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German Law/Citizenship of German - Russian


QUESTION: Hello Andreas,

I was born and have lived my entire life in the US. Over the years I have performed genealogical work on my family that I have shown to friends and family. A friend (who is a dual citizen) mentioned that it might be possible that I still retain German citizenship.
Background: My family (on both sides) moved from Germany to Russia (southern Ukraine) in the early 1820's. From what I can tell, they lived in Russia but were not Russian citizens. They stayed for several generations and then moved to the US in the mid 1870's. 2 of my great-grandparents were born (in the US) before their parents obtained US citizenship. So I guess my questions are:

Did the Germans who went to Russia to farm still maintain their German citizenship?

Would my 2 great-grandparents have maintained their German citizenship, thus passing it down to me?

Thank you for your time!

ANSWER: Hello Ed,

I honestly don't know what would have happened to somebody's citizenship between 1820 and 1871 if they went off to work in the Russian Empire. As you may know, there was no German state before 1871 and thus no German citizenship. The answer would therefore depend on the citizenship law of the kingdom or principality that your ancestors came from. On top of that, passports had not been widely established and were not necessary as travel documents, even for international travel, so they might not have left many traces.

Could you find any immigration paperwork in the US? What did they indicate as their citizenship?

The big problem with passing down citizenship in that time is a German law which was in place between 1871 and 1913 which required that German citizens living abroad needed to register with the German Consulate every 10 years, and would otherwise lose their German citizenship. If you know where in the US your ancestors lived during that time, you may take a look at the German Consular records, but this requirement is what kills off most ius sanguinis cases from that time, unfortunately. If you wished to apply for a certificate of German citizenship for yourself based on this ancestry, the burden of proof would be on you as the applicant. Thus, if any paperwork had been lost or destroyed, it would unfortunately be to your disadvantage.

Sorry that I couldn't help more,

Andreas Moser

---------- FOLLOW-UP ----------

QUESTION: Interestingly the immigration paperwork I found showed place of birth as Russia, but they described themselves as Russian-German.

My great-great-grandfather (who was born in Russia to German-born parents) naturalized in the US in 1890. His son (my great-grandfather) was born in the US in 1887. Based on what I have read on your blog that would potentially give birth-right citizenship however the requirement of registering with the consulate would be an issue for an infant. Would a minor (born in 1887) have the same requirement to check in with the consulate?

Once again, thank you for your time!

The law in place between 1871 and 1913 extended the loss of citizenship to the wives and the minor children (under 21 at that time) of the citizen in question, from what I have been able to find in secondary sources. (I am not in Germany and thus can't easily get hold of the old laws.)

But that might not even be relevant in your case.

It sounds to me that your great-great-grandfather thus would have lost his German citizenship because he naturalized more than 10 years after the law went into effect. Thus, he might not have had any German citizenship to pass on to his son in 1887.

One more thing about the self-description as "Russian-German". We would need to differentiate citizenship and ethnicity. Sometimes these coincide, often they don't. Especially in the grand European Empires before 1918 (like the Russian Empire), millions of citizens had a different ethnicity, different language, different religion than the official ones of the Empire. That was mostly not a big deal (except for pogroms against Jews, which were also prevalent in Russia).
Without looking at documents and the laws from that time (or asking an expert in the history of Russian citizenship law, which I am not), I would based on my experience not put too much weight on self-descriptions. Many people had a citizenship which they were not aware of and they didn't have the one that they thought they had. We have to consider that this was before the widespread use of passports.

Andreas Moser

German Law

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Andreas Moser


Extensive experience in international family law, especially international child abductions and child custody cases. All other areas of German law as well: constitutional law, criminal law, business and contract law, immigration law, inheritance law, and so on.


Lawyer in Germany from 2002 to 2009. Lawyer for US Army JAG Corps before. Bar-certified specialisation in family law and in administrative law. Articles and lectures about international and domestic family law.


2000 Law Degree from University of Regensburg, Germany 2002 admitted to the bar (until 2009) 2013 MA Philosophy at the Open University, UK

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