Published: March 12, 2025
- Denaturalization
- Revocation
- Prolonged Absence/Non-Compliance
- Renunciation
- Dual Citizenship Restrictions
- Endevio
Holding a second citizenship offers numerous advantages, such as enhanced global mobility, expanded business opportunities, and access to social services in multiple countries. However, it's crucial to understand that second citizenship is not always irrevocable. Various legal frameworks and compliance requirements across countries can lead to the loss of citizenship under specific circumstances. This article delves into the risks and legalities associated with losing second citizenship, focusing on denaturalization, revocation laws, and compliance requirements in different countries.
1. Denaturalization: Loss of Second Citizenship Due to Fraud or Misrepresentation
Denaturalization refers to the revocation of citizenship that was acquired through fraudulent means, false representation, or the concealment of material facts during the naturalization process. Many countries have stringent policies to ensure that citizenship is granted only to individuals who meet all legal requirements without deception.
Examples of Denaturalization Cases
- United States: In the U.S., individuals who are found to have procured citizenship illegally or concealed relevant facts can be subjected to denaturalization. For instance, if an individual worked illegally in the U.S. before naturalization and concealed this information, it could be grounds for revocation of citizenship. A notable example involves Elon Musk, who, according to legal experts, could face denaturalization if it's proven that he falsified information during his immigration process. Additionally, in 2018, Baljinder Singh, also known as Davinder Singh, became the first individual to be denaturalized under Operation Janus in the United States. He had failed to disclose a prior deportation order and had used multiple identities to obtain citizenship. This concealment led to the revocation of his U.S. citizenship.
- Austria: A notable example involves a Ukrainian individual who was stripped of Austrian citizenship for refusing to sing the national anthem during the naturalization ceremony. This incident underscores Austria's emphasis on adherence to national customs and the importance of compliance with cultural norms during the naturalization process.
How to Avoid It
To mitigate the risk of denaturalization, it's imperative to provide accurate and truthful information during the citizenship application process. Engaging reputable legal advisors can help navigate complex application requirements and ensure compliance with all legal stipulations.
2. Revocation of Second Citizenship Due to National Security or Criminal Activities
Several countries have enacted laws that permit the revocation of second citizenship from individuals who pose a threat to national security or engage in serious criminal activities, such as terrorism or espionage.
Examples of Countries with Strict Revocation Laws
- Malta: While specific cases of revocation due to national security concerns are less publicized, Malta's citizenship laws allow for revocation if an individual is found to be disloyal to the country or poses a threat to national interests. This measure ensures the protection of public safety and the maintenance of national security. Additionally, individuals who obtained Maltese citizenship through the Citizenship by Naturalisation for Exceptional Services by Direct Investment (CES) program can have their citizenship revoked if they are found to have misrepresented information during the application process or committed crimes post-naturalization.
- United Kingdom: The UK has the authority to revoke citizenship from individuals involved in activities that threaten national security, including terrorism and espionage. British nationality laws allow for revocation even if it renders an individual stateless in certain extreme cases. The UK has used this power in cases related to individuals accused of joining extremist groups abroad. For instance, Shamima Begum, who left the UK in 2015 to join the Islamic State in Syria, had her British citizenship revoked on national security grounds in 2019. Despite multiple appeals, including a recent attempt to have her citizenship reinstated, the UK Supreme Court refused to hear her appeal, maintaining the revocation.
- Austria & France: Austria permits the revocation of citizenship if an individual voluntarily joins a foreign military force without prior approval from the Austrian government, which can be considered a national security risk. France also has provisions to revoke citizenship from individuals who engage in acts of terrorism or crimes against state security, particularly for naturalized citizens.
- Switzerland: In 2019, Switzerland revoked the citizenship of a dual national for the first time. The individual had been convicted of conducting propaganda and recruiting fighters for an Islamist terrorist organization, actions that posed a serious threat to national security.
How to Avoid It
Adherence to the laws of the host country and maintaining a clean legal record are essential. Individuals who obtain second citizenship through investment or naturalization should be especially cautious about compliance requirements. Staying informed about the political and legal climate of the country where you hold citizenship can also help mitigate risks.
3. Loss of Second Citizenship Due to Prolonged Absence or Non-Compliance
Certain countries impose residency and compliance requirements for naturalized citizens. Failure to meet these conditions may lead to revocation or non-renewal of citizenship.
- Portugal: Portuguese nationality law has undergone various amendments, and while it allows for dual citizenship, there are residency requirements for naturalization. Failure to maintain a genuine connection to the country, such as prolonged absence without maintaining ties, could potentially impact one's citizenship status.
How to Avoid It
Be aware of your second citizenship's residency requirements, tax obligations, and other compliance mandates. Consulting with legal professionals can help ensure adherence to these obligations and prevent unintentional forfeiture of citizenship.
Suggested Reading: Portugal Golden Visa
4. Renunciation or Voluntary Relinquishment of Second Citizenship
Some individuals voluntarily renounce their second citizenship due to various reasons, including tax liabilities, military service obligations, or political considerations. In some cases, renunciation may also be necessary to comply with the laws of a country that does not permit dual citizenship.
Examples of Countries with Strict Renunciation Policies
- United States: The U.S. imposes an exit tax on high-net-worth individuals who renounce their citizenship, making the process financially significant. This measure ensures that individuals meet their tax obligations before relinquishing their citizenship. Additionally, renouncing U.S. citizenship can have long-term consequences, such as restrictions on re-entry and the potential loss of certain financial benefits.
- Singapore & Japan: Singapore requires its citizens to renounce any foreign citizenship upon reaching adulthood. Similarly, Japan mandates that individuals with multiple nationalities choose one before turning 22, effectively requiring renunciation of other citizenships.
- Caribbean Nations: Many Caribbean countries that offer citizenship by investment programs allow renunciation if individuals decide they no longer need their second citizenship. However, this process must be done formally and in accordance with local laws.
How to Avoid It
If you wish to retain your second citizenship, it's crucial to understand the legal and tax implications before making any decisions regarding renunciation. Some individuals choose to restructure their financial holdings or adjust their residency status instead of renouncing. Consulting with legal and financial advisors can provide clarity on the consequences of such actions.
Suggested Reading: Caribbean Citizenship by Investment Programmes
5. Dual Citizenship Restrictions in Some Countries
Not all countries recognize or allow dual citizenship. Some nations require individuals to relinquish their original nationality upon obtaining a second passport.
Examples of Countries with Dual Citizenship Restrictions
- Austria: Austrian nationality law substantially restricts dual citizenship. In general, Austrian citizens who voluntarily acquire another nationality automatically lose their Austrian citizenship unless they obtain prior permission to retain it. Exceptions are made in specific cases, such as for individuals who acquire another nationality at birth or those who are unable to renounce their existing nationality.
- India & China: India does not allow dual citizenship; instead, it offers an Overseas Citizenship of India (OCI) status, which grants certain privileges but is not equivalent to full citizenship. Indian citizens who acquire another nationality must renounce their Indian citizenship. Similarly, China does not permit dual citizenship, and individuals who obtain foreign nationality automatically forfeit their Chinese citizenship.
How to Avoid It
Research the dual citizenship policies of your host country before applying for a second passport. Some individuals opt for residency permits instead of citizenship to maintain flexibility.
Suggested Readings: Understanding Dual Citizenship and Countries that Allow Dual Citizenship
Endevio’s Due Dilligence Measures
Agenzija Endevio Ltd is authorised to act as an Accredited Agent by Agenzija Komunita Malta through licence number AKM-AGEN. At Endevio, we prioritize comprehensive due diligence to ensure that individuals acquiring second citizenship—particularly in countries like Malta—meet all legal requirements and remain fully compliant with national security regulations. Our multi-tiered screening process involves background checks, financial audits, and verification of all supporting documents to prevent any risks that could lead to revocation. By thoroughly assessing applicants before submission, we help ensure that citizenship remains secure and in good standing. Additionally, we provide ongoing guidance on compliance requirements to help our clients maintain their new nationality without legal concerns.
Final Thoughts
While second citizenship offers significant benefits, it is not always permanent. Governments can and do revoke citizenship under specific circumstances. Staying informed, ensuring compliance with local laws, and seeking legal counsel when needed are crucial steps in protecting your second nationality. If you hold or are considering obtaining a second passport in countries like Malta, Portugal, Austria, or various Caribbean nations, proactive measures can help you secure your status and enjoy the advantages of global mobility without unexpected legal complications. Contact us today at Endevio for expert guidance to mitigate the risks involved with acquiring a second citizenship.
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