In 2005, the US and France were the top two countries in the world accepting asylum seekers—together welcoming almost 90 thousand people. International law dictates how countries define asylum seekers; the process of getting asylum works in pretty much the same way in both countries.

The biggest difference seems to be attitudes towards asylum as a concept, which get expressed in policy decisions. In the United States, since the September 11, 2001, attacks on the World Trade Center, the government is particularly concerned with security. France’s asylum laws are, of course, wrapped up with Europe, and the EU has a tendency to see asylum seekers as illegal immigrants.

This piece looks at how the United States and France (and by extention Europe) figure out who is an asylum seeker. The laws reveal how each country balances its national interests with its humanitarian and international obligations.