Liliana Lyra Jubilut, Professor, Universidade Católica de Santos and Flávia Oliveira Ribeiro, PhD Candidate, University of Cologne
This paper seeks to debate whether humanitarian visas can be considered a form of externalization, as they represent the use of visa policy as a means of externalizing border control. The analysis focuses on Brazil’s policies and practices of humanitarian visas, beginning with the response to persons from Haiti, extending to those affected by the Syrian conflict, and more recently to those fleeing Afghanistan and Ukraine. It discusses the legal and procedural aspects of these visas and assesses the potential benefits and challenges of using humanitarian visas as an externalization mechanism, considering the balance between migration control and humanitarian protection. The findings suggest that, despite issues due to their ad hoc nature and implementation challenges, humanitarian visas can provide safe access to safe territories to vulnerable forced migrants, and expedite regular migratory status, and, in doing so outside the state’s territory, might be a novel approach to externalization, combining states’ interests in border control and the (human) rights of refugees.
The Visas Regime and its impacts on Refugees
In general, mobility is regulated and travelers need identity documents, usually passports, and, often, visas to enter foreign countries, depending on which nationality they have and their destination.[1] The 1948 Universal Declaration of Human Rights sets out the right to leave and enter one’s own country (article 13), which has been understood as the founding act of International Migration Law (IML).[2] However, there are no provisions in International Law (general or more specifically in Human Rights or in migration related norms) guaranteeing the right to enter foreign territories.[3] The right to enter is primarily a product of treaty law, unlike the customary nature of the right to leave,[4] and depends on discretionary requirements set out by each State.
Visa restrictions on passport holders from certain countries are among the most significant mechanisms by which States exercise their sovereign right to control entry into their territory.[5] The visa system was established as an effort to address the often-challenging balance between enhancing economic and political interests, on the one hand, and maintaining migration control and security, on the other.[6]
It is an interest-based and political decision. Reducing or lifting visa restrictions for citizens of certain countries must be understood within the broader context of bilateral or multilateral relations.[7] Visa restrictions are the norm globally, while visa waivers are the exception.[8] At the same time, visa regimes have become an important instrument of migration control in practice.[9]
In recent decades, visa restrictions have often been used as an important policy tool to deter the admission of undesirable migrants into national territory.[10] Thus, visas can be considered a core instrument in the migration policy agenda.[11] Moreover, visas can be understood as tools of externalization as they implement the transfer of admission control to the embassies of countries of origin or legal residence which processes and grants the visas. This has proven to be an efficient instrument of external border control.[12]
Visa regimes are unequal as they can be expensive, bureaucratic, and time-consuming,[13] and often lack justification,[14] especially in cases of denial. Discretion[15] is at the core of the system,[16] which operates on the basis of a rights’ expectation, given that even if the visa is obtained, the final decision on entering a foreign country is made at arrival, at border control, with the possibility of denial.[17] In reality, however, this risk is small, which is why the preselection role of the visa restriction system is so powerful.[18]
Once the visa has been obtained and the entry into the country has been made, in the case of a non-temporary stay, a regularization of migratory status must be sought. In this sense, visa restriction policy also aims to strictly control migration by trying to avoid visa overstays, i.e. people who have been granted permission to enter the country but then stay in an undocumented manner.[19]
Discretion also lies in the fact that visa regulations often fall under executive powers that do not require legislative changes, allowing governments to make modifications through administrative measures, thus avoiding parliamentary debates.[20] Due to this, visas are even more attractive as a migration policy tool.[21]
The visa system has a very unequal impact on people of different nationalities.[22] Moreover, the externalization of border control through visa restrictions may particularly affect asylum seekers,[23] who necessarily require territorial access to a secure country in order to claim their right to protection.[24] Even though International Law assures rights for refugees to try and mitigate the visa requirements (such as allowing for the dismissal of the need of a visa and/or the non-criminalization of irregular entries),[25] in reality, in several instances visas are very much still needed.
The Framework and Role of Humanitarian Visas
In this context, and in light of trying to balance the need of border control with human rights,[26] humanitarian visas have been established and used since the last decade to facilitate safe access to safe territories for forcibly displaced persons, including asylum seekers (and, therefore, refugees).[27] Humanitarian visas, are thus, both a form of complementary protection[28] (i.e. benefiting those persons who fall outside the scope of International Refugee Law[29]) but also a protection tool for refugees (and therefore as complementary pathway for protection).
Humanitarian visas can be understood as visas granted by States on the bases of humanitarian concerns or grounds, which in general have fewer of facilitated requirements. As visas in general, they are not regulated internationally but stem from states’ practices. Humanitarian visas have gained relevance in context of mixed migration flows,[30] in preventing non-refoulement,[31] and in expanding refugees’ protection.
While refugees should not need a visa to enter a safe territory to seek protection,[32] humanitarian visas can enable them to travel long distances on modes of transport that require a visa to board.[33] Moreover, humanitarian visas allow asylum seekers to enter safe territories to apply for refugee status recognition, and offer opportunities to grant legal status even to persons who are outside the refuge regime.[34] This derives from the fact that humanitarian visas can be either entry permits but in some instances can also grant regular residency permits.[35]
Humanitarian visas are thus relevant tools in broadening the scope of protection for forced migrants (including refugees).[36] Many countries in the Latin America have included humanitarian visas in their migration laws and/or practices,[37] one of them being Brazil.
Brazil’s Implementation of Humanitarian Visas
In Brazil, humanitarian visas were first introduced in 2012 in response to the need for international protection of persons fleeing the aftermath of the 2010 earthquake in Haiti.[38] These humanitarian visas have less stringent requirements than those for regular tourist visas, as they only demand a valid passport (even if it is less than six months from expiration), proof of residence in the affected country, and proof of good conduct.[39] In the absence of a valid passport, Brazilian embassies will issue a laissez-passer.[40] Moreover, other usual formal requests for a Brazilian tourist visa, such as the submission of bank statements, letters of invitation and a round-trip airline ticket, are dismissed.[41]
Initially, visas had to be obtained at the Brazilian Embassy in Port-au-Prince, and there was a quota of visas to be issued each year.[42] Both restrictions were later lifted.[43] After that, any number of humanitarian visas could be obtained at any Brazilian consulate.[44]
In 2013, as a result of the conflict in Syria, Brazil began granting humanitarian visas to people affected by this crisis.[45] In this instance, the wider provisions of the adopted resolution made it possible to grant visas not only to Syrians, but also to persons affected by the conflict, thus allowing minority groups such as Palestinians and Kurds to benefit from the Brazilian humanitarian visa program.[46]
Nevertheless, upon entering Brazilian territory, beneficiaries of both these schemes did not have guaranteed legal migratory status.[47] The most used path for regularization was seeking refugee status.[48] However, Brazil’s National Committee on Refugees (CONARE), the organ vested with Refugee Status Determination responsibility in the country, didn’t recognize the situation faced by Haitians as grounds for refugee status, even if Brazil adopts the regional definition established by the 1984 Cartagena Declaration on Refugees, that allow for recognition based on gross and generalized human rights violations.[49] Instead, the Brazilian National Immigration Council (CNIg), which is responsible for ruling on cases that are not covered by other legislation, granted residency permits for Haitians on humanitarian grounds.[50] In contrast to this, the Syrians’ refugee statuses were recognized.[51]
In light of these policies, in the negotiation and drafting for Brazil’s new migration law, the ad hoc mechanism of humanitarian visas was brought up as a complementary pathway that should be introduced in the legislation.[52] In 2017, said law was adopted (Law 13.445 of 2017[53]) and established humanitarian reception as a principle and guideline of Brazilian migration policy (art. 3) and a more permanent legal foundation for humanitarian visas (art. 14).[54]
Nevertheless, the use of humanitarian visas persists on a case-by-case basis for specific populations in response to specific contexts,[55] with Brazil’s administrative bodies continuing to issue case-by-case regulations and adopting the humanitarian entry visa or residency permit selectively.[56]
This has happened in two cases since the new 2017 migration law. In September 2021, the Brazilian government enacted an ordinance pertaining to temporary visas and residency permits for humanitarian purposes for Afghans.[57] The visa is valid for 180 days, after which there is a requirement to register with the migration authority, following which a temporary residence for a period of two years will be granted.[58]
A similar process was initiated for Ukrainians in March 2022.[59] In other words, the most recent migratory flows were not only granted safe access to safe territory but were also guaranteed temporary residency permits for humanitarian reasons, while keeping the possibility of applying for refugee status.
Humanitarian visas have become a significant aspect of Brazilian migration policy, with considerable potential for becoming a long-term feature of the country’s approach to migration. As their granting occur outside the country’s territory, they can be seen as a tool of externalization, at least in its common sense.
Evaluating the Practice of Humanitarian Visas for Border Externalization
As defined by the United Nations High Commissioner for Refugees (UNHCR), externalization of international protection refers to measures implemented or having effects outside a state’s territory that prevent asylum-seekers from reaching a country or region and/or from claiming or enjoying protection there.[60]
Consequently, externalization is associated with an attempt to prevent migrants from arriving in the countries, usually of the Global North.[61] This involves the transfer of responsibility for migration control and asylum procedures to other countries.[62]
Hence, humanitarian visas may be regarded partially as a form of externalization, given that they exemplify the utilization of visa policies, granted by embassies located in other countries, as a mechanism for border control. However, in the other two instances, namely the outsourcing of protection to another country and the goal of preventing refugees from accessing safe territory, humanitarian visas do not seem to meet the requirements of externalization, since it is the own country that issues the visas with an aim of facilitating the access of forced migrants to safe territory.
In light of this, an argument could be put forward that humanitarian visas could be a good practice in migration governance and in the reframing of externalization in a manner conducive to protection, as it balances border control and human rights, i.e. States’ interests and refugees’ needs and rights, through measures taking place outside the territory of the State.
Even so, from a protection standpoint, the implementation of humanitarian visas presents certain challenges. First, there is the uncertainty, precariousness and legal insecurity that accompany any visa, including those designated for humanitarian purposes.[63] These visas are established through resolutions issued by administrative organs of the Executive,[64] which may lead to expiration, amendment, or revocation depending on the government’s political will.[65]
Secondly, humanitarian visas have been established and applied in ad hoc situations based on nationality or specific contexts.[66] This raises concerns about potential violations of the principles of equality and non-discrimination.[67]
These same challenges, however, can be viewed as an a priori asset when assessed through the lens of migration control, as they may offer a more politically viable alternative to traditional protection measures,[68] and a positive example of externalization: due to the appeal of external border control and the flexibility of humanitarian visas, the model could appear feasible to states that might replicate it and adopt and adapt humanitarian visas to their interests and realities, while granting protection.[69]
A third challenge comes in the context of the implementation of humanitarian visas, especially in practical terms and once refugees arrive in the country. For instance, since September 2021, the granting of visas to Afghans has demonstrated a lack of preparedness on the part of the Brazilian authorities to receive the influx of migrants.[70] There was a lack of monitoring in terms of the number of visas that had been issued and the number of individuals who were expected to arrive in Brazil. Moreover, there was no arrival policy, which resulted in the establishment of precarious tent encampments of Afghans at Brazil’s largest international airport on repeated occasions over the course of several months.[71] In October 2023, in an effort to address the lack of planning and instead of providing adequate shelter (thus focusing on the policies in Brazil), the government opted to suspend the issuance of humanitarian visas (i.e. focusing on the external measure). The lifting of the suspension is contingent on the compilation of a comprehensive list of entities and the corresponding shelter vacancies for incoming migrants in Brazil.[72]
Conclusion
It can be argued that humanitarian visas have been beneficial to forced migrants, including refugees.[73] Humanitarian visa have been pivotal in enhancing safe access to safe territories and have guaranteed temporary residence permits for humanitarian grounds. Furthermore, these visas allow applicants to pursue the recognition of their refugee status.[74]
Moreover, humanitarian visas are based on humanitarian concerns and aim to assist forced migrants, thereby shifting the migration narrative from security and economic concerns to a more human-centered perspective.[75]
As their granting takes place outside the state’s territory, they can be seen as measures of externalization. In this sense, and taking into consideration their nature and framework, as well as the definition of externalization, humanitarian visas could also pivot the debates on externalization, assisting in finding a balance between states’ interests in border control and the (human) rights of refugees. Considering that externalization is a reality, changing it might be a good way forward, and in this context humanitarian visas can be seen as good practices that could be embraced and replicated.[76]
Footnotes
[1] Neumayer, E. (2006), Unequal access to foreign spaces: how states use visa restrictions to regulate mobility in a globalized world. Transactions of the Institute of British Geographers, 31: 72-84, 72.
[2] Chetail, V. (2019). International Migration Law. Oxford University Press, 77-78.
[3] Chetail, International Migration Law, 92; Neumayer, Neumayer, Unequal access to foreign spaces: how states use visa restrictions to regulate mobility in a globalized world, 72; Freier, L. F. & Holloway, K. (2019), The Impact of Tourist Visas on Intercontinental South-South Migration: Ecuador’s Policy of “Open Doors” as a Quasi-Experiment. International Migration Review, 53(4), 1171-1208, 1172.
[4] Chetail, International Migration Law, 92.
[5] Neumayer, Unequal access to foreign spaces: how states use visa restrictions to regulate mobility in a globalized world, 73.
[6] Neumayer, Unequal access to foreign spaces: how states use visa restrictions to regulate mobility in a globalized world, 73.
[7] Czaika, M., de Haas, H. & Villares-Varela, M. (2018), The Global Evolution of Travel Visa Regimes. Popul Dev Rev., 44(3): 589-622, 594.
[8] For instance, and only as examples, of the 193 countries recognized by the United Nations, the USA does not require visas from 41 countries, Germany from 92 countries, and Brazil from 94 countries, i.e. the minority in all 3 cases. This suggests that the not requiring a visa is not a general practice, but rather an exception. (US Homeland Security. Visa Waiver Program Requirements. Available at: https://www.dhs.gov/visa-waiver-program-requirements; Germany’s Federal Foreign Office. Overview of visa requirements/exemptions for entry into the Federal Republic of Germany. Available at: https://www.auswaertiges-amt.de/en/visa-service/-/231148; Brazil’s Ministry of Foreign Affairs. Visa Requirements by Country. Available at: https://www.gov.br/mre/pt-br/consulado-atlanta/english/visas/visa-requirements-by-country).
[9] Czaika, de Haas & Villares-Varela, The Global Evolution of Travel Visa Regimes, 592.
[10] Czaika, de Haas & Villares-Varela, The Global Evolution of Travel Visa Regimes, 592.
[11] Czaika, de Haas & Villares-Varela, The Global Evolution of Travel Visa Regimes, 592.
[12] Laube, L. (2019), The relational dimension of externalizing border control: selective visa policies in migration and border diplomacy. CMS 7, 29, 2 and 4.
[13] Neumayer, Unequal access to foreign spaces: how states use visa restrictions to regulate mobility in a globalized world, 74.
[14] Neumayer, Unequal access to foreign spaces: how states use visa restrictions to regulate mobility in a globalized world, 74.
[15] Neumayer, Unequal access to foreign spaces: how states use visa restrictions to regulate mobility in a globalized world, 74.
[16] Even though International Law has created rules in terms of visa discretion (both granting and entry), human rights (mainly through its principles) have at least set a standard of non-discrimination, meaning that States are free to set their visa rules, but once they do so, they must apply them in a non-discriminatory and equitable manner.
[17] Neumayer, Unequal access to foreign spaces: how states use visa restrictions to regulate mobility in a globalized world, 75.
[18] Neumayer, Unequal access to foreign spaces: how states use visa restrictions to regulate mobility in a globalized world, 75.
[19] Czaika, de Haas & Villares-Varela, The Global Evolution of Travel Visa Regimes, 592.
[20] Czaika, de Haas & Villares-Varela, The Global Evolution of Travel Visa Regimes, 593.
[21] Czaika, de Haas & Villares-Varela, The Global Evolution of Travel Visa Regimes, 592.
[22] Neumayer, Unequal access to foreign spaces: how states use visa restrictions to regulate mobility in a globalized world, 73.
[23] This paper will use both asylum seekers and refugees in its description of humanitarian visas, considering that the decision to recognize refugee status is declaratory and not constitutive. In light of this, all asylum seekers are potential refugees. And in the context of border control, this fact is relevant, whereas the distinction between them should not hinder rights. Moreover, given that refuge is a manner of implementing the right of asylum, in a series of the externalizations of asylum this distinction also seems to pale in comparison to protection needs.
[24] Laube, The relational dimension of externalizing border control: selective visa policies in migration and border diplomacy, 4.
[25] As, for instance, established in articles 28 and 31 of the 1951 Convention relating to the Status of Refugees.
[26] Chetail, International Migration Law, 76.
[27] Jubilut, L. L., Andrade, C. S. M. de & Madureira, A. de L. (2016), Humanitarian visas: building on Brazil’s experience. FMR 53, 76-78; Freier, L. F. & Luzes, M. (2021), How Humanitarian Are Humanitarian Visas? An Analysis of Theory and Practice in Latin America, in Jubilut, L. L., Marcia Vera Espinoza, M. V. & Mezzanotti, G., Latin America and Refugee Protection. Regimes, Logics, and Challenges (Berghahn Books), 316-335. 320.
[28] Jubilut, L. L. (2017), Humanitarian Alternative Pathways for Protection for Forced Migrants in Latin America?, in McAuliffe, M. and M. Klein Solomon (Conveners), Ideas to Inform International Cooperation on Safe, Orderly and Regular Migration, IOM: Geneva. 120. Available at: file:///Users/Liliana/Downloads/migration_research_leaders_syndicate.pdf
[29] Freier & Luzes, How Humanitarian Are Humanitarian Visas? An Analysis of Theory and Practice in Latin America, 319.
[30] Jubilut, Humanitarian Alternative Pathways for Protection for Forced Migrants in Latin America?, 120.
[31] Freier & Luzes, How Humanitarian Are Humanitarian Visas? An Analysis of Theory and Practice in Latin America, 316; Jubilut, L. L., Madureira, A. de L. & Levy, R. V. (2018), Proteção Complementar e Deslocados Ambientais: Itinerários, Limites e Possibilidades, in Jubilut, L. L. et al., Refugiados Ambientais (Boa Vista: Editora da UFRR), 292-321. 309.
[32] Supra note 25.
[33] Jubilut, Humanitarian Alternative Pathways for Protection for Forced Migrants in Latin America?, 119.
[34] Freier & Luzes, How Humanitarian Are Humanitarian Visas? An Analysis of Theory and Practice in Latin America, 319.
[35] Jubilut, Humanitarian Alternative Pathways for Protection for Forced Migrants in Latin America?, 119.
[36] Jubilut, Humanitarian Alternative Pathways for Protection for Forced Migrants in Latin America?, 119.
[37] Freier & Luzes, How Humanitarian Are Humanitarian Visas? An Analysis of Theory and Practice in Latin America, 316.
[38] Brasil, Resolução Normativa nº 97 do Conselho Nacional de Imigração de 12 de janeiro de 2012. 95-96. Available at: https://www.acnur.org/portugues/wp-content/uploads/2018/02/Colet%C3%A2nea-de-Instrumentos-de-Prote%C3%A7%C3%A3o-Nacional-e-Internacional.pdf
[39] Jubilut, Andrade & Madureira, Humanitarian visas: building on Brazil’s experience, 76-78.
[40] A laissez-passer is a travel document issued by a state to replace a passport when, for some reason, it is impossible to obtain a passport or when the passport is not accepted by the authorities in the destination country because, for example, it has expired.
[41] Jubilut, Andrade & Madureira, Humanitarian visas: building on Brazil’s experience, 76-78.
[42] Jubilut, Andrade & Madureira, Humanitarian visas: building on Brazil’s experience, 76-78.
[43] Jubilut, Andrade & Madureira, Humanitarian visas: building on Brazil’s experience, 76-78.
[44] Jubilut, Andrade & Madureira, Humanitarian visas: building on Brazil’s experience, 76-78.
[45] Brasil, Ministério da Justiça e Segurança Pública & Secretaria Nacional de Justiça & CONARE – Comitê Nacional para os Refugiados, Resolução Normativa nº 17, de 20 de setembro de 2013. Available at: https://www.gov.br/mj/pt-br/assuntos/seus-direitos/refugio/anexos/resolucao-normativa-n-17-do-conare.pdf
[46] Jubilut, Andrade & Madureira, Humanitarian visas: building on Brazil’s experience, 76-78.
[47] Jubilut, Andrade & Madureira, Humanitarian visas: building on Brazil’s experience, 76-78.
[48] Jubilut, Andrade & Madureira, Humanitarian visas: building on Brazil’s experience, 76-78.
[49] Jubilut, Andrade & Madureira, Humanitarian visas: building on Brazil’s experience, 76-78.
[50] Jubilut, Andrade & Madureira, Humanitarian visas: building on Brazil’s experience, 76-78.
[51] Jubilut, Humanitarian Alternative Pathways for Protection for Forced Migrants in Latin America?, 119.
[52] Spradel, M. A. (2018), Leis migratórias e conservadorismo parlamentar no Brasil: o caso da Lei 13.445, de 2017, in Cadernos de Debates Refúgio, Migrações e Cidadania, v. 13, n. 13, 37-59 (Brasília: Instituto Migrações e Direitos Humanos). 47.
[53] Brasil. Lei n. 13.445 de 24 de maio de 2017. Available at: https://www.planalto.gov.br/ccivil_03/_ato2015-2018/2017/lei/l13445.htm#:~:text=Institui%20a%20Lei%20de%20Migra%C3%A7%C3%A3o.&text=Art.,pol%C3%ADticas%20p%C3%BAblicas%20para%20o%20emigrante.
[54] Brasil. Lei n. 13.445 de 24 de maio de 2017.
[55] Jarochinski Silva, J. C., Franco, A. C. & Sampaio, C. (2021), How Humanitarian Are Humanitarian Visas? An Analysis of Theory and Practice in Latin America, in Jubilut, L. L., Marcia Vera Espinoza, M. V. & Mezzanotti, G., Latin America and Refugee Protection. Regimes, Logics, and Challenges (Berghahn Books), 393-418. 408.
[56] Jarochinski Silva, Franco & Sampaio, How Humanitarian Are Humanitarian Visas? An Analysis of Theory and Practice in Latin America, 408.
[57] Brasil, Portaria Interministerial MJSP/MRE n. 24 de 3 de setembro de 2021. Available at: https://portaldeimigracao.mj.gov.br/images/portarias/PORTARIA_INTERMINISTERIAL_MJSP.MRE_N%C2%BA_24_DE_3_DE_SETEMBRO_DE_2021.pdf
[58] Brasil, Portaria Interministerial MJSP/MRE n. 24 de 3 de setembro de 2021. Available at: https://portaldeimigracao.mj.gov.br/images/portarias/PORTARIA_INTERMINISTERIAL_MJSP.MRE_N%C2%BA_24_DE_3_DE_SETEMBRO_DE_2021.pdf
[59] Brasil, Portaria Interministerial MJSP/MRE n. 28 de 3 de março de 2022. Available at: https://www.in.gov.br/en/web/dou/-/portaria-interministerial-mjsp/mre-n-28-de-3-de-marco-de-2022-383558437
[60] UN High Commissioner for Refugees (UNHCR) (2021), UNHCR Note on the “Externalization” of International Protection. Paragraph 5. Available at: https://www.refworld.org/policy/legalguidance/unhcr/2021/en/121534
[61] Fröhlich, C. & Müller-Funk, L. (2020), Perceiving Migration Crises: A view from the European neighbourhood. German Institute of Global and Area Studies, 6.
[62] Krause, U. (2024), Externalisierung von Asylverfahren durch Deutschland? Politisch unverantwortlich, konzeptionell problematisch und praktisch risikoreich, Externalisierung von Asyl, Ein Kompendium wissenschaftlicher Erkenntnisse. Available at: https://externalizingasylum.info/de/externalisierung-von-asylverfahren-durch-deutschland/
[63] Jubilut, Andrade & Madureira, Humanitarian visas: building on Brazil’s experience, 76-78.
[64] Jubilut, Andrade & Madureira, Humanitarian visas: building on Brazil’s experience, 76-78.
[65] Jubilut, Andrade & Madureira, Humanitarian visas: building on Brazil’s experience, 76-78.
[66] Jubilut, Andrade & Madureira, Humanitarian visas: building on Brazil’s experience, 76-78.
[67] Jubilut, Andrade & Madureira, Humanitarian visas: building on Brazil’s experience, 76-78.
[68] Freier & Luzes, How Humanitarian Are Humanitarian Visas? An Analysis of Theory and Practice in Latin America, 318.
[69] Jubilut, Andrade & Madureira, Humanitarian visas: building on Brazil’s experience, 76-78.
[70] ACNUR (2024), Informativos para a população afegã. Available at: https://help.unhcr.org/brazil/informativos-para-a-populacao-afega/
[71] CNN Brasil (2024), Aeroporto de Guarulhos tem 122 afegãos à espera de acolhimento. Available at: https://www.cnnbrasil.com.br/nacional/aeroporto-de-guarulhos-tem-122-afegaos-a-espera-de-acolhimento/
[72] Brasil (2023), O que mudou na emissão de vistos por acolhida humanitária para afegãos após a publicação da Portaria Interministerial MJSP/MRE nº 42, de 22 de setembro de 2023? Available at: https://www.gov.br/mj/pt-br/assuntos/seus-direitos/refugio/perguntas-frequentes/faq-perguntas-frequentes/afeganistao/mudancas-na-emissao-de-vistos
[73] Jubilut, Humanitarian Alternative Pathways for Protection for Forced Migrants in Latin America?, 117.
[74] Jubilut, Andrade & Madureira, Humanitarian visas: building on Brazil’s experience, 76-78.
[75] Jubilut, Humanitarian Alternative Pathways for Protection for Forced Migrants in Latin America?, 117.
[76] Jubilut, Humanitarian Alternative Pathways for Protection for Forced Migrants in Latin America?, 117.