Why You Want a “Gray” 2nd Citizenship

By Parviz Malakouti-Fitzgerald, Esq. 

You want your 2nd citizenship as gray as possible

This article is based on this X post made on April 12th, 2026

People pursuing 2nd citizenship for safety and security of their family can learn from survivalist concepts. One of those concepts is the “gray man” - the idea that in tough times, you want to be able to disappear into a crowd when necessary.

All other things being considered equal, you want as gray of a 2nd citizenship as possible, especially if you’re getting that citizenship by investment. Citizenship by merit in which the “merit” is financial investment or donation (all the hotness nowadays among mobility infleuncers) counts as citizenship by investment here because they have very similar vulnerabilities.

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The Problem With Honorifics and Adjectives

Perhaps contrary to what many people might instinctually think, with citizenship, I believe on a long timeline, you generally do not want honorifics and adjectives attached to the citizenship, e.g. "honorary citizenship" (e.g. Vanuatu) or "economic citizenship" (e.g. Nauru) in that country's domestic law.

In many countries, these words create little distinctions that can be used now, or in the future, to discriminate against your citizenship or the benefits of your citizenship. You don't want to be classed differently under that country’s domestic law, even if the classification is currently benign.

Special “Types” of Citizenship vs. Statutes that Permit Citizenship by Investment

To be clear, I'm not referring to the mere existence of sections in a country's statutes and regulations that refer to the eligibility and process for obtaining citizenship by investment (e.g. "registration" under St. Kitts and St. Lucian law). Those sections are necessary, and will obviously be different than sections regarding naturalization or acquisition by other means.

But having a separate statutory term for a citizen by investment in the domestic law is definitely a negative for the long term security of the citizenship and its benefits. The easier to distinguish, the easier to discriminate. 

How the Discrimination Happens

A future ruling party in the country can discriminate against the particular citizenship “type”, as well as foreign countries with springboard benefits or passport recognition. The specific honorific makes the discrimination easier.

I think we will see much more of this discrimination in the coming years, especially from foreign countries. For example, a country could grant a treaty benefit to all citizens of a particular country except those who obtained it by investment.

Real World Examples

Example One: The E-2 Treaty Investor Change

The US's change in the definition of E-2 treaty investor in 2022, to exclude citizens by investment who haven't had domicile in the country for at least three years, is a good example. This requirement is now incorporated in INA § 101(a)(15)(E), although that doesn’t stop unscrupulous CBI promoters and mobility influencers from acting as if it doesn’t exist.

Example Two: Visa Free Access

A second example would be granting visa-free access to all citizens of a country except those who obtained it by investment.

Example Three: Passport Renewal

A third example would be St. Kitts having separate passport renewal criteria, including a possible background check, for citizens by investment versus other citizens. No bueno.

Why This Is a Long Term Liability

Domestic statutes cross-reference each other, and having a neatly identifiable category for people creates a group that can be put through the ringer the moment a major publication puts pressure on the country by showing that two out of seven thousand citizens by investment acted naughtily last year. This is a serious latent liability on the long timeline.

Most people get citizenship wanting and hoping to have it for the rest of their lives and the lives of their children. Fifty, sixty, seventy years is a long time, and a lot of political drama can happen in that period.

What "Gray" Citizenship Looks Like

You generally want your citizenship to be as gray as possible. To blend in with other citizenships from the country. As few distinct descriptors in the statutes and regulations creating the legal basis of the citizenship. You want the citizenship to be referred to in domestic law as similarly to other citizenships as possible. 

Domestic laws that make it illegal for agencies to discriminate on the basis of the origin of a citizen's citizenship would be even better. A law making it illegal for agencies to even inquire regarding the basis of the citizenship would be better still.

To my knowledge, no CBI country currently has a domestic law prohibiting its own agencies from inquiring regarding the basis of a person's citizenship. One can dream. This would be one of the characteristics of the “perfect” CBI program, in this author’s opinion. 

What You Can Do Now - Look to the Country’s Domestic Law

In the meantime, you can look for distinct statutory terms in the current statutes and regulations in the domestic law of the country granting the citizenship. Consult with a real mobility lawyer or consultant, other than CBI salesmen. It's what you can do now.

Words carry weight that might not be apparent now but can hit like a Mack truck in the future.

Book a Consultation with Malakouti Law

At Malakouti Law, we help people evaluate the pros and cons of different citizenship options, including potential vulnerabilities. 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.