Citizenship Planning - Important Points

Citizenship is the relationship between an individual and a sovereign state, defined by the laws of that state and with corresponding duties and rights. It implies the status of freedom with accompanying responsibilities. Citizenship is the most privileged form of nationality, a broader term which is used in international law to denote all persons whom a state is entitled to protect. Nationality also serves to denote the relationship between a state and entities other than individuals; corporations, ships, and aircraft, for example, possess a nationality. Modern concepts of citizenship crystallized in the 18th century during the American and French revolutions, when the term citizen came to suggest the possession of certain liberties in the face of the coercive powers of absolute monarchs.

Passports and Citizenship

A passport is a personal identification and travel document for international use issued by a sovereign State or a United Nations (UN) organization. Generally, only passports which are issued on the basis of a person's citizenship are of any interest and use.

Only through the acquisition of full citizenship can you legally acquire the right to a passport. Non-citizen passports and other passports issued to non-citizens are generally of limited use, with certain exceptions such as the non-citizens passport issued to persons holding a retiree residence permit in Panama, which is legal but also of limited use. Other exceptions include diplomatic passports issued to non-citizens, UN and refugee passports and certain travel documents issued by international organizations or individual States.

Diplomatic Passports

Diplomatic passports are only legal and useful if issued by the competent authorities within the issuing State or international organization and if the holder is properly accredited in the host State. Normally, diplomatic passports are only issued to persons who are citizens of the issuing State.

Dual Citizenship

Dual (or multiple) citizenship is the result of the interaction of the laws of two or more countries. People can become dual citizens automatically by birth within a certain territory (e.g. the United States), by descent from a citizen parent, or marriage, or after successfully applying for the citizenship of another country.

You can become a citizen of another country without losing your current citizenship only if the laws of the country of your current citizenship allow dual/multiple citizenship.

While many countries have no restrictions on dual citizenship, and while there is an international tendency to move away from strict single-citizenship policies, there are still important exceptions. Singapore, for example, is a strictly single-citizenship country and will require proof of relinquishment of all other citizenships the applicant holds. Singaporean citizenship is consequently of limited interest to most international clients.

For an overview of citizenship regulations in selected countries with regard to dual citizenship, click here.

How to Acquire Alternative Citizenship

Principal grounds for acquiring citizenship are birth within a certain territory, descent from a citizen parent, marriage to a citizen, and naturalization. The conditions under which the privilege of grant of citizenship or naturalization is given vary from state to state, but family relationships or lengthy periods of residence are usually essential, besides character and other requirements such as knowledge of the national language.


While residence permits are granted to investors and wealthy individuals in most countries, there are now only very few countries which have clear provisions in their laws for granting citizenship for economic considerations and without residence requirements.

Australia, Belgium, Canada, Hong Kong, Monaco, Portugal, the United Kingdom, the United States, Singapore and Switzerland are examples of countries which offer residence permits to wealthy individuals and investors. Other countries offer Citizenship-by-Investment Programs, sometimes also referred to as Economic Citizenship Programs (which is incorrect, as there exists no separate or “economic” citizenship: these programs allow an individual to become a full citizen, but by investment instead of by marriage, birth etc). There are currently only six countries which offer citizenship programs that provide a direct route to citizenship based on investment and which have passed Henley & Partners’ country due diligence – Austria, Antigua and Barbuda, Cyprus, Grenada, Malta, and St. Kitts and Nevis. The Citizenship-by-Investment programs of Antigua and Barbuda, St. Kitts and Nevis and Malta have been designed by Henley & Partners under relevant Government mandates.

Citizenship-by-Investment Programs offer you the opportunity to legally acquire a new citizenship quickly and simply, without any disruptions to your life.

Other Important Points

Other important points to consider when intending to become a citizen of choice include the geographic location of the chosen country, its official language, political and economic stability, its legal system, the banking and business environment, visa-free travel availability for passport holders of that country, the reputation of the country and the passport, and of course initial and future overall costs.

Beware of illegal "Programs" and unqualified Agents

The most important criterion for evaluating the usefulness of an alternative citizenship is that it be acquired in accordance with the constitution and laws of the issuing country, i.e. that it be legal. Citizenship documents and passports obtained by illegal means such as bribery are unfortunately not uncommon. In many countries it is possible to make illegal direct payments to corrupt government officials in return for passports and citizenship documents. Holders of such documents run a serious risk of exposure, arrest and deportation. Even in those countries where there are actual provisions in the law which give the Prime Minister or other government ministers relatively wide discretion regarding the granting of citizenship, if any payment is involved it is bribery, a crime in practically every country. This may and frequently does result in the revocation of previously granted citizenship and passports, for example after a change of government. Persons who have acquired documents this way are also frequently blackmailed and forced to pay further "fees" later on. It is therefore crucial that citizenship is obtained on the basis of specific provisions in the law and clear, official procedures.

But even in those countries which offer legal programs, one needs to be aware that in recent years these have attracted all sorts of companies and agents, real estate developers and others who have been attracted by the success of some of the programs, notably the one in St. Kitts and Nevis, which has brought more than a billion USD to the country since the program was redesigned and internationally positioned by Henley & Partners in 2006/2007.  Very unfortunately, not all of these companies apply best business practices and today extreme care must be exercised when selecting a lawyer, company or choosing to buy real estate under one of the Citizenship-by-Investment programs. The only really tightly regulated program in the world, with state-of-the art due diligence not only for applicants but also for agents promoting the program, is the Individual Investor Program in Malta.

Henley & Partners Can Advise You

Henley & Partners is the only firm that has a true global presence, over 20 years of experience and overview to offer you real opportunities to acquire alternative citizenship on a sound legal basis. We are also constantly aware of the many illegal "programs" frequently available over the Internet and through various agents, and we are the only firm to advise several Governments on legal, policy and operational aspects of Citizenship-by-Investment programs. We have our own offices in all relevant countries and constantly monitor the worldwide situation.


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