Books in Dialogue: GLOBALCIT Review Symposium on Yossi Harpaz, Citizenship 2.0 and Jelena Džankić, The Global Market for Investor Citizenship


Investors and ancestors: Džankić and Harpaz show the extent and limits of instrumental uses of citizenship

Rainer Bauböck, European University Institute and Austrian Academy of Sciences

These two books overlap and complement each other so nicely that they should be read as a pair. Both study the transformation of citizenship as a legal status in the international state system through instrumental uses by states and individuals. And both combine an empirical analysis with global scope based on impressive original datasets with in-depth studies of particular national and regional contexts.

They complement each other by looking at closely related but also somewhat different phenomena. Jelena Džankić studies access to citizenship for the global elite of the super-wealthy, while Yossi Harpaz focuses on the demand for extraterritorial citizenship of ‘first tier countries’, whose citizenship has the greatest utility value, among those who have the right ancestry or ethnicity. Džankić’s perspective is that of a comparative political scientist whose main interest is in national citizenship policies and laws but also in non-state organisations, such as the firms that act as intermediaries between states advertising their citizenship for sale and potential buyers. Although both books cover the supply side as well as the demand side for supplementary passports, Džankić puts much more emphasis on the comparative macro analysis of national laws and policies, whereas Harpaz’s particular strength lies in his fieldwork and the micro-level analysis of individuals’ motivations to look out for additional citizenships.

The three chapters based on Harpaz’s fieldwork show a rare gift for interpreting individual motives and attitudes by drawing on the respective context and teasing out similarities and contrasts between the three cases. Harpaz is not misled by his theory to search only for instrumental motives but lets his interview material speak freely, teasing out all the nuances and emotional ambivalences that drive his respondents towards seeking an external citizenship that they do not intend to fully and immediately use. Harpaz’s interpretations often point to ‘ironies’, which involve unintended consequences of institutional reforms or individual actions. Yet – unlike many other authors – he does not present these as paradoxes. Instead, he tries to explain unexpected findings based on his in-depth knowledge of contexts. As an illustration, let me mention his explanation of the ‘de-stigmatisation’ of German citizenship in Israel and the rising tide of applications for German passports as an indirect effect of Eastern enlargement of the EU, which created a broader interest in European passports.

There is a striking difference between the mere handful of states offering their passports in exchange for money to the tiny percentage of the global population whom the investor citizenship industry calls HNWIs (high net worth individuals) and the much larger number of states offering ancestry-based citizenship to extraterritorial populations. The former phenomenon has, however, received much more attention among policy makers, journalists and academic scholars than the latter. The reason is certainly that it is (wrongly in my view) regarded as marking a fundamental change in the meaning of citizenship by setting it on an irreversible path towards lightening (Joppke) and decline (Spiro) through commodification. By offering a comprehensive global survey that goes far beyond the highly selective anecdotal evidence that has prevailed so far, Džankić’s book provides a healthy antidote to such overgeneralised diagnoses. Harpaz, on the other hand, highlights a more neglected phenomenon the spread of which requires only three ingredients that are widely present in today’s world: (1) unlimited extraterritorial ius sanguinis that allows for the transmission or retrieving of citizenship across generations born abroad; (2) a trend towards toleration of dual citizenship; and (3) a rising upper middle-class in countries with ‘second tier citizenship’ with ancestral links to first-tier countries. Considering investor and ancestral citizenship in tandem makes one aware that what they have in common is not a trend towards commodification of citizenship, since individuals acquiring an additional citizenship based on a specific ancestry or ethnicity cannot choose in a global market and do not have to invest much money. It is instead an instrumental attitude towards additional citizenships (generally not the first one acquired at birth), which, as Harpaz’s fieldwork demonstrates, may well be combined with identity claims. 

Džankić’s analysis goes, however, beyond ‘pure’ investor citizenship programmes. It covers also discretionary facilitated naturalisation based on special achievements or special interests of the state as well as ‘path-to-citizenship’ programmes offering ‘golden visas’ to investors with fast-track access to citizenship based on residence. As her book documents, these two ways in which money can play a role in acquisition of citizenship are much more widespread than the actual sale of passports in a global market for a fixed price and independent of effective residence requirements. Chapter 2 of Džankić’s book shows that there is little new about giving privileged access to residence and citizenship to those who are willing to pay and invest their wealth. Such practices can be found in most city republics from ancient Greece and Rome up to the French Revolution. They were also not fully eradicated when citizenship was upscaled from local to national levels and became a core institution in the international state system. It was only with the strengthening of universal human rights and democratic norms of political equality after World War Two that special access to citizenship for wealthy foreigners came to be widely regarded as violating a ‘sphere boundary’ (Walzer, Sandel) between the political community and economic markets and as undermining political equality among citizens. While such policies are problematic in many ways – also because they are likely to breed corruption – golden residence permits and pathways-to-citizenship do not undermine the notion that citizenship should be based on a genuine link between an individual and a state so profoundly as the outright sale of citizenship without a residence condition does.

Džankić predicts that the market for pure investor citizenship programmes may soon reach its limits. On the supply side this business model has so far only been attractive for small countries (mostly island states) whose passports are relatively valuable in terms of visa-free travel opportunities but whose economies are relatively weak and for whom selling citizenship can boost state revenue significantly. On the demand side, Džankić detects decreasing marginal utilities in additional passports and points out that birthright transmission implies that the children of passport buyers will themselves not create further demand. She concludes that ‘the only possible option for the demand side of the global market for investor citizenship not to implode are (a) for the number of ultra-HNWIs to continuously grow in the developing countries, or (b) for citizenship status to be depreciated to such an extent that it is available for purchase at “high street prices”’ (p. 216).

Harpaz’s book also extends its empirical scope somewhat beyond the core phenomenon of extraterritorial acquisitions of first-tier citizenships based on ancestry by including the case of ‘birthright tourism’ in the US. He shows that it is not only wealthy Chinese women whom US birth clinics provide with US passports for their children, but also Mexican middle-class families. What these two pathways to instrumental citizenship have in common is that they are not primarily used as a ticket to immigration but in order to upgrade one’s status by joining a more prestigious club without abandoning the membership acquired at birth.

Harpaz’s book contributes significantly to explaining the rising demand for additional citizenships in middle income countries. It results from both persisting global inequality across states as well as rising inequalities within such countries. For their aspiring middle-class, acquiring a European or American passport compensates for the stagnant value of their native citizenship. The core concept introduced by the book is thus ‘compensatory citizenship’. I think it would also have been the most appropriate title. ‘Citizenship 2.0’ sounds maybe more interesting, but it slightly oversells the findings by suggesting that the institution of citizenship itself is undergoing a more fundamental and global transformation.

Among the most important contributions of both books is their shared insight that the demand for investor and ancestral citizenship is not so much driven by the desire to change a losing ticket in the birthright lottery for a winning one by getting a passport that enables the better-off in poorer countries to move to richer ones. Džankić analyses the market for investor citizenship instead as one for luxury goods that do not belong to life’s essentials but help to raise the owner’s prestige. Harpaz provides a lot of empirical evidence showing similarly that while mobility opportunities are certainly an important asset, the value of additional extraterritorial citizenships is most often consumed extraterritorially in one’s native country. Supplementary high-value passports raise their holders’ social prestige. They serve also as insurance policy in case of severe future economic or political crises, but as with most insurance schemes, they are not purchased because one already plans to expose oneself to the risk against which one takes out insurance.

Harpaz’s and Džankić’s books provide solid comparative evidence that will help to nuance the ongoing debate about the transformation of citizenship due to globalisation. Building on their findings, new questions could also be raised. During a global pandemic and with a looming climate catastrophe, one might wonder whether we are about to enter a new period of deglobalisation in which states are once again keen to tighten the boundaries around their membership in order to avoid becoming responsible for and having to take in nationals whom they have created through extraterritorial citizenship policies. For normative theorists like myself both books raise also intriguing questions about the relation between the internal equality of citizenship status and the inequality of conditions for acquiring it, which are starkly highlighted by the simultaneous trends of raising income criteria for regular naturalisation of immigrants and of making wealth more relevant for privileged access (discussed by Džankić in chapter 3). It would also be fascinating to extend the ongoing debate on the global moral arbitrariness of the ‘birthright lottery’ – which still creates territorial communities of citizens marked as equals because they share the same conditions of birth in the territory or having citizen parents – by examining in more depth the moral arbitrariness of extraterritorial citizenship based on ancestry or wealth, both of which reinforce global inequalities through an unequal domestic distribution of citizenship statuses and opportunities.