These Asian countries are giving dual citizens an ultimatum on nationality and loyalty

By CNN : Some Asian countries are tightening their immigration laws. Japan reinforced its strict stance in January when a court upheld the country's ban against dual citizenship, rejecting a lawsuit filed by Japanese citizens living in Europe.

These Asian countries are giving dual citizens an ultimatum on nationality and loyalty
These Asian countries are giving dual citizens an ultimatum on nationality and loyalty

Anna was born with the proper to dual citizenship, because she features a Japanese mother and American father. She spent her life travelling between both countries, and says she felt deeply connected to the 2 cultures.But Japan requires those with multiple passports to select one by the age of twenty-two -- an impossible choice for Anna, who requested a pseudonym for privacy reasons.

"I'm mixed race, I've lived both in Japan and therefore the U.S., I speak both languages, i'm completely reverse split the center in terms of my identity," she said. "It's like asking someone whether or not they love their mother or father more. It's such a cruel question."The past few decades have seen people travel and live abroad more, with the amount of international migrants -- people that changed their country of residence for a minimum of a year -- tripling from 1970 to 2015, consistent with the world organization for Migration.

At an equivalent time, tolerance to dual citizenship has generally increased. In 1960, but one-third of nations allowed citizens to accumulate a second nationality, compared to three-quarters today, consistent with a 2019 paper by Maartin Vink, professor of political sociology of Maastricht University within the Netherlands.

Asia is an exception thereto trend. it's the world's most restrictive region in terms of dual citizenship, with only 65% of nations and territories permitting it, consistent with the Maastricht Center for Citizenship, Migration and Development. To place that in perspective, 91% neutralize America , which rank because the most liberal.

And some Asian countries are tightening their immigration laws. Japan reinforced its strict stance in January when a court upheld the country's ban against dual citizenship, rejecting a lawsuit filed by Japanese citizens living in Europe. Hong Kong took a harder line in February, barring dual citizens from receiving consular protection -- a step never before taken within the Chinese city, where dual citizenship isn't legally allowed but had been tolerated.

"Dual nationality isn't recognized within the Chinese Nationality Law," said Hong Kong leader Carrie Lam in February. "That is extremely clear. We are strictly enforcing or implementing that specific policy."There are variety of reasons why the region is so resistant toward dual citizenship, including histories of conflict and colonialism. But in some countries, critics say the ban on dual citizenship also reflects a tilt toward nationalism -- and therefore the desire to take care of a monoethnic, monocultural identity.

Loyalty and nationalism - In Asia Pacific, only a couple ofplaces accept dual citizenship with no caveats, including Cambodia, East Timor, Australia, New Zealand and Fiji.Most countries are against it, although some choose to notstrictly enforce their policies, allowing people to staymultiple passports by simply not declaring them.

Others allow dual citizenship in restricted forms: the Philippines permits it for those that were born Filipino citizens, but not for naturalized Filipinos. South Korea allows children born to its nationals abroad to carry the passport of both their birth country and their parents.

One reason why many Asian countries oppose dual nationality may be a belief that it can create divided loyalties among citizens, said Jelena Dzankic, co-director of the worldwide Citizenship Observatory (GLOBALCIT), a world citizenship research network. "The reason why, historically and traditionally, countries haven't been permissive of dual nationality is because, whom are you getting to defend if the 2 of our countries attend war?" she said.

Japan drafted its current nationality laws shortly after war II, when many Japanese Americans were put in internment camps within the U.S.; other dual citizens renounced their loyalty to the japanese Emperor for his or her own safety, said Atsushi Kondo, a law professor at Japan's Meijo University.In one famous case, a U.S.-born Japanese-American dual citizen worked in Japan for a corporation that oversaw American prisoners of war. Upon his return to the US after the war, he was sentenced to death on treason charges. He was eventually pardoned and deported to Japan -- except for decades afterward, Japanese lawmakers pointed to the present case as an example of the conflicting obligations that came with dual nationality.

"In wartime, double citizenship showed disadvantage," Kondo said. "But in peacetime, dual citizens have many advantages" -- including visa-free visit more countries, greater international employment opportunities, potentially cheaper university education, and more. There are modern downsides, too -- as an example , US dual citizens need to pay double taxation, but that's not the case for many countries.The international context has now changed, and Japan's "beliefs are a touch outdated," he added -- yet the govt is reluctant to open up immigration laws and risk upsetting conservative voters.

China's ban on dual nationality is additionally to make sure that its nationals are "only giving undivided loyalty to the govt ," said Low Choo Chin, a history lecturer at the Universiti Sains Malaysia. During the conflict era, China's efforts to normalize relations with neighboring countries and end international isolation were hampered because "overseas Chinese were related to revolutionary activities" and Communist uprisings, Low wrote during a 2016 paper. So, the Communist government formulated the present nationality law in 1980 to resolve "diplomatic frictions" and to "end divided loyalty among the overseas Chinese."

Under Chinese President Xi Jinping, the govt has cracked down on dual citizens, encouraging the general public to report people secretly holding two passports. Those caught can find their access to public services curtailed.

The crackdown is a component of the government's anti-corruption efforts against "dual nationals taking advantage of the grey areas within the law, and trying to evade legal sanctions with (their) foreign nationality status ... fleeing abroad, transferring their assets," said Low, pointing to estimates by the Chinese financial institution that 18,000 corrupt officials may have fled the country with 800 billion yuan ($122 billion) between the mid-1990s and 2008.

The matter of citizenship was thrust to the fore during the COVID-19 pandemic. within the midst of a crisis that transcended national boundaries, governments were suddenly faced with questions like: Which citizens can we claim as our own? For whom are we responsible? Who can we protect?

Because China doesn't recognize dual citizenship, many Chinese nationals were forbidden from evacuating back to their country of second citizenship -- albeit that was their place of birth or primary residency.There were cases of families split apart; one British woman was told she couldn't evacuate together with her 3-year-old son because he features a Chinese passport, albeit he's also a British citizen with a British passport. within the face of international pressure, the govt eventually relented.


The idea of loyalty to one country and culture, particularly in East Asia, can also "imply the will to take care of a cohesive ethnocultural identity," said Dzankic, of GLOBALCIT. Several of the countries that do not allow dual citizenship also are highly homogenous -- as an example , 92% of China is Han Chinese, consistent with the CIA's World Factbook.

And one among the simplest ways for a rustic to regulate its ethnic makeup is thru the sort of citizenship it chooses to acknowledge .There are multiple ways of obtaining a primary , or second, citizenship, including through marriage, adoption and naturalization. But the foremost common ways are birthright citizenship (jus soli) -- meaning babies automatically gain citizenship of the country they're born in -- and thru parental descent (jus sanguinis), which sees children automatically gain the citizenship of their parents.

In Asia, the overwhelming majority of nations today don't recognize birthright citizenship, during a ll|one amongst|one in every of" one among the quickest ways for ethnically foreign or minority populations to grow in a country.Or if they are doing it's so with certain conditions, consistent with GLOBALCIT. South Korea as an example , only applies birthright citizenship for youngsters whose parents are unknown or haven't any nationality -- so if a toddler born on Korean soil has been abandoned, or its parents are stateless, it'll receive Korean citizenship.

"A shift from legal principle to legal principle has been witnessed in Asia within the course of the 20 th century," wrote Olivier Vonk at the Maastricht Centre during a 2017 paper. Bangladesh, Indonesia, and India are among the countries that have transitioned to primarily recognizing citizenship by descent.

The type of citizenship recognized, and therefore the rigidity of a country's restrictions, influence how diverse or homogenous its population are often , said Kondo."South Korea was also a monoethnic country within the old days," he said. "But they changed the policies, in order that they are more relaxed to double citizens now ... And now they're considered multi-ethnic, or a multicultural country," Kondo added.

South Korea liberalized its nationality law with sweeping amendments in 2010, which allowed permanent dual citizenship for its nationals for the primary time (albeit under specific circumstances); dual citizens who fall outside those circumstances got longer to choose; and a special naturalization path was created for talented individuals.

Japan remains strict in its nationality laws and is ethnically homogenous, said Kondo, though the government's statistics don't include an ethnic breakdown."Maybe ordinary Japanese (consider) ethnicity and citizenship as equal ... Such a standard feeling is robust in common Japanese," he said. Even some current politicians believe Japan "should be a monoethnic country," he said.

Even the term legal principle , citizenship by descent, implies ethnicity, said Anna, who is now based within the UK and declined to disclose her current citizenship status. The Latin translation means "right of blood," and Japanese citizenship is made on this concept -- so "the idea of blood is extremely strong in their understanding of citizenship."

If a naturalized Japanese citizen who isn't ethnically Japanese gives birth, that child would automatically become a Japanese citizen -- but social attitudes and norms still draw lines around ethnicity, she said. There continues to be bullying in schools and a way of social exclusion for biracial or mixed-race Japanese."It is that this thought of blood purity ... which is why albeit I even have Japanese citizenship, I'm not accepted as Japanese citizen in most cases because I'm not 'purely' Japanese as they might say ... because i do not appear as if them," she said. "A lot of it's xenophobia. tons of it's racism."


The recent moves in China, Japan and Hong Kong suggest parts of Asia are moving further faraway from dual citizenship whilst other parts of the planet embrace it. Malawi, which had previously banned dual citizenship, amended its laws to permit it in 2019. Russia and Norway followed suit in 2020.In Hong Kong the longer term of dual citizenship is unclear. Though the govt has insisted that it's taking a harder line in enforcement, it hasn't provided information on what measures are going to be taken or how the city's thousands of dual citizens are going to be affected.

"Maybe 70% of my friends have another passport," said Janice Tam, a Hong Konger who also holds a British passport. She isn't particularly worried about the government's recent rhetoric -- but "it depends on whether or not they force you to pick one," she said. "What is that the consequence of that? If you've chosen your foreign passport, what does one still get if you stay in Hong Kong?"

Ella Wong, who holds Canadian and Hong Kong passports, is additionally "optimistic" that dual citizens won't be affected in their lifestyle . Her only concern is that if Hong Kong continues to vary its immigration laws to be almost like China -- or adopt mainland laws altogether."With the Hong Kong passport, you do not know what it's getting to evolve into," she said. "Could it become a Chinese passport, then what does that mean in terms of travel and work and living?"

More broadly across Asia, most countries are unlikely to liberalize their laws anytime soon, said Low. The West "prioritizes liberalism, individual rights to (dual) nationality," she said. "(But) in many Asian constitutions, access to citizenship is extremely tough for migrant communities because governments believe that the proper to nationality may be a privilege, not a right. during this context, it's quite difficult to imagine that Asian governments would allow dual citizenship."Yet, experts and dual citizens remain hopeful that change will inevitably come as global migration grows. It takes time, said Vink, the Maastricht University professor.

And though they continue to be a minority, a couple of Asian countries have introduced new rules allowing more flexible citizenship arrangements. India, as an example , created a replacement category of permanent residency in 2005 that allowed people of Indian descent to measure and add the country.It's still not dual citizenship -- but it marked "a way of acknowledging the realities of a globalizing world and adapting to them step by step," Dzankic said. "Even though countries are generally restrictive of dual citizenship, one could ponder whether those intermediate statuses might be a step or a move towards a more permissive policy."

"I hope that the planet will change," she added. "What i feel is important or what is going to be important may be a move towards dual nationality, not as a mechanism of being associated with the state, but also as a mechanism for shielding individuals -- for granting them greater life opportunities within the future."