The modulation of cosmic ray electrons in the heliosphere plays an important role in improving our understanding and assessment of the processes applicable to low-energy galactic electrons. A full three-dimensional numerical model based on Parker's transport equation is used to study the modulation of 10 MeV galactic electrons, in particular inside the heliosheath. The emphasis is placed on the role that perpendicular diffusion plays in causing the extraordinary large increase in the observed intensities of these electrons in the heliosheath. The modelling is compared with observations of 6-14 MeV electrons from the Voyager 1 mission. Results are shown for the radial intensity profiles of these electrons, as well as the modulation effects of varying the extent of the heliosheath by changing the location of the termination shock and the heliopause and the value of the local interstellar spectrum. We confirm that the heliosheath acts as a modulation 'barrier' for low-energy galactic electrons. The significance of this result depends on how wide the inner heliosheath is; on how high the very local interstellar spectrum is at these low energies (E < 100 MeV) and on how small perpendicular diffusion is inside the inner heliosheath.