Xi Jinping’s vision for the “Great Rejuvenation of the Pan-Chinese Nation” and “China Dream” emphasises a shared ancestry and cultural identity among ethnic Chinese, both within China and abroad. Through “united front work,” the People’s Republic of China (PRC) thus seeks to unite “Chinese sons and daughters at home and abroad” under a common civilisational narrative. Despite its rhetoric of unity and shared heritage, however, the PRC offers limited legal and political protection to overseas Chinese.
INTRODUCTION
This article examines historical and contemporary connections between China and ethnic Chinese residing overseas via the lenses of politics and law. Exploring strategies employed by governments of China in the past century and a half to claim allegiance from ethnic Chinese of foreign residency and/or nationality is critical to understanding Xi Jinping’s agenda for the “great rejuvenation of the pan-Chinese nation” (Zhonghua minzu weida fuxing) and the “China dream” (Zhongguo meng), which Xi uses to embrace “Chinese sons and daughters at home and abroad” (hai neiwai Zhonghua ernü).
Under Xi, the PRC draws on biological, cultural, material, and emotional “ties” that overseas Chinese maintain with their “ancestral country” and adopts policies in continuity with, and in response to, ideational and institutional legacies of China’s century-long “extra-territorial policies for overseas Chinese” (qiaowu). By historicising the Xi-era diaspora policy, this article aims to shed light on the motivations and limitations of the PRC’s current “united front work” abroad, the opportunities and risks this outreach presents for ethnic Chinese communities in Southeast Asia (SEA) and elsewhere, and the diverse attitudes of overseas Chinese towards Xi’s rhetoric of pan-Chinese solidarity.
NON-TERRITORIAL SOVEREIGNTY IN LATE QING ENGAGEMENT WITH EUROPEAN AND AMERICAN POWERS: 1870s-1911
From the very beginning, tensions between the “ancestral land” and the “host society” over overseas Chinese have seen a clash between two types of sovereignty—non-territorial sovereignty and territorial sovereignty. The former recognises a state’s exercise of power outside its physical borders, particularly over its “people,” whose citizenship status is often determined by jus sanguinis (“right of blood”). Territorial sovereignty, on the other hand, recognises a state’s control over a specific area and the people residing within it, with citizenship typically determined by jus soli (“right of the soil”).
In his classic research on Chinese overseas, Philip Kuhn treats emigration from China as part of larger population movements in and outside of early modern and modern China. At the micro level, migration had been adopted since the 16th century by families living in coastal South China for survival. At the macro level, migration created “niches” for various dialect groups aligned with occupational categories, facilitating their integration into host societies. This created “corridors” which enabled emigrants to maintain cultural, economic, and social connections with their homeland areas (qiaoxiang), forging ties which were often stronger than those they had to host societies or to “China” as a whole.
By the mid-19th century, these migrants had formed stable creolised societies in SEA, preserving Chinese culture and social practices to various degrees, though often lacking proficiency in the Chinese language or political allegiance to the Qing government (1644 – 1911). The Peranakans—those of mixed Chinese and Southeast Asian descent in Indonesia, Malaysia, Singapore, and Thailand, or those who were China-born but were permanently settled in SEA, formed powerful commercial and cultural networks centred on Singapore, connecting European empires in SEA, Hong Kong, coastal China, and Siam. These localised Chinese communities achieved the status of “privileged second-class citizens”, and often acted as intermediaries between host societies and new migrants from China, through their commercial acumen.
Rather than facilitating overseas expansion, the Qing government had discouraged emigration, establishing its first overseas consulate in Singapore only in 1877 and abolishing in the process century-long emigration bans through the Great Qing Code in 1893. The Qing had gradually begun cultivating the loyalty of overseas Chinese — who were referred to as huaqiao (“Chinese sojourners”)—during the last decades of its existence. The turning point took place in 1909, with the promulgation of the first law in Chinese history that set a hard boundary between Chinese nationals (Zhongguo ren, “person(s) of China”) and foreigners (waiguo ren, “person(s) of a foreign country”). The 1909 Qing Nationality Law adopted jus sanguinis in determining nationality: A person whose father was a Chinese national, or whose mother was a Chinese national and whose father was stateless or of uncertain nationality, was a Chinese national. Valuing paternal bloodline, this law was a response to the Dutch 1910 Nationality Law which classified all Chinese born in Java as Dutch nationals (not full citizens)¾a manifestation of jus soli in determining nationality.
On the surface, the territorial form of sovereignty, insisted upon by the Dutch and by other Euro-American governments of Asian colonies at the turn of the 20th century, defined membership of the nation in a race-blind way. However, this was only true where obligations and control were concerned. Their “Chinese” race was the most important factor in determining what rights and privileges were accessible to ethnic Chinese residing outside of China. The Chinese Exclusion Act of 1882, the first and only major United States (US) law to prevent a single national group from immigrating, was initially set for 10 years but was made permanent in 1902. This law expanded to include newly annexed Hawaii and the Philippines, sparking widespread anxiety among Chinese Hawaiians and Chinese Filipinos over their political rights. It was against this background of race-based discrimination, which spread from the Americas to the Asia Pacific, that the Chinese in Southeast Asia, who were previously divided along dialect-occupation lines, joined forces in the 1905 anti-American boycott, through which some Chinese in the Straits Settlements started to identify “die(-ing) for the boycott” with “die(-ing) for the (Chinese) nation.” This movement, which began in Shanghai, became a “diaspora moment” as theorised by Shelly Chan, wherein overseas Chinese collectively identified with China “through their collective exclusion.”
Anxiety over the “racial status” of Chinese was expressed by an author for the Penang Sin Poe, who lamented that “The Chinese would have no single inch of land to stand though there is abundant land in the five continents of the world… and our Chinese would have no future at all.” This fear was pronounced among Chinese living outside of China, who, despite their legal nationalities, were categorised based on their country of origin. Relinquishing the “Chinese” status was difficult, especially under the US anti-Chinese immigration law. The 1882 Chinese Exclusion Act and the Amendatory Act of 1884 banned all labourers of the “Chinese race,” regardless of their legal nationality, from entering the US, while non-labourers required a certificate from the Qing government in order to enter. This anxiety was further amplified by increasing racial restrictions within the British Empire. In 1904, persons who were not of pure European descent on both sides were banned from taking cadet exams for civil and police service, reflecting a growing colour bar limiting non-white British subjects from gaining full imperial citizenship.
The historical memory of overseas Chinese being discriminated against is still mobilised today by the PRC government in promoting the correlation between the strength of the Chinese state and the dignity of overseas Chinese. It asserts, “The development and growth of China have washed away the insulting and oppression suffered by overseas compatriots in foreign lands during the past few centuries (jige shiji yilai zai guowai zaoshou de wuru he qiling). With a strong ancestral country, overseas compatriots feel that they have secure backing (yao’gan henying).”
The historical memory of overseas Chinese being discriminated against is still mobilised today by the PRC government in promoting the correlation between the strength of the Chinese state and the dignity of overseas Chinese.
NON-TERRITORIAL SOVEREIGNTY IN REPUBLICAN CHINA’S MANAGEMENT OF “OVERSEAS CHINESE AFFAIRS”: 1912-1949
In 1912, the Republic of China (ROC) succeeded the Qing as the internationally recognised government of China, having been “mothered” by overseas Chinese who provided human and financial resources to the anti-Manchu movement. The Nationalist Party (GMD), rooted in the anti-Qing revolution and deeply connected to Chinese communities abroad, sought continued support from SEA—or “South Sea” (Nanyang) in Chinese—to unify China under the “Three Principles of the People”¾“Principles of Nationalism (Minzu), Democracy (Minquan), and Livelihood (Minsheng)”—which Sun Yat-sen himself claimed to be identical to US President Lincoln’s “of the people, by the people, and for the people.” This nationalistic and non-Marxist socialist ideology of Anglo-Chinese constitutionalism was primarily developed among the Chinese diaspora in the late Qing by Sun Yat-sen, who was a US citizen of Chinese descent. Upon assuming power in 1929, the Nationalists maintained the principle of jus sanguinis in its Nationality Law, introducing a key reform that allowed Chinese women who married foreigners to retain their Chinese nationality. Foreign wives of Chinese men could obtain Chinese nationality only if their country’s laws did not allow them to retain their original nationality. This de-territorialised, biology-based definition of Chinese nationality enabled the Nationalist government to incorporate overseas Chinese into its national narrative, to include overseas delegates in Nationalist party congresses and ROC constitutional conventions, and to draw vital resources from overseas Chinese communities during World War II. It was no wonder that “Nanyang” was used by some to refer to the SEA as “nothing less than a second Republic of China” (bu chi wei di’er Zhonghuaminguo).
However, it also led to legal conflicts and identity confusion. To begin with, the Dutch and the Qing were engaged in lengthy negotiations over nationality, reaching the agreement that Chinese born or raised in the Dutch colonies would observe Dutch law as Dutch subjects, but could “reclaim” their Qing subjecthood upon returning to China. The climax of these clashes arising from the Chinese state’s extra-territorial claim of sovereignty was the British colonial government’s 1925 ban of GMD branches in British Malaya. Even though some scholars argue that GMD activities in Malaya “did not amount to a desire to establish an imperium in imperio in Malaya,” a report by the British colonial government in Malaya concluded that the GMD “present(ed) menace to British power in the Far East” and posed a “local danger to Malaya.”
The Nationalist government’s exercise of its sovereignty over ethnic Chinese who concurrently held other nationalities was supported, in discourse, by scholars at the state-sponsored Jinan school, who celebrated “Chinese colonialism” in Nanyang. Their works emphasised the historical success of Chinese settler colonialism and China’s geopolitical interest in maritime Asia. Their narrative, though self-contradictory, framed China as an ethno-empire-nation-in-aspiration fueled by the economic and social influence of its overseas communities. European colonisers in SEA viewed the Jinan school as a centre for spreading Chinese imperialism, perceiving it as a greater threat than the Japanese were, due to continued migration from China to this region during the early 20th century. This underscored the tension between territorial sovereignty insisted upon by governments of host societies of overseas Chinese, and non-territorial sovereignty insisted upon by the “ancestral land” of overseas Chinese.
It might be far-fetched to assume that the PRC government today would resurrect the historical Chinese pursuit of “colonising Nanyang” by simply amending its nationality law, including those with Chinese “blood” into the rank of PRC citizens, employing the notion of “national self-determination,” and claiming any place in SEA with an ethnic Chinese majority or plurality—such as Singapore, Sibu (Malaysia), and Singkawang (Indonesia)—as part of China. That said, the expectation remains alive in China that Chinese overseas, who share “same letters, same race, same ancestry, and same spoken language” with mainland Chinese, should always align with PRC interests internationally. It is difficult to assess how much this stance of the PRC regarding the “loyalty” of overseas Chinese derives, or departs, from Liang Qichao’s hailing of “eight great men who colonised [Southeast Asia]” (zhimin bada weiren): “Whether from the standpoint of geography or history, they (Southeast Asia) are natural colonies for our people.”
ONE OF “US,” BUT NOT QUITE: PRC’S UNITED FRONT WORK AND CHINESE OVERSEAS
In Southeast Asia, there is a large ethnic Chinese population spread across various jurisdictions. This is a colonial legacy, but the Chinese were not, strictly speaking, colonisers themselves. To mitigate the negative perception of overseas Chinese as disseminators of Communism—impacting both PRC diplomacy and the safety of local Chinese—the PRC implemented policies encouraging overseas Chinese to choose between PRC nationality and that of their host country. Those who chose the latter were expected to fully integrate into local society. Indonesia was the first to sign a treaty with the PRC for this arrangement, followed by Nepal (1956), Mongolia (1957), the Philippines (1973), Malaysia (1974), and Thailand (1978).
This approach marked a shift toward single nationality and introduced jus soli alongside jus sanguinis. The 1980 PRC Nationality Law, still in effect today, stipulates that “any person born in China whose parents are both Chinese nationals or one of whose parents is a Chinese national shall have Chinese nationality.” However, individuals born overseas to PRC citizens are recognised as PRC citizens only if neither parent holds foreign permanent residency at the time of the child’s birth. Dual nationality is to be avoided as much as possible, even if it means excluding those who reside or are simply born abroad with Chinese descent.
The crystallisation of the PRC’s policies toward overseas Chinese occurred at the same time that the PRC transformed its image from being a vanguard of world Communism to being an ethno-nation pursuing the “revival” of a particularistic ancient civilisation and its “ages of prosperity” (shengshi). This shift gave the PRC freedom to use civilisational discourse in domestic and international legitimation. Xi Jinping’s public speech in 2014 at the seventh Conference of the World Federation of Huaqiao Huaren Associations (CWFHHA) exemplifies this, as he invoked a common civilisational “soul” and common ancestral “root” to justify the Chinese Communist Party (CCP)-led common “dream” of revival, declaring that “tens of millions of overseas co-patriots across the world are all members of the great Chinese family.” Since assuming power, Xi has routinely referred to both “Chinese diaspora”/“overseas Chinese” (huaqiao) and “foreign citizens of Chinese descent”/“Chinese overseas” (huaren) as “overseas compatriots” (haiwai qiaobao, “overseas siblings in diaspora”), conflating two concepts that once carried distinct implications in Chinese political language. This trend reflects the PRC’s recent overseas Chinese policies, which increasingly blur distinctions between various groups of ethnic Chinese, regardless of their citizenship status, in state-sponsored overseas Chinese associations and conferences.
The promise of equal protection for Chinese citizens and foreign citizens of Chinese descent, however, has no legal foundation. The recent case of Noa Argamani, a young Israeli woman of Chinese descent kidnapped by Hamas in 2023, reveals the complexities surrounding the identities of persons of Chinese descent. When Israeli Prime Minister Benjamin Netanyahu requested Xi Jinping’s assistance for her rescue, Beijing declined, arguing that Noa’s mother, Liora Argamani, had renounced her PRC citizenship upon obtaining Israeli citizenship. The PRC’s decision was allegedly based on Noa’s status as being only half Chinese by blood and as lacking Chinese nationality. However, Noa was born in Beijing while her mother was still a Chinese citizen, which automatically granted her Chinese citizenship at birth, regardless of whether or not she ever applied for a Chinese passport. Since Noa did not renounce her PRC citizenship or acquire foreign citizenship while residing in Israel, she retains her PRC citizenship under the 1980 PRC Nationality Law.
A far cry from embracing overseas Chinese into the protective arms of the “motherland” depicted in Operation Red Sea — the navy action movie that topped the 2018 Chinese box office — the PRC government’s present indifference toward ethnic Chinese with foreign residency during crises aligns with its stance in the 1960s, and during the 1998 anti-Chinese riots in Indonesia. The sharp contrast between the extensive efforts the PRC made to rescue Huawei’s Chief Financial Officer, Meng Wanzhou (Sabrina Meng), from Canada on US fraud charges, and its lack of responsibility towards its citizens trafficked to Myanmar by scam gangs, further illustrates the underlying logic that governs the PRC government’s overseas actions in protecting the interest and security of “Chinese sons and daughters” — providing “strong backing” (jianqiang kaoshan) for Chinese outside of China, but only when it served the PRC’s perceived interest.
While the party-state appeals to blood and cultural ties to draw investment and loyalty from overseas Chinese, its nationality laws and policies deny overseas Chinese PRC citizenship, leaving no legal obligation for the PRC to protect them. This relationship defies the internationally accepted principle of “the existence of reciprocal rights and duties,” on top of “a social fact of attachment, a genuine connection of existence, interest, and sentiment” between the state and “its people.” The PRC’s global power projection has improved significantly in recent decades, but the party-state continues and will continue in the foreseeable future to prioritise its strategic goals and political expediency over its ties with Chinese overseas, who, in the end, were neither part of the sovereign people of China (Zhongguo renmin) or the larger category of the Chinese citizenry (Zhongguo gongmin), but only part of the nebulous pan-Chinese nation (Zhonghua minzu) that was useful discursively but that was ill-defined legally and politically.
The PRC’s global power projection has improved significantly in recent decades, but the party-state continues and will continue in the foreseeable future to prioritise its strategic goals and political expediency over its ties with Chinese overseas …
CONCLUSION
While Xi Jinping and the CCP conceive of “Chinese sons and daughters at home and abroad” to be essential to the “great rejuvenation of the pan-Chinese nation,” this imagination of united Chinese-ness may not resonate with non-PRC citizens of Chinese descent—such as Penny Wong (Australia), Morris Chang (ROC, Taiwan), and Jensen Huang (USA)—who appreciate their Chinese heritage but hold political views that diverge from PRC interests. These ethnic Chinese leaders in various countries and fields are representative of Chinese migrants worldwide who “range from willingness to cooperate” with Xi’s cause “to disinterest or open rejection.” As former Prime Minister of Singapore Lee Hsien Loong stated, Singapore encourages the development of Chinese culture (Huayu wenhua, “Sino-phone culture,” or Huazu wenhua, “ethnic Chinese culture”), which cannot be equated to the culture of China (Zhongguo wenhua). While Singapore strives for a constructive relationship with China, its international positions and actions would not always meet the expectations, or go along with the interests, of the PRC. This stance mirrors that of many Chinese Malaysians, who maintain a strong pride in Chinese civilisation while fiercely embracing their Malaysian identity and defending Malaysia’s territorial claims against China.
In other words, PRC efforts in recent years in recruiting overseas Chinese to serve its “road to revival” have achieved only limited success. The gap between the goals and effects of Xi-era diaspora policy can be partially attributed to its inherent contradictions — appealing to ethnic ties of overseas Chinese without formally embracing them into the non-ethnic PRC nation. The purpose of “united front work” (tongyi zhanxian) is to form temporary alliances with those who do not fall into the core supporting forces of the CCP but who otherwise show the potential of being persuaded to support the party-state’s agendas for the time being. The PRC’s united front work, “overseas Chinese affairs” included, ultimately does not align with the long-term interests of overseas Chinese. The gap can also be partially attributed to the very structure of the post-World War II international order in which most countries had established their constitutions based on civic, not ethnic, nationalism. The intimate and inseverable connections that prompted overseas Chinese to identify their cause with that of the Chinese nation are long gone, together with state-sponsored Social Darwinism and explicit racist policies that plagued the world during the late 19th century and early 20th century.
There is a clear lesson from history, though: the rise of China-oriented nationalism among ethnic Chinese in Southeast Asia, particularly in the Dutch Indies and British Malaya at the turn of the 20th century, was driven not by Qing China’s expansionist policies but by discriminatory policies that barred overseas Chinese from full citizenship in their host countries. Anti-Chinese rhetoric, often disguised as local resistance to PRC influence or Chinese colonialism, is rising amid de-globalisation fueled by US-China de-coupling. Right-wing politicians, especially in Southeast Asian countries with notable Chinese populations, frequently depict ethnic Chinese communities outside China as agents of the PRC government purportedly aspiring to reshape regional and even global order in a Sino-centric way. To counter the PRC’s “united front work” among ethnic Chinese communities overseas, host countries should allow Chinese communities to “settle down and take local roots” (luo di sheng gen), and should ensure ethnic Chinese citizens of these countires to enjoy equal rights and fulfil equal constitutional duties as other citizens. By doing so, these host countries would be realising their constitutional promise to provide a future of social harmony and national sovereignty. In turn, Chinese communities worldwide would flourish under favourable conditions, giving rise to multiple expressions of Chinese-ness that reflect the diverse visions of these communities.
This is an adapted version of ISEAS Perspective 2025/19 published on 10 March 2025. The paper and its references can be accessed at this link.