Multiple or dual citizenships/nationalities

General
1

We are observing cases where an individual is listed with multiple or dual citizenships/nationalities — such as Hong Kong (HKSAR), United Kingdom, and/or China (PRC) — or combinations involving China/PRC alongside Western countries (e.g., UK, Australia, Canada, US). However, we know that under the Nationality Law of the People’s Republic of China (Article 3), the PRC does not recognize dual nationality for any Chinese national. In practice, this means:

As a result, some of our clients (particularly those with strict internal policies or operating in risk-averse sectors) view entries showing ‘multiple citizenships’ involving China as potentially invalid, erroneous, or indicative of data quality issues, and may question the reliability of the screening hit or even dismiss it.

How should we best position and explain this situation to clients in a clear, defensible, and compliant manner? Specifically:

  • What is the most accurate way to describe why multiple nationalities can legitimately appear in PEP/sanctions/watchlist data even when Chinese law prohibits dual nationality?

  • How can we reassure clients that this is not necessarily a data error but reflects real-world complexities (e.g., de facto dual possession of passports, historical BNO status, foreign naturalization without formal renunciation, or source-specific reporting of self-declared/claimed/documented nationalities)?

  • What best practices or phrasing should we use in client communications, reports, or training to address this — e.g., emphasizing risk-based assessment, the need for further verification (such as passport copies, self-declaration, or official records), and alignment with FATF guidance on handling citizenship in due diligence?

  • Should we recommend treating such entries as higher-risk flags (due to potential opacity, sanctions evasion concerns, or inconsistencies) rather than dismissing them?

2

Hi! A few thoughts on this:

  • Our database stores various country associations for individuals. If the country is placed in the citizenship or nationality field, that indicates that the source has stated this explicitly. However, a lot of the time a source will just describe a more ambiguous association between a person and a country - those are kept in the country property.
  • This is absolutely indicative of data quality issues. Take this gentleman: the UN has basically classified him as being linked to three countries. Whether those countries agree that he is their citizen is (to some extent) immaterial to us - it’s the legal reality of the list.
  • For PEPs from China, it looks like a lot of the ones marked as third-country citizens are from Hong Kong. Just cross checking one or two, it doesn’t seem entirely off: Fernando Cheung - Wikipedia

Maybe some broader thoughts:

  • When you build a UI for our data, make sure not to promote country property values to be shown as citizenship. It should be shown as “affiliated countries” or some verbiage like that.
  • I think it’s worth to prepare for people from the sanctions data slice to be linked to a very large number of countries. That’s just an intrinsic property of the biography of someone like UBL, who spent time living in Saudi, Sudan, Afghanistan and Pakistan. The question “what passport do you carry” is incredibly difficult for those people.