Comments on Circumvention of Lawful Pathways

March 28, 2023

KIND strongly supports the Administration’s expansion of lawful pathways for migration and its efforts to ensure safe, humane, and orderly processing and access to protection at the U.S.-Mexico border. The Proposed Rule, however, stands in stark contrast to these aims and would reinforce restrictive approaches that are inconsistent with U.S. and international refugee law and that have proven devastating to the rights and wellbeing of children and other protection seekers. By dramatically limiting asylum eligibility for most individuals who travel through another country in their search for protection, the Proposed Rule would dangerously contract the U.S.’ humanitarian protection system and deepen the vulnerability of children, families, and others seeking safety.


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