28 Melbourne University Law Review [Vol 41(2):Adv Australian citizen’.134 In addition, an Australian citizen with dual citizenship automatically lost their Australian citizenship if they ‘serve[d] in the armed forces of a country at war with Australia’.135 This provision has been part of Australian citizenship legislation since its introduction in 1948 but has never operated to deprive a person of their citizenship.136 The Allegiance to Australia Act created three new avenues for citizenship deprivation that apply to Australians with dual citizenship. Two of these avenues provide for citizenship loss to take place automatically upon fulfilment of particular criteria. First, a dual citizen can lose citizenship by committing prescribed conduct with the intention of: ‘advancing a political, religious or ideological cause’;137 ‘coercing, or influencing by intimidation, … [a] government’;138 or ‘intimidating the public’.139 The conduct that triggers citizenship loss is defined by reference to terrorism and foreign incursions and recruitment offences.140 Secondly, the longstanding provision providing for automatic citizenshiploss for dual citizens who ‘serve[] in the armed forces of a country at war with Australia’141 is updated to include ‘fight[ing] for, or … in the service of, a declared terrorist organisation’.142 However, the law specifies that being in the service of such an organisation does not include the provision of ‘neutral and independent humanitarian assistance’,143 unintentional actions,144 or actions committed under duress or force.145 These two grounds are triggered automatically when a citizen engages in particular activity and do not require a conviction or the exercise of a ministerial discretion. However, the Minister does have an obligation to take reasonable steps to inform a person who has lost their 134 Ibid ss 34(1)(c), (2)(c). 135 Ibid s 35(1). 136 See, eg, Kim Rubenstein, Submission No 35 to Parliamentary Joint Committee on Intelligence and Security, Inquiry into the Australian Citizenship Amendment (Allegiance to Australia) Bill 2015 (20 July 2015) 3. 137 Australian Citizenship Act 2007 (Cth) s 33AA(3)(a). 138 Ibid s 33AA(3)(b)(i). 139 Ibid s 33AA(3)(b)(ii). 140 Ibid s 33AA(6). 141 Ibid s 35(1)(b)(i). 142 Ibid s 35(1)(b)(ii). 143 Ibid s 35(4)(c). 144 Ibid s 35(4)(a). 145 Ibid s 35(4)(b). Advance Copy