We may think of Canada as our kinder, more generous neighbor, but a new study by the Harvard Immigration and Refugee Clinic indicates that the country’s has adapted a decidedly un-Canadian approach to refugees. The authors of the study write that Canada is “systematically closing its borders to asylum seekers and avoiding its refugee protection obligations under domestic and international law.” Canada’s policies are driving migrants and refugees to the United States, where they may encounter a detention system that “falls far below international law requirements.” According to UN standards, asylum seekers should not be detained at all, but the authors write that the United States repeatedly holds refugee applicants in custody for months, and even years, at a time.

It’s hard to say which country comes across better—or worse—in the study. Since last year, when Canada passed a series of reforms to its refugee system, it has implemented various bulwarks to deter refugees from even arriving at the Canadian border. The Safe Third Country Agreement makes it almost impossible to enter Canada by land, as it prohibits asylum seekers who first set foot in the States to then apply for refugee claims in Canada (the agreement also applies to those who first arrive in Canada and then apply for US residency, but for geographic reasons, that scenario is far less frequent). Canadian Liaison Officers are now able enforce border laws from foreign posts—they’re stationed in forty-nine different locations—and intercept more than 4,000 people from boarding a plane or a boat to Canada each year. (As a point of comparison, US Customs and Border Patrol officers with a similar set of responsibilities can be found in just eight countries.) Canada has also been found, per the report, to outsource immigration enforcement to airlines and various private transport companies, meaning that asylum seekers don’t even have the opportunity to discuss their case with an immigration agent who may be more empathetic when, say, a passport is missing or a visa has been denied. Private companies, meanwhile, have been found to treat passengers inappropriately and to deny entry based on minor inconsistencies or gaps in identification papers. Canada’s approach is referred to as “pushing the border out”—or creating physical barriers far away from state lines, making the border more ephemeral yet more exclusive.

The problems described with the US refugee system have little to do with admission and more to do with the system asylum seekers must navigate after they arrive. Many refugees to the United States come from countries that have been granted Temporary Protected Status, or TPS, which means that their citizens are able to live and work in the United States for a limited amount of time. Haiti, Somalia, and Syria have all recently been granted TPS; last week, twenty-nine congressmen sent a letter to the Department of Homeland Security recommending that the Philippines receive TPS following the devastation caused by the typhoon. All other asylum seekers are unable to seek employment or apply for government benefits until their application is approved; while you wait, you have no other choice but to scramble, a dynamic recently investigated by Human Rights Watch. The US immigration detention system frequently holds asylum seekers in inhumane conditions for lengthy amounts of time. Last week, the organization Detention Watch Network released a report showing that immigrants in detention lack access to medical care, are served maggot-infested food and are not infrequently held in solitary confinement. (In September, Immigration and Customs Enforcement, or ICE, issued a statement calling for more limited and more monitored use of solitary confinement in immigration detention centers, but it’s unclear how the new policy has been implemented as ICE, citing “privacy standards,” makes very little information available.)

Canada and the United States aren’t the only countries with a less-than-inviting policy for refugees. Last week, the government of Israel voted to give $3,500 to any African migrant who elected to leave the country and to build a new detention facility for those who chose to stay. “We are determined to remove the tens of thousands of infiltrators who are here,” said Prime Minister Benjamin Netanyahu. But what of the so-called “infiltrators” unable to return to the countries where they were born?