By the end of this guide, you’ll understand how Comoros’ citizenship-by-investment (CBI) program works, what benefits and risks it brings, and why it has attracted both interest and criticism worldwide.

What Is the Comoros Citizenship by Investment Program?

Comoros launched its CBI scheme in 2008 to attract foreign capital in exchange for passports, offering a streamlined donation route instead of complex real estate or business ventures, as detailed in the Nomad Capitalist analysis of Comoros CBI program.

Investment Options

• A single non-refundable donation to the National Development Fund
• No minimum age for dependents
• No requirement to live or visit Comoros

These options are outlined in the Global Residence Index report on Comoros citizenship.

Eligibility and Requirements

To qualify, you must:
1. Submit a clean criminal record
2. Provide proof of funds
3. Complete all application forms
4. Undergo a due diligence check

According to Henley & Partners, due diligence includes sanctions-list screening and source-of-wealth verification to ensure the legitimacy of all contributions.

Benefits of a Comorian Passport

A Comoros passport grants you:

• Visa-free or visa-on-arrival access to 51 countries, including Malaysia and Turkey, as ranked by the Henley Passport Index
• A second nationality without residence obligations
• Potential tax planning opportunities—Comoros has no wealth or inheritance taxes, a point noted in the Economy of Comoros on Wikipedia

“A Comoros passport can open doors in markets where you’d otherwise face visa delays.” – Global Residence Index

Application Process and Timeline

1. Prepare Documents: Birth certificates, police reports, and bank statements
2. Submit Application: Through an authorized agent
3. Due Diligence: Usually takes 3–4 months
4. Approval and Oath: Sign a citizenship oath in Comoros or via embassy
5. Passport Issuance: Within 1–2 months after approval

Total processing time averages 6–8 months, according to M-Citizenship’s timeline.

Due Diligence and Security Checks

International bodies have flagged concerns about money-laundering risks in some CBI programs. Comoros now uses third-party firms for enhanced vetting, as reported by IMI Daily.
The country ranks 161 out of 180 in Transparency International’s 2022 Corruption Perceptions Index, reflecting ongoing governance challenges.

Controversies and Program Suspension

Historical Scandals

In 2008, Comoros signed agreements to grant passports to stateless “Bidoon” communities in the Gulf, a deal that critics argued prioritized revenue over due diligence, according to a report by Reuters.

2018 Suspension

Facing domestic outcry and international pressure, the Comoros Parliament halted new applications in 2018 pending a governance review, as covered by Africanews. As of mid-2023, officially accepted applications remain suspended.

International Scrutiny

• The United Nations has questioned the program’s transparency, highlighting risks of unverified citizenship grants in a UN press release.
• The African Union voiced concerns that citizenship-by-investment schemes could undermine regional migration policies in its AU statement.

Diplomatic Ripples and the Black Market

Comoros’ sale of citizenship strained ties with some Gulf States, which feared uncontrolled migration flows, according to an investigation by Middle East Eye. Meanwhile, reports of forged Comorian passports circulating in black-market networks raised global security alarms, as noted by INTERPOL.

Economic and Legal Impact on Comoros

Public Finances

Funds raised were intended for infrastructure and education. However, the IMF’s Article IV Consultation report for Comoros raised concerns about the transparency of fund allocation, noting instances where development funds lacked clear expenditure documentation (IMF Article IV report).

Legal Limits for Economic Citizens

New citizens cannot:
– Vote in national elections
– Serve in the military
– Hold senior public office for 10 years

These restrictions aim to preserve domestic political rights for natural-born Comorians.

Role of Intermediaries

International agents earn up to 10% commission on each file. Critics argue that these fees inflate costs for applicants and reduce net revenues for the state.

How Comoros Compares to Other CBI Programs

Program   | Status   | Minimum Investment
————|————-|———————
Cyprus | Suspended (2020) | €2,150,000 in real estate, as detailed in the EU report on Cyprus citizenship scheme
Moldova | Suspended (2015) | €100,000 donation, reported by Euractiv
Comoros | Suspended (2018) | $45,000 donation

Next Steps for Aspiring Applicants

If you’re considering a second passport, weigh Comoros’ low investment requirement against ongoing suspensions and reputational risks. Stay informed on legislative updates and choose a reputable agent to protect your interests.