Sterilization in macroeconomics is the process by which a central bank offsets the effect of its foreign exchange or balance-sheet operations on domestic liquidity. In simple terms, if the central bank buys foreign currency and unintentionally injects too much money into the economy, it can “soak up” that extra money through other operations. Understanding sterilization is essential for studying exchange-rate management, inflation control, reserve accumulation, and the limits of monetary policy in open economies.
1. Term Overview
- Official Term: Sterilization
- Common Synonyms: Sterilized intervention, liquidity sterilization, monetary offsetting, neutralization of liquidity impact
- Alternate Spellings / Variants: Sterilisation (UK spelling), sterilized foreign exchange intervention
- Domain / Subdomain: Economy / Macroeconomics and Systems
- One-line definition: Sterilization is a central bank action that offsets the effect of foreign exchange intervention or similar operations on the domestic money supply.
- Plain-English definition: If a central bank takes some action that would normally add or remove too much money from the banking system, it may take a second action to cancel that side effect.
- Why this term matters: Sterilization helps explain how policymakers try to manage exchange rates without losing control of inflation, interest rates, and domestic liquidity.
2. Core Meaning
At its core, sterilization is about separating two policy goals that would otherwise move together.
What it is
When a central bank intervenes in the foreign exchange market, it usually changes domestic liquidity at the same time:
- Buying foreign currency typically injects domestic currency into the system.
- Selling foreign currency typically withdraws domestic currency from the system.
Sterilization is the follow-up step that offsets that liquidity effect.
Why it exists
Central banks may want to:
- reduce exchange-rate volatility,
- resist excessive currency appreciation or depreciation,
- accumulate foreign reserves,
- defend financial stability,
without accidentally causing:
- inflation,
- overheating,
- an unwanted fall or rise in interest rates,
- excessive credit expansion or contraction.
What problem it solves
It solves a policy conflict:
- External objective: manage exchange-rate pressure or reserves.
- Domestic objective: keep money supply and interest rates aligned with monetary policy goals.
Without sterilization, an exchange-rate operation can unintentionally become a monetary easing or tightening.
Who uses it
Main users include:
- central banks,
- monetary authorities,
- ministries working with debt-management offices,
- macroeconomists,
- bond and FX market analysts,
- banks and treasury professionals who monitor liquidity conditions.
Where it appears in practice
Sterilization appears in:
- managed exchange-rate systems,
- emerging markets with large capital inflows,
- reserve accumulation episodes,
- crisis periods when a central bank defends the currency,
- liquidity-neutral bond purchase programs,
- central bank balance-sheet management.
3. Detailed Definition
Formal definition
Sterilization is a policy operation through which a central bank neutralizes the effect of foreign exchange intervention, reserve accumulation, or similar balance-sheet actions on the domestic monetary base.
Technical definition
In balance-sheet terms, sterilization means offsetting a change in the central bank’s net foreign assets (NFA) with an opposite change in its net domestic assets (NDA) so that the monetary base changes little or not at all.
Operational definition
Operationally, sterilization may involve one or more of the following:
- selling government securities,
- issuing central bank bills,
- absorbing bank liquidity through term deposits,
- using reverse liquidity facilities where local terminology supports that,
- increasing reserve requirements,
- using foreign exchange swaps or related instruments,
- coordinating with the government on market stabilization instruments.
Context-specific definitions
In foreign exchange policy
This is the most common meaning. The central bank intervenes in the FX market and then offsets the impact on domestic liquidity.
In broader central bank balance-sheet policy
The term may also refer to neutralizing the liquidity impact of:
- bond purchases,
- crisis support operations,
- special market-stabilization facilities.
In empirical research
Sterilization is often measured by a sterilization coefficient, which estimates how strongly domestic asset operations offset reserve-driven changes in liquidity.
4. Etymology / Origin / Historical Background
The term comes from the idea of making something “sterile” or inactive. In economics, it means making the liquidity effect of one action economically inactive by offsetting it with another action.
Historical development
Early central banking and gold flows
Before modern floating exchange rates, central banks often dealt with gold inflows and outflows. If gold entered the country, it could expand the domestic monetary base. Some authorities tried to sterilize gold inflows to avoid inflation or excessive credit growth.
Bretton Woods era
Under fixed or managed exchange-rate systems, balance-of-payments pressures had direct monetary consequences. Sterilization became a practical tool for countries trying to maintain exchange-rate arrangements while preserving internal stability.
Post-Bretton Woods and managed floats
After major currencies moved toward floating exchange rates, sterilization remained important in countries that still intervened heavily to smooth exchange-rate movements.
Emerging markets and reserve accumulation
In the 1990s and 2000s, many emerging economies accumulated large foreign exchange reserves due to export surpluses and capital inflows. Sterilization became central to policy discussions because reserve accumulation often created too much domestic liquidity.
Post-2008 balance-sheet policy
After the global financial crisis, the term was also used in discussions of whether central bank asset purchases were sterilized or unsterilized, especially when authorities wanted to support specific markets without broadly expanding liquidity.
How usage has changed
The meaning has remained consistent, but the context has widened:
- earlier: gold inflows and exchange-rate systems,
- later: capital flows and reserve accumulation,
- more recently: broader central bank balance-sheet and liquidity management.
5. Conceptual Breakdown
Sterilization is easier to understand if you break it into its main components.
1. Triggering event
Meaning: The first event that creates unwanted liquidity pressure.
Examples: – central bank buys dollars to prevent currency appreciation, – central bank sells dollars to support a weakening currency, – central bank purchases bonds for market stability.
Role: Creates the initial need for sterilization.
Interaction: The larger the intervention, the greater the potential liquidity effect.
Practical importance: You cannot understand sterilization without first identifying the source of the liquidity change.
2. Initial liquidity effect
Meaning: The direct effect on domestic money or bank reserves.
Role: This is the side effect that policymakers want to neutralize.
Interaction: FX purchases usually increase liquidity; FX sales usually decrease it.
Practical importance: This determines whether the central bank must absorb liquidity or inject it.
3. Offset instrument
Meaning: The tool used to neutralize the side effect.
Common tools: – open market sales or purchases, – central bank bills, – term deposit facilities, – reserve requirement changes, – liquidity repo or reverse-repo style operations depending on local framework.
Role: Delivers the second step of sterilization.
Interaction: Tool choice affects speed, cost, transparency, and market impact.
Practical importance: A central bank may want sterilization, but its ability depends on having usable instruments and deep enough markets.
4. Degree of sterilization
Meaning: How much of the initial liquidity change is offset.
Types: – Full sterilization: entire liquidity effect is offset. – Partial sterilization: only part is offset. – No sterilization: the liquidity effect is allowed to remain. – Over-sterilization: the offset is larger than the original effect.
Role: Determines final monetary impact.
Interaction: A central bank may choose partial sterilization if full sterilization is too costly or too disruptive.
Practical importance: Sterilization is not all-or-nothing.
5. Time horizon
Meaning: Whether the offset is short-term or durable.
Role: Some interventions create temporary liquidity fluctuations; others create persistent structural excess liquidity.
Interaction: Short-term tools may not be enough for long-lasting reserve accumulation.
Practical importance: Repeated sterilization can become expensive or operationally difficult over time.
6. Cost and sustainability
Meaning: The financial and policy burden of sterilization.
Sources of cost: – paying higher domestic interest on sterilization instruments, – holding lower-yielding foreign reserves, – market distortion, – balance-sheet strain.
Role: Determines how long sterilization can be maintained.
Interaction: Large, persistent inflows make sterilization harder.
Practical importance: Sterilization can buy time, but it is rarely a free or permanent solution.
7. Expectations and signaling
Meaning: Markets interpret sterilization as a policy signal.
Role: It shows the central bank wants exchange-rate action without changing the broader monetary stance.
Interaction: Expectations can affect the exchange rate, interest rates, and capital flows.
Practical importance: Even when the accounting offset is clear, the market reaction may still differ from policymakers’ intentions.
6. Related Terms and Distinctions
| Related Term | Relationship to Main Term | Key Difference | Common Confusion |
|---|---|---|---|
| Foreign exchange intervention | Sterilization often follows it | Intervention changes FX conditions; sterilization offsets domestic liquidity effects | People often treat intervention and sterilization as the same action |
| Sterilized intervention | Directly linked | This is intervention plus an offsetting liquidity operation | Not all intervention is sterilized |
| Unsterilized intervention | Opposite policy choice | The central bank allows the money supply effect to remain | Some assume all FX intervention changes only the exchange rate |
| Open market operations (OMO) | Common sterilization tool | OMOs are broader monetary tools and can be used for many purposes | Not every bond sale or purchase is sterilization |
| Liquidity absorption | Partial synonym | Absorption may happen for routine rate management, not necessarily due to FX intervention | Routine liquidity management is sometimes mislabeled as sterilization |
| Reserve accumulation | Common trigger | Reserve accumulation may require sterilization; it is not sterilization itself | Rising reserves do not automatically mean sterilization happened |
| Quantitative easing (QE) | Often contrasted with sterilization | QE aims to expand liquidity; sterilization aims to neutralize it | Both involve balance-sheet operations, but their intent differs |
| Capital controls | Policy alternative or complement | Capital controls affect inflows/outflows directly; sterilization offsets their liquidity consequences after the fact | They solve different parts of the problem |
| Impossible trinity / trilemma | Theoretical backdrop | The trilemma explains why sterilization has limits in open economies | Sterilization does not eliminate the trilemma |
| Reserve requirements | Possible tool | They can absorb liquidity but are a blunt instrument | Some think reserve requirements are always the preferred sterilization method |
Most commonly confused terms
Sterilization vs intervention
- Intervention is the FX market action.
- Sterilization is the liquidity offset that may follow.
Sterilization vs monetary tightening
- Sterilization is not necessarily a tightening signal.
- Its purpose is often to keep monetary conditions unchanged after another action.
Sterilization vs QE
- QE intentionally expands central bank money.
- Sterilization neutralizes expansion or contraction.
Sterilization vs capital controls
- Sterilization manages the monetary effects of flows.
- Capital controls manage the flows themselves.
7. Where It Is Used
Economics and macroeconomics
This is the main field where the term is used. It appears in discussions of:
- exchange-rate regimes,
- open-economy macroeconomics,
- capital inflows and outflows,
- reserve accumulation,
- inflation control,
- monetary autonomy.
Banking and central banking
Sterilization is highly relevant to:
- central bank balance-sheet management,
- interbank liquidity conditions,
- reserve management,
- short-term interest-rate control,
- bank funding conditions.
Policy and regulation
It appears in:
- central bank operating frameworks,
- reserve management policy,
- debt-management coordination,
- public discussions of inflation and exchange-rate stability.
Financial markets
Sterilization affects:
- bond yields,
- short-term rates,
- FX expectations,
- carry trades,
- liquidity in money markets.
Business operations
Businesses do not “perform” sterilization, but they feel its effects through:
- exchange-rate stability,
- funding costs,
- working capital rates,
- import and export competitiveness.
Investing and valuation
Investors watch sterilization because it can influence:
- currency outlook,
- local bond markets,
- inflation expectations,
- central bank credibility,
- equity valuations through liquidity conditions.
Reporting and disclosures
Sterilization is usually inferred or discussed through:
- central bank balance sheets,
- reserve money data,
- foreign reserve statistics,
- open market operation announcements,
- government or central bank debt issuance data.
Accounting relevance
This term is not a standard corporate accounting term. Its accounting relevance is mainly in:
- central bank balance-sheet composition,
- public finance interest costs,
- reporting of reserve assets and liquidity operations.
8. Use Cases
1. Absorbing liquidity after capital inflows
- Who is using it: Central bank in an emerging market
- Objective: Prevent excessive currency appreciation without fueling inflation
- How the term is applied: The central bank buys foreign currency inflows, then sells domestic securities or absorbs deposits
- Expected outcome: Exchange rate is smoother, while domestic liquidity remains controlled
- Risks / limitations: Ongoing inflows can make sterilization costly and difficult to sustain
2. Managing a commodity or export boom
- Who is using it: Central bank in an export-driven economy
- Objective: Prevent export earnings from creating an inflationary domestic credit boom
- How the term is applied: Reserve accumulation is paired with liquidity absorption measures
- Expected outcome: The economy avoids overheating while retaining reserve buffers
- Risks / limitations: Large sterilization operations may raise domestic interest costs and distort bond markets
3. Smoothing exchange-rate volatility in a managed float
- Who is using it: Monetary authority
- Objective: Reduce sharp currency swings without changing the monetary policy stance
- How the term is applied: FX intervention is followed by liquidity-neutralizing operations
- Expected outcome: More orderly currency markets with stable domestic interest conditions
- Risks / limitations: If markets doubt the policy, exchange-rate effects may be short-lived
4. Defending the currency during capital outflows
- Who is using it: Central bank during stress
- Objective: Support the currency without triggering a severe domestic liquidity crunch
- How the term is applied: The central bank sells foreign reserves, then injects domestic liquidity back into the banking system
- Expected outcome: The exchange rate is supported while banks remain liquid
- Risks / limitations: Reserve loss may still be large, and currency pressure may continue
5. Preserving inflation-target credibility
- Who is using it: Inflation-targeting central bank
- Objective: Avoid sending an unintended signal of easing or tightening
- How the term is applied: The liquidity impact of FX operations is neutralized so policy rates remain meaningful
- Expected outcome: Domestic monetary stance remains consistent with the inflation target
- Risks / limitations: Full credibility requires clear communication and reliable implementation
6. Liquidity-neutral market support operations
- Who is using it: Central bank during market dysfunction
- Objective: Purchase targeted assets or support a market segment without broad liquidity expansion
- How the term is applied: Liquidity added through one operation is withdrawn through another
- Expected outcome: Market stress is reduced while overall liquidity remains controlled
- Risks / limitations: Complex design, communication challenges, and uncertain market transmission
9. Real-World Scenarios
A. Beginner scenario
- Background: A country receives a lot of export dollars.
- Problem: The domestic currency is rising too fast, hurting exporters.
- Application of the term: The central bank buys the dollars to slow appreciation. That purchase injects local currency into banks, so the central bank then sells bonds to absorb the extra money.
- Decision taken: Use sterilized intervention instead of leaving the new money in the system.
- Result: The currency becomes less volatile, and inflation pressure is reduced.
- Lesson learned: Sterilization lets the central bank influence the exchange rate without automatically loosening monetary policy.
B. Business scenario
- Background: A manufacturing firm imports raw materials and exports finished goods.
- Problem: The currency is swinging sharply, making pricing and budgeting difficult.
- Application of the term: The central bank intervenes to smooth FX moves but sterilizes the liquidity effect to avoid pushing borrowing rates far away from policy goals.
- Decision taken: Use sterilized FX intervention rather than unsterilized intervention.
- Result: The firm sees a more stable exchange rate without a major distortion in working capital rates.
- Lesson learned: Businesses may not use sterilization directly, but they benefit from the stability it can create.
C. Investor / market scenario
- Background: A bond investor notices foreign reserves rising sharply.
- Problem: The investor wants to know whether inflation and bond yields will rise due to added liquidity.
- Application of the term: The investor checks whether the central bank is selling securities or absorbing deposits at the same time.
- Decision taken: Conclude that reserve accumulation is being partly sterilized.
- Result: The investor expects less inflationary pressure than a simple reserve increase would imply.
- Lesson learned: Reserve growth alone does not reveal the whole policy stance.
D. Policy / government / regulatory scenario
- Background: A government wants a competitive exchange rate, but inflation is already elevated.
- Problem: Supporting the currency objective through reserve accumulation could worsen domestic inflation.
- Application of the term: The central bank and government coordinate bond issuance or liquidity-absorbing operations.
- Decision taken: Use partial sterilization with regular review of inflation, costs, and debt-market conditions.
- Result: Exchange-rate pressure is moderated, but sterilization costs become an important policy consideration.
- Lesson learned: Sterilization often requires coordination across monetary policy, debt management, and fiscal authorities.
E. Advanced professional scenario
- Background: A macro analyst studies an emerging market over 24 months of heavy capital inflows.
- Problem: The analyst wants to estimate how much of reserve-driven liquidity was offset.
- Application of the term: The analyst compares changes in net foreign assets and net domestic assets, calculates a sterilization ratio, and checks short-term rate stability.
- Decision taken: Conclude that sterilization was high at first but weakened as costs and market constraints rose.
- Result: The analyst expects greater inflation risk and more pressure on the central bank’s balance sheet.
- Lesson learned: Sterilization is dynamic; it can become less effective or less sustainable over time.
10. Worked Examples
Simple conceptual example
A central bank buys foreign currency worth 100 units of domestic currency.
-
FX purchase:
–ΔNFA = +100– Domestic liquidity rises by 100 -
Sterilization step:
– Central bank sells domestic securities worth 100 –ΔNDA = -100 -
Net effect:
–ΔMB = +100 + (-100) = 0
Interpretation: The exchange-rate action happened, but the domestic monetary base did not change.
Practical business example
A country wants to avoid a sharp appreciation because exporters are losing competitiveness. The central bank buys incoming foreign currency from banks. If it stops there, banks will hold more reserves, credit could grow faster, and inflation risks may rise.
So the central bank absorbs the extra liquidity through bond sales and term deposits. Exporters get a more stable currency environment, while domestic inflation risks are kept in check.
Numerical example
Suppose:
- The central bank buys USD 2 billion
- Exchange rate = 80 domestic currency units per USD
- Domestic liquidity injected =
2 billion × 80 = 160 billion
Now suppose it sterilizes by:
- selling government securities worth 120 billion
- absorbing 20 billion through term deposits
Step 1: Measure the initial FX effect
ΔNFA = +160 billion
Step 2: Measure the domestic offset
ΔNDA = -120 - 20 = -140 billion
Step 3: Calculate net effect on monetary base
ΔMB = ΔNFA + ΔNDA
ΔMB = 160 + (-140) = 20 billion
Step 4: Interpret
- Initial liquidity injection: 160 billion
- Offset applied: 140 billion
- Net increase in monetary base: 20 billion
This is partial sterilization.
Advanced example
Now suppose the central bank is defending the currency during outflows.
- It sells USD 1.5 billion
- Exchange rate = 82 domestic currency units per USD
- Liquidity withdrawn =
1.5 × 82 = 123 billion
If the central bank worries this will tighten domestic liquidity too much, it may lend back some funds:
- liquidity injected through repo or lending operation = 90 billion
Then:
ΔNFA = -123 billionΔNDA = +90 billionΔMB = -123 + 90 = -33 billion
Interpretation: The domestic tightening caused by reserve sales was mostly, but not fully, offset.
11. Formula / Model / Methodology
Sterilization has no single universal “formula” in the way a valuation ratio does, but there are standard analytical identities.
1. Monetary base identity
Formula
ΔMB = ΔNFA + ΔNDA
Meaning of each variable
ΔMB= change in monetary base or reserve moneyΔNFA= change in net foreign assets of the central bankΔNDA= change in net domestic assets of the central bank
Interpretation
- If
ΔNFArises because the central bank buys foreign currency, domestic liquidity usually rises. - If the central bank wants to sterilize that effect, it makes
ΔNDAnegative. - Full sterilization means:
ΔNDA = -ΔNFA
so that:
ΔMB = 0
Sample calculation
If:
ΔNFA = +200ΔNDA = -150
then:
ΔMB = 200 - 150 = 50
So 150 of the 200 liquidity injection was sterilized.
Common mistakes
- Confusing the monetary base with broad money such as M3
- Ignoring valuation changes in foreign reserves
- Treating all changes in domestic assets as sterilization-related
Limitations
This is a simplified balance-sheet identity. Real-world central bank accounts may include more detailed items, valuation adjustments, and off-balance-sheet tools.
2. Sterilization coefficient
Formula
A simple accounting version is:
S = -ΔNDA / ΔNFA
Interpretation
S = 1→ full sterilization0 < S < 1→ partial sterilizationS = 0→ no sterilizationS > 1→ over-sterilizationS < 0→ domestic action amplified rather than offset the FX effect
Sample calculation
From the earlier numerical example:
ΔNFA = +160ΔNDA = -140
So:
S = -(-140) / 160 = 140 / 160 = 0.875
This means 87.5% of the initial liquidity effect was sterilized.
Common mistakes
- Sign errors
- Mixing monthly and annual changes
- Ignoring that reserve changes may reflect valuation, not intervention
Limitations
This simple ratio is useful for intuition, but research often estimates sterilization econometrically rather than using a raw accounting fraction.
3. Approximate carry cost of sterilization
Formula
Annual carry cost ≈ (i_d - i_f) × A_s
Meaning of each variable
i_d= domestic interest rate paid on sterilization instrumentsi_f= yield earned on foreign reserve assetsA_s= amount sterilized
Interpretation
If domestic sterilization instruments pay more than reserve assets earn, sterilization can create a cost.
Sample calculation
Suppose:
- domestic sterilization rate = 6%
- foreign reserve yield = 3%
- sterilized amount = 500 billion
Then:
Annual carry cost ≈ (0.06 - 0.03) × 500 billion
Annual carry cost ≈ 0.03 × 500 billion = 15 billion
Common mistakes
- Ignoring FX valuation gains or losses
- Ignoring maturity mismatch
- Assuming cost is the only consideration; sometimes sterilization is still necessary
Limitations
This is a rough approximation, not a full income statement.
12. Algorithms / Analytical Patterns / Decision Logic
Sterilization is not a trading algorithm, but it does follow clear policy logic and analytical patterns.
1. Central bank decision framework
What it is
A step-by-step way to decide whether and how much to sterilize.
Why it matters
It helps balance exchange-rate goals, inflation control, and liquidity conditions.
When to use it
Whenever interventions or reserve movements materially affect the domestic banking system.
Typical decision logic
- Identify the source of liquidity change.
- Estimate its effect on reserve money and market rates.
- Compare that effect with the desired monetary stance.
- Choose an instrument: – bond sale, – term deposit, – reserve requirement, – liquidity injection or absorption facility.
- Decide full, partial, or no sterilization.
- Monitor rates, inflation, bank reserves, and market functioning.
- Adjust if costs or side effects become excessive.
Limitations
Policy decisions also depend on politics, communication, market depth, and crisis conditions.
2. Analyst detection pattern
What it is
A practical method used by economists and investors to infer sterilization from public data.
Why it matters
Central banks may not publish a simple “sterilization number.”
When to use it
When studying reserve accumulation, FX intervention, or liquidity policy.
Pattern to look for
- foreign reserves rise sharply,
- reserve money rises only slightly or not at all,
- net domestic assets decline,
- central bank or government securities issuance rises,
- short-term rates remain near target.
Limitations
Reserve changes may reflect valuation effects, and domestic operations may be driven by unrelated monetary objectives.
3. Effectiveness assessment framework
What it is
A way to judge whether sterilization worked.
Why it matters
An offset on paper does not always mean success in the economy or markets.
When to use it
After major interventions or prolonged inflow/outflow episodes.
Main checks
- Did the exchange rate stabilize?
- Did short-term rates stay near the policy target?
- Did inflation or credit growth remain contained?
- Did bank liquidity remain functional?
- Were costs manageable?
- Did sterilization attract even more inflows through higher yields?
Limitations
You never observe the counterfactual with certainty.
13. Regulatory / Government / Policy Context
Sterilization is usually an operational policy practice, not a standalone legal category. Its legal basis comes from a country’s central bank powers over:
- foreign exchange operations,
- reserve management,
- monetary policy implementation,
- securities operations,
- liquidity facilities,
- reserve requirements.
Important: Exact tools, legal authorizations, and reporting practices differ by jurisdiction. For live policy work or compliance, verify the latest central bank acts, operating frameworks, and official circulars.
International / global context
Globally, sterilization is discussed in:
- IMF and BIS policy analysis,
- open-economy macroeconomics,
- reserve management and capital flow management debates.
There is no single global rulebook. The main issues are:
- whether the central bank has the instruments to sterilize,
- whether sterilization is financially sustainable,
- how it interacts with exchange-rate regime and capital mobility.
India
In India, sterilization has historically been associated with:
- RBI liquidity management,
- open market operations,
- reserve requirement changes,
- government coordination mechanisms such as market stabilization instruments,
- absorption of durable liquidity linked to capital inflows and FX reserve accumulation.
Because operational frameworks evolve, readers should verify:
- current RBI liquidity facilities,
- present use or non-use of market stabilization tools,
- current reserve requirement policy,
- recent circulars and monetary policy statements.
United States
In the US, sterilized foreign exchange intervention has existed historically through Federal Reserve and Treasury coordination, but it is not the central focus of routine monetary policy communication because:
- the dollar generally floats,
- domestic monetary policy is rate-focused,
- FX intervention is relatively infrequent compared with some emerging markets.
Sterilization questions can still arise in discussions of:
- FX operations,
- balance-sheet implementation,
- reserve management and money market conditions.
European Union / Euro area
In the euro area, the ECB has at times used liquidity-neutralizing methods around specific asset purchase or market support programs. The exact approach depends on the policy episode and operating framework in force at the time.
Key point: in Europe, “sterilization