**3. Discussion**

This section considers the similarities and differences between the UK and The Netherlands. As discussed above, the two countries were chosen on the basis that they represented contrasting approaches to welfare delivery—on the one hand, a regime dominated by neoliberal ideology (UK) and, on the other, one that has adopted an approach influenced by social democracy (Netherlands) which nonetheless limits the inclusionary nature of the welfare state through hard and soft power to preserve a sense of social security for its members (Barker 2018). Given challenges to assumed opposition of neoliberalism and welfarism, this research suggests that the parallel approaches to the policing of the borders through welfare have become accentuated through strategies of attrition, in an unfolding state of exception during a global health crisis.

### *3.1. UK—Coercion and Technologies of Surveillance*

The UK has been extensively criticised for adopting an explicitly punitive approach to migration—for example, by the explicit objective of creating a hostile environment and focusing on immigrant criminality (under Conservative Home Secretaries Theresa May and Priti Patel). Crucially these processes have been extended into welfare policies which have made noncitizens with limited entitlements and precarious legal status increasingly vulnerable to deprivation and homelessness (with rough sleeping used as grounds for removing permission to remain in the UK). As writers such as McKee et al. (2020) have shown, welfare and support agencies (including landlords) have become increasingly recruited in the governance of immigration, using stigma and other forms of power (Tyler 2020) to undermine the legitimacy of claims to migrant rights. These exclusionary processes have been reinforced during the pandemic—as the state of exception (to monitor and limit movement and ensure direct, punitive intervention by the state via information sharing and interagency collaboration) becomes normalised in welfare delivery.

As a consequence of rolling out crimmigration control in the UK since at least 2010 and by enshrining the 'hostile environment' policy in statute within the 2014 and 2016 Immigration Acts, those lacking full citizenship status (particularly those without documented legal status) are increasingly marginalised and excluded from wider society by restricting access to work, welfare and housing. The convergence of criminal and immigration law and its associated exclusionary practices has produced new legal tools available to a range of actors in a variety of institutional contexts, including social welfare providers—amongst others (Bowling and Westenra 2018). Crucially, these social control mechanisms extend far beyond the geographical border to reach deep into civil society, affecting a diverse range of policy areas such as housing, employment, health and education.

Uniquely, within the UK immigration system prior to Brexit, being homeless was the one category into which citizens of countries in the European Union who live in the UK can fall where they are not seen to be exercising their EU member Treaty Rights (as an employee, a jobseeker, a retired person or being economically self-sufficient). The consequence is that, on this basis, a foreign national who ordinarily has the right to live and work in the UK under the European Union's freedom of movement can be subject to administrative removal (deportation) (Serpa 2019). In 2012, 'Operation Nexus'—an interagency collaboration between the police and the Home Office to remove European Economic Area (EEA) nationals without a Right to Reside and/or who have otherwise had encounters with law enforcement—was piloted in London and later rolled out in another six English regions. Between 2012 and 2015, some 3000 'high harm' foreign national offenders (FNOs) were deported under Nexus—many of whom were targeted following engagemen<sup>t</sup> with homelessness and support, rather than criminal justice agencies (Griffiths and Morgan 2017). Deportations enforced under 'Operation Nexus' represent a small but significant part of the deportation machine in the UK which ensnares homeless groups along with (alleged and convicted) criminal offenders, contributing to the deportability of the crimmigrant Other. Based on technologies of surveillance, the UK represents a highly coercive and punitive attitude towards the governance of migration, one which clearly articulates the convergence of criminal and immigration law.

These crimmigration processes have been reinforced through proposals in 2021 (under the Nationality and Borders Bill) including suggestions that migrants should be held in an offshore hub; those arriving without permission could be given prison sentences up to four years (from six months under existing legislation) and those guilty of smuggling migrants could face life sentences (rather than 14 years) (Wadhera 2021). Declaring the asylum system as 'fundamentally broken', Patel has proposed new forms of social control to detect, capture, punish and ultimately banish migrant groups (The Home Office 2021). An explicit connection to crimmigration was demonstrated in Patel's speech in May 2021, criticising local group opposition to deportation and defence of local residents—see, for example, the successful action of local community groups in Glasgow Pollokshields to resist the deportation of two local men (Mackie and Brown 2021). Patel's response was as follows:

I have a message to those who seek to disrupt the efforts of our enforcement officers. They should think about whether their actions may be preventing murderers, rapists and high harm offenders from being removed from our communities— and they should think long and hard about the victims of these crimes.
