It is now a decade since the United Kingdom, along with Germany and Belgium, followed the policy of traditional countries of immigration, such as the United States, Canada and Australia, and introduced legislation which provides for the imposition of fines on carriers for bringing in passengers with incorrect papers.1The Immigration (Carriers' Liability) Act 1987 (“the Act”)2imposed fines on carriers of £1,000 for each illegal entrant brought to the United Kingdom. This fine was doubled in August 1991 and two years later extended to cover passengers without transit visas where these were required.3