Anna Dziedzic mainly to Chinese citizens. As in Tonga and Kiribati, purchasing a passport did not automatically lead to conferral of citizenship. 135 In addition to these formal government schemes, illegal passport sales also thrived in some states. In 1998, the Vanuatu Ombudsman exposed high level government officials who were issuing diplomatic passports to ‘honorary consuls’ and other sham positions in return for payment.136 Over the 1990s, Samoan passports were sold in Hong Kong and China, with revenue and the passports themselves later unaccounted for.137 Officials in Solomon Islands were convicted of corruption offences over the illegal sale of passports (but not citizenship) to Chinese nationals.138 4.2.2. Citizenship for sale Over time, several Oceania states came to sell not just passports but citizenship. In some states, this was done through broad discretionary powers of naturalisation given to executive governments, permitting, for example, naturalisation of persons on ‘national interest’ grounds. More recently, two states – Samoa and Vanuatu – have legislated for detailed investor citizenship programs.139 Discretionary investor citizenship In Tonga, the sale of passports became the sale of citizenship in 1984 when the Nationality Act was amended to give the King of Tonga the power to grant naturalisation to any foreigner of “good character on humanitarian grounds” for a prescribed fee.140 After a court challenge, the scheme was discontinued in 1988. It was briefly reintroduced in 1996, along with provisions giving holders of Protected Person Passports the right to apply for naturalisation.141 Similar legislative provisions to permit discretionary naturalisation “in the public interest” for “distinguished service” to the country in exchange for a prescribed fee enabled the sale of citizenship in the Marshall Islands between 1987 and 1996.142 During this time, the Marshall Islands sold around 2000 citizenships, mainly to applicants from China. The program ended at the same time that the United States made migration and entry to the United States on Marshallese passports more difficult.143 Nauru legislated in 1997 to create a category of ‘citizen investor’ for a person and his or her family who “has made an investment in the island of Nauru in such form and of such amount as determined by Cabinet”.144 It is estimated that 1000 sales were made between 1998 and 2002, generating eight percent of Nauru’s GDP. Nauru’s citizenship by investment the Kiribati passport (1997-2010), 10 January 2011, KIR103658.FE, available at: https://www.refworld.org/docid/4e02e0ba2.html. 135 Immigration and Refugee Board of Canada, Tuvalu: Acquisition of Tuvalu passports and/or citizenship by foreigners, 22 February 2000, TUV33786.E, available at: https://www.refworld.org/docid/3ae6ad7d1c.html. 136 Ombudsman of Vanuatu, ‘Report on the Improper and Unlawful Issue of Diplomatic and Official Passports’ (1998). 137 Fossen (n 131) 146. 138 R v Kaliuae [2010] SBHC 25; Crocombe (n 132) 166. 139 This typology is drawn from Džankić (n 130) ch 4. 140 Nationality Act c 25.06 (Tonga) s 8B. 141 Nationality (Amendment) Act 1996 (Tonga); Fossen (n 131) 141–6. 142 Citizenship Act 1984 (Marshall Is) s 404 (repealed 2001). 143 Fossen (n 131) 147–50. 144 Nauruan Community Act 1956-1997 s 5(6)-(9). Although the scheme ended, persons holding citizenship by investment retain it: Naoero Citizenship Act 2005 (Nauru) s 10. 26 RSCAS/GLOBALCIT-Comp 2020/1- © 2020 Author