to extend deprivation of citizenship to dual nationals following the November 2015 terrorist attacks in Paris were opposed and ultimately shelved in early 2016. Naturalized citizens may also be more vulnerable to deprivation of nationality. First, nationality can be deprived on grounds of fraud or misrepresentation only if conferred by naturalization as part of a troubling new pattern have been revoking nationality by retroactively nullifying naturalization on grounds of fraud or non-fulfilment of the conditions for acquiring nationality. Second, the perception that a naturalized person will have, or be eligible to acquire, another nationality may be erroneous. This form of inequality between natural-born and naturalized citizens may raise concerns under international law. To avoid such concerns, the 2015 Citizenship amendment act of Australia, in introducing grounds for deprivation based on terrorism-related offences, stipulates that the new grounds apply “to a person who is an Australian citizen regardless of how the person became an Australian citizen (including a person who became an Australian citizen upon the person’s birth)”.88 Importantly, several States with such new terrorism-related grounds for deprivation have preserved or established due process protections in line with Article 8(4) of the 1961 Convention. The 2015 Citizenship Amendment Act in Australia, for instance, includes specific provisions on the right to speedy and written notice and to review “in the High Court of Australia under section 75 of the Constitution, or in the Federal Court of Australia under section 39B of the Judiciary Act 1903”.89 Establishing appropriate due process safeguards along these lines is crucial to ensuring that deprivation of nationality is not arbitrary. As a final, practical note, States should be mindful that revocation of nationality may actually be less effective as a national security measure than existing tools available under international law, including monitoring and surveillance, criminal investigation and prosecution. Depriving terrorists or suspected terrorists of nationality may also conflict with a State’s obligation to extradite or prosecute perpetrators of international crimes.90 Removing dangerous individuals may endanger citizens living abroad, and the citizens of other States. Alternative means of addressing security-related concerns are therefore to be encouraged. 88 Australian Citizenship Amendment (Allegiance to Australia) Act 2015, Section 33AA, available at: www.legislation.gov.au/Details/ C2015A00166. 89 Ibid., Section 33AA(10) and 33AA(11). 90 See, UN Security Council resolution 2322 (2016) Adopted by the Security Council at its 7831st meeting on 12 December 2016, S/RES/2322 (2016), available at: http://undocs.org/S/RES/2322(2016) 32

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