Latest / IMI Podcasts / Moreno Wants Americans to Pick One Passport. The World Moved On Decades Ago
Transcript
- 0:00SPEAKER_00: In december twenty twenty five, U.S.
- 0:02SPEAKER_00: Senator Bernie Moreno of Ohio introduced a bill that would ban Americans from holding dual citizenship.
- 0:10SPEAKER_00: The Exclusive Citizenship Act of twenty twenty five would force existing dual citizens to choose one nationality within a year or forfeit their American passport.
- 0:22SPEAKER_00: GovTrack's forecasting model gave it a three percent chance of enactment.
- 0:27SPEAKER_00: That number alone should tell you something about the bill's prospects.
- 0:31SPEAKER_00: But what makes the proposal truly remarkable is not its odds in Congress.
- 0:37SPEAKER_00: It is how spectacularly it runs against the direction of the rest of the planet.
- 0:42SPEAKER_00: Three out of four countries now permit their citizens to acquire a second nationality without forfeiting the first.
- 0:50SPEAKER_00: That figure comes from the MacMede Global Expatriate Dual Citizenship Data Set maintained by Maastricht University, which tracks two hundred countries from nineteen sixty to twenty twenty.
- 1:05SPEAKER_00: A caveat before we go further.
- 1:08SPEAKER_00: Macamede measures only one side of the coin, whether a country strips citizenship from nationals who voluntarily naturalize abroad.
- 1:18SPEAKER_00: It does not capture whether countries require that immigrants renounce when naturalizing.
- 1:23SPEAKER_00: For anyone weighing a second passport, though, that first question is the one that keeps him up at night.
- 1:30SPEAKER_00: Will my home country let me keep what I already have?
- 1:35SPEAKER_00: For governments designing residence and citizenship by investment programs, the answer to that question is what makes the entire product viable.
- 1:45SPEAKER_00: Moreno's bill would place the United States in the company of China, the Gulf States, and a handful of others.
- 1:52SPEAKER_00: It would contradict Supreme Court precedent going back to 1967.
- 1:57SPEAKER_00: Afroyim vs.
- 1:58SPEAKER_00: Rusk.
- 1:59SPEAKER_00: The US government does not even track who holds dual citizenship.
- 2:05SPEAKER_00: An estimated 500,000 to 5.7 million Americans are dual citizens, with some estimates suggesting over 40 million may qualify through ancestry alone.
- 2:18SPEAKER_00: Good luck enforcing that.
- 2:20SPEAKER_00: For governments designing residence and citizenship by investment RCBI programs, the global acceptance of dual citizenship is what makes the entire product viable.
- 2:33SPEAKER_00: To understand just how out of step the Moreno Bill is, it helps to look at how the world got here.
- 2:40SPEAKER_00: Dual citizenship spent most of the twentieth century in the same moral category as tax evasion or draft dodging.
- 2:48SPEAKER_00: The comparison to bigamy was common in legal literature of the period and not always tongue in cheek.
- 2:55SPEAKER_00: International treaties from the nineteen thirties through the nineteen sixties treated overlapping nationalities as a problem to be solved, not a right to be protected.
- 3:07SPEAKER_00: Then the consensus started cracking.
- 3:10SPEAKER_00: Europe's nineteen sixty three Convention on the Reduction of Cases of Multiple Nationality had required signatories to strip citizenship from nationals who acquired another.
- 3:22SPEAKER_00: States began withdrawing from those provisions through the nineteen seventies and nineteen eighties.
- 3:28SPEAKER_00: By nineteen ninety seven, the European Convention on Nationality had flipped entirely, taking a neutral stance on whether multiple nationality was even undesirable.
- 3:39SPEAKER_00: Vink et al, in twenty nineteen, recorded seventy five policy changes in Macamide's binary measure.
- 3:48SPEAKER_00: Of those, eighty five percent were liberalizations, clustered in the nineteen nineties and two thousands.
- 3:55SPEAKER_00: The trajectory, roughly nineteen sixty, approximately thirty eight percent of countries accepted dual citizenship.
- 4:04SPEAKER_00: 1990, approximately 50%, estimate based on the Macamide Trend Line.
- 4:11SPEAKER_00: 2000, approximately 60%, following reforms across Latin America and post Cold War Europe.
- 4:19SPEAKER_00: 2017, approximately 73% per Vink et al.
- 4:25SPEAKER_00: Divi Tuxhi Divdesmit Septindesmit Sechi Procenti per Machimidi's most recent update.
- 4:35SPEAKER_00: What took centuries to build as orthodoxy took about thirty years to dismantle.
- 4:41SPEAKER_00: This one gets overlooked.
- 4:43SPEAKER_00: Once countries allowed mothers to transmit citizenship to their children, the number of people born with two nationalities rose automatically.
- 4:52SPEAKER_00: Stripping citizenship from people whose only act was being born became eventually untenable.
- 5:00SPEAKER_00: Colombia in nineteen ninety one, the Dominican Republic in nineteen ninety four, Costa Rica and Ecuador in nineteen ninety five, Brazil in nineteen ninety six, and Mexico in nineteen ninety eight all reformed their laws within a single decade.
- 5:19SPEAKER_00: In each case, overseas communities had lobbied hard.
- 5:23SPEAKER_00: The old rules forced them to choose between political belonging at home and practical integration abroad.
- 5:31SPEAKER_00: They chose neither.
- 5:32SPEAKER_00: They demanded both.
- 5:34SPEAKER_00: Vink et al found that countries were far more likely to liberalize if their neighbors had already done so.
- 5:41SPEAKER_00: Peer pressure, it turns out, works on nation states too.
- 5:46SPEAKER_00: When military conflict between states was routine, dual nationality raised genuine questions about battlefield loyalties.
- 5:55SPEAKER_00: Once that fear faded, so did the strongest argument for restriction.
- 6:00SPEAKER_00: Most of the world has come around.
- 6:02SPEAKER_00: The Americas and Oceania moved fastest.
- 6:06SPEAKER_00: Most EU member states impose no restrictions.
- 6:10SPEAKER_00: All five Eastern Caribbean CBI jurisdictions recognize dual citizenship.
- 6:16SPEAKER_00: Without that, CBI programs would be functionally unworkable.
- 6:21SPEAKER_00: Nobody acquires a Caribbean passport to give up the one they already have.
- 6:26SPEAKER_00: Germany's june twenty twenty four reform was the most consequential recent shift, eliminating the requirement that naturalizing immigrants renounce their prior citizenship while cutting the residency requirement from eight to five years.
- 6:42SPEAKER_00: Record naturalizations followed.
- 6:45SPEAKER_00: South Africa's Constitutional Court struck down automatic revocation in may twenty twenty five, retroactive all the way to nineteen ninety five.
- 6:55SPEAKER_00: Nigeria, Liberia in 2022, and Malawi in 2019 joined the permissive column.
- 7:04SPEAKER_00: The resistors are a shrinking but stubborn group.
- 7:07SPEAKER_00: China officially prohibits dual citizenship, though enforcement is selective, and anyone in the CBI market can tell you that demand from Chinese nationals for second passports remains among the highest in the world.
- 7:21SPEAKER_00: Japan formally requires that dual nationals choose by age twenty two, though enforcement has been inconsistent.
- 7:30SPEAKER_00: Singapore, Malaysia, and Indonesia also don't recognize dual citizenship, making Southeast Asia one of the world's most restrictive areas when it comes to dual nationality?
- 7:42SPEAKER_00: Austria permits it only where it arises involuntarily.
- 7:46SPEAKER_00: The GCC states all formally prohibit it.
- 7:50SPEAKER_00: Slovakia's twenty ten restriction is the single sharpest reversal in the data set, and it had nothing to do with principle.
- 7:59SPEAKER_00: On the same day that Hungary offered simplified naturalization to ethnic Hungarians abroad, Slovakia, home to roughly five hundred thousand ethnic Hungarians, decreed that any citizen who voluntarily acquired another nationality would lose Slovak citizenship.
- 8:17SPEAKER_00: Geopolitics pure and simple.
- 8:20SPEAKER_00: The law was partially relaxed in twenty twenty two, but the core restriction persists.
- 8:26SPEAKER_00: CBI programs exist because people want to add a nationality, not swap one.
- 8:32SPEAKER_00: Global acceptance of dual citizenship is what makes that possible.
- 8:37SPEAKER_00: And the relationship runs both ways.
- 8:40SPEAKER_00: Every time a CBI program grants citizenship to someone who has never set foot in the country, and nothing bad comes of it, the case for restriction gets a little weaker.
- 8:52SPEAKER_00: The programs, by normalizing multiple nationality on a mass scale, are themselves part of the engine driving this trend.
- 9:01SPEAKER_00: The holdouts are becoming fewer and more isolated.
- 9:05SPEAKER_00: For a market built on layering citizenships, that is the most important structural fact of all.
- 9:11SPEAKER_00: Senator Moreno's bill is not going to reverse sixty years of global liberalization.
- 9:18SPEAKER_00: The holdouts are becoming fewer and more isolated, and the trajectory is not ambiguous.
- 9:25SPEAKER_00: For a market built on layering citizenships, that is the most important structural fact of all.
- 9:33SPEAKER_00: This episode first appeared as an article by Amada Bas on IMIDALY dot com.
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