GENEVA, SWITZERLAND — As globalization deepens and cross-border mobility increases, a quiet but significant legal crackdown is unfolding across Asia: an ultimatum on dual citizenship.
Nations like Japan, China, and Hong Kong are doubling down on policies that demand loyalty to one nation only, forcing thousands of dual nationals, often born into their status, to make a heartbreaking decision between legal recognition and cultural belonging.
In January, a Japanese court upheld the country’s controversial nationality law, reaffirming that citizens must choose one nationality by age 22. The case, brought by Japanese citizens living abroad, challenged Japan’s long standing stance against dual citizenship, but was rejected on constitutional grounds.
The decision has been wrenching for individuals like “Anna,” a mixed-race woman born to an American father and Japanese mother.
“I’m mixed race. I’ve lived both in Japan and the US. I speak both languages. I am completely split down the middle regarding my identity,” she said. “It’s like asking someone whether they love their mother or father more. It’s such a cruel question.”
Dual Citizenship: A Global Shift — with an Asian Exception
Globally, the acceptance of dual citizenship has grown significantly over the past six decades. In 1960, fewer than one-third of countries permitted dual nationality, but more than 75% do today, according to Maastricht University research.
However, Asia remains the most restrictive region globally, with only 65% of countries allowing some form of dual nationality, often with caveats. In contrast, 91% of countries in the Americas support dual citizenship.
In 2024 and 2025, the trend in Asia has not liberalized but hardened, with countries tightening enforcement, restricting consular services, and using loyalty laws to curb political dissent and safeguard national identity.
Japan’s Legal Ultimatum: Choose by Age 22
Japan’s post–World War II nationality law compels citizens with multiple nationalities to declare allegiance to a single country before they turn 22. While this policy has been loosely enforced in some cases, recent court rulings suggest the government is ready to get serious.
Key Implications:
- Japanese dual nationals abroad may be forced to surrender their Japanese citizenship to retain another nationality.
- Those who do not declare may be automatically stripped of Japanese nationality.
- Children born abroad to Japanese parents may face denial of citizenship if they do not register in time or choose a nationality under pressure.
According to Atsushi Kondo, law professor at Meijo University, Japan’s harsh stance stems from historical fears of disloyalty during wartime — a legacy still echoed in today’s nationality debates.
China: From Tolerance to Crackdown
In contrast to Japan’s legal rigidity, China’s crackdown has been more opaque — but no less severe. Though Chinese law does not recognize dual citizenship, many Chinese nationals have quietly held second passports for years. That era is ending.
Under President Xi Jinping’s anti-corruption campaign, Beijing has encouraged citizens to report suspected dual nationals, with consequences ranging from loss of access to public services to asset freezes, passport revocation, and even arrest.
Notable Developments:
- Hong Kong’s February 2025 decree stripped dual nationals of consular protection — the first step in the city’s history.
- Public informant hotlines have been established in several cities to report dual nationals.
- According to estimates from China’s central bank, 18,000 corrupt officials fled the country with $122 billion between the mid-1990s and 2008, prompting a new focus on dual nationals exploiting legal loopholes.
“China’s refusal to acknowledge dual nationality ensures that its citizens give undivided loyalty to the Communist Party,” said Low Choo Chin, a historian at Universiti Sains Malaysia. “The law was designed to eliminate grey areas — and loyalty tests are now being rigorously enforced.”
Identity in Crisis: When Law and Heritage Collide
The crackdown is more than just a legal development — it’s a profoundly personal rupture for millions of people, particularly among the Asian diaspora, who live and work across borders but maintain family, cultural, and financial ties to their homelands.
During the COVID-19 pandemic, the consequences became stark: several dual-national families were split, unable to evacuate together. In one widely reported case, a British mother was told she could not leave China with her toddler son, who held a Chinese passport, even though he was also a British citizen.
Also, Chinese-born Canadian citizens were denied boarding evacuation flights due to “passport inconsistencies.”
Nationalism and Ethnicity: Loyalty by Design
The rejection of dual nationality in Asia often reflects a desire to preserve ethno national identity. Policymakers have historically viewed dual allegiance as a threat in highly homogenous countries like China, Japan, and South Korea.
“Citizenship is used not just as a legal tool, but as a gatekeeper of cultural purity,” said Jelena Dzankic, co-director of the Global Citizenship Observatory (GLOBALCIT). “Countries are asking: Who are you loyal to — and can you be trusted if you’re both?”
This has especially affected mixed-race individuals and those with dual-heritage families, who must navigate not only government policies but social stigma and institutional discrimination when choosing one passport over another.
Amicus International Consulting: Offering Legal Identity Solutions in a Polarized World
As legal regimes grow more restrictive, Amicus International Consulting offers individuals a compliant, discreet, and lawful pathway to global identity restructuring, second citizenship, and international mobility — without violating national laws or sparking political conflict.
“We see a rising number of clients in Asia and the diaspora who need help navigating these impossible choices,” said an Amicus spokesperson. “We don’t just offer passports — we offer clarity, protection, and lawful strategies for living freely in an increasingly divided world.”
Amicus Offers:
- Legal Second Citizenship through Ancestry
(e.g., EU, Caribbean, and Latin American countries with descent-based citizenship) - Residency Solutions in Extradition-Free or Neutral Nations
(For individuals at risk or with politically sensitive backgrounds) - Legal Identity Change Services
(For safety, privacy, or cultural reintegration under a new identity) - Tax and Privacy Structuring
Fully compliant with FATCA, CRS, and OECD regulations
Case Study: Japanese American Businesswoman Navigates Nationality Law
A Tokyo-born executive with U.S. dual citizenship contacted Amicus in 2024, facing pressure to renounce her American nationality under Japan’s age-22 declaration law.
Amicus successfully guided her through a legal retention and privacy pathway, preserving her international assets, shielding her identity, and lawfully aligning her with one nationality in public, while privately retaining both nationalities for global movement and tax structuring.
Case Study: Hong Kong–UK Family Divided by Policy
A family of four, split between British and Chinese passports, faced consular protection gaps in Hong Kong. With growing risks to the children’s legal rights and education status, Amicus helped relocate the family to a neutral Caribbean jurisdiction, securing legal residency, school placement, and long-term asset protection, without triggering Chinese nationality conflicts.
Conclusion: Nationality in the Age of Division
Dual citizenship once symbolized global freedom, opportunity, and mobility. Today, it has become a battleground for loyalty, identity, and political control in Asia. As countries like China and Japan grow more rigid, global citizens must proactively manage their legal status to avoid becoming collateral in a geopolitical tug-of-war.
Amicus International Consulting remains committed to offering transparent, lawful, and ethical solutions — enabling individuals to live freely, protect their families, and chart their future, no matter their passport.
📞 Contact Information
Phone: +1 (604) 200-5402
Email: info@amicusint.ca
Website: www.amicusint.ca
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