has become legal, procuring still remains illegal. Procuring includes anything that would be considered the organisation or facilitation of services for prostitutes. The criminalisation of the purchase of sex from adults has been a continuing topic of discussion in the Nordic countries. In June 2006, parliament voted by 158 to 15, with four abstentions, to approve a bill which outlaws the buying of sexual acts if it is linked to human trafficking. The issue was raised again in 2013 by the Justice Minister. The current legal position in Finland therefore allows for the private sale of sexual acts but any form of human trafficking is both against the law and in breach of international human rights obligations. Venla Roth comments that the current Finnish penal position can be seen as a compromise between the two conflicting positions on the legality of prostitution. Foreign prostitutes A significant number of the prostitutes working in Finland are foreign. The proportion of the prostitutes that are migrants has increased over time, largely due to increased accessibility, political positions and economic factors. This increased accessibility may be attributed to the geographic location of Finland because of its proximity to other European countries as well as the fact that Finland is considered to be a transit country. In 1999, a special section was enacted under the Aliens Act in Finland. It specifies that where there are reasonable grounds to suspect an alien may sell sexual acts, he or she may be refused entrance into the country. The provision was justified as an objective to protect Finnish citizens from the social disturbances caused by prostitutes coming in from the East. Statistics Following the enactment of the special provision, between 1999 and 2007, Border Guard authorities refused the entry of more than 1730 persons on the grounds of suspicion that they sold sexual acts or had earned their income though dishonest means. By 2006, this number had escalated to 3300 refusals. These figures continue to increase, with Finnish police reporting that during the years of 2011 and 2012, there were more persons than ever deported because of suspicions of the sale of sexual acts. Despite legislative prevention measures, there continues to be a significant number of foreign prostitutes working in Finland. The National Bureau of Investigation estimated in 2002 that the annual number of foreign prostitutes was between 10,000 and 15,000, with most of them originating from Russia