Comparative Regional Report on Citizenship Law: Oceania changing the Constitution to permit dual citizenship, raising concerns about the impact that dual citizenship for non-Indigenous residents might have on Indigenous rights to land ownership. He argues that a country “still struggling to develop a full blown nationalism, a prerequisite for a robust national sovereignty” 129 cannot afford the dilution of national allegiance implied by dual citizenship. This brief survey of the motivations behind the legal change to permit dual citizenship indicates that, at the regional level, the desire to reintegrate Pacific Islanders living overseas into their home state have come to outweigh fears – justifiable in light of colonial experiences – of foreign ownership and exploitation. 4.2 Citizenship by investment A second feature of the citizenship laws of Oceania is the region-wide experimentation with forms of investor citizenship. Also known as ‘economic citizenship’ or citizenship or passport sales, investor citizenship schemes are used by small Oceanic states to attract revenue in exchange for granting citizenship to persons who otherwise have no connections to the country.130 For states with limited economic resources, the sale of passports and citizenship can provide significant revenue, and in some cases constitutes a significant proportion of a country’s GDP.131 In return, those who purchase citizenship might get a passport with visa-free entry to certain states or greater freedom of movement, or tax or other concessions in their home state. Some are misled to believe that holding citizenship of the Pacific state will give them preferential access to the United States or other popular immigration states. Most purchasers of citizenship in Oceania have been from mainland China, Hong Kong and Taiwan.132 4.2.1. Passports for sale States in Oceania were early pioneers in passport sales. In 1982, the King and Privy Council of Tonga created ‘Tongan Protected Person Passports’, which were sold mainly in Hong Kong. The passports did not confer citizenship, residency rights or visa-free entry, and several states in the wider Asia-Pacific region refused to recognise them. In order to ward off constitutional challenge in Tonga, the passport sales were given a legislative basis and redescribed as travel documents rather than as a conferral of citizenship.133 In the mid 1990s, Kiribati and Tuvalu also experimented with selling passports but not citizenship. Kiribati introduced an ‘investor passport’ in 1996, which came with the right of residence. This scheme was repealed in 2004. 134 In 1997, Tuvalu began selling passports, 129 John R Haglelgam, ‘Letter to the Editor: Former FSM President on Dual Citizenship Act’ The Kaselehlie Press (Pohnpei, 8 February 2017) <http://www.kpress.info/index.php?option=com_content&view=article&id=529:letter-to-the-editor-former-fsmpresident-on-dual-citizenship-act&catid=10&Itemid=119>. 130 Jelena Džankić, The Global Market for Investor Citizenship (Springer 2019) 8. 131 Anthony Van Fossen, ‘Citizenship for Sale: Passports of Convenience from Pacific Island Tax Havens’ (2007) 45 Commonwealth & Comparative Politics 138, 141. 132 Ron Crocombe, Asia in the Pacific Islands: Replacing the West (IPS Publications, University of the South Pacific 2007) 64–5, 165–7. 133 Fossen (n 131) 141–6. 134 Immigration and Refugee Board of Canada, Kiribati: Whether foreigners can obtain passports through the Investor Passport Program; whether this program gives residence or citizenship rights; if applicable, the circumstances leading to the loss of these rights; the significance of the letters before the status and number on RSCAS/GLOBALCIT-Comp 2020/1 - © 2020 Author 25