Harm reduction programs for sex workers have been hampered by the prioritization of law enforcement over AIDS prevention. For example, the April 2010 “strike-hard” campaign against prostitution in Beijing, during which bars, nightclubs, saunas, and karaoke bars were raided, created an atmosphere that critically impeded human immunodeficiency virus (HIV) outreach activities for sex workers. In China, criminalization has limited the growth of a coherent and cohesive set of nongovernmental organization (NGO) actors working with sex workers to prevent HIV infection. Compared with other risk groups for HIV sexual transmission, such as men who have sex with men, the NGO community for sex workers is fragmented and poorly coordinated with government efforts, and basic rights for sex workers are often violated. This article examines civil society groups working on AIDS prevention and care for female sex workers in China and reviews constraints to their operations. China’s HIV prevention programs for sex workers are compared with sex worker HIV prevention in other Asian states where more well-developed NGOs exist and criminalization has been better balanced with harm reduction approaches, and recommendations are offered on improving China’s policies and programs.