JOURNAL OF CONTEMPORARY EUROPEAN STUDIES  31 parties to the ECHR, only France has signed the ECN. The ECN goes furthest in limiting state power to deprive of citizenship: conduct that is seriously prejudicial can lead to loss of citizenship but, unlike the 1961 UN Convention, the person concerned cannot be made stateless. CoE experts were less convinced that terrorism falls under this specific ground of loss of nationality suggesting divergent standards in relation to national security and loss of nationality (Mantu 2015, 79; 87). Although the ECHR does not contain a human right to a nationality, the European Court of Human Rights (ECtHR) has recognized that nationality is part of one’s social identity and as such protected under Article 8 ECHR (Karrassev v. Finland, Genovese v. Malta). Most ECHR cases have dealt with state refusals to grant nationality, and, in one case, the ECtHR found such refusals to be discriminatory as children born out of wedlock could not obtain nationality (Genovese v. Malta). Ramadan v. Malta is one of the few cases where loss of nationality has been tested against Article 8 ECHR protection. The applicant acquired nationality via naturalization based on his marriage. Once that marriage was annulled as a marriage of convenience, the applicant’s naturalization was withdrawn on fraud grounds. The ECtHR found that ‘a loss of citizenship already acquired or born into can have the same (and possibly a bigger) impact on a person’s private and family life’ (Ramadan, para 85) but did not consider the state measure arbitrary. Its decision was based on three elements that resemble the interpretation given to the notion of arbitrary deprivation by UN bodies: the measure had a legal basis, it respected procedural grounds, and the effects of the revocation for the applicant’s right to private and family life were not deemed serious enough to justify a violation of Article 8 ECHR since the applicant was not expelled and continued his life in Malta despite losing nationality. When exercising their nationality powers, as EU member states, France and the UK are obliged to have due regard to EU law (Micheletti), even if the EU has no competences in the field of nationality law. In Rottmann, the European Court of Justice acknowledged the legitimate interests of a state to withdraw fraudulent naturalizations, but identified the EU principle of proportionality as a limit to state power because losing national citizenship leads to loss of EU citizenship. A citizenship deprivation order needs to examine the effects of that measure in relation to loss of both national and EU citizenship by performing a proportionality check that scrutinizes the consequences for the person concerned and his family members of losing the rights enjoyed by every citizen of the Union; the gravity of the offence committed; the lapse of time between naturalization and withdrawal; and the possibility of recovering the original nationality. Based on the above discussion, it is possible to speak of a convergent trend in international, human rights and EU law toward establishing obligations for states not to arbitrarily deprive of nationality and to prevent statelessness. Yet, the legal framework designed around the right to nationality reflects the tension between nationality as a corollary of state sovereignty and the far-reaching effects that state nationality decisions can have for the person concerned and for the international community (Kesby 2012) since citizenship deprivation is not outlawed entirely. As the next sections will illustrate, the limits of the current framework of protection become clearer at the national level when international legal standards intersect with political considerations around national security, immigration, and terrorism. UK citizenship: a privilege that can be revoked Under Section 40 of the British Nationality Act (BNA), the Home Secretary can make a citizenship deprivation order if satisfied that it would be conducive to the public good and to