Abstract:
An Israeli military Freedom of Information disclosure, obtained by Declassified UK, confirms more than fifty thousand six hundred serving IDF members hold foreign citizenship, twelve thousand one hundred thirty five American, six thousand one hundred French, five thousand Russian, with four thousand four hundred forty holding two additional citizenships. This piece verifies active investigations across six countries, a Belgian sniper unit prosecution including three Americans and a German, a Metropolitan Police dossier naming ten British nationals, an RCMP probe, Australian monitoring of twenty dual nationals, a Center for International Policy analysis of American War Crimes Act authority, and the Hind Rajab Foundation ICC complaint naming roughly one thousand soldiers built substantially from their own social media evidence. It documents forty UN experts 2024 warning that states permitting dual citizens to serve risk complicity, and draws a bounded comparison to the legal principle underlying Nuremberg, that citizenship carries obligations a foreign uniform cannot erase, while stating plainly that scattered investigations are not convictions and the comparison describes a door opened rather than a trial underway. The piece is framed as the first in a series that will next examine the financial and institutional networks enabling this service.
Main Article:
A Freedom of Information request filed with the Israeli military returned a number few outside a small circle of legal researchers had previously seen in full. More than fifty thousand six hundred serving members of the Israel Defense Forces hold citizenship in a country other than Israel. Twelve thousand one hundred thirty five are American, the single largest foreign contingent, ahead of six thousand one hundred French and five thousand Russian citizens, with smaller numbers from Germany, Ukraine, Britain, Canada, and a cluster of Latin American states, and, less expected, citizens of Yemen, Tunisia, Lebanon, Syria, and Algeria appearing in the same disclosure. Four thousand four hundred forty of these soldiers hold two foreign citizenships beyond their Israeli one, and a hundred sixty two hold three or more. This is the Israeli military own data, obtained by Declassified UK, not an outside estimate, and it is the starting point for a legal question now moving, country by country, from advocacy filing to active police investigation.
The mechanism enabling this is a principle of international law with a long history and a name most governments would rather not have to use against their own citizens, universal or active nationality jurisdiction, the doctrine holding that a state retains the authority to prosecute its own nationals for war crimes and crimes against humanity regardless of where in the world those acts were committed. A dual national who fights for a foreign army does not, under this principle, shed the legal obligations of the second passport in his pocket, and a government that chooses to look away from evidence of its own citizen involvement in war crimes is making a choice, not observing a limit written into the law.
Six governments have already begun, in documented and verifiable ways, to test whether they will make that choice. Belgian prosecutors opened a formal investigation in October 2024 into a Belgian Israeli citizen serving in the IDF Refaim sniper unit, and reporting indicates the entire twenty one person unit, including three Americans, two French nationals, a German, an Italian, and the Belgian citizen himself, is now under scrutiny. Belgian authorities went further in July 2025, briefly detaining and interrogating two visiting Israeli soldiers on Belgian soil. In the United Kingdom, advocacy groups submitted a formal dossier to the Metropolitan Police war crimes team in April 2025 naming ten British nationals, a sample deliberately chosen, according to the Palestinian rights lawyer who assembled it, specifically so British authorities could no longer claim ignorance of the broader population his own organization estimates may run into the hundreds. The Royal Canadian Mounted Police confirmed in June 2025 it was investigating possible war crimes in Gaza, a probe widely understood to be aimed at dual national Canadian reservists. Australia own Centre for International Justice has been independently monitoring roughly twenty dual nationals who served in the IDF. And in the United States, the Center for International Policy has published a direct legal argument that the 1996 War Crimes Act already gives Congress and the State Department the authority to investigate and charge American dual nationals, while acknowledging plainly that federal action of this kind is unlikely under the current administration, a gap between legal authority and political will this piece will return to.
The most significant single filing to date came not from a government but from a Belgian based advocacy organization, the Hind Rajab Foundation, which submitted a dossier to the International Criminal Court in 2024 naming roughly one thousand IDF soldiers it alleges committed war crimes in Gaza, built substantially from the soldiers own social media posts, service members who, in the words of one Gaza based human rights lawyer working with the same evidence, felt fully immune, and so posted footage of what they had done without concealment. The foundation named specific dual national totals inside its own complaint, twelve French citizens, twelve Americans, four Canadians, three Britons, two Dutch nationals, and stated publicly that it holds evidence on many more individuals beyond the thousand named, evidence it intends to pursue through the national courts of each soldier home country rather than waiting on the International Criminal Court alone.
This is where the door opens onto the comparison this piece was asked to draw, and it deserves to be drawn precisely rather than as pure rhetoric. The tribunal that sat at Nuremberg after the Second World War rested on a principle that was, at the time, a genuine departure from prior practice, that following orders, wearing a uniform, and acting as a soldier of a sovereign state did not place an individual beyond the reach of law if the acts committed were themselves criminal under a law that superseded any national command. What is happening now, distributed across Brussels, London, Ottawa, Canberra, and The Hague rather than concentrated in a single postwar tribunal, is the same principle being tested against a live, ongoing conflict rather than applied retrospectively to a war already over. Forty independent United Nations experts made the underlying logic explicit in 2024, advising member states that permitting their own dual citizens to serve in the IDF risked making those states complicit in war crimes or crimes against humanity, precisely the same chain of reasoning, that citizenship in a state committed to the rule of law carries obligations a foreign uniform cannot erase, that animated the postwar tribunals themselves.
None of this constitutes a Nuremberg trial, and this publication states that distinction plainly rather than let the comparison run further than the documented record supports. What exists today is a scattered, uneven, nationally fragmented set of investigations, some barely begun, others stalled by the same political will the Center for International Policy own analysis identifies as the binding constraint in the American case specifically. Six countries opening files is not six countries securing convictions, and the gap between an investigation announced and a soldier standing trial has, in nearly every legal system on earth, historically been measured in years rather than months. What this piece will state plainly, because the documented record supports it, is that the legal door these governments have opened, however narrowly, is not one that closes again easily once opened. A police file, once created, exists. A dossier submitted to the International Criminal Court, once filed, remains part of that court own record regardless of whether any single case within it proceeds to trial. And a soldier who has posted his own actions to social media, believing himself beyond the reach of any court, has created evidence no future change in political will can retroactively erase.
This publication intends this piece as the first in a series, not a complete account on its own. The soldiers named in these investigations did not act alone, and did not act without support that made their service possible in the first place, financial networks that fund travel and equipment for foreign volunteers, immigration authorities that process the paperwork allowing dual nationals to serve, and governments that have, in some cases, been asked directly by their own citizens legal representatives to intervene and have declined. The next piece in this series will examine that layer of the structure, the enabling apparatus surrounding the individual soldier, because a door opened onto individual criminal accountability, this piece argues, tends over time to widen toward the question of who built the door frame in the first place.
References:
1. Declassified UK, via The Canary, "Dual-Nationals Fighting for Israel Implicated in War Crimes," February 2026. Citing the IDF Freedom of Information disclosure of 50,632 dual and multi-national soldiers, the breakdown by nationality, and the figures of 4,440 soldiers with two foreign citizenships and 162 with three or more.
2. Middle East Eye, "Thousands of Western Nationals Serve in Israel's Army Amid Gaza Genocide: Report," February 2026, and Palestine Chronicle, "Numbers Are In: Israeli Army Data Reveals Americans, Europeans and Arabs in Its Ranks," corroborating the same disclosure.
3. Middle East Monitor, "Prosecution of Dual-National Israeli Soldiers," October 2024. Citing the Washington Post estimate of approximately 23,380 US citizens serving in Israeli forces and the Hind Rajab Foundation's use of the active nationality principle.
4. Arab Center DC, "Accountability for War Crimes in Gaza: Where We Are." Citing the Belgian prosecution of the IDF "Refaim" sniper unit, the nationalities of the 21 soldiers under investigation, and the July 2025 detention of two Israeli soldiers in Belgium.
5. Justice Info, "Dual Nationals Accused of War Crimes in Gaza," May 2025. Citing PCHR director Raji Sourani's estimate of British-Israeli dual nationals serving and the April 2025 dossier submitted to the UK Metropolitan Police naming ten British nationals.
6. The Conversation, "Israel's Call-Up of 130,000 Reservists Raises Legal Risks for Dual Citizens and Their Home Countries," June 2026. Citing the RCMP investigation, the Australian Centre for International Justice's monitoring of approximately 20 dual nationals, the 40 UN experts' 2024 advisory following the ICJ's plausible genocide ruling, and the UN Human Rights Council commission's call for prosecution under domestic law or universal jurisdiction.
7. Center for International Policy, "Enforce the War Crimes Act Against Americans Who Committed Them in Gaza." Citing the legal authority under the 1996 War Crimes Act and the assessment that federal action is unlikely under the current administration.
8. Yahoo News/Al Jazeera, "Thousands of Western Nationals Fought Israel's War on Gaza: What to Know." Citing the Hind Rajab Foundation's ICC complaint naming approximately 1,000 soldiers and the specific dual-national breakdown of 12 French, 12 American, 4 Canadian, 3 British, and 2 Dutch citizens named in the filing.