There is not much that the government can do to help Danes with dual citizenship who find themselves detained in their second country.

The Foreign Ministry has received several requests for help from people who were prevented from leaving their other country of citizenship. Ole Mikkelsen from the ministry said that since the detainee is also a national of another country, the Danish government has limited authority.

“Under international law, countries are not even required to give us what is called consular access or even allow us to talk to the detainee,” Mikkelsen told DR news.

Thami Najim, the Danish-Moroccan citizen who has been imprisoned in Morocco since February, was recently denied permission to see his Danish attorney, Bjørn Elmquist. Najim is charged with threatening the security of Morocco and receiving foreign funds intended to be used for terrorist activities. Elmquist said he plans to ask the foreign minister, Villy Søvndal (Socialistisk Folkeparti), to pressure Moroccan authorities to allow him to see Najim.

Even PM Helle Thorning-Schmidt (Socialdemokraterne) has not been able to prevail in the case of Abdulhadi al-Khawaja, perhaps the most well known dual-citizenship Dane being imprisoned in his original homeland. Al-Khawaja, who holds dual Danish and Bahraini citizenship, is serving a life sentence in Bahrain for demonstrating against the incumbent government and organising protests during the Arab Spring uprisings. He has been on a hunger strike and was recently granted a new trial. Thorning-Schmidt said that she has written a letter to both the king and the prime minister of Bahrain demanding al-Khawaja’s release to no avail.

The state-run Bahrain News Agency (BNA) reported that Bahrain’s Supreme Judiciary Council had decided that Denmark’s demands were not in keeping with international law.

Mikkelsen strongly urged travellers to think twice before travelling back to a country where they may have unfulfilled obligations. He cited the case of a Danish citizen called 'Hassan'.

Hassan is a dual citizenship Dane who found out the hard way that he had not completed compulsory military service in his second homeland, Iran. He was stopped as he tried to return to Denmark after a visit to Iran and told he could not leave until he served two years in the Iranian military.

“I could serve the two years,” Hassan told DR news. “I would probably lose my job. My whole life is in Denmark."

Hassan could also leave Iran if he paid authorities 50,000 kroner, but he said he has no desire to pay that much even if he could raise the money.

Hassan’s case is still being examined by the Iranian government, so he declined to give his last name to DR.