151. When recalling that, under the inter-American system, the principle of non-refoulement is broader in meaning and scope and, owing to the complementarity that exists in the application of international refugee law and international human rights law, the prohibition of refoulement constitutes the cornerstone of the international protection of refugees or asylees and of those requesting asylum.188 This principle is also a customary norm of international law, 189 and is enhanced in the inter-American system by the recognition of the right to seek and to receive asylum. 152. In this way, such persons are protected from refoulement as a specific means of asylum under Article 22(8) of the Convention, regardless of their legal status or migratory situation in the State in question and, as an integral component of the international protection of refugees, under the 1951 Convention and its 1967 Protocol, Article 33(1) of which establishes that “no contracting State shall expel or return (“refouler”) a refugee in any manner whatsoever to the frontiers of territories where his life or freedom would be threatened on account of his race, religion, nationality, membership of a particular social group or political opinion.”190 153. This necessarily means that such persons cannot be turned back at the border or expelled without an adequate and individualized analysis of their application.191 Before returning anyone, States must ensure that the person who requests asylum is able to access appropriate international protection by means of fair and efficient asylum proceedings in the country to which they would be expelling him. States also have the obligation not to return or deport a person who requests asylum where there is a possibility that he may risk persecution, or to a country from which he may be returned to the country where he suffered this risk (the so-called “indirect refoulement”).192 B.2.c) The minimum guarantees of due process in proceedings to determine refugee status 154. The right to seek and to receive asylum established in Article 22(7) of the American Convention, read in conjunction with Articles 8 and 25 of this instrument, ensures that the person applying for refugee status must be heard by the State to which he applies, with due guarantees and in the corresponding proceeding. 155. Consequently, given the special regulation of the right to seek and to receive asylum, and in relation to the minimum guarantees of due process that must safeguard migratory proceedings (supra paras. 132 to 136), in proceedings relating to a request for recognition of refugee status or, if appropriate, in proceedings that may lead to the expulsion or deportation of an applicant for this status or of a refugee, the States’ obligations to respect and ensure the rights recognized in Article 22(7) and 22(8) of the American Convention must be analyzed in 188 Cf. Executive Committee of the United Nations High Commissioner for Refugees. Conclusions on the international protection of refugees approved by the Executive Committee. 1991 (forty-second session of the Executive Committee) No. 65 (XLII) General conclusions, para. c. 189 Cf. Paragraph 4 of the Declaration of the States parties to the 1951 Convention and/or the 1967 Protocol relating to the Status of Refugees indicates: “Acknowledging the continuing relevance and resilience of this international regime of rights and principles, including at its core the principle of non-refoulement, whose applicability is embedded in customary international law.” 190 Article 33(2) of the 1951 Convention establishes that this benefit “may not be claimed by a refugee who there are reasonable grounds for regarding as a danger to the security of the country in which his is, or who, having been convicted by a final judgment of a particularly serious crime, constitutes a danger to the community of that country.” 191 Cf. IACHR. Report on the situation of the human rights of applicants for asylum under the Canadian system for the determination of refugee status. OEA/Ser.L/V/II.106. Doc. 40. Rev. 1. February 28, 2000, para. 111. 192 Cf. United Nations High Commissioner for Refugees, Submission by the Office of the United Nations High Commissioner for Refugees in the case of Hirsi and Others v. Italy, March 2010, available at: http://www.unhcr.org/refworld/docid/4b97778d2.html, para..4.3.4. 49