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The Government of Comoros does not fully meet the minimum standards for the elimination of trafficking and is not making significant efforts to do so, even considering the impact of the COVID-19 pandemic, if any, on its anti-trafficking capacity; therefore Comoros remained on Tier 3. Despite the lack of significant efforts, the government took some steps to address trafficking, including passing penal code amendments that criminalize all forms of trafficking; acceding to the 2000 UN TIP Protocol; developing a 2020 national action plan to combat trafficking; and partnering with an international organization to train law enforcement officials on trafficking crimes. However, the government continued to lack formal procedures to identify trafficking victims or refer them to care and has not identified or referred any trafficking victims to protective services since 2013. The scale of trafficking crimes in Comoros was unknown, in part due to the lack of identification procedures, and the government did not investigate, prosecute, or obtain convictions for any sex trafficking or forced labor crimes. Reports continued that informal mediation and financial settlements, in lieu of investigation and prosecution of crimes, may have resulted in the return of children to their alleged exploiters. The government did not conduct anti-trafficking public awareness campaigns.

Develop standard operating procedures to identify trafficking victims—especially among vulnerable groups, including children in domestic work and at Quranic school—and refer them to care. • Investigate and prosecute trafficking crimes, and sentence convicted traffickers, including complicit officials, to penalties as prescribed in the penal code. • Amend trafficking provisions in the penal code to prescribe penalties for adult sex trafficking that are commensurate with penalties prescribed for other grave crimes, such as rape. • Develop, adopt, and implement a multi-year national action plan to combat trafficking. • Improve coordination among the Anti-Trafficking Task Force by providing funding or in-kind resources, convening it regularly, and sharing data on trafficking crimes. • In coordination with NGOs and international partners, provide comprehensive protective services to trafficking victims. • Increase anti-trafficking training to all front-line officials, including law enforcement, social workers, health service providers, prosecutors, judges, and civil society. • Cease returning trafficking victims to their exploiters. • Engage French officials to prevent the trafficking of unaccompanied Comorian youth in Mayotte. • Expand anti-trafficking public awareness campaigns to all three islands. • Develop national-level data collection on trafficking crimes, including anti-trafficking law enforcement efforts and trafficking victims identified.

The government maintained inadequate anti-trafficking law enforcement efforts. In February 2021, the government enacted amendments to the criminal code that criminalized sex trafficking and labor trafficking. Article 266-11 of the new criminal code prescribed penalties of seven to 10 years’ imprisonment and a fine of 30 million Comorian francs ($74,880) for offenses involving an adult victim, and 10 to 20 years’ imprisonment and a fine of 30 million Comorian francs ($74,880) for those involving a child victim. These penalties were sufficiently stringent. However, the penalties prescribed for adult sex trafficking were not commensurate with those prescribed for other grave crimes, such as rape.

The government did not systematically collect data on law enforcement efforts, including human trafficking. The government did not report investigating, prosecuting, or convicting any traffickers, despite previous reports listening centers recorded many cases that may have been trafficking. The government has not reported investigating a trafficking case since 2014 and has never reported convicting a trafficker. The government also did not report any investigations, prosecutions, or convictions of government employees allegedly complicit in human trafficking offenses; however, corruption and official complicity in trafficking crimes at all levels of government remained significant concerns, inhibiting law enforcement action during the year. The police lacked basic resources, including vehicles, fuel, and equipment, which limited their ability to investigate trafficking cases. The judicial system in Comoros remained weak; observers continued to report criminals were frequently convicted and sentenced, but then released without explanation, creating a culture of impunity among criminals, including potential traffickers. While discouraged by the government, families or village elders continued to settle many allegations of sexual violence, possibly including sex trafficking and child domestic servitude, informally through traditional means without recourse to the formal court system. Many rural families still preferred informal arrangements with host families; children in these arrangements were particularly vulnerable to trafficking. In previous years, judges were known to negotiate agreements between a child’s parents and his or her trafficker, often returning the child to trafficking situations. Some police reportedly returned sexually abused children to their exploiters, sometimes due to a lack of shelters or an alternative form of care.

The government, in partnership with an international organization, provided training for 30 law enforcement officials on trafficking crimes, compared with no trafficking-related trainings in previous years. The government, in partnership with an international organization, organized training sessions for the Anti-Trafficking Task Force focused on the UN TIP Protocol and identifying cases of exploitation, including trafficking. The government, in partnership with the same international organization, also trained the task force and a group of religious judges on combating human trafficking in accordance with the principles of Islamic law. In partnership with an international donor, the government provided training to 20 police officers on Anjouan on children’s rights, which may have included information related to child trafficking.

The government maintained inadequate victim protection efforts. The government did not identify any trafficking victims during the reporting period and has not identified a victim since 2013. The government did not develop or employ systematic procedures to identify trafficking victims or refer them to the limited care available. The government continued to provide financial support, including salaries for employees and office space, to listening centers (Service d’ecoute); however, the government did not provide anti-trafficking training to staff. The listening centers, with assistance from an NGO, offered medical care, psycho-social counseling, and legal assistance mostly to women and children who were victims of abuse and violence, including potential trafficking victims. The government continued operating listening centers in four locations—two on Grande Comore, one on Anjouan, and one on Moheli. In 2020, the listening centers reported providing assistance to at least 189 women and children, compared with at least 144 in 2019. The listening centers recorded these persons as victims of abuse; however, because of inadequate training on trafficking victim identification, some of these victims may have been trafficking victims. On all three islands, the listening centers reportedly coordinated with the Morals and Minors Police Brigade on cases.

The government did not report assisting in the repatriation of any victims during the reporting period. The government also did not report making additional efforts to investigate, identify, or assist the 3,000 to 4,000 unaccompanied Comorian children on the island of Mayotte, a French department, after France denied the National Human Rights Commission in Comoros visas in 2018. There were no shelters available, for short- or long-term use, for adult or child victims. In 2018, the government identified a possible site for a temporary shelter, but the government did not report making any progress in establishing a shelter for the second consecutive year. Similar to last year, the Morals and Minors Police Brigade did not report whether any children were assisted or whether the government provided financial or in-kind assistance to 10 foster homes that reportedly existed on Grande Comore. In the absence of adequate funding and shelter, listening center staff and police sometimes provided temporary shelter in their private homes; however, government officials often returned children to their parents or guardians where they might have originally faced abuse or were vulnerable to trafficking. There were no reports the government inappropriately penalized victims for crimes traffickers compelled them to commit; however, because there were no standard victim identification procedures, victims may have remained unidentified in the law enforcement system. Despite requirements of the 2015 child labor law, the government did not establish a support fund for children vulnerable to trafficking.

The government demonstrated mixed efforts to prevent trafficking. In June 2020, Comoros acceded to the 2000 UN TIP Protocol. The interagency Anti-Trafficking Task Force, composed of representatives of relevant government agencies, the listening centers, and international organizations, continued to lead the government’s anti-trafficking efforts and met nine times in 2020, compared with one meeting in 2019. For the first time since 2015, the task force adopted an anti-trafficking national action plan, which delegated specific, short-term actions to relevant government agencies for implementation in 2020. The government implemented some of these actions, such as training law enforcement officials; however, most activities were not completed during the reporting period. The government did not report conducting any national public awareness campaigns during the reporting period, despite requirements in the 2015 child labor law to do so. The government continued to fund two toll-free emergency lines for all three islands, which were used to report crimes to the listening centers. During the reporting period, the listening centers received 9,072 calls reporting abuse and exploitation, a significant increase compared with 1,139 calls the previous year; however, the government did not track call data related to potential victims of human trafficking.

The Ministry of Labor employed four labor inspectors who were responsible for implementing the 2015 child labor law prohibiting child trafficking; they did not receive training on the relevant trafficking laws and did not receive operational resources to conduct labor inspections of informal work sites, where children were especially vulnerable to forced labor. Inspectors did not remove or assist any children as a result of labor inspections during the reporting period. The absence of a clear understanding of trafficking may have resulted in the misclassification of cases as other crimes, such as child labor, abuse, and rape. The government did not have effective policies or laws to govern labor recruiters and did not report holding anyone civilly or criminally liable for fraudulent recruitment during the reporting period. In 2016, the labor ministry signed an agreement with several labor recruitment agencies to facilitate review of the transnational recruitment processes and to monitor job advertisements in an effort to identify recruitment activities that might endanger Comorians seeking overseas employment; however, the government has made no efforts to regulate labor recruitment agencies since then. The government did not provide anti-trafficking training to its diplomatic personnel. The government did not make efforts to reduce demand for commercial sex acts.

As reported over the past five years, human traffickers may exploit domestic and foreign victims in Comoros, and traffickers may exploit victims from Comoros abroad. Traffickers may exploit Comorian women and Malagasy women who transit Comoros in forced labor in the Middle East. Traffickers may exploit Comorian adults and children in forced labor in agriculture, construction, and domestic work in Mayotte, a French department. Traffickers and employers on Anjouan may subject children, some of whom were abandoned by parents who left to seek economic opportunities in other countries, to forced labor, mostly in domestic service, roadside and market vending, baking, fishing, and agriculture. Poor rural families, often on Anjouan and Moheli, frequently send their children to live with wealthier relatives or acquaintances in urban areas or on Grande Comore for access to schooling and other socio-economic benefits; these children are vulnerable to physical and sexual abuse and forced labor in domestic servitude. Most Comorian children aged 3 to 7 (and some as old as age 14) study at informal neighborhood Quranic schools headed by private instructors, where they may be vulnerable to exploitation through coercion and forced labor as field hands or domestic servants as payment for instruction and subjected to physical and sexual abuse. The estimated 3,000-4,000 unaccompanied Comorian children on Mayotte, a French department, are especially vulnerable to domestic servitude and sex trafficking. Comorians may be particularly vulnerable to transnational trafficking due to a lack of adequate border controls, corruption of government officials, and the existence of international criminal networks involved in migrant smuggling.

U.S. Department of State

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