Last month, Dr Luke Evans presented the First Cousins (Prohibited Relationships) Bill, which would ban not only marriage and civil partnerships between first cousins, but also sexual relations between them. At last, someone in this debate has got to the point. Cousin marriage is unconditionally legal in 18 of the United States plus the District of Columbia, and conditionally legal in a further six. Proponents of a ban here should ask themselves why there was not one already. There did used to be. Until the Reformation, the Late Roman ban on marriage to the fourth degree of consanguinity had obtained, extended to affinity because in marriage, “the two shall become one flesh”. Catholic Canon Law has therefore always banned cousin marriage, at one time to the seventh degree, although with possibilities of dispensation since the ban was not in the Bible.
Such dispensations did the Hapsburgs no good, but our own Royal Family would agree with NHS England that cousin marriage, not least where one party was an immigrant, had “benefits” that included “stronger extended family support systems and economic advantages”. Queen Victoria and the immigrant Prince Albert were first cousins. By descent from that marriage, the King’s parents were third cousins, while they were also second cousins once removed through a different line. Prince Philip was not only an immigrant, but an asylum-seeker who took refuge in Britain because he had relatives here, one of whom he married. Britain intervened militarily in his native land to restore his family to the Throne. Talk about bringing their troubles to our door.
It was not a happy marriage between Victoria and Albert’s granddaughter, Princess Victoria Melita of Saxe-Coburg and Gotha, and their grandson, Grand Duke Ernest Louis of Hesse and by Rhine, although rather more successful was the union between Ernest Louis’s sister, Princess Irene of Hesse and by Rhine, and another of Victoria and Albert’s grandsons, Prince Henry of Prussia, even if two of their three sons were haemophiliacs. The other one did not die until 1978. Did Queen Elizabeth II never meet him? At any rate, cousin marriage was the most uncompromisingly Protestant thing about her public life. Ernest Louis and Victoria Melita were known in the Royal Family as Ernie and Ducky, but she was not the only ducky in the marriage, which was dissolved after only six years in 1901.
That brings us to the fact that the legality of marriages between first cousins was a product of the Reformation. Its prevalence until the First World War, and as recently as that, was a badge of Protestant honour, since Henry VIII had legalised it when he had wanted to marry Catherine Howard, who was Anne Boleyn’s first cousin, and since although William and Mary never had children (there’s that Ducky thing again), the intention had been that they would, and they were first cousins whose marriage would not ordinarily have been possible in the Catholic Church. Does the Orange Order, named after a fruit, now wish to ban a marriage such as William of Orange’s? Would the four stripes of Northern Irish Unionist in the House of Commons vote for that ban? We may be about to find out.
This seems to be about the Two Cultures. Although Charles and Emma Darwin were first cousins who had 10 children, and although Albert and Elsa Einstein were both maternal first cousins, and paternal second cousins such that her maiden name was Einstein, the mere thought of this practice is profoundly shocking to scientists. But to people formed by the study of literature and history, then, while that is where it belongs, that is where you will find it routinely. Mainstream British society was educated out of it, and not very long ago, so that can obviously be done. South Asians are hardly unreceptive to education.
Anglo-Saxons and Scotch-Irish still regularly marry their first cousins in several of the parts of the United States that voted for Donald Trump, and they did so as a matter of course into the very recent past. But if the argument is that this was something that certain other ethnic groups did, then , much as I would still vote for this Bill since it was available, it may be better to treat the matter as one of health education rather than of criminal law. After all, that was what worked with everyone else. Nineteenth-century novels are full of marriages between first cousins as the most normal thing in the world. In HMS Pinafore, Sir Joseph Porter marries his adoring Cousin Hebe. Between 1979 and 1981, the makers and viewers of To the Manor Born took it as read that Audrey fforbes-Hamilton’s late husband had been her cousin. Although Coronation Street does not, both Emmerdale and EastEnders still feature such arrangements between white characters whose families were supposed to have lived in Emmerdale or Walford since time out of mind, and that seems to raise no eyebrows. Still, the King is a last great hurrah of that sort of thing. His mother was one of the least inbred monarchs ever, and his son and grandson are not at all inbred. Educate people, and it will mostly or entirely die out. That worked with everyone else. Even the Royal Family.
Yet since the intention would apparently be to prevent genetic defects, which is not the only reason to oppose cousin marriage, then it would be pointless without the criminalisation of sex between first cousins. So be it, but we have already raised the age of marriage to two years above the age of consent, a literally preposterous arrangement. It is now legally impossible to do the decent thing, but not to do the indecent thing. Pity poor Imam Ashraf Osmani of Northampton, who in January was handed a suspended sentence of 15 weeks’ imprisonment for having performed a nikah, which has no legal status whatever, so that two 16-year-olds could have a perfectly lawful sexual relationship without sinning. The second time as farce.
Something similar applies to polygamy. As you could marry your cousin by nikah, with no legal standing, and the two of you could then have children perfectly legally as you could have done anyway, so you can take three more wives alongside your legal one by nikah, with no legal standing, and have children with all of them. Or you could take all four wives by nikah alone. In fact, any man can have children with four different women simultaneously if they will let him. Doing so with two, often in arrangements that lasted decades, has never been especially uncommon, and nor has sending the bill to the DWP or its predecessors. Whatever else that may be, it is certainly not un-British.
On 1 July, the Swedish government formally outlawed first-cousin marriage, presenting the ban not simply as a measure to reduce inherited disorders but as protection against coercion, honor-based oppression and clan control. The immediate reaction, recorded by Svenska Dagbladet, was strikingly subdued. In Rinkeby, a Stockholm district with a large immigrant population, some residents welcomed the ban while others objected to political intrusion into family life. The most telling reservation was that the law would remain largely declaratory unless vulnerable young people were offered alternative sources of protection. After all, coercion and protection are two sides of the same system: the family that houses, employs and defends its members also acquires the power to supervise their friendships, sexuality and marriages.
Britain considered the issue less decisively than Sweden in December 2024, when the Conservative MP Richard Holden introduced a Bill prohibiting marriage between first cousins. Although he cited genetic risks and coercion, his more original argument drew on conclusions reached separately by the anthropologists Joseph Henrich and Jack Goody: cousin marriage helps preserve clan power by keeping property, loyalty and opportunity within the extended family.
Holden was opposed by Iqbal Mohamed, the independent Muslim MP for Dewsbury and Batley, who argued that prohibition would stigmatize minorities and prove difficult to enforce. Education, genetic screening and protection against forced marriage were preferable. Yet Mohamed also acknowledged the institution’s economic logic: cousin marriage strengthened family bonds and put families on a “more secure financial foothold”.
The two MPs were describing the same institution from opposite ends: Holden emphasizing the power the clan exercises over its members, Mohamed the protection it offers. Where governments are weak or indifferent, the extended family can become bank, welfare office, employment agency and court of appeal. But protection has a price. People who depend on the family cannot easily defy it.
The liberal response to this issue tends to stop at individual consent. Are two adults entitled to marry? Are minorities being stigmatized? These are necessary questions, but they can obscure the distribution of power within which consent is exercised. Multiculturalism is acutely conscious of injuries inflicted on minorities while often reticent about systems of authority exercised within minority cultures.
On the face of it, cousin marriage has little to do with Middle Eastern investments in the Shard, Canary Wharf or Manhattan office blocks. Still less do they appear connected to the Trump family’s increasingly intimate business relations with the dynasties of the Gulf. Yet they belong to the same structural landscape: a form of social organization resting upon blood, marriage, personal knowledge and reciprocal loyalty. This is very different from the other kind of social organization, more common in the West, which assigns property and authority to artificial persons — courts, universities, offices, companies and states — that exist independently of the mortal individuals temporarily occupying them.
Such distinctions can be traced back to the Middle Ages. Western modernity, following its millennium-long gestation within the Catholic Church, depended not upon abolishing the family but upon creating institutions powerful enough to compete with it. Goody, writing as an anthropologist specializing in kinship, and Henrich, drawing much later on comparative psychology and cultural evolution, arrived independently at versions of this argument. Both suggest implicitly that Max Weber’s celebrated account of the Protestant ethic and the emergence of capitalism begins much too late.
Weber explained the rise of capitalism partly through the moral psychology of ascetic Protestantism. Calvinists, uncertain of their salvation, looked for evidence of election in disciplined work, sobriety and accumulation. His argument is illuminating, but Protestantism encouraged capitalist behavior only because Latin Christendom had already constructed the institutional base upon which capitalism could build. Antwerp had become Europe’s leading commercial center under Catholic Habsburg rule before Protestant Amsterdam absorbed much of its displaced trade, capital and expertise. Venice, Genoa and Florence were wealthy long before the Reformation.
The more fundamental institutional revolution was Catholic. From late antiquity onwards, the Western Church attacked many of the reproductive arrangements through which kin groups preserved property and power. Its marriage program — arguably the most far-reaching exercise of social engineering in history — prohibited polygyny, concubinage, divorce, adoption and remarriage, as well as unions within widening circles of blood and affinity. In 517, for example, the Synod of Epaone in Burgundy decreed that unions with first and second cousins were incestuous and henceforth forbidden, along with marriage to stepmothers, widows of brothers, sisters-in-law and aunts by marriage. The prohibition was extended to the seventh degree by Pope Gregory III in 732, and reaffirmed throughout the medieval period, although enforcement was uneven. The prohibition was later reduced to kinship of the fourth degree.
The Church’s stated reasons were scriptural and theological. Marriage created “one flesh”, and the incest prohibitions were held to protect the sacramental purity of marriage. But the institutional effect was also material. By restricting heirs, remarriage and the means by which lineages recovered property, the Church made it easier for wealth to pass into monasteries, bishoprics and charitable endowments. In his seminal work The Development of the Family and Marriage in Europe (1983), Goody argued that this was no accidental by-product. By the Reformation, the Church and its affiliates had become the largest landholders in Germany and doubtless much of northern Europe.
The consequences, intended or otherwise, were revolutionary. Marriage restrictions weakened large kinship groupings. They encouraged smaller households, unions outside the lineage, voluntary associations and trust between unrelated people. In The WEIRDest People in the World (2020), Henrich argues that populations subjected most intensively to the Church’s rules gradually became more individualistic and more disposed to trust strangers. The Church did not merely preach universal brotherhood; it interfered with the institutions that made family the principal source of social identity. It broke the clan in order to save the individual soul.
But weakening kinship created a new problem. If property, authority and memory were no longer transmitted exclusively through blood, where could social continuity reside? The answer was the corporation, an originally ecclesiastical structure later secularized and appropriated by business. An abbey survived its abbots; a bishopric its bishops. Masters and students passed through Oxbridge, but the university and its colleges remained. Kings died, but the Crown endured. Offices, endowments and obligations acquired an existence independent of the bodies temporarily administering them.
While promising eternity to believers’ souls, the Church created an earthly analogue of eternity in law. The corporation was an immortal body, distinct from the mortal governors, shareholders and employees composing it. Property could belong not merely to a proprietor and his heirs but to an institution that never died — the “dead hand” of mortmain. Protestantism may have supplied capitalism with Weber’s “this-worldly asceticism”. But it was Catholic canon law that supplied the indispensable legal fiction of corporate personality. Eternity, a diminishing expectation with the growth of religious skepticism, migrated from heaven to Companies House and Wall Street.
The theological ancestry of the modern company is curiously neglected in conventional accounts of secularization. As I used to explain to my students, Jesus Christ was, in this structural sense, the original president of Coca-Cola and of every other corporation operating under Western law. The Enlightenment did not simply expel religion and leave autonomous reason in its place. It inherited legal and metaphysical inventions developed over many centuries by the Latin Church.
The contrast with Islamic societies is stark, though it is not a contrast between commercial sophistication and backwardness. Muslim jurists developed complex rules governing trade, credit, inheritance, partnership and charitable endowments, sustaining commercial networks from the Atlantic to the Indian Ocean when much of northern Europe remained economically primitive. But Islamic law did not develop corporate personhood in the same expansive and adaptable form as Latin canon law. The waqf (Islamic trust) could preserve property for generations, but its purposes were fixed by its founder. Commercial partnerships remained tied to particular individuals and might dissolve when a partner died, whereupon his share passed among prescribed heirs, often fragmenting the estate.
Nor did Islamic law generally challenge endogamous marriage. Cousins are absent from the prohibited degrees enumerated in the Qur’an which also expressly mentions cousin categories among those permitted to the Prophet. In many Arab societies, marriage to a father’s brother’s daughter became especially valued, a practice seen by critics as a way of circumventing female rights of inheritance. Studies have generally placed consanguineous marriage at roughly two-fifths to more than half of all unions in Saudi Arabia, although rates vary by region and have declined in some younger and urban populations. Combined with inheritance rules, such marriages retain property and obligations within the extended family and reinforce lineage solidarity.
A related contrast appears in legal culture. Western justice came to revere the idea of depersonalized justice symbolized by the blindfold statue of Lady Justice holding a balance: abstract rules applied without regard to the litigants’ identities. Lawrence Rosen’s studies of Moroccan courts describe a different philosophy. The qadi assesses reputation and character, and seeks a settlement that restores workable relationships between contending parties. His authority lies not simply in imposing a rule from above but in knowing how the parties stand within a web of obligations. The relevant distinction is between trust vested in procedure and trust vested in personal knowledge.
The Western achievement was not moral superiority but the institutionalization of mistrust, nourished by the doctrine of original sin. Because human beings were assumed to be greedy, partial and mortal, offices and procedures were constructed to constrain and outlast them. Authority belonged — at least theoretically — to the office rather than the office-holder or their family. Official rules made nepotism harder: appointments could be challenged, accounts audited and conflicts exposed. While the West never eradicated favoritism, it forced favoritism to disguise itself.
It is here that Gulf sovereign wealth funds enter the picture. A sovereign fund, such as Norway’s, is supposed to embody depersonalized capitalism: professionally managed, globally diversified and capable of yielding revenue across generations. Yet in a Gulf monarchy it may also operate as an investment arm of the ruling establishment — simultaneously national treasury, investment company, diplomatic instrument and development agency. Its assets belong nominally to the state, but senior princes appoint managers, determine strategic priorities and use investments to cultivate relationships abroad. A decision may be commercially rational while also serving diplomacy, prestige and dynastic security.
The results are visible across Western cityscapes. Qatar’s fund owns Harrods and the Shard, jointly controls Canary Wharf Group and holds a substantial stake in Heathrow. Saudi Arabia’s Public Investment Fund owns Newcastle United and has invested in Lucid, Uber and a multitude of technology and entertainment ventures. It also supplied $2 billion to Jared Kushner’s Affinity Partners even after an internal advisory panel reportedly raised objections. Qatari and Emirati funds initially invested about $200 million each; in 2024 Qatar’s investment authority and Abu Dhabi-based Lunate supplied a further $1.5 billion between them.
There is nothing inherently sinister about Arab ownership of Western property. American private-equity firms, Russian oligarchs, European luxury conglomerates and British pension funds do not acquire moral purity merely by being Western. Gulf funds employ highly trained professionals and seek financial returns. Petrodollar capital, however, emerges from political systems in which personal confidence, dynastic authority, discretion, patronage and reciprocal obligation remain central to governance. Its influence lies not only in formal ownership but in the field of access, gratitude and dependency surrounding it.
The Khaldunian paradigm is helpful here. Ibn Khaldun, the 14th-century North African historian and political theorist, understood political power as arising from asabiyya — group feeling, or clannish solidarity. A ruling house governs because its members possess a cohesion unavailable to more fragmented populations. In time, luxury and dependence weaken that solidarity, exposing the dynasty to replacement by a tougher group arriving from the margins.
Far from escaping this logic, the Gulf monarchies have modernized it. Oil revenues allow ruling families to transform lineage solidarity into ministries, sovereign wealth funds, global portfolios and high-tech security services. Kinship has not disappeared into the anonymized structures of the bureaucratic state; bureaucracy has become an instrument through which dynastic cohesion operates internationally. The Gulf sovereign wealth fund is Asabiyya Inc.
Patrimonial capital becomes especially potent when it encounters Western elites predisposed to behave in like fashion. Kushner’s Affinity Partners offers the clearest example. After serving in Donald Trump’s White House, where he played a central role in Middle Eastern policy, Kushner obtained billions in commitments from Gulf sovereign funds.
The scandal does not depend upon proving a crude exchange of policy for payment. It lies in the blurring of public and private realms. A president’s son-in-law conducts diplomacy with hereditary rulers and then receives capital from funds answerable to those ruling establishments. Public service creates private relationships; private relationships produce commercial opportunity; commercial interests shadow future public policy. The form may be corporate, but the substance is courtly.
With Trump’s return to power, the overlap between his family’s businesses, diplomatic connections and political authority has become ever more conspicuous. Sons, sons-in-law, golf buddies, property developers, cryptocurrency promoters and Gulf princes inhabit the same web of transactions. The problem is larger than corruption in its prosecutable form. Bribery law assumes a reasonably clear distinction between public office and private gain. Today, that very distinction is being eroded, bringing about what could be described as “re-feudalisation”. Under feudal arrangements, government was personal: land, jurisdiction, family alliance and military obligation formed a single web. A favorite might simultaneously be ambassador, financier and beneficiary of royal patronage. The sovereign’s household was not neatly separable from government.
The modern state emerged by extracting office from the household. Treasury funds ceased, in theory, to be the ruler’s private money, while diplomats and civil servants served an institution rather than a family. These principles were never perfectly realized. But hypocrisy — the tribute vice pays to virtue — acknowledged the institutional ideal: nepotism had to be concealed because public and private interests were understood to be different.
Constitutional government still depends upon offices whose purposes cannot be privately inherited, purchased or repaid. It requires decision-makers capable of distinguishing friendship from duty, and national resources from family assets. Once that separation collapses, elections may mask continuity, but real power reverts to a pre-modern feudal order.
The Swedish ban on cousin marriage concerns much more than an uncomfortable minority custom. It asks whether liberal societies can discuss the institutional consequences of kinship without subjecting families to ethnic prejudice or romanticizing national culture. Cousin marriage endures because it performs vital economic and political work: it concentrates trust within the lineage. Prohibition alone cannot dissolve that structure. People will not abandon the protections of kinship merely because the state declares them undesirable; the state must demonstrate that its institutions are worthy of trust.
The medieval Church’s marriage prohibitions redirected trust outwards, towards voluntary associations and the artificial persons of the abbey, city and state. The modern West was built through that long and incomplete transition from blood to office, household property to corporate property, and personal rule to institutional authority. Today, that movement appears to be going into reverse. Citizens are invited to regard cousin marriage solely as a private choice while presidents convert public office into family opportunity. Governments speak the language of transparency while courting funds that combine national wealth with dynastic power. The artificial persons created to restrain kinship — the state and the corporation — are being reoccupied by kin-based households.
Sweden has outlawed the marriage of first cousins. The more difficult task is preventing the return of government by aunts and uncles, cousins, sons, sons-in-law and their cronies.
