Defining Citizenship

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To understand how a better system for managing global mobility might operate, we first have to examine how people are moving around the world today. Passports and visas are one part of the story, but there’s also the matter of status. Governments grant people different rights through statuses like citizen, resident, and asylum seeker, according to the criteria of their choosing. This defines, in legal terms at least, the relationship any of us can have with a place.

Table: Select citizenship by investment programs. Source: Henley & Partners.

The most straightforward status a person can have is to be a citizen of a country. Citizenship is generally granted as a result of birthplace, heritage, or a process called “naturalization,” which refers to adopting a new country and becoming a citizen over time. Citizens can live, work, and play within the borders of a country. They’re entitled to apply for a passport and that passport allows them to travel to other countries. They’re expected to follow the rules and laws of the places they visit, and if they don’t, they can be deported back to their country of citizenship and banned from returning in future.

Most people are citizens of one country, though there are at least 4.2 million people in the world today who are stateless, meaning they hold citizenship of no country at all.* Stateless people are often victims of geopolitics, falling through the cracks as nation-states fail and new ones emerge, global borders shift, or ethnic discrimination takes hold. Without citizenship, they’re denied passports and, by extension, have no global mobility rights.

In some circumstances, citizenship can also be renounced. When a person receives a US passport through naturalization rather than birthright, for example, they can be “denaturalized” if they violate the terms of their citizenship. Stripping someone of their citizen status requires a high burden of proof and usually only happens in the case of serious crime, terrorism, or espionage. When it does happen, the person is deported back to their prior country of citizenship.

Some people have or are entitled to citizenship of more than one country, such as someone with parents from two different countries who was born in a third. For these people, the notion of nationality is often separate from their social, cultural and linguistic identity. Take me as an example: My parents hold two different passports and my husband a third. I spent time growing up in a fourth country, I’m currently residing in a fifth, and I spent time in more than forty countries during my first eight years as a digital nomad.

I’m not alone. Citizenship options have dramatically increased for people across the globe, and no more so than for the generations growing up in the 21st century. In 1960, 62% of countries revoked the citizenship of a person who took on another nationality. By 2020, 76% of countries had adopted the reverse approach, letting their people hold additional passports without repercussions for their citizenship.*

Nearly all recent policy changes have been towards greater tolerance of multiple citizenships, though acceptance has progressed more slowly in Africa and Asia than the rest of the world.* As the people of African and Asian countries join the global middle class, the trend will likely progress faster. There are already signals: Nigeria saw record numbers of its citizens buy second passports as a precaution against the government’s poor handling of COVID-19 and ongoing protests in 2020.* More prosperity means more options in terms of citizenship and mobility. Nigerians aren’t the first ones to explore their options.

Since the 1980s, a secretive global industry worth $25B a year* has sprung up to facilitate the global mobility of the world’s ultra-wealthy. Essentially, people with enough money can buy the right to live almost anywhere. Of course, there exists a thriving black market for stolen and fake passports, but there is also a perfectly legal market to purchase citizenship or residency. Citizenship has become a sought-after commodity for those who can afford it, akin to fine art or diamonds.

The concept of citizenship by investment originated on the Caribbean island of Saint Kitts and Nevis in 1984, when the government launched the world’s first “golden visa” program. Lacking natural resources or soft power influence, Saint Kitts and Nevis came up with a plan to grow its economy by acquiring more citizens. Foreigners who made “substantial” economic contributions would be granted an additional citizenship and a powerful new passport offering favorable visa access to more than 150 countries, including desirable destinations like the UK, the EU, and Singapore.

In exchange for injecting capital into an adopted nation, these wealthy migrants are entitled to residency, which in many countries, can be converted into a second passport in a matter of months. The cost can be as low as $100K but often totals several million dollars.* There’s often no obligation to reside in or even visit the target country. That nickname, “golden visa,” recognizes the reality that only the rich and powerful can afford to buy these free movement privileges.

Other countries were quick to follow Saint Kitts and Nevis’s lead. Today, more than half of the world’s nations have dedicated programs offering citizenship or residency in exchange for cash.* These programs aren’t just limited to tax havens or emerging economies either; many of the world’s advanced economies are willing to sell passports to the highest bidders.

The UK’s Tier 1 Investment Visa offers a route to residency in as little as 10 weeks for anyone with enough cash. The terms are simple: investors buy £2M (roughly US$2.7M) in British corporate bonds, share capital or loan capital in UK-registered companies. In exchange, the UK government grants residency status, allowing them to live and work in the country. After five years, they can apply for permanent residency. Invest £5M, it takes three years, or invest £10M and it takes just two years. From there, converting permanent residency into citizenship—and the coveted British passport that comes with it—takes only one more year.

Nomad Capitalist is a consultancy that helps its clients leverage their global mobility, to “go where they’re treated best.” Before its launch in 2008, the firms helping the wealthy obtain passports were largely localized to a particular country. They acted as intermediaries between passport-seekers and the government, and had the advantage of being physically present in the relevant country. Nomad Capitalist is global, with a strong social media presence and marketing that targets high-earning nomads—those who make at least $500K a year or have an “investable net worth” of $1M. Long-term clients might choose to switch passport providers like the rest of us do cell phone contracts or credit card companies. Nationality is becoming more arbitrary—but citizenship is only one way to move around the world.

Citizens have the right to reside in their country of origin, and depending on international treaties, they may also be able to reside in additional countries. For example, a person with a Belgian passport has the right to reside in Belgium. The EU’s freedom of movement policy also allows a Belgian citizen to reside in any of the bloc’s other 27 member states—by default and without applying for permission. All they have to do is travel to a place and, if they’re staying for longer than a few months, register with the local municipality.

Residency is different from citizenship. While a Belgian person is entitled to residency in Spain, they’re not entitled to Spanish citizenship, and a non-citizen resident has fewer rights than their neighbors who hold both residency and citizenship. Residents can’t necessarily vote in their host country’s national elections and often aren’t entitled to welfare benefits. In the EU, migrants can apply for either permanent residency or a passport from their adopted nation after five years of living and working as a temporary resident.

Similar arrangements exist between members of the East African Community, a regional bloc consisting of Burundi, Kenya, Rwanda, South Sudan, Tanzania, and Uganda, and as part of the Central American Border Control agreement between El Salvador, Guatemala, Honduras, and Nicaragua. In these examples, citizens receive alternative or additional passports in recognition of their global mobility rights.

If a citizen spends a long time away from their country of origin (usually upwards of five years, which is about how long it takes to gain permanent residency elsewhere), they may no longer be entitled to the same rights there as resident-citizens. So, when we talk about citizens, there are actually at least three distinct categories of person we may be referring to:

• non-resident citizens: citizens of a country living outside that country

• resident-citizens: citizens of a country living inside that country

• non-citizen residents: migrants who are not citizens, but live and work in the country

The nuances of these statuses are often lost in debates about immigration and borders. The citizenship and residency routes available to those without inherited wealth or birthright advantages are expensive, complicated, and restrictive. And while straightforward wealth isn’t the only way to level up your global mobility rights, it’s undoubtedly the most efficient.

These contradictions and inequities highlight how murky our modern notions of citizenship, residency, and mobility have become. The question to ask is not whether people should be allowed to exit one country in favor of another—clearly that’s already happening. It’s whether we believe everybody should have access to free movement, or that it should continue to be a privilege for the ultra-wealthy alone, with the heaviest restrictions levied on the least privileged.