2021] NATIONALITY LAWS 93 precise mechanisms of the discrimination may vary from case to case. Racialized citizenship often intersects with gender and religious discrimination. 36 It can manifest both directly and indirectly, and across distinct “moments” of the citizenship cycle, from acquisition, to naturalization, to deprivation of citizenship.37 Across all of these moments or sites of racialized citizenship, writes David Scott FitzGerald, “racialization may consist of negative discrimination against a particular group and/or a positive preference that favors a particular group.”38 The first moment presents differently depending on whether a state adopts jus soli (right of soil, or birthright citizenship) as its guiding principle, or jus sanguinis (the principle of citizenship by descent). 39 At the second stage, naturalization or conferral of citizenship can be restricted, or denied, for certain groups. 36 See generally Special Rapporteur on Contemp. Forms of Racism, Racial Discrimination, Xenophobia and Related Intolerance, Report, U.N. Doc. A/HRC/38/52 (Apr. 25, 2018) [hereinafter Special Rapporteur Report on Contemporary Forms of Racism]. See also E. Tendayi Achiume, Governing Xenophobia, 51 VAND. J. TRANSNAT’L L. 333, 353–55 (2018) [hereinafter Achiume, Governing Xenophobia]. Achiume notes that “the absence of religion from Article 1’s otherwise broad definition of racial discrimination” undermines “ICERD’s capacity comprehensively to address the contemporary problem of xenophobia.” Id. However, she also notes that the Committee has found that Article 1 may apply to cases involving religious discrimination in some cases. Id. See, e.g., Comm. on Elimination Racial Discrimination, General Recommendation Thirty-Two, on the Meaning and Scope of Special Measures in the International Convention on the Elimination of Racial Discrimination, ¶ 7, U.N. Doc. CERD/C/GC/32 (Sept. 24, 2009) [hereinafter General Recommendation Thirty-Two]; Radha Govil & Alice Edwards, Women, Nationality and Statelessness, in NATIONALITY AND STATELESSNESS UNDER INTERNATIONAL LAW 169 (Alice Edwards & Laura van Waas eds., 2014); Comm. on Elimination Racial Discrimination, Rep. on the Fifty-Sixth Session (Mar. 6– 24, 2000) Fifty-Seventh Session (Jul. 31–Aug. 25, 2000), U.N. Doc. A/55/18, at 152 (Aug. 25 2000); Comm. on Elimination Discrimination Against Women, General Recommendation No. Thirty-Two on the Gender-Related Dimensions of Refugee Status, Asylum, Nationality and Statelessness of Women, U.N. Doc. CEDAW/C/GC/32 (Nov. 14, 2014). 37 See FitzGerald, supra note 35. 38 Id. 39 Id. at 131. For an interesting discussion of jus sanguinis as being “historically tainted because it is rooted in practices and conceptions that rely on ethno-nationalist ideas about political membership,” see Costica Dumbrava, Bloodlines and Belonging: Time to Abandon Ius Sanguinis?, in DEBATING TRANSFORMATIONS OF NATIONAL CITIZENSHIP 73, 73 (Rainer Bauböck ed., 2018). But see Rainer Bauböck, Ius Filiationis: A Defence of Citizenship by Descent, in DEBATING TRANSFORMATIONS OF NATIONAL CITIZENSHIP, supra, at 83 (noting that the following contributions to this collection challenge Dumbrava’s view on this question).