Comparative Regional Report on Citizenship Law: Oceania a Minister (in Fiji and Samoa); the Cabinet (in Nauru) or the Citizenship Commission (in Solomon Islands).106 In Kiribati, Papua New Guinea and Vanuatu, even where a court finds that citizenship was obtained by misrepresentation or fraud, a Minister can decide not to cancel a person’s citizenship if satisfied that the offence was of a minor nature and that the true facts would not have affected the grant of citizenship.107 In five states, legislation makes clear that loss of citizenship on this ground takes effect on or after the date of the decision of the relevant authorities (ex nunc).108 In Palau, on the other hand, where citizenship is revoked on this ground, the revocation is effective from the date of the original grant of citizenship (ex tunc).109 In Tonga, the order of revocation has effect from “such date as the King may direct”.110 In the Federated States of Micronesia, Kiribati, Samoa, Solomon Islands and Tuvalu the effective date of loss of citizenship is not clear on the face of the legislation. Failure to meet the conditions of naturalisation Laws in some Oceanic states permit deprivation of citizenship where the person fails to comply with specified criteria for naturalisation. The most common ground of this kind is failure to reside permanently in the state after naturalisation, which is a ground for loss of citizenship in Nauru, Samoa and Tuvalu.111 Other less common grounds for loss of citizenship also fall into this category. For example, a person who is granted Nauruan citizenship upon their marriage to a Nauruan may be deprived of that citizenship if he or she remarries a non-Nauruan after divorce or the death of his or her spouse.112 In an example of a different kind, a person granted Samoan citizenship by investment can lose that citizenship if the investor fails to carry out the investment or maintain his or her pre-determined net worth.113 106 Citizenship of Fiji Act 2009 (Fiji) s 17(2)(a); Naoero Citizenship Act 2017 (Nauru) s 23(1); Citizenship Act 2004 (Samoa) s 15; Citizenship Act 2018 (Solomon Is) s25(1); Nationality Act c 59 (Tonga) s 12(1). 107 Citizenship Act 1979 (Kiribati) s 8(2); Constitution of Papua New Guinea 1975 s 70(2); Citizenship Act c 112 (Vanuatu) s 14(2). 108 Citizenship of Fiji Act 2009 (Fiji) s 17(5)(a); Naoero Citizenship Act 2017 (Nauru) s 23(6); Citizenship Act 1984 (Marshall Is) s 407; Citizenship Act c 112 (Vanuatu) s 14(2). 109 Citizenship Act c 13.1 (Palau) s 143(a). 110 Nationality Act c 59 (Tonga) s 12(1). 111 Naoero Citizenship Act 2017 (Nauru) s 23(1)(b); Citizenship Act 2004 (Samoa) s 16; Citizenship Act c 24.05 (Tuvalu) s 7(6). 112 Naoero Citizenship Act 2017 (Nauru) s 24. 113 Citizenship Investment Act 2015 (Samoa) s 19(a),(b). RSCAS/GLOBALCIT-Comp 2020/1 - © 2020 Author 21