In an increasingly globalized world, dual citizenship remains a contentious issue, offering both benefits and challenges. It has the potential to inspire national unity beyond national borders on the one hand and the power to encourage separation on the other hand by creating “us” versus “them” narratives. Dual citizenship laws and their associated impacts constitute a major gap in the academic study of citizenship throughout Africa. This report analyzes a few cases of dual citizenship laws across the continent, focusing on their political, economic, and social impact. It examines the potential advantages and disadvantages for African countries in permitting or restricting dual citizenship of their diaspora communities.

This report examines dual citizens and the African diaspora in the context of dual citizenship laws and origin countries. Dual citizens hold citizenship in both their country of origin and that of another country, but the concept remains complex. Some states grant them full rights and benefits, while others require nationals to renounce foreign citizenships before returning home.

“The African diaspora” is a complex term. Diaspora populations consist of people who have migrated from one place to another. The term is undoubtedly linked to an identity. In general, the “African diaspora” encompasses many people, including those born or raised on the African continent but now reside elsewhere and those born or raised outside of the African continent with parents, grandparents, great-grandparents, or other close ancestors who originated from Africa. Defining the African diaspora is challenge because of the various parameters used to describe this population. The African Union (AU), for example, has identified issues with defining the people who make up what the Union symbolically calls “Africa’s sixth region”.¹“The Six Regions of the African Union”, West Africa Brief, Sahel and West Africa Club, http://www.west-africa-brief.org/content/en/six-regions-african-union. Accessed 24 Sept 2022. In 2005, a panel of AU experts developed and adopted the following definition for the diaspora: “The African Diaspora consists of peoples of African origin living outside the continent, irrespective of their citizenship and nationality and who are willing to contribute to the development of the continent and building of the African Union.”²Executive Council Seventh Ordinary Session, (African Union, 2 July 2005). https://au.int/sites/default/files/decisions/9629-council_en_28_june_2_july_2005_council_executive_council_seventh_ordinary_session.pdf  In a 2010 speech, Dr. Jinmi Adisa, the then-Director of Citizens and Diaspora Directorate of the AU Commission, referred to this definition and the criticisms it faced. To some, not adding “permanently” before “living outside the continent” made the definition too inclusive. To others, implying in the last line that members of the diaspora can only identify themselves as such if they want to contribute to developing Africa and the AU made the definition too exclusionary. In response to the critiques, the AU concluded that the 2005 definition was still cohesive and all-encompassing enough to be respectful of heritage, migration patterns, the principle of inclusivity, and view that the AU had already taken years prior that the diaspora could be seen as a participating member in building the Union. The 2005 definition was also “a working definition” that reflected a nuanced population that is also a work in progress.³Speech by Dr. Jinmi Adisa, 21-22 October 2010, https://au.int/sites/default/files/speeches/27319-speech_dr_adisa_au_diaspora_meeting_ny_21-22_oct_2010_wuyi.pdf (see PDF p. 4-6) Accessed 8 Aug 2022 The AU has continued to use the 2005 definition as its starting point when referring to the African diaspora,⁴Gibril Faal, “Strategic Business and Operational Framework for an African Diaspora Finance Corporation”, May 2019, https://au.int/sites/default/files/documents/40899-doc-EN_- _ADFC_Business_and_Operational_Framework_-_May_20191.pdf (see PDF p. 15-17). and other scholarly articles refer to this definition as well.⁵Crush, Jonathan. “Diasporas of the South: Situating the African diaspora in Africa”, published 2011,https://books.google.com/books?hl=en&lr=&id=D19Km91e9I8C&oi=fnd&pg=PA55&dq=dias poras+of+the+south+situating+in+africa&ots=jVbFulM97U&sig=TFMBxSChobELP_Y0Rj3mYd yg6ZY.   ⁶Ateghang-Awankem, Bernadette and Kenneth Yongabi Anchang. “Engaging African Diaspora in the Fight against Vaccine Hesitancy”, published 2020, http://article.scipublichealthresearch.com/pdf/AJPHR-9-1-4.pdf. ⁷Darkwa, Samuel-Kofi. “From Brain-Drain to Brain-Gain: The African-Diaspora Community and Development in Africa”, published 2020, https://www.researchgate.net/profile/Samuel Darkwa/publication/340565752_From_Brain-Drain_to_Brain-Gain_The_African Diaspora_Community_and_Development_in_Africa/links/5e90d6ef92851c2f5294b186/From -Brain-Drain-to-Brain-Gain-The-African-Diaspora-Community-and-Development-in-Africa.pdf Keeping the definition in mind, the members of the diaspora that this report will focus on are the people of African origin living outside the continent who can claim citizenship (i.e. hold a passport) in one African country as well as in a non-African country.

This report will first give the reader a sense of the importance of dual citizenship for a state and its society by examining the implications of diaspora and dual citizens in reference to the economic, social, and political realms. Then we will examine these realms and associated dual citizenship laws in reference to East Africa, North Africa, West Africa, and Southern Africa to ascertain their implementation across the African continent. In the progress section, we look at the collective themes and trends across Africa regarding dual citizenship laws. Finally, we return to the big picture and offer recommendations regarding these laws for African states.

IMPLICATIONS

There is a growing global trend of states embracing dual citizenship, and diaspora populations are increasingly seizing the opportunity.⁸Vertovec, Steven. “The Political Importance of Diasporas.” migrationpolicy.org, September 21, 2021. https://www.migrationpolicy.org/article/political-importance-diasporas. This section highlights the implications of dual citizenship laws on African states. The report also reviews one of the possible advantages and disadvantages of dual citizenship laws in economics, society, politics, and foreign policy. The focus is on the diaspora’s impact on their country of origin.

Economic

The rising migration of Africans to Europe and the United States, has heightened focus on the economic impact of those leaving the continent. A significant number of countries in Africa suffer from “brain drain” or similar ills that lead much of its educated population to leave the continent in hope of a better financial future elsewhere. Some diaspora members sever ties with their home countries, while many actively seek ways to give back.

The economic implications of diaspora populations have focused on a few issues. For example, diasporas assist the economy of their countries of origin through remittances and other means, including hometown associations and charitable initiatives that directly affect economic development, poverty reduction, and capacity building. Diaspora populations are also an integral part of the development of low-income and lower-middle-income countries as they maintain their connection and the policies of the country allow it. Several factors may play a role in how effective diaspora populations can be in the development of their countries. For instance, they will have a significant impact if they can access economic resources or are afforded greater ease in communication and travel. Without these engagement barriers, diaspora expats and entrepreneurs can leverage their expertise and social capital to drive economic development in the Global South through foreign direct investment, technology transfer, and capacity building. However, it is important to note that diaspora populations could also contribute to societal ills by creating the conditions for criminal networks to thrive.⁹Vertovec, Steven. “The Political Importance of Diasporas.” migrationpolicy.org, September 21, 2021. https://www.migrationpolicy.org/article/political-importance-diasporas.

Social

The African diaspora populations play a pivotal role in addressing the economic, political, and social challenges facing their country of origin. However, discrimination, xenophobia, Afrophobia, and other forms of intolerance often hinder their full participation in political and economic activities.¹⁰Kapur, Devesh. 2014. “Political Effects of International Migration.” Annual Review of Political Science 17, 479-502. Despite these barriers, diaspora populations raise awareness of these social injustices and advocate for progress in their homeland. Additionally, they facilitate cross-border exchanges of ideas, fostering cultural understanding abroad and introducing innovative solutions back home.

Political

Diaspora populations impact their home country’s domestic politics in many ways. Perhaps the most obvious is lobbying host countries to shape the political agenda regarding the country of origin. Additionally, diaspora populations may find safety in distance and support opposition governments or politicians through verbal or material support. Therefore, even from afar, diaspora populations could have major political impacts on political parties, social movements, and civil society organizations within their origin country. Unfortunately, diaspora influence is not always “positive”, and they can cause considerable domestic strife or exacerbate existing tensions.

LESSONS

Africa is a continent with diverse societies that do not all respond to the phenomenon of dual citizenship in the same way. With that in mind, we split up our findings on a regional basis.

East Africa

The East African region, particularly in the Horn of Africa, is known for being politically fragile and prone to different types of conflicts. As a result, this area also experienced massive displacement, with people migrating to Europe through the dangerous journey of the Mediterranean. Millions of diasporas are originally from this part of Africa and are present in many Western countries. Whether tied to their country of origin or became citizens of the countries they migrated to, the East African diasporas have always engaged in their home countries’ socioeconomic and political issues. In this regard, Ethiopia and Somalia are instrumental in understanding the region. Regardless of where members of the Ethiopian diaspora reside, they maintain continuous engagement with their country of origin, but their influence on the political, economic and social aspects varies.

Ethiopia

The diaspora based in Western countries, i.e., the US, Australia, and Europe, tend to be more interested in participating in local Ethiopian politics. Based on their group or individual interests, this part of the diaspora gets involved in various political discourses. Directly or indirectly, they can financially and technically support the local political parties. The diaspora also uses free mainstream social media resources to propagate their political views, ideologies, and insights to shape and influence local politics. Whenever there is the need to approach the decision-makers of the countries where they reside, they reach out to them individually or in different ways, such as organizing demonstrations to help their agenda get the attention of political leaders. The recently observed #NoMore and #StopTigrayGenocide campaigns/ demonstrations are two examples. There were demonstrations held in many US and European cities, organized by two opposing political views, and showed how the diaspora can influence foreign relations. Since these members of the diaspora are primarily constituencies with the legal right to vote in their host country and to meet with their local representatives to discuss issues that matter to them, they can affect, not only influence the viewpoint of politicians and decision-makers on matters related to Ethiopia. This is particularly true in countries such as the US where there is a significant number of Africans who hold American citizenship.

African states gain political benefits from dual citizenship laws because the diaspora can influence the governments of countries where they reside to secure their national interests. However, African governments could manipulate this advantage to remain in power and the diaspora can sometimes be found to be enabling dictators to stay in power. In the Ethiopian context, concerning the war in the northern part of the country, a majority of the non-Tigrayan diaspora supports the government’s social and economic policies more than they disagree with its violation of the human rights and civil liberties of the Tigrayan minority. As a result of the endorsement of the federal Ethiopian government by some segments of the non-Tigrayan diaspora, some Western partners overlook human rights violations, recognize the government as legitimate, and maintain diplomatic engagement. Nonetheless, the Tigrayan diaspora has been steadfast in their efforts to champion justice through advocacy in the international community. In some ways, they have significantly influenced the relations of Ethiopia and some key Western countries by claiming that the Ethiopian government has waged a genocidal war on the people of Tigray. Their advocacy has created a huge economic cost for the Ethiopian government. While western powers keep their diplomatic channels with Ethiopia open, they have cut down aid, revoked trade privileges, and other previously granted benefits, with the African Growth and Opportunity Act being one example.

The diaspora remains engaged in economic ventures with their country of origin for several reasons, with a primary focus on supporting relatives through remittances. Moreover, there are also attractive investment opportunities provided by local governments for the diaspora to take part in and benefit from. Many have returned to the continent fully or partially and are doing business in different sectors. The reduction of unemployment, the increase in revenue, and the new technologies they bring into the countries are a few of the vital advantages. However, in Ethiopia, stringent business regulations limit access to certain industries — such as banking, telecommunications, and the public service sector—exclusively to Ethiopian nationals. In this regard, not allowing dual citizenship has the disadvantage of limiting a nation’s economic growth.

There are abundantly available resources in terms of capital and knowledge that could have helped to boost the economy. However, the political and economic ideology that the Ethiopian government has held until recently is that there is a need for significant government interference in the economy. The very reason for restricting some business sectors solely for Ethiopian citizens is a pretext the government uses to always keep itself in control of the economy and politics of the country. Regarding politics, not allowing dual citizenship restricts members of the Ethiopian diaspora who want to participate directly in their home country’s political issues.

However, when considering the situation from another perspective, restricting dual citizenship could be a way to prevent and protect Ethiopian politicians from a conflict of interest. As all participants in Ethiopia’s political decision-making process are barred from having any other citizenship outside their Ethiopian citizenship, they each have more significant incentives to preserve the country’s national interests. Yet, this restriction has not deterred members of the Ethiopian diaspora from embracing their national heritage. Despite living outside of Ethiopia and not being allowed dual citizenship, members of the Ethiopian diaspora maintain their sense of Ethiopian identity and their various ethnic and religious traditions and beliefs through churches and community associations. They engage with families and friends back home even if they bear citizenships of the countries they live in and are not technically “Ethiopians”. To summarize, barring dual citizenship law in Ethiopia has a limited impact on the social interaction and trust among Ethiopians living in Ethiopia and members of the Ethiopian diaspora.   

Somalia

Perhaps the most visible immigrants in different parts of the Western world are from the Somali diaspora. Because of decades-long unrest and civil war, millions of Somalis have left their homes and migrated seeking better lives in Europe, the USA and Australia. Somalia allows dual citizenship, and the country even had a British-Somali president until his recent defeat at the last national election.

One advantage of Somalia allowing dual citizenship is the diaspora’s right to freely participate in the local politics of their home country and improve democratic conditions. It must also be noted that the active, young, and energetic part of the population has made its way to Europe or the United States, leaving behind a mostly vulnerable population who has not been able to leave the country for reasons such as age and health conditions. Somalia benefits from dual citizenship when educated members of its diaspora bring back skilled knowledge and democratic culture to the country, allowing it to advance economically and politically. As all Somalis can participate in the political activities, they can all provide leadership that could take the country closer towards a democratic system.

Like others in the African diaspora, many Somalis living outside of Somalia help their family back home through remittances. In fact, the relatively “free” financial regulations have allowed the Somalis outside of Somalia to own their own financial institutions that are remittance focused. The country’s economy is typically characterized as consumption-oriented with a very low rate of domestic production. Most people in the country depend on their family members in the diaspora for their basic survival. Considering the lack of security, prevalent instability, and conflict-prone nature of the country, it is a wise decision to allow dual citizenship so citizens can freely participate in whatever economic junctures they deem attractive to sustain the fragile state’s economy and existence. Some members of the diaspora have returned home and started their own businesses by training the local community. The lack of or disruption of formal education, especially higher-level education, suggests that such training opportunities would have a significant impact in changing the lives of young people experiencing poverty in Somalia.

Somalia’s society is deeply rooted in clan-based structures, where clan leaders wield significant influence. Despite living abroad and often holding dual citizenship, the Somali diaspora remain strongly connected to their clans, valuing social and psychological belonging over nationality. In Somali culture, social trust is shaped more by clan affiliation than shared nationality. This was evident when a former president of Somalia renounced his British citizenship before seeking re-election to garner political support, only to lose because of clan-based dynamics—highlighting that being Somali alone was insufficient to secure public trust.

In Somalia, allowing dual citizenship has a positive impact in terms of creating the conditions necessary for democratic consolidation. The ability of any Somali passport holder to freely participate in politics is just one benefit of this policy.  Somalia also benefits economically from its non-restrictive citizenship law. Social trust, however, cannot be easily gained because of the highly clan-structured nature of Somali society.

North Africa

As a region where countries have similar populations but a variation in regime types and political stability, North Africa provides key insights into the benefits and challenges that come with allowing dual citizenship. It is worth pausing to give a quick recap of what is happening in the region at the time this report is being written. Morocco, perhaps the most stable country in the area, still has the potential for instability because of the Western Sahara region. Algeria and Tunisia are facing economic woes and political transitions. Libya is returning to the path of increased political tensions, dual institutions, and renewed conflict. Finally, Egypt has issues with armed groups, political Islamists, and an economic crisis. Academically, the region’s similar populations and ideologies within the context of different governments and economies make it an interesting place to analyze any policy, especially the impact of the diaspora community.

Interest in dual citizenship among its citizens in North Africa may be high.¹¹S Gumedze ‘The influence of the African diaspora on democracy-building processes in countries of residence’ (2019) 3 Global Campus Human Rights Journal 113 -126 https://doi.org/20.500.11825/992 This is attributed to a staggering amount of civil unrest, contributing to mass migrations out of the region. Those seeking or already possessing a degree, especially advanced degrees, tend to find little happiness in staying in their home country under these conditions. However, the reputation of the region makes leaving the area difficult. Many foreign fighters fighting worldwide, either as part of a militia or a smaller cell, hail from North Africa. This adds a layer of complexity to both North Africans seeking dual citizenship elsewhere and those returning to their country of origin. Returning foreign fighters and the reputation of North Africans abroad will likely play a role in their state’s determination to adopt dual citizenship policies. With the educated leaving and the notoriety of certain nationals from the region, businesses do not want to take the political risks associated with operating in the region. These factors exacerbate each other and decrease the quality of life of individuals in North Africa and threaten regional security by not allowing the region to escape its conflict trap. However, there are many bright spots in the region and perhaps dual citizenship laws would help the area start the process of recovery.

Algeria, Morocco, and Tunisia

Algeria, Morocco, and Tunisia allow dual citizenship with no forced renunciation. The Tunisian dual citizenship law existed since 1975 although there is some alleged gender discrimination associated with it. However, a focus on women’s rights has led to more inclusive citizenship laws.¹²Renard, Thomas. “Returnees in the Maghreb: Comparing policies on returning foreign terrorist fighters in Egypt, Morocco and Tunisia. Egmont Paper 107, April 2019.” (2019). https://www.egmontinstitute.be/app/uploads/2019/04/EP107-returnees-in-the-Maghreb.pdf The social impacts go beyond a more inclusive society as some have recently disparaged those with dual citizenship by implying that they have contributed to the negative perceptions of Tunisia abroad.¹³See Whitaker, Beth Elise. 2011. “The Politics of Home: Dual Citizenship and the African Diaspora” International Migration Review 45 (4): 755-783 for more information on the politics of dual citizenship and its impact. However, there is a counter-movement to the name and shame campaign that is promoting Tunisians abroad and reminding the local population that those living outside of the country are indeed Tunisians. Dual nationals may have to deal with some backlash, even though these individuals provide the Tunisian economy about five percent of its gross domestic product (GDP) through remittances.¹⁴Tunisia citizenship law to boost women’s rights. Accessed October 3, 2023. https://english.alarabiya.net/articles/2010/09/13/119172.

The current politics of Algeria and Tunisia are in flux as both are going through transitions, therefore conditions for their respective diasporas could soon change as a result. Tunisia is marred by political uncertainty and economic crisis. President Saied’s democratic backsliding continues, and the Tunisian people are uneasy, as evidenced by the record-low turnout rate in the most recent parliamentary elections.¹⁵MEE Staff. “Tunisian MP Urged to Resign after Calling Dual Nationals ‘bastards’ and ‘Scum.’” Middle East Eye, January 17, 2020. https://www.middleeasteye.net/news/tunisian-mp-urged-resign-after-calling-dual-nationals-bastards-and-scum. Moreover, the constitution is likely to be revised soon. Tensions in Algeria have cooled considerably since a protest movement ousted long-time President Abdelaziz Bouteflika in 2021.

The current authorities released some political prisoners but there are calls by Human Rights Watch among other advocacy groups to release more.¹⁶Girardini , Sophie. “The Moroccan Diaspora: A Factor to Consider in Governmental Policy Making.” https://www.moroccoworldnews.com/, September 4, 2022. https://www.moroccoworldnews.com/2022/09/351152/the-moroccan-diaspora-a-factor-to-consider-in-governmental-policy-making. Historically, Algeria has been a very insular state, but, geopolitically, it has been more active lately, which could be good for its diaspora populations as Algeria shows signs of life internationally.¹⁷https://en.qantara.de/content/tunisia-in-turmoil-will-tunisians-rise-up-against-kais-saied Lessons identified from Morocco, Egypt, and Libya could be informative for these transitions depending on the direction and willingness of national and local political actors.

Morocco is an interesting case study in terms of its commitment to its diaspora and one that may highlight the advantages of diaspora involvement. First, it is well-organized with dedicated organizations such as the International Forum of Moroccan Competencies Abroad, the Moroccan Invest Network, and Moroccans Residing Abroad. Additionally, the Moroccan government authorized a National Migrants Day, conferences, and the Council of the Moroccan Community Abroad.¹⁸“Algeria: 3 Years on, Repression on Protest Tightens.” Human Rights Watch, February 21, 2022. https://www.hrw.org/news/2022/02/21/algeria-3-years-repression-protest-tightens. The Moroccan diaspora significantly contributes to the Moroccan economy and promotes Morocco abroad. Still, while the nation has agreed to and approved the political participation of its diaspora population, they have yet to implement this policy.

Political participation of the Moroccan diaspora has evolved over time. There has been some broad participation in political, economic, and societal decision-making through six working groups: Scientific, Technical and Economic Skills for Inclusive Development; Citizenship and Political Participation; Administration, Public Rights of Users and Policies; Worship and Religious Education; and Gender Approach and New Generations.¹⁹Hill, Thomas M. “A Newly Assertive Algeria Seizes an Opportunity | United States Institute of Peace.” United States Institute for Peace, January 19, 2023. https://www.usip.org/publications/2023/01/newly-assertive-algeria-seizes-opportunity. These working groups were designed to promote the economic and social benefits of diaspora; however, the 2011 constitution expanded these responsibilities for political purposes. As of 2021, efforts to grant Moroccans living abroad benefits like representation in the House of Representatives and voting rights had yet to be implemented. Several factors might explain this delay: some doubts the diaspora’s ability to represent Moroccans’ interests, while political instrumentalists in Morocco view granting dual citizenship as a threat to political agenda.²⁰El Hasnaoui, Anas. “The Moroccan Diaspora: What Are the Modes of Political Participation?” Arab Reform Initiative, November 18, 2021. https://www.arab-reform.net/publication/the-moroccan-diaspora-modes-of-political-participation/. While Morocco is well-engaged with its diaspora, more could be done politically to achieve its full potential.

Egypt and Libya

The aforementioned relatively successful and inclusive diaspora policies can be contrasted with those of two countries—Egypt and Libya— with potentially more questions than answers. In Egypt, those seeking a second citizenship must get permission or declare it to the ²¹El Hasnaoui, Anas. “The Moroccan Diaspora: What Are the Modes of Political Participation?” Arab Reform Initiative, November 18, 2021. https://www.arab-reform.net/publication/the-moroccan-diaspora-modes-of-political-participation/. This is a contentious issue in Libya and Egypt because of fear surrounding the intention of politicians and prominent public figures with dual citizenship.²²El Hasnaoui, Anas. “The Moroccan Diaspora: What Are the Modes of Political Participation?” Arab Reform Initiative, November 18, 2021. https://www.arab-reform.net/publication/the-moroccan-diaspora-modes-of-political-participation/. In November of 2011, Decree 130/2011 was enacted, which provided all Egyptians over the age of 18 the right to vote in elections and referendums regardless of their country of residence. Although, as evidenced by Alaa Abd El Fattah, dual citizenship issues are still politically contentious issues. ²³Malek, Dalia. 2021. Report on Citizenship Law: Egypt. Country Report 2021 (16), European University Institute and Global Cit.

Meanwhile in Libya, the government is trying to determine exactly how to define dual citizenship and for what purposes. After the fall of Ghaddafi in 2011, Libya has not been able to find stability. There have been a few elections, transitional governments, and many clashes between armed groups during this period. There have been processes at work to try to develop a new Libyan constitution via the Constitution Drafting Assembly (CDA); however, a lack of inclusion and political consensus so far has prevented its adoption. Libya suffers from a debate over an election or a constitution. Which one ought to come first? For our purposes, Libya is a case of political instrumentalism when it comes to the diaspora.

After the Libyan revolution in 2011, there were no laws forbidding dual citizenship for political office as Libya began its transition to democracy. This fact asserts that, at least initially, there were more positive attitudes toward dual citizens –– perhaps with thoughts of dual citizens returning to Libya. However, during the drafting sessions of the Libya Constitution in 2016, this positive outlook shifted as lawmakers agreed that candidates for office could not hold dual citizenship unless they renounced it at least five years before running for president or one of the chambers of parliament.²⁴Malek, Dalia. 2021. Report on Citizenship Law: Egypt. Country Report 2021 (16), European University Institute and Global Cit. This change was primarily interpreted as a way to exclude dual citizens from influential political powers since some questioned their motives. Khalifa Haftar is one example of a Libyan with dual citizenship that some in the country did not want to run for president. Field Marshal Haftar–the leader of the Libya National Army and supporter of the Libya House of Representation, the Eastern-backed Libyan government– is a dual citizen who desires to run for president but has been suspected of war crimes, among offenses. While he claimed to support democracy, little evidence suggests this is true. Additionally, there are armed groups from western Libya that will never abide by a Haftar administration. However, Haftar is not the sole reason for the instrumental usage of dual citizenship laws. Concerns exist that some might exploit Libya’s vulnerable status and return from exile. Some of these claims may be legitimate, while others could be unfounded. However, the Muslim Brotherhood used this window to return to Libya after being exiled by Ghaddafi. Some other Libyans who held key positions and had been exposed for being dual citizens include Ali al Tarhouni, Mohamed Yusuf al-Magariaf, Ali Zeiden, Abdulrahman Swehle, and Mustafa A.G. Abushagur.²⁵Ebrahim, Nadeen, and Sarah El Sirgany. “An Egyptian Activist Hoped Dual Citizenship Would Save Him. It Hasn’t so Far.” CNN, November 10, 2022. https://www.cnn.com/2022/11/10/middleeast/alaa-abd-el-fattah-egypt-dual-nationality-cop27/index.html. The political scrutiny of Libyans with dual citizenship signals the deep mistrust toward them in Libya.  This lack of trust has decreased encouragement for members of the Libyan diaspora to participate in the country’s politics.

West Africa

We now shift to West Africa, a region where over 10 countries allow some form of dual citizenship, including: Benin, Burkina Faso, Cape Verde, Côte d’Ivoire, The Gambia, Ghana, Liberia, Niger, Nigeria, Senegal, and Sierra Leone.²⁶Center, Defender. “Dual Citizens in Libya: A New Tool of Political Isolation? – Defender Center.” Defender Center – Defender Center for Human Rights, March 25, 2022. https://defendercenter.org/662. To highlight the variety in this region that is composed of mostly anglophone and francophone countries, this section will focus on two lesser-known examples in Liberia and Senegal.

Liberia

Liberia originally restricted citizenship to black people who were (a) born in Liberia and/or (b) had a Liberian father.²⁷Fetouri, Mustafa, Marc Español, and Maggie Fick. “Landmark Ruling Could Have Big Implications for Libya’s Leaders.” Al Monitor. Accessed January 3, 2022. https://www.al-monitor.com/originals/2017/10/libya-opposition-dual-citizenship-leaders-law.html. Liberians that became nationals of another country automatically lost their Liberian citizenship and anyone who, for example, had a Liberian mother but a non-Liberian father could also not acquire Liberian citizenship. After much campaigning by the diaspora, the citizenship laws were changed in 2022. President George Weah’s administration declared 2022 as the year of the diaspora, with the hopes that the campaign would bring more tourism much like what happened in Ghana during the 2019 Year of Return.²⁸Morozova, Evgeniya. ”List of countries that allow dual citizenship”. Immigrant Invest, https://immigrantinvest.com/blog/countries-that-allow-dual-citizenship-en/. Accessed June 2, 2023. Now Liberians who couldn’t acquire or had lost citizenship due to the previous laws have a path towards remedying that situation.

However, there are a few notable caveats to the new law. Citizenship still requires the person to be black, and now, at least one of their parents must be Liberian as well. Liberians with dual citizenship can now hold jobs and own land in Liberia. However, they cannot hold positions like president or minister of finance. ²⁹Bondo, Dounard. ”All you need to know about Liberia’s new dual citizenship law”, Aljazeera, 27 Jul 2022, https://www.aljazeera.com/features/2022/7/27/all-you-need-to-know-about-liberias-new-dual-citizenship-law. While members of the diaspora support the shift in these citizenship laws, there are concerns among Liberians about how these laws can perpetuate the divide between the elite and everyday citizens.³⁰Bondo, 2022. This suggests that while Liberia has allowed for more economic participation from its diaspora, the change in the dual citizenship law alone has not dismantled all the barriers necessary for the diaspora’s full participation, particularly in the social and political spheres. 

Senegal

In 1960, Senegal adopted its Code of Nationality as part of their constitution and later amended in 1989 to include more provisions for dual citizenship. Senegal does not promote dual citizenship, but under the Code of Nationality, the law does not prohibit Senegalese nationals from attaining a second citizenship, nor does it require them to renounce their Senegalese citizenship. The state, however, sees individuals with dual citizen status as just Senegalese. Holders of dual citizenship status in Senegal are only recognized as Senegalese citizens and must renounce their Senegalese citizenship for Senegal to acknowledge their foreign citizenship. Additionally, the Code of Nationality also prohibits the president from holding a second citizenship.³¹Bondo, 2022.

In 1993, Senegal went a step further regarding rights for their diaspora abroad, compared to many other states, by allowing Senegalese citizens in France, Canada, Italy, Germany, and the United States to vote in Senegal’s elections. While voting rights are limited to those residing in those countries, Senegal’s incorporation of the diaspora in the political process could be connected to the remittances received, which contribute 9-10% of Senegal’s overall gross domestic product.³²”Liberia: President Weah Signs Into law Dual Citizenship Bill, Others”, Liberian Observer, 8 May 2022, https://www.liberianobserver.com/liberia-president-weah-signs-law-dual-citizenship-bill-others. Accessed May 6, 2023. Voting rights allow for further promotion of sending remittances to contribute to the overall state’s economy. This example shows that even with no explicit promotion of dual citizenship by Senegal, the Senegalese diaspora still participate in the country’s economy and politics, albeit in relatively limited ways.

Southern Africa

The Southern Africa Development Community (SADC) is an economic grouping of 15 African countries with a total population of approximately 270 million.³³”‘New Dual Citizenship Law Didn’t Make Natural-born Liberians 2nd Class Citizen’ – ALCOD” Front Page Africa Online, Sept 5, 2022, https://frontpageafricaonline.com/news/new-dual-citizenship-law-didnt-make-natural-born-liberians-2nd-class-citizen-alcod/. Accessed May 6, 2023. As a region, SADC is characterized by large-scale movements of people within countries and across borders. In 2020, an estimated 2.5 million SADC country citizens were living in another SADC country. Short-term, cross- border movements between countries number in the millions each year. With the collapse of apartheid and greater integration into the global economy, the region has also become a destination for migrants from the rest of Africa and other parts of the globe, including Asia and Latin America.³⁴“Senegal Constitution 2001 (Présidence).” Senegal Constitution 2001 (présidence) : Citizenship Rights in Africa Initiative, January 22, 2001. http://citizenshiprightsafrica.org/senegal-constitution-senegal-2001-presidence/.

The SADC region faces a major challenge not only from internal migration and arrivals from other parts of the world but also from citizens emigrating in search of better opportunities. In the early 2000s, approximately 1.5 million Southern Africans had migrated globally, a number that has since grown significantly.³⁵“Personal Remittances, Received (% of GDP) – Senegal.” World Bank Open Data, 2023. https://data.worldbank.org/indicator/BX.TRF.PWKR.DT.GD.ZS?locations=SN. This trend is concerning, as many emigrants are highly educated and skilled individuals who could contribute to national development. Without proactive government interventions to address their concerns, the region will continue to lose talent. This section will analyze diaspora engagement trends, organized by two key themes reflecting the nuances of Southern African diaspora policies.

Governments recognize the pivotal role migrants and diasporas play within the political, social and economic spheres of their home and host countries. They contribute significantly to investments, cultural exchange, humanitarian aid, remittance transfers, and entrepreneurship. Acknowledging these developmental benefits, African states are implementing policies to harness the contributions of migrants and diasporas more effectively.

Migration governance has been at the center of international politics for the past two decades and is evolving in different ways. The main reasons for continued emigration include better employment prospects overseas, the desire to provide children with better opportunities, high levels of local taxation, safety and security concerns, dissatisfaction with remuneration, and job opportunities. Emigrant social networks increasingly encourage relatives, friends and colleagues to follow their path. In addition, COVID-19 has highlighted the dire situation facing many countries in the Southern Africa region.³⁶Kästle, Klaus. “List of African Countries – Nations Online Project.” Countries by Continent :: African Countries – Nations Online Project. Accessed January 3, 2023. https://www.nationsonline.org/oneworld/africa.htm.

Expounding on abovementioned sentiments, South Africa, Zambia and Zimbabwe are at the receiving end of brain drain. Highly skilled and well-educated people seek better opportunities in Europe and other more developed areas to attain a more balanced and sustainable lifestyle. Southern Africa youths are eager for career progression, development, and fair compensation. However, governments have become rigid, denying and causing growing discontent. For example, Zimbabwe has high levels of literacy and approximately 90% of the total population aging between 15 and above. To further solidify the foregoing sentiments from an African perspective, a European Council study found that Africans aged 15 or older desire to move to another country for a longer period or even permanently. Such situations have considerably pushed young people to look for better opportunities in other countries.³⁷Martin, M, The Crisis of Extreme Inequality in SADC Fighting austerity and the COVID-19 pandemic, 2008.

African Politicians Stifling Diaspora Voices

Some political leaders in Southern Africa oppose dual citizenship to maintain an image of national progress. Meanwhile, diaspora members, familiar with democratic principles and rights, often criticize illiberal government policies. As a result, dual citizens are seen as a threat to the state and potential agents of regime change.³⁸Marie-Laurence Flahaux and Hein De Haas, African migration: trends, patterns, drivers,(Comparative Migration Studies, 2016.

However, this strategy can be counterproductive. Distancing and stifling the voice of diasporas only increases tension, especially in today’s digital world, where social media keeps people connected. Even in countries like the Democratic Republic of Congo, where internet is restricted, people find ways to communicate. Dual citizenship can bring significant benefits, such as increased business opportunities, investments, trade, and connections with key stakeholders, which can all open doors for the state. To harness these advantages, government must engage with diasporas and implement effective business policies.

Diaspora Entrepreneurs

Members of the diaspora who have been particularly successful economically in other countries can do much more than send remittances to family members in their countries of origin. Governments in low-income countries are aware that foreign direct investment (FDI) is vital to the growth of their economies; diasporas are perceived as pioneer investors, considering the fragility of these markets.³⁹John Oucho and Jonathan Crush, Contra Free Movement: South Africa and the SADC Migration Protocols (Africa Today 48 2001), 139-158. Other entrepreneurial activities of note include “nostalgia trade” (which meets the demand of diasporas for products from their country of origin) and “diaspora-led import-export businesses,” which have a more diverse product base and clientele. Although there are limited studies on African diaspora entrepreneurship, the following are probable development impacts on the countries of origin:

• Identifying new economic prospects through their local contacts, knowledge and culture;
• Sustainable local business development, job creation and innovation;
• Technology transfer from the Global North to Global South;
• Diaspora members act as early innovators into a country, which may act as a catalyst for further investment by diaspora and non-diaspora members;
• Developing capital markets in countries of origin;
• Reassuring FDI by providing market and operational information about the homeland to potential investors and brokering relationships with buyers, suppliers, partners, government officials and lending institutions in the homeland; and

Acting as sources of local knowledge about investment opportunities, information about regulations and procedures, or familiarity with language and customs decreases the transaction cost associated with investment.

PROGRESS

A thread that wraps around the continent’s diaspora policies is not whether a country wants to engage with their diaspora but how much. For some countries, there is a lack of trust. In other countries, there is trust, but only so much. Regardless of whether governments want to build trust for more social cohesion across borders or if they have a specific agenda to grow remittances, neither action can happen without further diaspora engagement. This section will point out a few recommendations for how countries can move in that direction.

Recommendations

Africa needs to recognize and appreciate the developmental benefits of social remittances. While diaspora financial contributions are well acknowledged in migration and development debates in Africa, their skills, networks, experiences, and insights also play a pivotal role in shaping development strategies. Hence, one recommendation is to recognize and appreciate the role of social remittances in development.

Second and third-generation Africans are not engaged in diaspora participation. The census data shows that this is a significant population. However, it may be challenging to identify. Therefore, more research is needed to understand the characteristics of this group. African governments should work closely with diaspora organizations with access to these communities and design engagement strategy. It is worth noting that these communities are potentially more likely to participate in diaspora engagement through volunteering their skills and expertise; thus, it may be important to have policies and programs in place to access the resources they have to offer.

African governments also need to improve institutions and structures to enable easier access to key civil servants and policymakers both in the home countries and in their embassies. In the UK for example, equipping staff with the resources and capacity to operate better in Africa or Europe could be a step in the right direction. While that can create change on the national level, more work needs to be done on the grassroots level.

African governments and the African Union realize the role of the African diaspora at large in development and many of them have been working on policies and strategies to harness the resources available in the diaspora. However, more work is needed to improve diaspora engagement. Firstly, African governments and the AU need to gain a better understanding of the structures of diaspora organizations, how those organizations and individuals can contribute to development strategies in their countries of origin, and where their limitations lie. The focus may need to shift from searching for large organizations with a national reach to assisting smaller diaspora organizations. Institutional practices may need to be assessed and modified to make them more transparent and easier to navigate for diaspora engagement.

CONCLUSION

This report investigates the use of dual citizenship laws in states across the African continent. Policymakers could benefit from understanding the consequences of enacting or not enacting these laws on their state’s development, sustainability, or fragility. The cases presented in this report demonstrate a few common trends, possible prescriptions, and potential mitigation strategies. This report began by asking how dual citizenship laws may impact African states in the political, social, and economic realms to gauge their impact. By pulling back the curtain and revealing how these laws impact states, we can draw on some key insights for the continent. Laws that allow dual citizenship are on the rise and increasingly politicized regardless of their potential for economic and social benefits. When policymakers who use these laws to create “us” versus “them” narratives, who truly benefits? Do outcomes differ when citizens or the diaspora advocate for these laws over the government? These questions warrant exploration in policy literature.

This report has taken a tour around Africa to examine how dual citizenship laws impact African states. We started the journey in East Africa, notably Ethiopia and Somalia, which provided a helpful comparison between Somalia, a state that allows dual citizenship, and Ethiopia, another that does not. Ethiopia does not allow dual citizenship, and while there is already evidence that the government does this to protect its economic and social policies from outside influences, further research is required to determine whether disallowing dual citizenship is an attempt to encourage members of the diaspora to return to the country. Ironically, suppose the state did allow for dual citizenship. In that case, it may be by reinforcing a social fabric, strengthening a common identity, and assisting in the state’s economic development by increasing diaspora involvement. Somalia may provide an example of the benefits of dual citizenship to the social and economic realm.

North Africa provides further evidence of the politicization of dual citizenship laws as seen in Egypt and Libya. Political instrumentalists continue to take advantage of society in Egypt and Libya through politically exclusive laws. In both countries, these decisions are driven by fear, predominantly of politically influential groups or individuals, such as the Muslim Brotherhood or Khalifa Haftar. Tunisia is another example of where political exclusion is in the early stages, but it should not be overlooked since political instrumentalism has increased in this country in tandem with the rise of political uncertainty. As evidenced by this report, it should be noted that states that do not allow dual citizenship laws tend to suffer from political uncertainty and consternation.

On the other hand, Morocco and Algeria allow dual citizenship and the stability in their political, economic, and social affairs are quite positive. More research would need to be completed to determine if there is a causal connection, but the resiliency and dual citizenship connection should be noted. Algeria and Morocco appear to be fairly resilient to political unrest. Although Algeria is now a country to watch, their institutions appear robust enough to handle political change. Morocco and Tunisia’s history demonstrate the benefits of dual citizenship laws, such as promoting inclusion of diaspora populations in the political, economic, and social affairs of the country which leads to improved accountability and transparency, higher contributions to GDP, and a more cohesive society.

West Africa and Southern Africa are the final regions of our journey around the African continent. Regarding Liberia, it is still too early to get a full picture of the impact of the country’s recent decision to allow and expand access to dual citizenship. With that in mind, Liberia should be watched closely with the interest of providing further confirming or disconfirming evidence for the claims in this report. Even in Liberia, fear of outside influence has stifled full political inclusion, and it has instead led to political exclusion. On the other hand, Senegal gives further evidence as to the economic benefits of engaging with the diaspora and allowing dual citizenship, such as the state receiving more revenue streams by giving more possible revenue streams for the state. The Southern African region reinforces the economic benefits of diaspora and dual citizenship opportunities although there are still further improvements to be made. The region also promotes the idea that allowing dual citizenship could enhance governance via political accountability and transparency, even if that level of political inclusion may not be felt everywhere as some states still fear the political influence of diaspora populations.

In the end, we can draw on some interesting findings and policy implications. First, allowing dual citizenship and expanding dual citizenship laws can boost diaspora engagement by increasing remittances and encouraging return migration. Allowing dual citizenship may also promote a more cohesive society when political instrumentalists are not present – usually in states without a large degree of political uncertainty or fear. More detailed research is required to determine whether there is a relationship between African States’ fragility, political exclusion, and underdevelopment and their dual citizenship policies. Based on this report’s findings, however, granting dual citizenship mutually benefits African diaspora populations and their respective countries of origin.