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November 2019

Migration and Policy: A Comparative Analysis

By Immigration, Recent

The vociferous debate over the expulsion of illegal immigrants from Israel is characterized by many myths and few facts. Opponents of expulsion voice incessant claims about a discriminatory and inhumane immigration policy and contend that Israel fails to comply with international standards, especially concerning its obligations towards the UN Refugee Convention to which it is a signatory.

In order to verify these facts, we examined the treatment of illegal immigrants and asylum seekers in four western countries that, like Israel, are contending with the phenomenon of large-scale illegal immigration: The United States, Australia, the United Kingdom, and Canada.

Our study presents a comprehensive description of the policy regarding illegal immigration as expressed in legislation, government resolutions, and other various programs in the respective countries, while distinguishing between the many concepts that tend to become “scrambled” in the public debate: illegal immigrants, asylum seekers, and refugees.

We gathered the illegal immigration figures for each country (the immigrants’ identity, the circumstances of their arrival etc.) and surveyed the measures adopted by each country during recent years in order to curb illegal immigration. We also examined the policy towards asylum seekers – the ratio of approved refugee status requests, the process of determining their status, resettlement etc.

The main findings are presented below:

Without exception, each of the countries surveyed invests significant resources in attempting to reduce the phenomenon of illegal immigration, occasionally adopting harsh measures, in accordance with the extent of the threat posed by the wave of immigration:

  • Australia combats human smuggling in boats with a “Sovereign Borders” campaign to bolster border enforcement and has restricted immigration to Australia via the establishment of an “Offshore Processing” policy whereby illegal immigrants are dealt with outside the country’s borders until their status is finalized.
  • The United States has invested huge sums in securing its border with Mexico, from “Operation Gatekeeper” in the Clinton era to the construction of a security fence under the Bush administration. President Trump has continued this trend by leading a legal battle to cancel immigration programs that had been implemented under the Obama administration and through the extension of security forces’ authority to detain foreigners.
  • The United Kingdom has focused on limiting negative socio-economic consequences for its citizens that stem from the increased immigration of cheap labor into Britain. For example, the UK passed legislative reforms that penalize companies which choose to employ illegal immigrants and impose restrictions on service provided to immigrants by public institutions.
  • Canada, a country with a proven positive attitude towards immigration, has recently adopted a non-compromising policy towards illegal immigration. During the ten-year term of the previous Prime Minister, Stephen Harper, Canada reinforced its borders and adopted harsher punishments against human smuggling. This policy was relaxed markedly when Prime Minster Trudeau entered office in 2015. Despite the change and following an increasing trend of mass immigration from the US, Canada has recently begun signaling a lack of tolerance towards this phenomenon.


Even more significant differences between the different countries were found when examining treatment of asylum seekers and refugees:


  • Australia refuses the entry of immigrants attempting to breach its borders by boat (regardless of their reasons for immigrating), and transfers them to detention facilities, mainly in Papua New Guinea or Nauru, where they await a decision in their case by the Australian Ministry of Immigration. In general, even if they are eventually recognized as refugees, Australia usually attempts to resettle them in other countries.
  • In comparison to the other countries surveyed, Canada demonstrates an extremely friendly attitude towards asylum seekers, with an especially high ratio of approved asylum requests – close to 70% as of 2017 (an increase of approximately 44% from 2013).
  • The UK has registered a fairly constant ratio of refugee recognition in recent years. Our study reveals that Britain’s relative share of approved refugee requests is tiny compared to the other E.U. countries. The current government has a clear policy according to which every possible effort should be made to restrict the entry of asylum seekers into Britain. In practice, this is achieved by transferring large-scale financial aid to other countries willing to accept refugees and by returning those denied asylum to their country of origin.
  • The US adopted a relatively friendly attitude towards asylum seekers until the beginning of the Trump era. The Obama administration set extremely high refugee quotas that positioned the country as a leader in the resettlement of refugees within its own borders. However, President Trump has striven to reduce these quotas and toughen the conditions for receiving political asylum in the United States.


Regarding the treatment of illegal immigrants, our study found that the holding of asylum seekers and illegal immigrants in detention centers is a common phenomenon. Israel is no different to Australia, Great Britain and the United States in its use of this means, perceived as a central means of deterrent in dealing with illegal immigration. Conditions in these facilities vary from country to country but cannot be described as comfortable in any of them. The underlying assumption of this approach is that a more generous policy will constitute an incentive for future would-be infiltrators.

Ultimately, Israel’s policy towards illegal immigrants is consistent with that of other leading western democracies. An analysis of the situation in Israel reveals an even more complex picture of the immigrant population and it is reasonable to assume that most of them are indeed not refugees. Nevertheless, the survey indicates the absence of formal policy that is expressed by the failure to determine a legally based refugee quota and the inadequate treatment of requests for political asylum.

We believe that the State of Israel must initiate primary legislation that determines the desired refugee quota while weighing up demographic, social, as well as humanitarian considerations. Furthermore, it would, in our opinion, be fitting were the State of Israel to adopt a more comprehensive immigration policy that distinguishes between refugees who are persecuted in their country of origin and fled its horrors and migrant workers seeking better living conditions. Resources and personnel must be allocated to a more thorough clarification of their identity and to enable the relevant authorities to offer quicker and more individual treatment of each request.

The State of Israel must acknowledge the new reality of global immigration and adjust its immigration policy that for years has primarily been directed at the absorption of Jewish immigrants. A more efficient system will assist in the eradication of illegal immigration while at the same time lead to an improvement in the human rights of illegal immigrants until final clarification of their status.


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