Got a Million Dollars? You Could Become a Citizen of Another Country

In a closely watched decision this year, the US Supreme Court narrowly rejected a challenge to birthright citizenship under the Fourteenth Amendment, reaffirming that nearly everyone born on US soil is a citizen. For legal theorist Ayelet Shachar, the ruling is not just about a technical reading of a constitutional clause. It speaks to the deeper question of what citizenship is meant to be—and what happens when that status itself is put up for sale.

We spoke to Shachar about so‑called golden passports and golden visas, the risks of letting the rich buy their way into more secure and prosperous societies, and how it could exacerbate global inequality. 

Shachar is a renowned legal scholar and political theorist, and was the 2025–2026 William Lyon Mackenzie King Visiting Professor of Canadian Studies at the Weatherhead Center. She is currently the Tragen Professor of Law and director of the Institute of European Studies at UC Berkeley. Her areas of expertise include migration policy, border regimes, and the ethics and philosophy of citizenship. She’s the author of several award-winning books, including The Shifting Border: Legal Cartographies of Migration and Mobility; The Oxford Handbook of Citizenship; and The Birthright Lottery: Citizenship and Global Inequality.

Q: You’ve written that where you are born has enormous consequences for your life. How do most people in the world actually acquire citizenship?

A: Most people in the world—roughly 97 percent— acquire citizenship by automatic birthright: you're born on the territory, no questions asked, you are a citizen. The question of which country you are automatically entitled to citizenship in has tremendous ramifications. On average, if you're born in a richer country, you will have a longer life expectancy, better health care, more robust basic rights protections, and so on.  

Allocation of citizenship based on birthright means that you will belong to country X or Y, depending on something that is, from a moral perspective, entirely arbitrary. That is, you have not had any impact on whether you will be born in a richer country or a poorer country; in a democratic country or an autocratic country; in a country that will respect your rights or a country that will, if you're a member of a minority community, impose tremendous restrictions—if not sheer violence—against you. 

So we face a paradox: the territorial principle of birthright citizenship is vital to creating equality at home, among those sharing the same political community, operating as an anti-caste principle. It anchors membership and belonging to place, not to bloodline or the legal status of the parent. This is what makes the recent US Supreme Court decision so important. 

Globally, however, once we look outside our nation’s borders, we realize that reliance on birthright citizenship, which acts as an egalitarian principle domestically, has the opposite effect globally. It locks out the rest of the world due to circumstances none of us control—where or to whom we are born. In this sense, it acts as a legal mechanism of inherited status that perpetuates inequality, especially when coupled with strict border controls and near-insurmountable barriers to entry for those not born as citizens. 

Q: You’ve called this a global “birthright lottery.” How does the new market for buying citizenship fit into that picture?

A: We live in a world where those who drew the short stick in the birthright lottery are cast back into the open sea or the scorching heat of the desert. Yet, the super-rich escape these standard rules and harsh realities. Instead of allowing those with the gravest need to find sanctuary, those with the greatest means have a backdoor to premium access. How? By literally buying citizenship. 

A new market now permits high-net-worth-individuals (as they are known in the wealth management industry) to purchase “golden passports” in countries that have introduced legislation to put citizenship up for sale. These countries waive standard[AS1]  immigration requirements, such as habitual residence, for this velvet-rope category of would-be citizens. Instead of relocating, their money crosses the border on their behalf. In return, their naturalization process is turbocharged. In many Caribbean countries, no residency is required at all. A wire transfer of US$250,000[2] [3] [AS4]  translates into obtaining a fresh passport within four-to-six months. This transactional route allows the world’s wealthy to overcome the birthright lottery. Everyone else is priced out.

Q: There are some obvious reasons why a person would want to pursue additional citizenship, such as access to better services. What are some others?

A: There are several reasons. Oftentimes people don't give up their initial citizenship. They buy another one, or in some cases not just dual, but multiple citizenships. One often cited reason is the ability to gain greater mobility. Different countries have different visa-free entry agreements with third countries; passport-selling countries afford easier travel to more destinations without requiring a visa.  

There are also reasons that might be relevant for pretty much everyone in the world today given our geopolitical instabilities, which is to say if something terrible happens in my home country, I would want to have a plan B, I would want to have the possibility to escape to another country, for myself and my family.  

There are also some more concerning reasons why people might want to purchase another citizenship. People may look for ways to gain financial secrecy, launder illicit funds, or evade taxation. This is a bit technical, so bear with me. Assume a person obtains a golden passport and then registers it as their country of residence for tax reporting purposes; despite the fact that they don’t actually live there, they may have created a path to evade their own home country's taxation obligations. The OECD [Organisation for Economic Co-operation and Development] has called out these practices, which breach the common reporting standard and circumvent transnational transparency measures. This particular combination of putting up citizenship for sale without requiring individuals to relocate while offering zero taxation regimes is an open door that may tempt a saint, and it is not at all clear that those in the business of buying and selling citizenship are saints.

In addition, there's a high association of these programs with various forms of corruption, with major scandals reported in Cyprus, Malta, Dominica, and Vanuatu, to name a few examples. Investigative journalists, civil society organizations, and the European Commission have also raised the alarm about security risks associated with these programs, asking who is really getting in and whether they include sanctioned individuals and dirty money. It’s very difficult to find information about who purchased those citizenships or verify the sources of their wealth; the transactional nature of this program notwithstanding, they are anything but transparent.

Q: There’s a lot of terminology in this space—“citizenship by investment,” golden passports, golden visas. Can you walk us through the basic distinctions?

A: A golden passport is a program that offers tailor-made, exclusive pathways to attain citizenship swiftly and bypass traditional immigration requirements in exchange for a significant financial investment, without requiring any civil bond or connection between the applicant and the state. The buyers rarely seek a new place to call home. Instead, these programs bring the logic of offshoring and hedging to the realm of citizenship. 

These preferential-for-the-rich pathways are also known as citizenship-by-investment programs. These programs disrupt the familiar conception of citizenship as grounded in civic ties and political relations. Instead, they expressly commercialize sovereignty and commodify citizenship. A passport is marketed as “golden” precisely because it is high-priced, offering easy-pass access to citizenship to those seen as desired on account of their deep pockets. In this respect, these schemes undermine the foundations of democratic citizenship grounded in reciprocity, equality, and solidarity. 

Q: And that’s different from the golden visa?

A: The term “golden visa” refers to purchasing an opportunity to reside in the country, not to gain automatic citizenship in it. 

So the golden passport is the one that has really generated a lot of controversy. In addition to the commercialization of political membership, these programs create a disturbing hierarchy among those who may wish to escape the birthright lottery: those with the financial muscle to buy citizenship are fast-tracked to securing a golden passport, while at the same time imposing on everyone else stricter barriers to passage through the multiple gates of admission: entry, settlement, and naturalization.

Q: Why would states be willing to sell such a core status? What’s in it for them?

A: Primarily it's about revenue. It would be more significant for very small economies, and this helps explain why we see a disproportionate representation of island states that also operate as partial tax havens among those engaged in these cash-for-passport transactions. In certain cases, it has come to account for a significant proportion of their GDP.  

There was a thought among policymakers that this is a risk-free strategy. It’s actually not risk-free because you might become overreliant on one particular industry or source of revenue. But it's also not risk-free for the citizens of these countries. Citizenship by investment bears nonfinancial costs. It erodes democratic equality and places mono-citizens of the selling country at risk due to abuses of the program. By example, if country A loses trust in country B’s sale of passports, it could take away its visa-free access. This means that people who never engaged in passport transactions are penalized. For instance, they may suddenly be barred from traveling abroad to the bedside of an ailing family member or attending a relative’s wedding. Unlike the footloose millionaires who treat the additional passport as a portfolio asset, their passport and home country are not a “Plan B,” but a real home.  

Q: You can find brokers online who list all the countries, from small Caribbean states to European countries, who sell visas or citizenship. Many of these schemes ask very little of the buyer in terms of residency or civic engagement. What does that do to the character of citizenship?

A: It brings the market into political relations in a crude way at a time when citizenship is already under attack from so many different directions. I want to go back to the recent US Supreme Court decision upholding birthright citizenship and the modern interpretation of citizenship as the “right to have rights.” Across a range of intellectual traditions, citizenship is understood as foundational to our dignity, our security, our ability to expect something from our fellow citizens and our own government. It’s also associated with having a political voice and a promise of equality—a promise repeatedly breached on account of race, gender, sexual orientation, and related grounds, but a powerful promise that holds an aspirational dimension and serves as a basis for claims-making. 

Citizenship everywhere is tightly guarded. It seems incredibly inconsistent and unfair to bar the “Dreamers” who have lived the better part of their lives in this country from gaining access to membership in the only country they know as home, whereas someone who has no connection but can funnel money from abroad is given a large welcome mat. What does it mean if the criterion for acquiring membership becomes the ability to wire transfer money across borders? Does that in some way make you a member of a political community? And if so, how and why? 

We can't just talk about the pros and cons of purchasing citizenship without putting it in this broader context and in the dire moment we are living through—fraught with tensions surrounding borders and identity issues, the rise of populist nationalism, and the surge in anti-immigrant sentiment worldwide. 

Q: Speaking of US policy, in his first term, President Trump tried to eliminate DACA (Deferred Action for Childhood Arrivals) but was blocked by the federal courts. Nevertheless, his administration rescinded some DACA protections— at the same time expanding wealthy investor routes like the so‑called Trump Gold Card. What does that contrast tell us about this “new era” of citizenship?

A: It tells us that citizenship is always about inclusion and exclusion, but in the United States, as elsewhere in the world today, the rationales are blatantly contradictory. The DACA children were not born in the US, but have resided in this country, have studied in this country, have served this country, and there's bipartisan agreement that there should be a mechanism to allow them to stay in this country with a secure legal status and a clear path to citizenship. 

So DACA excludes individuals who seem to be exactly the people who deserve inclusion, who have earned in the deepest way the right to have rights in the United States.

Q: And now we have the proposed Trump Gold Card, which is an expedited version of the longstanding EB-5 “immigrant investment visa,” but this visa has no requirements to invest the money in enterprises or create jobs, like the EB-5. 

A: This scheme brings to the fore the sharp incoherence I just described: if wealthy foreign nationals pay US$1 million to the US government for a fast-tracked green card, why do others have to spend years in residence and in waiting to become citizens? What makes wealth a substitute for solidarity, shared fate, the political life of a republic? 

Citizenship is far from perfect. It promises equality, yet no country has ever fulfilled that promise. And we know that certain groups have been, and remain, excluded and deeply discriminated against. However, the answer is not to bar access to citizenship, especially for those who have most to gain from the right to have rights, but to make citizenship more robust and worth fighting for, as we have seen in the groundswell mobilization in the US before the Supreme Court rendered its decision. If we look beyond the domestic realm, the global arena is ripe for new political imaginations. But the solution is definitely not to say, “give us a million dollars and you'll gain citizenship.” 

Contributor Bio

Ayelet Shachar was the 2025–2026 William Lyon Mackenzie King Visiting Professor of Canadian Studies in the Canada Program at the Weatherhead Center for International Affairs. She is currently the Tragen Professor of Law and director of the Institute of European Studies at UC Berkeley. Her areas of expertise include migration policy, border regimes, and the ethics and philosophy of citizenship.