Anna Dziedzic where a woman who, prior to her marriage to a non-citizen was a Tongan subject, but is no longer married.84 A second, and now more common, way in which naturalisation is available to former citizens is to give preferential access to those who renounced or lost their citizenship as a result of laws to avoid dual citizenship. As explained in Part 4.1, on the date of independence, eleven of the twelve Oceanic states prohibited dual citizenship. By 2019, however, all but three expressly permit dual citizenship (the two exceptions are the Federated States of Micronesia and the Marshall Islands, while Kiribati is a partial exception in that it prohibits dual citizenship for people of non-i-Kiribati descent). As states amended their citizenship laws to permit dual citizenship, many also provided a new avenue for former citizens who had lost their citizenship upon taking up a foreign citizenship to regain their citizenship. In the Federated States of Micronesia, Papua New Guinea and Tuvalu, a former citizen can apply to regain citizenship after five years residence.85 In Tonga, the residence requirements for naturalisation of former citizens are waived,86 and no residence requirements apply in Nauru or Vanuatu. 87 In Fiji, former citizens who lost citizenship upon acquisition of a foreign citizenship have preferential access to naturalisation, in that the Minister must grant such applications, and may only refuse them on character grounds.88 Naturalisation for those with special achievements or contributions Six states in the region provide for naturalisation for persons who have special achievements or who make a special contribution to the state. The Marshall Islands, Tuvalu and Vanuatu include public service of various kinds as a ground for naturalisation.89 Papua New Guinea is alone in recognising sporting achievement as a ground for naturalisation, introduced by constitutional amendment in 2016.90 Four states include financial or business contributions as a ground for naturalisation. Schemes for citizenship by investment and passport sales have a long history in Pacific states, as discussed in Part 4.2 of this report. 84 Nationality Act c 25.06 (Tonga) s 8(4). Citizenship and Naturalisation Act c 7.2 (FSM) s 203(1); Constitution of Papua New Guinea 1975 s 73(1); Citizenship Act c 24.05 (Tuvalu) s 9. 86 Nationality Act c 59 (Tonga) s 17(1). 87 Naoero Citizenship Act 2017 (Nauru) s 17; Citizenship Act c 112 (Vanuatu) s 18. 88 Citizenship of Fiji Act 2009 (Fiji) s 8(6). 89 Citizenship Act 1984 (Marshall Is) s 404; Citizenship Act c 24.05 (Tuvalu) s 6(5); Citizenship Act s 112 (Vanuatu) s 20(2)(a), (b). 90 Constitution of Papua New Guinea 1975 s 67(4); Citizenship Act 1975 (PNG) s 6A. 85 16 RSCAS/GLOBALCIT-Comp 2020/1- © 2020 Author