Comparative Regional Report on Citizenship Law: Oceania program ended in 2003 after international concerns about the use of Nauruan passports by suspected terrorists.145 Amendments to Papua New Guinea’s Constitution and Citizenship Act in 2016 created a category of naturalisation for persons who have “resources, capital, commitment and credentials to invest in the country’s economy to create employment and impart skills to citizens”. 146 Like the programs in the Marshall Islands, Nauru and Tonga, citizenship by investment is granted at the discretion of minister, with advice from the Citizenship Advisory Committee. Official programs for investor citizenship Vanuatu and Samoa have developed more detailed programs, with criteria set out in legislation. Since 2013, Vanuatu has developed a range of different schemes for citizenship by investment. They share a common framework and allow a person who pays a prescribed application fee and invests a specified amount into a state development fund to apply for Vanuatu citizenship.147 In contrast to other forms of naturalisation, investors are not required to reside or spend time in Vanuatu before being granted citizenship. Vanuatu’s citizenship by investment programs have proven popular. In 2018, 1800 citizenships were sold, providing Vanuatu with 30% of its revenue.148 In Samoa, the Citizenship Investment Act 2015 provides a pathway to Samoan citizenship for persons of a minimum net worth who are willing to invest a predetermined amount within three years. Investors and their family members are granted permanent residence and can apply for citizenship after three years of residence (compared to five years for ordinary naturalisation). Benefits and risks Citizenship by investment is a popular way for small island states in Oceania to generate revenue. However, as this overview shows, schemes for the sale of citizenship are not without risk. In several cases, the sale of passports and citizenship has been tainted by corruption and the revenue generated not re-invested in the state. The discretionary nature of many citizenship by investment schemes in Oceania has led to a lack of transparency, which further facilitates corruption. When passports and/or citizenship are issued too freely, a state’s international reputation can be diminished, leading to restrictions on visa free travel or the removal of concessions by other states. Domestically, citizenship by investment schemes are often controversial and unpopular with a public concerned about corruption, the domestic impact of immigration, and the cheapening of their emotional connection to citizenship. The exposure of the sale of citizenship in Tonga was a spark in the pro-democracy movement in Tonga.149 Even the most transparent 145 Fossen (n 131) 153–5. Constitution of Papua New Guinea 1975 s 67(4) (b). See also Citizenship Act 1975 (PNG) s 6B. 147 Citizenship Act c 122 (Vanuatu) s 13C. Variously called the ‘Capital Investment Immigration Plan’, ‘Honorary Citizenship under Vanuatu Development Support Program’ and ‘Vanuatu Contribution Program’. 148 Sarah Treanor and Vivienne Nunis, ‘How Selling Citizenship Is Now Big Business’ BBC News (10 October 2019) <https://www.bbc.com/news/business-49958628>. 149 Fossen (n 131) 143. 146 RSCAS/GLOBALCIT-Comp 2020/1 - © 2020 Author 27