Weapons of Massive Deception: Defusing the Destructive Potential of Citizenship in a New Geopolitical Era What about naturalising ethnic kin groups in neighbouring states without claiming or controlling their territory? The best-known case is Viktor Orbán’s policy of turning ethnic Hungarians in the neighbourhood into citizens.207 The policy had two intended effects: rejecting symbolically the 1920 Trianon Peace Treaty in which Hungary lost territories with ethnic Hungarian majority populations and creating loyal voters for his FIDESZ party in Hungarian elections. In one of the affected countries (Slovakia), the policy also upset the internal recognition of ethnic Hungarians as an ethnic minority through triggering a law depriving them of their Slovak citizenship if they chose the Hungarian one.208 A similar policy envisaged by the 2017 Austrian government towards German speaking South Tyrolians was fortunately scrapped after strong protests by Italy and the implosion of the Austrian government coalition in 2019.209 In most cases it would be an exaggeration to say that citizenship was used as a weapon against another state. But there is still a potential for destabilisation – not of a target country’s territory, but of its internal recognition and accommodation of ethnic minorities. This should be enough to create a concern for international law, which has so far been addressed through soft law norms like the 2001 Venice Commission Report210 and the Bolzano recommendations of the OSCE High Commissioner on National Minorities211 mentioned by Jain.212 Bulgaria’s policy of first offering North Macedonians EU citizenship213 via a Bulgarian passport and then blocking the start of EU accession negotiations for North Macedonia in November 2020 illustrates how co-ethnic citizenship policies may eventually also affect another country’s external sovereignty.214 Finally, consider states that massively inflate the numbers of their citizens abroad through unlimited transmission of nationality iure sanguinis across generations combined with acceptance of dual citizenship.215 In these cases, the main concern is about the effect of such policies on electoral outcomes and the meaning of citizenship in the country that hands out the passports. There is no weaponisation involved since citizenship policies do not target and destabilise other countries. However, they still interfere with domestic equality of citizenship by selectively bestowing the advantages of a second nationality on another country’s citizens.216 If this happens on a massive scale, it could justify complaints towards the citizenship-granting state and might become an issue for soft international norms articulated as recommendations. Instead of throwing up our hands in despair at the conflict of norms at the heart of international law, one could thus build a sliding scale of cases, with hard international law norms kicking in at one end of the spectrum and soft ones at the other. In fleshing out such a scale, the principles of genuine link and voluntary naturalisation should play a subsidiary role. A proof of genuine link or consent in extraterritorial naturalisations is never sufficient to justify violations of the territorial integrity of another state. Where extraterritorial naturalisations have the intent or effect of territorially destabilising another state, it does not matter much whether the populations concerned regard themselves as having a genuine connection to the country that offers its citizenship and whether they genuinely consent to their naturalisation (as Ganohariti says they did in Abkhasia, South Ossetia and Transnistria) or are forced to choose an external citizenship under threats of discrimination if they don’t (as Knott argues was the case in Crimea).217 If international law did not rule out claims to 207 Pogonyi 2017. 208 Bauböck 2010. 209 Bauböck R. and Haller M. (2021), Dual Citizenship and Naturalisation: Global, Comparative and Austrian Perspectives, Austrian Academy of Sciences Press. 210 ‘Report on the Preferential Treatment of National Minorities by their Kin-State, adopted by the Venice Commission at its 48th Plenary Meeting’, Council of Europe, Doc. 168/2001. 211 ‘Bolzano/Bozen Recommendations on National Minorities in Inter-State Relations’, Organization for Security and Co-operation in Europe (2008). 212 Jain 2022. 213 ‘10,720 persons get Bulgarian citizenship in 2015’, GLOBALCIT, 16 February 2016, 10,720 persons get Bulgarian citizenship in 2015 - Globalcit. 214 Barigazzi J., ‘Bulgaria blocks EU membership talks for North Macedonia’, Politico, 17 November 2020, Bulgaria blocks EU membership talks for North Macedonia – POLITICO. 215 Dumbrava C. and Bauböck R. (2015), Bloodlines and belonging: Time to abandon ius sanguinis, Robert Schuman Centre for Advanced Studies and EUDO Citizenship Observatory, RSCAS 2015/80. 216 Harpaz Y. (2019), Citizenship 2.0: Dual Nationality as a Global Asset, Princeton University Press. 217 Ganohariti 2022; Knott 2022. European University Institute 38