Peter Spiro This is in large part a function of a changed landscape in which dual citizenship is widely accepted where it was once aggressively suppressed. Nonconsensual citizenship is a different quantity where it merely adds to one’s citizenship of choice. Of course, it can implicate identitarian costs – no one likes to carry the passport of a hated oppressor. In this respect, Lindsey Kingston’s description of the identity-destroying imposition of US citizenship on Indigenous Americans is instructive.180 But as long as one gets to keep one’s real citizenship, as it were, that oppression seems somewhat ephemeral. Imposed citizenship could also be oppressive where it results in unwanted obligations. It is first of all difficult effectively to enforce obligations in the absence of territorial control. Citizenship imposed on individuals beyond territorial control is thus unlikely to be much of a weapon insofar as a state is less likely to be able to enforce any attendant obligations. An interesting outlier case involves the unique U.S. tax regime imposing tax liabilities on external citizens,181 including those who have the status through accident of birth. Leaving aside questions of jurisdiction, moreover, as citizenship obligations dissipate more generally, the status is less likely to implicate material costs in any context. If citizenship does not demand much of its holders there is a lowered risk that it will oppress. There may be exceptions. Russia’s passportisation policies, which are at the center of this Forum, present an example. Although passportisation prior to occupation poses lower risks to individuals, insofar as acquisition of Russian nationality on an external basis is more likely to be volitional and unlikely to involve the exaction of obligations, the constructive imposition of citizenship after occupation has translated into serious costs for many in the form of military conscription. That surely counts as oppressive citizenship. At the same time, however, the legality of conscripting Crimean residents does not depend on the legality of the citizenship policy. Russian conscription of Crimeans violates the well-established rule of international humanitarian law that occupying forces may not conscript residents of occupied territories.182 It’s not clear what a norm against weaponised citizenship would add to that regime. In any case, the Russian policy appears the only recent example in which the imposition of citizenship has resulted in a direct cost on individual holders. Finally, there is the anomalous case of the constructive imposition of Comoros citizenship on otherwise stateless bidoons in the UAE. There may have been a cost of sorts implicated in this transaction to the extent the gambit succeeded in relieving international pressure to extend Emirati citizenship to this population. That gambit appears to have failed; human rights groups have not relented in their criticism of UAE deprivation of bidoon rights,183 and some states (including the US) have refused to recognize passports issued under the scheme. Kuwait retreated from replicating the UAE policy in the wake of its rejection. In the meantime, the Comoros citizenship itself does not result in any direct burdens on its holders. It may not be oppressive in any real sense, disgraceful though the policy may be (in some cases it might actually benefit the bidoons, in the same way that Bronwen Manby describes of the Moroccan nationality attributed to residents of the Western Sahara).184 Citizenship (weakly) weaponised Nor is citizenship much of a weapon as used against other states. States have no doubt come to see citizenship policy as a tool. But instrumental uses of citizenship are typically benign. Where they have been pathological, other states have objected. To the extent that citizenship adds anything to the state’s policy armoury, it has been mostly defused. 180 Kingston 2022. 181 Spiro 2017. 182 ‘Crimea: Conscription Violates International Law’, Human Rights Watch, 1 November 2019, Crimea: Conscription Violates International Law | Human Rights Watch (hrw.org). 183 Bidoons in the United Arab Emirates, Geneva Council for Rights and Liberties, September 2019. 184 Manby B. (2023), ‘Weaponisation of citizenship: two wrongs won’t make a right (or respect rights)’, GLOBALCIT, https://globalcit.eu/ weaponized-citizenship-should-international-law-restrict-oppressive-nationality-attribution/7/ (hereinafter ‘Manby 2023’). 33 Robert Schuman Centre for Advanced Studies