On 21 March 2023, the European Commission brought an action before the Court of Justice of the EU, claiming that the republic of Malta is in violation of article 20 of the Treaty on the Functioning of the European Union and article 4(3) of the Treaty on European Union and compromises the integrity of EU citizenship. This action is a consequence of the Maltese practices of issuing passports to non-EU citizens for which the government receives financial compensation instead (European Commission v Republic of Malta, 2023). This lucrative business is made possible by national laws; however, the problem lies in the fact that European citizenship is acquired automatically when acquiring national citizenship and, thus, the holder of the national citizenship has access to the entire EU (Treaty on European Union, 2012).

Moreover, not only the Maltese government uses this practice, but also the Bulgarian and Cypriot governments offered their passports for the right price, although the latter two officially stopped doing so in 2022 and 2020, respectively (Džankić, 2022). With the Russian invasion of Ukraine, the question must be asked: how desirable it is that access is offered by individual member states to citizens of nations EU member states have sanctions drawn up? Can the EU prevent the issuance of passports and, furthermore, impose a revocation?