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Commodification of citizenship and global inequalities

Citizenship is commonly conceptualised as a status conferred upon individuals within a national political community, echoing the seminal work of T.H. Marshall (Marshall, Bottomore, 1992MARSHALL, Thomas H.; BOTTOMORE, Thomas. Citizenship and Social Class. London: Pluto Press, 1992. [1950]). Consequently, discussions surrounding citizenship often centre on the notion of equitable access to rights and responsibilities. However, it is imperative to acknowledge that citizenship encompasses more than mere parity in rights; it also encompasses the unequal distribution of these rights and the mechanisms that perpetuate disparities in life opportunities and outcomes. Given the global landscape characterised by stark economic, social, and political disparities among nation-states, the citizenship one holds at birth significantly influences their life prospects. As illustrated by Branco Milanovic (2013MILANOVIC, Branko. Global Income Inequality in Numbers: in History and Now. Global Policy, v. 4, n. 2, p. 198-208, 2013.), one's birth citizenship significantly influences income opportunities, along with political liberties and educational prospects.

In the modern era, obtaining national citizenship beyond that conferred at birth has become increasingly challenging, as naturalisation and immigration policies of nation-states tend to be highly selective (Glick Schiller, Salazar, 2016GLICK SCHILLER, Nina; SALAZAR, Noel B. Regimes of Mobility Across the Globe. Journal of Ethnic and Migration Studies, v. 39, n. 2, p. 183-200, 2013.). Historically, citizenship was perceived by states as a reflection of loyalty, and acquiring additional citizenship was often viewed with suspicion. However, in recent decades, many countries have relaxed legal constraints on holding multiple citizenships (Ong, 2006ONG, Aihwa. Neoliberalism as exception: mutations in citizenship and sovereignty. Durham: Duke University Press, 2006.; Sassen, 2006______. Territory, Authority, Rights: from Medieval to Global Assemblages. Princeton: Princeton University Press, 2006.). Embedded within a neoliberal framework emphasising individualism and flexibility, citizenship has acquired new strategic and pragmatic significance for individuals (Bauböck, 2019BAUBÖCK, Rainer. Genuine links and useful passports: evaluating strategic uses of citizenship. Journal of Ethnic and Migration Studies, v. 45, n. 6, p. 1015-1026, 2019.; Harpaz, Mateos, 2018HARPAZ, Yossi; MATEOS, Pablo (eds.). Special Issue: Strategic Citizenship: Negotiating Membership in the Age of Dual Nationality. Journal of Ethnic and Migration Studies, v. 45, n. 6, 2018.; Harpaz 2019HARPAZ, Yossi. Citizenship 2.0: Dual Nationality as a Global Asset. Princeton: Princeton University Press, 2019.). Consequently, alternative avenues for citizenship acquisition have gained popularity. Examples include Brazilians and Argentines obtaining additional citizenship in Italy or Portugal through ancestry rights (Cook-Martin, 2013COOK-MARTIN, David. The Scramble for Citizens. Stanford: Stanford University Press, 2013.; Zanini et al., 2015ZANINI, Maria C. C.; ASSIS, Glaucia; BENEDUZI, Luis Fernando. "Cidadãos de direito, estrangeiros de fato: narrativas de ítalo-brasileiros(as) na Itália". História Oral, v. 18, n. 1, p. 117-145, 2015.); Russian families choosing to give birth in countries with jus soli laws to confer more advantageous citizenship by birth to their children (Ruseishvili, 2021); and economic elites from Middle Eastern nations investing in citizenship-by-investment programs in the Caribbean (Surak, 2021SURAK, Kristin. Millionaire mobility and the sale of citizenship. Journal of Ethnic and Migration Studies, v. 47, n. 1, p. 166-189, 2021.).

This conversation explores the instrumental attitudes toward citizenship by both states and individuals to advance their respective interests. It occurred within the context of the research on strategic citizenship and birth tourism, conducted by Svetlana Ruseishvili during the 2023-2024 academic year at the London School of Economics and Political Science (LSE), and hosted by Kristin Surak1 1 Supported by Capes-Print fellowship and FAPESP “Bolsa de Pesquisa no Exterior” fellowship (2023/05431-1). The conversation took place on November 30th, 2023, and was recorded and transcribed. The text has since been reviewed and edited by Svetlana Ruseishvili and Kristin Surak. .

Kristin Surak’s work on elite mobility, international migration, nationalism, and politics has been translated into a half-dozen languages. Her most recent book The Golden Passport: Global Mobility for Millionaires______. The Golden Passport: Global Mobility for Millionaires. Cambridge: Harvard University Press, 2023. (Harvard University Press, 2023), unpacks the global market in the sale of citizenship to wealthy individuals. Through citizenship by investment, or “golden passport” programs, economic elites in developing countries acquire additional citizenship in exchange for sizeable investments in the selling country. In the book, Kristin scrutinises the dynamics of demand, supply, and the global web of intermediaries that enable this market. The author also raises important questions regarding the global inequalities that shape all angles of this market.

It may seem that expectant mothers seeking to give birth in jus soli countries are very different to wealthy people buying passports in places they may have never even visited, but the two practices share a common thread on strategic attitudes on national citizenship. This conversation seeks to shed light on how individuals navigate the highly unequal global hierarchy of citizenships and passports. It explores the contemporary pathways available for acquiring citizenship beyond the conventional birthright principle. Additionally, the conversation touches upon the potential repercussions of the commodification of citizenship on the relationship between nation and state. Finally, the discussion addresses the intertwined nature of restrictive migration policies and citizenship regimes, emphasising how these factors serve as foundational elements for capitalist reproduction.

This conversation broadens the understanding of citizenship beyond the notion of equality and access to rights, and will be of interest to scholars working on unequal citizenship regimes and international mobility, as well as scholars of global elites and global inequality.

Svetlana Ruseishvili:In recent years, you have published several academic articles and books, such as The Golden Passport: Global Mobility for Millionaires (2023), which address the commodification of citizenship. It seems that there is a shift in the meaning of citizenship globally: if traditionally citizenship used to be a synonym for loyalty and patriotism, today it is more like a saleable strategic asset. Could you please describe the theoretical debate around this topic in recent years?

Kristin Surak: If we are looking at changing meanings of citizenship, it's important to take the wider context into account. Very often, the starting point for those questions - queries about what citizenship means - comes out of a North Atlantic and often European context. This means that in academic debates, very often citizenship is associated with, as you put it, questions of loyalty and patriotism, and they are often linked to issues around democracy and political participation. That's historically been the way a lot of academic research has problematised citizenship. But if we extend our vision and think about citizenship globally and how it's transformed over the course of the 19th through the 20th centuries, we have to take into account the overarching context of empire and imperialism.

When we start to look at it through the lens of a world of empire, those questions of loyalty and patriotism become very complicated and blurry. For example, the French case is often taken as an ideal type of citizenship. But at the same time, it had large overseas imperial holdings, and in colonies and other French holdings, membership was extended to different degrees and different grades, depending on the geographical location, race, religious affiliation, gender, and class. These also changed over time across the long history of the French empire. For example, during World War I, many soldiers from French colonies in, for example, West Africa, fought on behalf of France's interests, and many of them, of course, sacrificed their lives as well. At that point in time, they were not French citizens but French subjects and had much more limited rights, although they did have the possibility of mobility into France. And they tried to use that “demi-citizenship” - their partial membership - as well as their military service, to argue that they should actually be considered full citizens and have full rights. Even if we often imagine that French citizenship was primarily about “liberty, equality, and fraternity,” it remained very much tiered and very much exclusive, as much as it was inclusive. But the situation was complex. The development of independence movements, in particular, meant that those former French subjects who at one point would have had at least some mobility and access to France, for example, suddenly lost it because they lost that French subjecthood and instead became “foreign” Senegalese.

So, the question of whether citizenship is a mutually agreed social contract or whether it's about loyalty and patriotism is problematic in the first place. When you look at it historically, it's much more complicated. Because of that, I don't see a shift from one into another: a shift in citizenship as about loyalty or patriotism or democratic participation into citizenship as a strategic asset. If one looks at the historical record, one sees states being very strategic about the inclusion and exclusion of various populations and individuals also being very strategic about inclusion and exclusion and where they're going to try to claim membership. And that’s what's interesting, and it’s possible to examine how those dynamics play out differently or transform over time. So if we ask if the meaning of citizenship is changing, especially if we’re looking at the world of citizenship by investment, challenging this question - rather than taking it at face value - provides a starting point for us to challenge some of the fundamental assumptions that a lot of academic literature, particularly literature coming out of the North Atlantic, that has often been highly influential and has defined debates elsewhere. We need to move past many of the baseline assumptions in the citizenship canon.

Svetlana Ruseishvili: Indeed, citizenship embodies a dual dynamic of inclusion and exclusion, as explored by scholars like Rogers Brubaker. While citizenship confers certain rights and privileges upon individuals, it also delineates boundaries that exclude others. Moreover, citizenship intersects with issues of inequality, shaping access to resources, opportunities, and rights within societies. British sociologist T.H. Marshall, in his classic essay “Citizenship and Social Class” (1950), which became a cornerstone in citizenship studies, pointed out that although citizenship is an equaliser, it also is "the architect of legitimate social inequality". In your book, “The Golden Passport”, you argue that it is both "interstate and intrastate inequality" that drives demand for additional citizenships. In other words, both the inequality of citizens within nation-states and the glaring inequalities between different countries make people who can afford it look for other citizenships to increase their life opportunities. Could you tell us more about how citizenship and inequality feed back into capitalism today?

Kristin Surak: Thinking about the demand for additional citizenships means looking at two sides of the equation. Number one, is the question of legal possibility in the first place. There's been a massive expansion of policies that recognise and enable dual citizenship, and that's occurred across the globe since the end of World War II. Of course, some people will still get dual citizenship even if it’s not officially recognised, but it's harder to maintain. It's more risky. There are quite a number of countries that still don't recognise dual citizenship. China doesn't recognise it, and neither does India, and so if you think about it as a proportion of the world population, that's already about 40% of the global population who aren’t allowed to have dual citizenship, although some people might have it.

Number two, and I suppose this is why you're asking this question, is the availability of naturalisation options - things like citizenship by investment, for example. We often think about naturalisation as something that comes after immigrating to a country. So citizenship that's acquired in adulthood becomes much more like a social contract because a person enters into it based on her own decision, which is unlike citizenship at birth. We get no choice in the citizenship that we're born into. In that sense, it's hardly a social contract at all. But in the case of citizenship through naturalisation, we often assume that it’s based on a story of immigrating to a country, developing ties and bonds, and then eventually becoming a citizen. However, that's only one model, and it's not even the most common model. Some countries make it virtually impossible to naturalise: China naturalises very few people, and most of the Gulf states naturalise very few people. You can live in Dubai for 30 years, have worked there all your life, you can even have been born there to foreign parents. But it's very unlikely you'll become a citizen unless you negotiate something on an individual basis with the government.

Then there are countries like Italy, for example, which naturalises a lot of people through ancestry clauses who may have never even lived in Italy in the first place. Hungary is another country that has likely naturalised more people of Hungarian ancestry than people of non-Hungarian ancestry who moved to Hungary and spent time there. These opportunities are obviously well known in Latin America, where there are large populations of people with Italian or Spanish ancestry. For them, it’s just a matter of finding the right documents to prove that ancestry and then they can pick up citizenship without even moving there.

So, when talking about dual citizenship, we also need to keep in mind that some countries allow it and others don’t, and there are many ways of acquiring it. There is more variation than often is taken into account. But what I'm looking at in the world of citizenship by investment are programs that countries create where a person invests or donates a specified amount to a government, goes through some background checks, and then has a pretty easy time becoming a citizen. Some countries will legitimise this by saying, ‘Of course, we're going to give country membership to these people who've given so many economic resources to us. We're recognising their great contributions to our country.’ Other people will characterise this as ‘paying to play’ or simply buying citizenship in effect.

However, the market around citizenship by investment programs is really structured by both inter-country inequality and inter-country inequality. That is, the inequalities within countries between people who can afford it and people who cannot, and inequalities between countries in what citizenship gets you. We often think about citizenship as equality, but if we look at it globally, we see there's a lot of inequality in what it supplies. If you're from Pakistan, for example, you can only go to about 30 or 35 countries visa-free. You can be a college graduate with a PhD in engineering and be very successful in what you're doing, but you're still going to have a very hard time getting visas and travelling if you are from Pakistan. But if you happen to be a Japanese citizen, you'll get 190 countries visa-free. You'll have virtually no barriers put up for you when travelling around the world. And those inequalities - and there are many other sorts - go beyond just visa-free access.

For example, if you want to start an import business in Europe and you're not European, it can be very challenging to get bank accounts and other sorts of things depending on where you're from. It can even be more basic things. I had a research assistant from India who was trying to fly back from India to London and realised that he couldn't get on any of the cheap flights because he wasn't allowed to transit in certain countries because of his citizenship. People with privileged passports often don't think about these things, whereas people without privileged passports confront them all of the time.

Svetlana Ruseishvili: Let’s go back for a moment to the point that citizenship is an instrument for exclusion. When you mentioned Italy, Spain or Portugal naturalising Latin Americans by descent, we see that citizenship becomes a tool a state uses to allow some populations to enter its political community but not others. In this case, they are more likely white people with European roots, while other non-European migrants who live in these countries their entire lives could have a lot of trouble becoming citizens de jure. So, on one side, there are states instrumentalising citizenship for their needs, and people from the other trying to cope with this exclusion by other means, like additional citizenship.

Kristin Surak: Yes, absolutely. And as you're saying, states are instrumental, states are strategic, and individuals are instrumental and strategic as well. And what’s at stake is membership in what we think of as ‘countries’ but what we call a nation-state in social science. It's that ‘nation’ side of the hyphen that gets packed with issues around identity and emotions and tends to be very emotionally laden. That’s why sometimes people when you talk about being strategic around citizenship, are like, 'Oh my God, you know, how can you possibly do it?’ Because they see it as quasi-sacred. There's a strong emotional element, a strong identity element attached to it for them. And that's coming from that ‘nation’ side of the nation-state. But it's the ‘state’ side, that legal status, that really is fundamental in these cases. I could have a strong Brazilian identity that I create for myself and see myself as perfectly Brazilian, and learn perfect Brazilian Portuguese and everything else. But it won't make me a Brazilian citizen. That's a legal status that the state decides on. Yet it's very often that ‘nation’ side that makes it complicated when we're analysing the way that both states are strategic about this and people are strategic about it, too.

Svetlana Ruseishvili: There is also this very interesting question about the modern principles of citizenship acquisition. In many ways, birthright citizenship is like a lottery that determines a person's chances according to the national territory in which she was born, as Ayelet Shachar (2009 SHACHAR, Ayelet. The Birthright Lottery: Citizenship and Global Inequality. Cambridge: Harvard University Press, 2009. ) termed it in her book. And those chances are absurdly unequal for citizens of different countries, as you mentioned.

Kristin Surak: What's interesting in looking at citizen acquisition, as you point out, is that the key distinction really is between citizenship that's assigned at birth and citizenship that's acquired later as an adult. What's interesting in looking at citizenship as it's assigned at birth is countries with jus soli legal provisions - you're just born in that territory, and you become a citizen - are predominantly in the Americas, all the way through North and South America. This is because of the timing of European colonisation, which came while feudal principles were still strong when determining membership. Under European feudal systems, belonging depended on the law of the soil you were born on. Jus soli was also useful for colonisation and European attempts to settle massive land masses, which, of course, went along with the genocide of many native peoples and the Transatlantic slave trade, etcetera. So, there are very complicated dynamics behind the jus soli provisions that are most common in the Americas.

But for the most part, citizenship is based on who your parents are - a sort of “blood” notion of it. In fact, some people argue that it really is primarily about blood and it's something just inherited. You see this very often in places where they don't have very jus soli citizenship provisions, in which case it just comes down to this adjudication of who your parents are, and that's how it's passed down. So, I'm a US Citizen, and I live in the UK. If I were to have a child in the UK, that child would be able to get US citizenship because of the birthright effect. And because most people in the world are not international migrants, they're in the territory where they are citizens, it's not very problematic whether it's one or the other type of citizenship acquisition.

But the big question is, ‘What happens when people are adults and aren’t just born into citizenship but have the opportunity to choose it? What sort of options are available?’ As you you rightly pointed out, what's interesting in the case of extended ancestry citizenship options - ones that allow not just the children or grandchildren of citizens to naturalisation, but that go back for many generations - is that they are more common in European contexts. Especially in Eastern Europe, they have been used as a way to embrace populations, particularly after the end of the Cold War, of potentially wealthy, successful people who are outside of the country and might bring capital in or have a strong relationship with that country. There can be very instrumental reasons in the mix of motives for countries.

But at a global level, it also means that access to European citizenship is often racialised. So, who has easy access to European citizenship? If you look at the Latin American context, those who have easy access to European citizenship through ancestry tend to be a whiter population and wealthier population. It's not people whose ancestry is primarily indigenous or who are the descendants of enslaved people from Africa. There is a racialised component affecting who has easy access to these privileged citizenships in Europe.

But there are also very tricky things, too. Sometimes, it's impossible to lose citizenship. For example, if you're a citizen of Morocco, you're a subject of the Moroccan king, and you can never lose that status. You cannot shed Moroccan citizenship. They don't allow it. So, if you start looking at an individual country basis, there are all sorts of really interesting twists and turns.

Svetlana Ruseishvili: You mentioned different forms of migration and border control, which overlap with the control by citizenship acquisition. How do they intersect and produce forms of global inequality, and how do people navigate through them?

Kristin Surak: That's a very good question. It gets at the intersection between citizenship and international migration. States police their borders, and very often, the first thing they look at when screening who can come in is that person’s citizenship. Are you able to cross the border easily or not, depending on your citizenship?

I taught at New York University in Abu Dhabi for a semester and had a colleague with a PhD from Harvard. She was a full-time professor at NYU, and she happened to be a Nigerian citizen. She was invited by a university in France to give a talk and had to start the visa process three months in advance, showing her employment contract, bank statements, and lots of documentary evidence in order to get a visa so that she could give a prestigious keynote university lecture in France. In the end, they weren't in time with the visa, so she couldn't go. She's highly skilled, highly paid, etcetera, but she still could not easily give a talk in France simply because of the passport she carries. It says a lot about patterns of inequality. Wealthy countries are very reluctant to give easy access to people from less wealthy countries, and that hits everybody across the board.

There can be ways of working around it. She was able to afford the time and effort and had the possibility of at least trying to apply for a visa, but she still didn't get it in the end simply because she was from a much poorer country than France. Citizenship provides a selection mechanism for screening moving across country borders and one that’s unequally selective. Unless we move to a world of open borders, and it's very hard to imagine that happening any time soon, countries will screen who they allow in. Currently, they are selective based on citizenship and based on one’s country's GDP in the first instance.

Svetlana Ruseishvili: What are the pathways for obtaining additional citizenship available for people today?

Kristin Surak: There are dozens of different types of legal provisions that can provide citizenship through naturalisation. It can be anything from moving to a country and spending time there. It can be through marriage. It can be through service in the military. It can be for artistic or scientific achievements. In my book, I look at one particular pathway, which is citizenship by investment. With these programs, a country sets out a particular amount of money you have to donate to a government or invest in the country, and it specifies the types of investments you can make to qualify. It's usually an investment in real estate, business or stocks, or it can be a combination of those. You put together an application. Then, you show your bank statements. The country does a set of background checks to make sure that you're clean or that they want you, so there's a bureaucratic procedure that usually takes anywhere between a few months to as long as a year. And if you pass all of that, the country will make you a citizen pretty straightforwardly, very often without any residence requirements or sometimes even without any requirement to visit the country. Right now, there are over twenty countries that have legal provisions that enable citizenship by investment. However, just having a legal provision is different from having a fully operational program where a country is naturalising at least a couple of hundred people through these means every year. In fact, most of the sales come from just eight countries - five in the Eastern Caribbean, plus Malta, Turkey, and Vanuatu. And through those programs, about 50,000 people gain new citizenship every year. Most of the demand comes from the Middle East, China, and the former Soviet Union, but recently, a lot of US citizens have become interested in these options, too - in getting a new passport.

Svetlana Ruseishvili: Could you go into more detail about this global citizenship-by-investment market that is the topic of your latest book, "The Golden Passport"?

Kristin Surak: What I do in the book is break down this global market and citizenship by investment. So, I look at the countries that sell citizenship, or effectively the supply side. I look at the people who naturalise through these programs or the demand side. And then I look at the intermediaries that make the market possible, that is, the long chains of service providers that connect supply and demand and make a big profit off of these things as well. To trace how that works, I went to 16 countries and talked to over 500 people. I put together a dataset on these programs, and I looked at how they evolved over time.

There are a number of very interesting things that emerged from the investigation. One is the geopolitics of this scene. So we often think of citizenship as about the rights that you get within a state, but with citizenship by investment, people are often interested in the rights that citizenship gets them outside of the country, in third countries, whether it’s visa-free access, business benefits, et cetera. Your citizenship affects not only the rights you get within a state but also the rights you have outside it. And those extra-territorial benefits are generally secured through a treaty. But because the benefits that investor citizens seek are in third countries, it means that other states have a great deal of power over the value of another country’s citizenship ‘product,’ and this opens a space for geopolitics to play a role. One of the stories I tell in the book is about the geopolitics of the market and the dynamics between big countries and little countries.

In the book, I also look at the economic outcomes for the countries themselves, as well as what this means in terms of the whole citizenship by the investment industry. It’s a question of whether or not these programs are really paying off, and who they’re paying off for, who’s really benefitting. In some countries, the programs account for more than 10 per cent of GDP - they are huge and can be the main source of FDI. In some places, citizenship is the number one export (since the investor citizens usually don’t live in these countries but stay abroad). But not all of the economic benefits that are possible end up in the country, and I trace out these limits too.

I was also curious about the social side of things. I talked to local people in the countries to find out what they think. There, I found a huge diversity of opinions, depending on the person and the country. I talked to a lot of buyers and intermediaries as well to look at demand and understand why people go for these programs in the first place. In terms of motives, there are a lot of complexities and unexpected twists and turns.

Then, I knit it together at the end to look at what this means for inequality and global inequality, what it means for extraterritorial rights and geopolitics, what this means for strategicness around citizenship, and what it means for neo liberalisation, too.

Svetlana Ruseishvili: What impressed me about your book is that many countries that offer citizenship by investment are former colonies. What is colonialism's legacy in this process, and what are the implications of selling citizenship for the sovereignty of these states?

Kristin Surak: The connection to colonialism is interesting. First of all, you have to be independent in order to have citizenship to sell in the first place. So, anything that's a dependent territory doesn't have this as an option. And that’s why so many are former British colonies. Britain tended to allow - or even encourage - its very small colonies to become fully independent, whereas France, the Netherlands, Spain, and Portugal did not. For very small “microstates,” with a population of less than 1 million, remaining dependent on the Metropol can be economically more rational since there are many challenges to running a very small country with few natural resources where everything must be imported. In the British case, the financial hub in the City of London found it very useful to encourage the development of offshore sectors in these places, and the British government was broadly tolerant of that since it enabled them to get them off of Whitehall’s books. Now, Turkey is the main seller of citizenship, but the original scene was dominated by microstates that were former British colonies.

Svetlana Ruseishvili: And what about the social profile of the citizenship buyers? In your book, you dispel the myth that they are only mega-rich. You cited cases of economically successful refugees and stateless people for whom citizenship by investment could be the only quick and effective way to get papers.

Kristin Surak: Because my fieldwork covered so much ground, I came across a huge range of cases and a lot of variability. But a broad rule of thumb is that most people are unwilling to spend more than 10% of their liquid assets on these options. If you look at costs, the lowest official price point for the programs starts at about 100,000 USD in the Caribbean and goes up to about a million dollars or so for an EU citizen. So, the price varies depending on the range of rights and possibilities that citizenship brings. But in general, that means that most people will have liquid assets of about $1 million. So they're not poor, but some also have less than $1 million and might get loans from people or look for other ways of getting the funds so that they can apply simply because they're quite desperate. Virtually anyone going for these options is in the middle-class to upper-middle class. You don't get the poorest of the poor going for these sorts of options, but they're not necessarily billionaires or even people with assets of 100 million USD. The way one service provider described most of the market to me is that it's, as he put it, the “poor millionaires”, people with between 1 to 5 million USD in liquid assets. They tend to be from places like China, the Middle East and increasingly Russia and the post-Soviet space as well. So in effect, people with “bad passports” who are looking for improved options.

Svetlana Ruseishvili: What are their main motivations? What are they looking for?

Kristin Surak: It’s usually four things. The first one is better mobility in the present, easier visa-free access, and easier travel than what they're getting on their current citizenship. Number two is an insurance policy for the future. They want a Plan B since they don't know what's going to happen. They don't know what their government's going to do, especially if they’re in an authoritarian regime. So, a second citizenship is an insurance policy. Some people I spoke to also described lifestyle benefits and quality-of-life opportunities as a motive. For many, what this meant was a bit vague because most of the time, people aren't looking to move to these countries, but they might describe wanting better options for their children, say, ‘I want better schooling chances for my children,’ etcetera. You can buy citizenship in Malta and easily move to Switzerland and you put your kids in nice private schools and accompany them as a parent as well. And then the final one is business opportunities. That can be everything from opening bank accounts, which can be easier or more difficult depending on your citizenship. You might also get import tax breaks, depending on your citizenship. Turkish citizens, for example, get import tax breaks when bringing goods into Europe. So, if you have a business that wants to import into the European market, it can be economically beneficial to be Turkish. You can get tax benefits depending on what you're doing, etcetera.

Within those motives, a lot of people think that tax evasion is a key one, that people can easily evade taxes with these options. But tax is very complicated. If you look at the wealthy people in the world and the ways that they evade or avoid taxes, there are so many different options that they have available outside of these programs. If these programs were really a silver bullet to lowering one's tax burden, there would be far more people doing this, especially wealthy people in the Global North.

Still, an interesting new trend has been a huge boom in recent years in the number of US citizens looking at these options. They are wealthy US citizens and are usually not shedding their US citizenship, so they're keeping their US tax status. Instead, they tend to be people who don't like what's going on in US politics, whether they're on the political left or the right or just hate them all. They also include people who were very concerned about what was going on during COVID-19, whether they liked what the government did or hated what the government did. Plus, suddenly, during Covid, US citizens had a very hard time moving across borders. Their previously very privileged passport didn’t open all doors for them, and so many became very risk-averse. They want a Plan B, Plan C, Plan D, Plan E. This boom in wealthy US citizens has been an interesting development to watch.

Svetlana Ruseishvili: In some ways, it reminds me about less resourceful people, undocumented migrants, who sometimes purchase forged passports and papers at informal markets. Essentially, every social strata has different options available to them with more or less risks involved. So, individuals seeking to improve their life chances linked to citizenship navigate through different strategies, from very uncertain options to very luxurious ones.

Kristin Surak: Yes, absolutely. I think, in general, it comes down to what options are available to a person and what they can afford. So, for example, the demand for citizenship by investment options in South America has been very low in comparison to other parts of the world, and this is partly because ancestry options are available to many people. An ancestry option is often much cheaper than citizenship by investment, and you can qualify for a very privileged passport in Europe. If you can become an Italian or Spanish citizen very easily, why invest in becoming a citizen in a more peripheral place? And, of course, there are possibilities - as you described before - to buy forged documents. Some people do that, of course, but they don't know if that will always work or if they will get caught. There are a lot of risks involved with false documents. Some people don't buy a forged passport, but they buy false documents to do an ancestry option. For example, there are a number of cases of Russians who buy the documents to invent a Romanian ancestor and use that to get Romanian citizenship. Then, through that route, they become an EU citizen. People use many different strategies depending on what's available to them and what risks they're willing to take.

Svetlana Ruseishvili: Does having additional citizenship have anything to do with being a "citizen of the world"? As you mentioned, citizenship is perceived as something formal, while nationality is full of identity meanings. I like the case you cited in your book that some people you interviewed were very critical of cosmopolitanism. Even though they had several citizenships, they still identified themselves in mono-national ways.

Kristin Surak: This goes back to that tension between nation and state that we talked about before. And you're absolutely right. There's a lot of people who are strategic about it. They want a travel document. They want to improve their travel opportunities. It's an asset or a tool for many of them, but it doesn't really affect their identity. What I found interesting in my interviews is many people who are naturalising through these programs were kind of reluctant to take on the term “citizen of the world” or “global citizen” for themselves. Some people I spoke to, especially if they were raised in a single national context, still had a strong identity around that nationality, and they saw that identity as different from their travel document. One person I spoke to said that he realised that his passport was an ID, not his identity.

But I also talked to some younger people who naturalised through these programs and grew up in multiple countries, went to international schools, and had a couple of languages. They didn't necessarily grow up in their country citizenship. They were more likely to identify as a global citizen or just say that they don't have any kind of national identity. Nationality, for them, was just not an important identity, and they built their identity in other ways. I found that quite interesting, that sort of malleability and flexibility and the range of differences in the way that people relate to national identities. One of the big determinants in these cases is where you grew up, how you grew up and how mobile you were as a child.

Svetlana Ruseishvili: This distinction between nation and state is something that we should address theoretically and empirically as well. What, in your view, is the future of citizenship? Some scholars propose rethinking the compulsory nature of citizenship and allowing for more flexible ways for people to leave and enter the political community of citizens. Shachar (2009 SHACHAR, Ayelet. The Birthright Lottery: Citizenship and Global Inequality. Cambridge: Harvard University Press, 2009. ) proposes a jus nexi principle (as opposed to the prescriptive jus soli and jus sanguinis), Sassen (2003 SASSEN, Saskia. The Repositioning of Citizenship: Emergent Subjects and Spaces for Politics. CR: The New Centennial Review, v. 3, n. 2, p. 41-66, 2003. ) proposes a post-national citizenship, the Italian philosopher Donatella Di Cesare (2020)DI CESARE, Donatella. Estrangeiros residentes: uma filosofia da migração. Belo Horizonte: Editora Âyiné, 2020. talks about "ius migrandi", etc. These debates seem to put the link between citizenship and nationality into question. In your opinion, could the commodification of citizenship (which disconnects it from national identity) in contemporary, flexible capitalism lead to a more flexible and fairer conception of citizenship in which undocumented people could become citizens in the countries where they live and contribute?

Kristin Surak: That's a good question. Many of those debates come from a background of normative or political philosophy and start with the question, ‘How should we decide who becomes a citizen?’ As a political sociologist, though, I tend to approach such questions differently. For me, what’s more important than asking, ‘How should we organise a system? What's morally best in these cases?’ is asking, ‘How do states act around these issues?’ This gets at the deeper question of, ‘What is the nature of state power?’ We have citizenship because states gain power by embracing or encaging populations while also excluding others whom the state defines as ‘unwanted.’ Population control is a very important source of state power. Population size, for example, is a very important component of GDP. One of the reasons why China's GDP is so big is because its population is big, too. But they don't want everyone - they want to be able to exclude too.

At the same time, we live in a world of capitalism. And capitalism needs jurisdiction to operate. It needs legal boundaries and the rule of law to protect the ownership of private property for it to work. The state defines jurisdictions of all sorts, including subnational jurisdictions and jurisdictional carve-outs. Capitalism loves that, too. But fundamentally, it needs the rule of law to protect private property.

So those are two key functions of states: they define jurisdictions and embrace and exclude populations. If we’re going to ask questions about how membership should be defined, we have to be realistic and recognise that we live in a world of global capitalism. The same states that we’re asking all sorts of questions about in terms of how they determine membership are the same ones that anchor global capitalism. It’s in the shifts in global capitalism that we need to position our questions of how citizenship can change.

And it is indeed shifting. What we see, in general, is the growth of regionally interchangeable citizenships. The European Union is probably the best example of that, where being a citizen of one European member state is similar to being a citizen of 27 different member states. The Economic Community of West African States (ECOWAS) is moving more and more in that direction in Western Africa towards a model that’s not just about allowing the free flow of labour across the borders of member-states but of people in general. Mercosur gives extensive rights to citizens of other Mercosur countries. The Gulf Cooperation Council (GCC) and Caribbean Community and Common Market (CARICOM) countries do this too. If we look globally, what we see is the growth of such regional blocs, where citizens get a lot of regional benefits based on that citizenship. I think if we see any change, there will be more movement in that direction. But because global capitalism relies on states bounding off jurisdictions and defining off populations, I don't think we will see a decline in citizenship or increasing equality around citizenship since capitalism thrives on inequality.

Svetlana Ruseishvili: Thank you for our conversation. I'm confident it will be valuable for those researching migration, citizenship, and inequality. Success for your new book!

References

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  • ______. Territory, Authority, Rights: from Medieval to Global Assemblages. Princeton: Princeton University Press, 2006.
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  • ZANINI, Maria C. C.; ASSIS, Glaucia; BENEDUZI, Luis Fernando. "Cidadãos de direito, estrangeiros de fato: narrativas de ítalo-brasileiros(as) na Itália". História Oral, v. 18, n. 1, p. 117-145, 2015.
  • 1
    Supported by Capes-Print fellowship and FAPESP “Bolsa de Pesquisa no Exterior” fellowship (2023/05431-1). The conversation took place on November 30th, 2023, and was recorded and transcribed. The text has since been reviewed and edited by Svetlana Ruseishvili and Kristin Surak.

Section editors

Tuíla Botega, Emmanuel de Nazareth Brasil

Publication Dates

  • Publication in this collection
    17 June 2024
  • Date of issue
    2024

History

  • Received
    05 Feb 2024
  • Accepted
    06 May 2024
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