UAE’s New Citizenship Law: “Big Questions Unanswered”

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When, on January 30th, the ruler of Dubai took to Twitter to announce that the Emirati government had changed its citizenship law to allow for the naturalization of investors, doctors, and other people of particular merit or utility to the UAE, the investment migration industry – for which the UAE is the largest hub – was abuzz with discussion of the good news.

In our initial article on the matter, we pointed out that – as far as we know for the moment – the policy changes do not constitute a citizenship by investment program. To gauge industry reactions, IMI contacted the Dubai-heads of two of the region’s largest CBI service providers.

Ready to help
“As a company, we applaud the UAE government’s amendments to their citizenship policy, says Mimoun Assraoui, CEO of Dubai-based RIF Trust and Vice Chairman of the Latitude Group. “This is certainly a progressive step forward for our industry and the UAE. As the need for mobility and the opportunities to choose to establish oneself anywhere in the world grow, the UAE’s new citizenship and investor visa policies will allow them to retain the outstanding contributions and talent of expats currently residing in the UAE and further attract newcomers from around the world.”

Such progressive policies, he says, have caught the eye of multinationals that are moving their headquarters to the country, including, he says, the Latitude Group.

Warmly welcoming the policy changes, Assraoui hints that a natural next step would be to articulate the particulars, which as yet remain unfinished, and that his firm would be at the government’s disposal in that respect.

“As specialists in citizenship and residency in the UAE for close to a decade, we are pleased to offer any assistance the UAE government might require to continue to develop these policies.”

Nomination only
Henley & Partners’ Managing Partner in Dubai, Philippe Amarante, however, points out that, a positive step in the right direction as it might be, what the UAE has announced doesn’t amount to a citizenship by investment program.

“It’s not a program; it’s [naturalization] at the discretion of the government,” he points out, further commenting that he doesn’t expect it to become a mass-marketed policy. “There are big questions unanswered, i.e., around dual citizenship. What if the investor renounces his primary citizenship? Will the UAE retain the right to revoke the Emirati one? Probably not,” he concludes.

Legally speaking, in cases where the revocation of a citizenship would render the subject stateless, such revocation is not permitted under international law.

Amarante also points out that this week’s announcement doesn’t mean gaining citizenship through investment in the UAE is a fait accompli. “Between the announcement of the UAE golden visa and its eventual implementation, I think we saw twelve months pass,” he recalls.

Questioned as to whether he thinks we’ll soon see the publication of detailed requirements or whether the government will prefer to leave the precise qualification criteria up to their own judgement on a case-by-case basis, Amarante says he’s not expecting much in the way of Caribbean-style CBI application guides.

“I do not expect a certain catalogue to be published as the process will be governed by recommendation and nomination only, at least as of today.”