Tag Archives: Europe

Free Havens for Refugees (mostly by Pieter Cleppe)

Pieter Cleppe, head of the Brussels office of the think tank Open Europe, has written a piece advocating something akin to my idea of passport-free charter cities. (Also see my thoughts on charter city constitutions here and here,  my post about the abortive charter city experiment in Honduras, and my post “Make More Singapores!”) Cleppe advocates “free havens” in response to the recent tragedies in the Mediterranean. The rest of this post is by Cleppe (see the original piece here, it is reprinted with his permission), except a few comments of mine at the end:

Free havens as a solution to the refugee crisis

The latest tragedies in the Mediterranean once again highlight that migration is without any doubt one of the challenging issues of our time. Few dispute that it would be a bad idea to close borders completely. On the other hand, few support opening borders completely, recognising the obvious downsides to this.

The debate mostly focuses on the type and number of immigrants allowed into wealthier societies. There is very little debate about what to do with those wanting to leave their country when even the most generous quotas would have been filled.

Since 2011, 3 million people have already fled Syria, and 6.5 million are internally displaced. The EU hasn’t accepted more than 200.000 of them, while it faces ever increasing numbers of refugees, from Syria and other places, attempting to enter illegally. Even if Western countries drastically increased their willingness to welcome refugees, this would in no way serve demand. Nearly everyone agrees refugees should have the right to flee war-torn countries, but politically, there is no willingness to welcome everyone, whether one agrees with that or not.

The solution proposed below is a humble attempt to launch this debate and provide a more sustainable solution than the ones offered in the past.

One way to deal with this challenge has been to ignore it and to let people sort it out themselves. The result has been that the most vulnerable were delivered to human traffickers, at best reaching the Western world as an illegal immigrant, at worst finding the Mediterranean Sea as their graveyard.

A better solution has been to provide shelter for them in refugee camps. This clearly is an honourable attempt to minimise suffering. There are currently estimated to be up to 50 million refugees. The United Nations High Commission on Refugees offers them protection and life-saving supplies at refugee camps in more than 125 countries. Often, these camps aren’t temporary and sometimes conditions are horrendous. Often, refugees are also banned from becoming economically active. Thailand, for example, banned Burmese refugees living on the Thai-Burmese border from leaving their camps in 2014.

One of the 120.000 Burmese refugees in Thailand describes how living in such a camp, with its travel and work restrictions, while being forced to be nearly completely dependent on outside help for food, shelter, protection and other basic needs, have adverse psychological and social effects on the refugees:

“Living in the camp is similar to living in prison because I can’t go outside or make my own decision. I can commute only in the camp. The camp is surrounded by barbed wire. If we go outside of the camp, Thai police will arrest us. In the long run, it affects not only my physical but also my mental health.” (Christine, 22, refugee, who spoke with Burma Link in Mae La refugee camp in May 2014)

Lebanon’s 470,000 Palestinian refugees, of whom over 50 percent live in 12 refugee camps who’re controlled by competing Palestinian armed groups, face restrictions to practice about 30 different professions. Whatever solutions one has for the Israeli–Palestinian conflict, surely condemning generations of Palestinian refugees to this fate can’t be one of them.

A preferable solution could be to create “Free havens”: a refugee zone but then one with stable rule of law, protection and opportunities for economic investment, where refugees can actually build up a life and aren’t condemned to wasting their precious time.

This has been tried, but only very occasionally, although with extraordinary success. Most prominently in the last century, it was applied in Hong Kong, effectively a refugee zone, governed by the British rule of law, welcoming millions of Chinese wanting to fled war, totalitarian rule and turmoil in mainland China. Refugee camps at best offer refugees safety, but Hong Kong offered those Chinese refugees something which even the best refugee camps can’t offer: the opportunity to develop yourself.

Refugees, broadly defined as people fleeing from both war and economy misery, aren’t asking for a lot. They want a better life. Not necessarily a whole of a lot better. Only slightly better, if nothing else is possible. Refugees don’t only want shelter. They want to be able to develop themselves. Why would they need to wait before their country returns to the better or before wealthier countries decide they’re willing to welcome them?

A tiny percentage of land in the world is urbanized, perhaps around three percent. Would it really be so impossible to identify a place where no-one lives and welcome anyone willing to go there? Would it really be impossible to identify a place where really no-one would be bothered? If a city the size of Las Vegas can be successfully developed in the middle of a desert, there shouldn’t even be any requirements in terms of average temperature or access to the sea, although a climate like California would clearly be preferred.

It’s highly likely that such a place would be part of the territory of a State. But why would this State not allow “Free havens” to be hosted? Perhaps in some remote part of it, not to bother any of its citizens with any possible burden, especially if it would be financially compensated for it, for example by charity organisations wanting to offer refugees a better perspective or by companies investing in these Free havens, which could attract a lot of skilled individuals?

Why would companies not be interested to invest in these Free havens, just as they invest in the poorest parts of the world already, which often would not offer the same standards of justice and safety that such a Free haven would offer, given that these Free havens could be administrated by officials from countries with a certain level of rule of law?

Why would such a Free haven offer standards of justice and safety that are sufficiently high to make such a project succeed, so people would actually voluntarily want to go there, and companies would actually want to invest, thereby freeing up the resources needed to compensate the host State to actually allow such a Free haven to exist on its territory?

The answer is simple: For this project to be a success, it needs to become more safe than the most unsafe place in the world and its investment climate should beat the most horrible place on earth to do business, to attract those fellow human beings who actually have to survive there at the moment. Surely that shouldn’t be too much of a challenge. Would it really be so hard to do better than North Korea, Syria or Congo?

This project, which could be driven by the private sector, states, supranational organisations or various actors working together, doesn’t exclude everything that’s already happening: opening borders for trade, trying to develop poor countries, attempting to pacify violent conflicts, providing emergency aid to the most needed, allow more migrants to enter wealthy countries or develop refugee camps when no other option is there. This project simply offers a solution for immigrants who are not or insufficiently helped by what is already been done: the vast majority of them. If it is so simple, why not just take action?

So what is this again?

Let’s create “Free havens”: refugee zones but then with rule of law, protection and opportunities for economic investment, where refugees can actually build up a life and aren’t condemned to wasting their precious time

Which countries would allow such zones on their territory?

That’s a challenge the EU is currently facing, at least if it continue with its idea to establish immigrant-processing centres outside the EU. These offshore centres may be based in key transit countries such as Niger, Egypt, Turkey or Lebanon. France, Germany and Malta would reportedly be keen on the idea. When seeking refuge there, asylum seekers would get the chance to indicate in which EU country they’d like to apply for asylum, and at one point there may even be a system of forced “burden sharing”, which is however unlikely, given that national politicians in the EU rightly think such sensitive policies should be decided at the national level.

To convince them, Niger, Egypt, Turkey, Lebanon or maybe even Morrocco would logically need to be compensated for hosting such centres. Given the huge amount of funds available in national and European aid budgets, reaching a compromise shouldn’t be impossible.

The only element the EU Commission would need to change in its current plan, is to combine its welcoming of refugees offshore with a rule of law – mission. The EU has some experience with “rule of law”-missions. Part of its EULEX-mission in Kosovo was to administer justice in the most delicate sectors over there. It must be said that there have been major problems with the implementation, but at least Kosovo has known some kind of stability. Either way, the main difference between Free havens and the mission in Kosovo would be that anyone moving to such a Free haven would do so voluntarily.

Has something like this ever been tried?

As I made clear earlier: yes, indeed. Hong Kong effectively served as such a Free haven to Chinese refugees. It probably also served to convince mainland-China to choose the path of international trade.

Why would companies want to invest there?

Fair question. The likes of Ikea or Coca Cola would certainly need to consider this carefully, but a safe investment zone governed by officials from countries with a relatively high level of rule of law surely should be able to compete with countries where a revolution or social unrest is always only around the corner?

How much would this cost?

The Belgian police and justice system costs around 3 billion euro per year, to serve 11 million people. With 10 billion per year, which is not even 10 percent of the EU’s 130 billion euro budget, 20 million refugees could already be welcomed, as 7 billion euro would be reserved for basic infrastructure. Also co-financing from investors could be attracted. Even if only 1 million out of 50 million refugees could be welcomed at first, it would be a massive step forward.

Anyone dealing with the EU budget knows massive spending improvements could be made. More than 270 billion euros are still being sent to agricultural landowners, including the Queen of England, between 2014 and 2010. Given how the EU’s agricultural policies have been hurting developing countries for decades, it wouldn’t be such a bad target to find funds.

Is it politically feasible?

Former UK Prime Minister Tony Blair once proposed off-shore asylum centres, the European Commission is keen them, several member states are open to something like this. The whole idea really comes down to accepting two realities: one reality is that many people currently want to flee their country. Another reality is that a large majority of the European population, rightly or wrongly, is only willing to accept a tiny part of all the refugees in the world. So welcoming them in a safe place somewhere else is not more than obvious solution.

What if it goes wrong?

Amnesty International has criticized the European Commission’s suggestion to externalize refugee policy, warning that there may be “human rights violations” in many countries outside of the EU. Fair point, but this is being addressed when EU countries themselves would run these zones. What if EU countries would still mismanage the whole thing, and these Free havens wouldn’t be so nice at all? Even in that case, given that every refugee would obviously only go there voluntarily, people would only come if the welcoming zone would be nicer than refugee camps or the places from which they are fleeing. Surely, it can’t be hard to beat these standards?

Won’t it lead to a brain drain?

In the event that these Free havens turn out to be a massive success and start attracting not only desperate refugees but also people that are already relatively well off, we would indeed face this discussion. I won’t go into detail here, but there are also upsides to intelligent people moving to work in wealthier countries, given the fact that they can send more money back home to help their families than if they had stayed.

Isn’t this “apartheid”?

When you accept that migration should be limited, you accept a certain form of “apartheid” already. To support unlimited migration is a fair position to hold, but has very little support. Why then not try to improve the fate of those who’re not welcome in wealthier countries?

Pieter Cleppe

There’s no explicit open borders advocacy here. (Open borders is a “fair position to hold, but has very little support.”) But if a global archipelago of passport-free charter cities were established, the right to emigrate would be effectively realized, even if the more general right to migrate were not. I’m all for it. And this is a good example of how human rights can be the thin end of the wedge for open borders, as religious freedom was once the thin end of the wedge, first for freedom of speech, expression, and conscience, then for democracy. If we take seriously the responsibility of the international community not to drown desperate people or trap them in places where their lives are in danger, we will be on a path that, if followed devoutly enough, leads quite far in the direction of open borders. It would be, among other things a fitting Western repentance for the blood of the Jews of the MS St. Louis.

Related reading

In addition to the links included by Smith in the leading para, the following might be of interest to readers:

Conversation between Steve Teles and GiveWell

Below are excerpts from a recent conversation between GiveWell staff (Holden Karnofsky and Timothy Telleen-Lawton) and Steve Teles, Associate Professor of Political Science at Johns Hopkins University about policy advocacy. I have included only the excerpts that directly discuss immigration, although the immigration section of the discussion includes a lot of general discussion of the policy advocacy “map” as Teles calls it.

Steve Teles: Within a year or two there will be a bill passed, and that is likely to exhaust Congress’s desire to legislate on immigration for about a decade. So it’s not worth investing a lot of money on the legislative lobbying side, at least as it’s currently defined: along the lines of numbers, regularization of status, internal enforcement.

It will be a very complicated bill, with a lot of responsibility passed on to regulatory agencies. There will be lots of litigating as well, so getting the optimal outcome from the law requires acting at the regulatory rulemaking side through the agencies, the litigation stage, and the actual implementation of the law in practice.

The process will be very long, maybe indefinite. The Clean Air Amendments of the 1970s are still being fought over. So it’s worth investing on the litigation and rulemaking side more than the legislative side.

Related material we’ve covered at Open Borders includes part 2 and part 3 of Fabio Rojas’ series on how to move in the direction of open borders.

Later in the conversation:

GiveWell: On the immigration reform bill, how do we figure out how much capacity is already there and how much room there is for funding? How would we decide how to get involved?

Steve Teles: You should talk to Min Hsu Chen, a professor at CU Boulder, who knows a lot about immigration, law, and civil rights.

It’s useful in these cases to do an advocacy map: who’s out there working on this, what are they working on, how stable is their funding. Since many of these issues are incredibly technical you often need people who have been doing this for a long time. The reputation of the people is normally the most important thing, and is inherently non transparent, since everyone has an interest in distorting how influential they are. The goal is to fund someone who has influence, which requires gaining the trust of people who can tell you who really has influence and who doesn’t. This makes it important to go deeply into an issue over time. Being a long term funder puts you into a multi iteration game with people you deal with, decreasing the probability of getting burned.

Back to opportunities on immigration: the regulatory side is the most elite dimension, involving lawyers, regulators, politicians, law review articles, etc. Another side would be immigrant self organizing, something funders rarely do. Funding tends to do things for immigrants, rather than increase their capacity to organize themselves. They’re a population that’s tough to organize, being transient and weakly settled, and are a group that politicians are rarely afraid of. The most important thing in politics is fear, and if they had organizational capacity politicians might fear them.

Organizing immigrants might impact employers or the media, eventually affecting people’s perception of what the nature of the issue is. Depending on the status of immigrants this could include electoral organizing. Ben Sachs (Harvard) writes about a potential role for organized labor in helping immigrants: casual immigrant workers are at risk of not getting paid or having regulations broken, and modern style labor organizations can help with these issues. Immigrant rights probably has more of a “funding arbitrage” opportunity than immigration as such.

Immigrants can be organized via worksites or at churches. The immigration bureaucracy is a mess and especially difficult for individuals who aren’t organized.

Related material on our website includes an optimistic blog post on the role of organizing by David Bennion, a post by Nathan Smith about Jose Antonio Vargas, and a more pessimistic and cynical take from me.

GiveWell: We’ve heard the claim that there aren’t many people interested in letting people from the
developing world into the US – either in support of it for humanitarian reasons, to improve the US, or for libertarian anti-border reasons.

Steve Teles: Admittedly immigration is not one of the topics I know much about, comparatively speaking. On this question, it’s partly a function of funding. It’s also the way people think about it – many people think of the humanitarian issue on an individual level, not as a numbers issue, or they think of it as letting family members in rather than letting in people from impoverished countries more broadly. The “trade not aid” argument is the same idea as immigration, but immigration doesn’t get discussed in that context generally – maybe it could be.

The most disruptive thing to a political environment is a new issue dimension. It tends to motivate and mobilize a new set of people who realize they have a stake, and it changes what people think the issue is about. So injecting a new issue dimension into immigration may be valuable. This could be accomplished either with a new, special purpose organization or an existing one. A new organization would start out with no branding, which is good and bad: you have neither the cachet nor the baggage of an existing group.

Philanthropists do create new things all the time. The NRDC was basically created by the Ford Foundation. They look for an opportunity that doesn’t already exist, find good people and give them some seed capital. These people might be ones who already work in a space but aren’t achieving their potential or want a new job. Finding them probably requires being embedded in a space, so that people trust you and tell you things like this.

Related material on our site: my blog post double world GDP versus scope insensitivity.

GiveWell: What about other countries? We would potentially see value in bringing about more open borders in any developed country, but that seems like a difficult field to survey.

Steve Teles: There are comparative immigration policy experts. In fact, the system at the moment is better in the US than many other countries, which are using human capital weighted systems to figure out who to bring in. Funding people in European countries would be very difficult, since we don’t know the landscape. The US system is more permeable, whereas the systems of bargaining and deep bureaucracy in European countries make them difficult to influence from an outside perspective.

Some good people to talk to: Antje Ellermann, at the University of British Columbia, who has written about deportation and knows a lot about German policy specifically. She’s a humanitarian, less of a nationalist. Peter Skerry of Boston College knows the INS bureaucracy really well. He’s more of a restrictionist but would be an interesting person to talk to. He knows something about the European bureaucracy as well. Rebecca Hamlin at Grinnell is working on a book comparing the immigration policies of the US, Britain, and Australia, looking at immigration processing at a deep regulatory level, and knows the intersection of regulation and courts really well. Many of the people at that intersection are former students of Robert Kagan of Berkeley.

A blog post by Carl Shulman is related.

Croatia, the EU, and Yet Another Experiment in Open Borders

Yesterday Croatia became the 28th member of the European Union. In doing so joined Europe’s great experiment in free trade and free immigration across diverse languages, beliefs, and cultures. The EU is not without its issues, but creating a large open borders region across Europe has not been the reason countries like Greece, Spain, Italy, Portugal, and Ireland have gotten into trouble.

Croatia is currently looking at a  18% unemployment rate and increasing options to move to a country like Germany with its 5% rate should be welcome. There are limitations still in place however. Croats won’t be able to go work in the United Kingdom for another seven years, and the country won’t enter the passport-less Schengen Area until 2015 at the earliest. Part of being able to do means clamping down harder on the country’s borders with countries outside the EU, a process that will require some significant investments.

Joining the EU probably won’t solve all Croatia’s current woes. But every person from Croatia who gets to try life somewhere else in Europe, and every European who finds a place to live or work in Croatia is a little improvement in the world. And every time a country opens itself up to freer migration without causing disaster the empirical case for open borders gets just a little stronger.

Open borders: the solution to conflict in the Middle East

Anne-Marie Slaughter, a respected US academic and former bureaucrat in the field of international studies, recently authored an interesting piece highlighting an unconventional 2-state solution for Israel and Palestine:

“Two-state condominialism” is as visionary as the name is clunky. The core idea is that Israelis and Palestinians would be citizens of two separate states and thus would identify with two separate political authorities. Palestine would be defined as a state of the Palestinian people, and Israel as a Jewish state. Under “condominialism,” however, both Palestinians and Jews “would be granted the right to settle anywhere within the territory of either of the two states, the two states thus forming a single, binational settlement community.”

…Palestinians “would have the right to settle anywhere within Israel just as Jews would have the right to settle anywhere within the territory of the Palestinian state. Regardless of which of the two states they lived in, all Palestinians would be citizens of the Palestinian state, all Jews citizens of Israel.” Each state would have the authority and the obligation to provide for the economic, cultural, religious, and welfare needs of its citizens living in the other state’s territory.

Condominialism recognizes the reality of the deep interconnectedness of Israeli settlers in the West Bank with the rest of Israel – through roads, water supplies, electricity grids, administrative structures, and economic relationships (just as Israeli and Palestinian parts of Jerusalem are interdependent). Instead of trying to separate and recreate all of these structures and relationships, it makes far more sense to build on them in ways that benefit both states’ peoples and economies. And, in a world in which many citizens spend an increasing proportion of their time in virtual space, de facto condominialism is already happening.

As ideas go, I’ve seen worse. I like this a lot. In fact, I like this enough to the point that I would like to know: what’s keeping the rest of the world from trying this out? In many parts of the world, the forms of “deep interconnectedness” Slaughter describes already exist in total defiance of arbitrary, human-defined borders. In fact, I am a bit surprised she almost seems to gloss over the human relationships and communities that constitute the most important interconnectedness here.

To take an example I’m familiar with, it matters little to a Malaysian living in East Malaysia on the island of Borneo where the technical border is. Not when he and his family have been living and moving across the land long before any international border sprung up separating Malaysia and Indonesia. Across the South China Sea in West Malaysia, Malaysians who live in the north are permitted to cross our border with Thailand without passports or visas, a governmental nod to our deep interconnectedness. Stories like these can be found across the world, including in the southern US, where people still recall how, before paranoia post-9/11 set in, communities divided by a border paid it no heed, their lives bonded together by social and economic ties that matter far more than arbitrary lines drawn on a map.

And to her credit, Slaughter closes by obliquely pointing to the relevance of open borders outside the Middle East:

In the 1950’s, after four decades of war across Europe, the idea of a European Union in which member states’ citizens could live and work freely across national borders while retaining their political allegiance and cultural identity seemed equally far-fetched. (Indeed, the name of the political process by which the EU was to be constructed, “neo-functionalism,” was every bit as abstract and cumbersome as “two-state condominialism.”) Yet French and German statesmen summoned the vision and the will to launch a bold experiment, one that has evolved into a single economy of 500 million people.

The EU has proven that on a fairly large scale, open borders work. (I am not too sure about the feasibility of a single currency, though.) To the extent that open borders in the EU have been detrimental, they have been addressable by keyhole solutions (such as transparent, clearly-defined temporary restrictions on immigrant flows to allow societal adjustment). And to the extent that they have been harmful in spite of keyhole solutions, it is absolutely clear that most, if not all, predictions of catastrophe have not come to pass.

Borders may be arbitrary, but we don’t need to abolish them to have open borders. Indeed, Slaughter says: “To make this work, the borders of each state would first have to be defined – presumably on the basis of the 1967 borders, with mutually agreed territorial swaps.” Borders define the area of a state’s sovereign jurisdiction. But they don’t define the human relationships that form the warp and weave of everyday life. Fundamental morality and economics agree: we need open borders.

What international evidence exists for adverse impacts from illegal immigration or amnesties for immigrants?

In the US, California is every restrictionist’s (and fair-minded skeptic’s) example of how badly things can go wrong if you mismanage immigration policy. I have not yet seen someone cite country-level evidence of poor immigration policy’s impacts: given that Italy and Spain have given multiple amnesties to unauthorised immigrants over the last 3 decades, and the current state of their economies, this seems surprising. Does anyone know of a comprehensive analysis that looks at jurisdictions outside the US?

To be clear, I often see specific references to how life in California is now terrible because of illegal immigration. Commonly-cited examples are the problem of the state government’s debt, a dysfunctional state government, soaring crime rates, deteriorating levels of social trust, a collapsing public school system, the high level of unemployment…I could continue on. I often see references made to California as the ultimate end-state for any jurisdiction that permits a large amount of illegal immigration, and would like to understand if this conclusion has been validated or supported by analyses that look at other jurisdictions with large amounts of illegal immigration. A previous post considered this question in the context of comparisons between the US states, but for this post, I’m interested in international comparisons.

I’m fine with somewhat unsophisticated stabs at this analysis: breadth can be just as important as depth, and given the rather poor state of knowledge about the ultimate impacts of high levels of immigration, any research or analysis can prove valuable. My understanding is that France and Germany both have ongoing processes for unauthorised immigrants to regularise their status, and considering the widespread use of discrete amnesties in other European countries’ immigration policies, it would be interesting to see if there are any different impacts, and what people’s thoughts are on the impact of either option has been relative to a counterfactual where these European countries did not regularise any unauthorised immigrants whatsoever.

The US has only implemented one amnesty of note, in 1986. In Europe, amnesties are much more common. Poland for example announced in 2011 its third amnesty since 2003 (though to be fair, Poland has much fewer unauthorised immigrants than the US). Surely there has been some study of the impacts of these amnesties, or even some informal comparison that correlates the number of unauthorised immigrants to various socioeconomic indicators at the country level. And I’m only really somewhat aware of amnesty policies in Europe: I’m not even sure what arrangements, if any, exist in other continents.

And going beyond amnesty, large numbers of unauthorised immigrants exist in various countries. The number of unauthorised immigrants could similarly be correlated to various indicators, as informal analyses in the US often do with California. If we rank countries by the percentage of their population that is present without legal authorisation, how would that compare to the ranking of countries by GDP per capita, or public debt per capita, or rankings in international educational aptitude surveys like PISA or TIMMS? What about ranking countries by the number of previously unauthorised immigrants whose legal status has since been regularised? Here are two charts (from link #3 at the end of this post) which rank EU countries:

EU-27 regularizations through programsEU-27 regularizations through mechanisms

A quick glance suggests that some of the worse-performing Eurozone economies have been much likelier to offer larger-scale regularisations. However I’m not sure what to make of Germany and France coming in right behind four of the PIIGS on this scale, or of Germany and France topping the list when it comes to mechanism-based (i.e. ongoing) regularisations. Moreover within the PIIGS it also seems quite clear that Italy and Spain are performing better than Greece (I am not sure where Portugal stands). So the correlation, if there is one, does not appear to be that strong.

(Something else that may be food for thought: according to the source for these charts, France once insisted that the EU adopt a continent-wide ban on mass regularisations of the “amnesty” type currently being discussed in the US. This idea was dropped because Spain vetoed it. It would be fascinating to learn what’s driving the different approaches here.)

If anyone knows of material that might be pertinent to the issues I’ve raised here, I would love to hear about it in the comments of this post. We can compile a compendium and document it on an Open Borders page about illegal immigration, and/or the regularisation of unauthorised immigrants. This compendium would be a useful reference for future discussions and blog posts on this site.

I’ll start by listing out some documents I’ve been able to find, and will add to this list as people post in the comments:

  1. Why Countries Continue to Consider Regularization, Amanda Levinson (2005) — a good summary of how different countries approach regularisation/amnesty, and where volumes stood as of 2005
  2. Regularisation programmes in France, Amanda Levinson (2005) — a good summary of the French approach, but no contextualisation with respect to how it compares to elsewhere
  3. Regularizations in the European Union, Kate Brick (2011) — probably comes closest to what I’ve been looking for, has excellent comparisons of different countries’ approaches to regularisation