sex-working populations at the periphery of care.

Although the analysis focuses on sex work governance, the ecological framework developed here has wider relevance. Cascading vulnerability may arise wherever marginalised populations navigate fragmented welfare, legal and regulatory systems in which engagement with one institution produces exposure within others. Similar dynamics may be visible in areas such as migration control, homelessness governance, or child protection systems. Ecological analysis therefore provides a way of tracing how institutional tensions redistribute risk across organisational actors and vulnerable populations.