The Robustness of a Citizenship and Its Benefits
By Parviz Malakouti-Fitzgerald, Esq.
When you buy a car, you're naturally going to be pissed off if the car dies in 2 years, or if you can no longer use reverse, recline the seat, or go over 40 MPH. You expect some longevity from the thing and its functions.
Moreover, you understand that some cars last longer than others. That's why used Toyota Land Cruisers are greatly valued while Ford Tauruses are not.
For some reason, people pursuing 2nd citizenship have largely suspended this reasonable assumption. They don't think about variances in durability, toughness, ruggedness, robustness, or longevity when it comes to 2nd citizenship. Choose your favorite word. I'm referring to the quality of resistance to involuntary degradation.
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In the realm of mobility, I call this quality robustness. (Shout out to Nassim Taleb, even though he angrily called me an idiot and blocked me on X.)
Here is the unpopular truth: not all citizenships, nor all citizenship benefits, are created equal in their robustness.
Look to the Source of the Benefit
In order to evaluate how robust a citizenship and its benefits are, you must make inquiry into the source of those benefits and their common attack vectors.
Everybody knows that citizenships come with different benefits: immediate highest right of entry and stay, visa-free travel, satellite residency rights, non-mobility treaty benefits, consular assistance, consular springboarding, etc. The list goes on.
But the robustness of these benefits rests upon totally different elements, some of which are outside the exclusive control of the country of citizenship. This is why I always hammer the point that while citizenship granting is highly centralized, recognition of a citizenship's benefits is highly decentralized.
Exclusive Control vs. Non-Exclusive Control
The country's exclusive control versus non-exclusive control of a benefit is a key fault line in this analysis.
As an example, 3rd country visa-free access is outside the exclusive control of the country of citizenship. It relies upon treaties with foreign countries, and therefore upon relations between those two countries, as well as domestic law, policy, and even public opinion in the 3rd country.
However, the immediate highest right of entry to one's own country of citizenship is exclusively within the control of that country. ("Within exclusive control" does not mean immune to influence by foreign countries.)
Example: if someone had obtained Iranian citizenship in 1978, on the eve of Iran becoming a pariah in the West, they'd be disappointed with their loss of visa-free access. But their highest immediate right of entry to Iran would have remained largely undisturbed (assuming they want to return!).
Core Mobility Benefits vs. Springboard Mobility Benefits
Therefore, the former benefit (3rd country visa-free access) is more fragile than the latter, because the former has more attack vectors.
The former is a springboard mobility benefit. The latter is a core mobility benefit, entirely unreliant on cooperation from a foreign country. Other springboard benefits follow a similar analysis.
A powerful heuristic: core mobility benefits are more robust than springboard mobility benefits.
Add the Timeline of Life
We already know that these benefits, even when enjoyed at 100%, have different values, especially considering the subjective preferences of different citizens.
For example, a Hungarian citizen may value his ability to reside in Austria (satellite residency benefit) more than his ability to visit Bolivia visa-free (visa-free benefit) in this present moment. He may value his ability to reside in Hungary the most (core residency benefit).
But the different benefits also have different ROBUSTNESS values when considered over the timeline of the citizenship. The visa-free travel provided by Hungarian citizenship is more likely to be degraded, or even entirely lost, over the remaining decades of the person's life than his ability to reside in HUNGARY.
For a sober analysis of these benefits, you must add the timeline of life.
So springboard mobility benefits must be discounted by the 2nd citizenship planner or consumer in relation to core mobility benefits. And to do that, you need to actually look at the legal bases of these benefits.
Know the Legal Basis of Each Benefit
A few examples:
1. Visa-free access - usually bilateral treaties
2. Satellite residency - usually union treaties (e.g., TFEU Art. 21) or bilateral treaties
3. Consular assistance - the Vienna Convention on Consular Relations (VCCR) and the domestic law of the country of citizenship
These legal bases have wildly different qualities and circumstances affecting their creation, change, and loss over time.
While nobody can predict exactly what nation-states will do, there are definitely patterns in their behavior regarding mobility benefits that can be identified. Those qualities and patterns must be considered.
The Bottom Line
A naked list of the benefits of a particular citizenship is just words on a page, totally devoid of those wildly differing robustness values. One benefit will be gone tomorrow, and another will last a lifetime.
Consider this factor. Plan your freedom of movement accordingly.
Book a Consultation with Malakouti Law
At Malakouti Law, we help people evaluate the pros and cons of different citizenship options, including how robust each citizenship and its benefits are likely to be over time. Click here to book a consultation.
This article is for general informational purposes only and does not constitute legal advice. Immigration and citizenship laws vary by country and change frequently. You should consult a qualified attorney regarding your specific circumstances before making any decisions related to citizenship, residency, or investment migration.
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