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Comoros (Tier 2 Watch List)

The Government of Comoros does not fully meet the minimum standards for the elimination of trafficking but is making significant efforts to do so. The government made key achievements during the reporting period, considering the impact of the COVID-19 pandemic, if any, on its anti-trafficking capacity; therefore Comoros was upgraded to Tier 2 Watch List. These achievements included investigating trafficking crimes (for the first time since 2014) and initiating the country’s first trafficking prosecution. The government identified trafficking victims for the first time since 2013 and referred all victims to protective services. The government, in partnership with an international organization, developed and implemented standard operating procedures (SOPs) for victim identification and provided training on the procedures to officials on all three islands (Grande Comore, Anjouan, and Mohéli). The government also conducted anti-trafficking awareness campaigns for the first time in three years. Despite these achievements, the government has never reported convicting a trafficker; remained without a national referral mechanism (NRM) to refer victims to appropriate care; did not finalize a multi-year national action plan (NAP) to combat trafficking; and did not allocate specific funding for anti-trafficking efforts, including activities conducted by the Anti-Trafficking Task Force.

  • Vigorously investigate and prosecute alleged traffickers, including any complicit officials, and sentence convicted traffickers to penalties as prescribed in the penal code.
  • Systematically and proactively identify trafficking victims by screening for trafficking indicators among vulnerable populations, including children in domestic work, children attending Quranic schools, and Comorians repatriated from the French Department of Mayotte, and refer all victims to appropriate services.
  • Finalize and implement a formal NRM to refer victims to appropriate care.
  • 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.
  • Allocate dedicated funding for the Anti-Trafficking Task Force to fully implement its activities.
  • Increase anti-trafficking training to all front-line officials, including law enforcement, social workers, health service providers, prosecutors, judges, and civil society.
  • Finalize, implement, and fund a multi-year NAP to combat trafficking.
  • Increase collaboration with French officials to address the trafficking of Comorians on Mayotte.
  • Implement and consistently enforce strong regulations and oversight of labor recruitment companies, including eliminating recruitment fees charged to migrant workers and holding fraudulent labor recruiters criminally accountable.
  • Expand anti-trafficking public awareness campaigns to all three islands, specifically targeting vulnerable populations on Anjouan and Mohéli.
  • Develop national-level data collection on trafficking crimes, including anti-trafficking law enforcement efforts and trafficking victims identified.

The government increased anti-trafficking law enforcement efforts. February 2021 amendments to the criminal code 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 ($69,000) for crimes involving an adult victim, and 10 to 20 years’ imprisonment and a fine of 30 million Comorian francs ($69,000) 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 coordinated with an international organization to draft the country’s first standalone anti-trafficking law; the draft was pending approval by the National Assembly at the end of the reporting period.

The government investigated four trafficking cases— three for forced labor and one involving both sex and labor trafficking—during the reporting period, compared with zero investigations since 2014. The government initiated one trafficking prosecution—the country’s first—involving a French-Comorian man accused of exploiting a Malagasy girl in forced labor in Comoros. The government has never reported convicting a trafficker. The government did not report any investigations, prosecutions, or convictions of government employees allegedly complicit in human trafficking offenses. The police lacked basic resources, including vehicles, fuel, and equipment, which limited their ability to investigate trafficking cases. 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. For the second consecutive year, the government increased law enforcement training efforts. The government, both independently and in partnership with international organizations, trained police, gendarmerie, immigration authorities, and other officials on anti-trafficking enforcement, policies, and laws. Comorian authorities collaborated with Ivorian authorities to investigate a forced labor case. The government also pursued collaboration with French authorities to investigate a forced labor case on Mayotte; however, due to local inaction on the case, Comorian authorities attempted to have the suspect extradited to Comoros.

The government increased victim protection efforts. The government, in partnership with an international organization, identified eight trafficking victims—the first victims identified since 2013—and referred all victims and their dependents to care. Of the eight victims identified, traffickers exploited six in forced labor and two in both forced labor and sex trafficking; three were exploited in Comoros, and five were exploited abroad in Cote d’Ivoire, Oman, Tanzania, and on Mayotte; two were male, and six were female; six were adults, and two were children; and four victims were Comorian nationals, while the other four were foreign nationals from Burundi and Madagascar. The government, in partnership with an international organization, developed the country’s first SOPs for victim identification, which included a manual and questionnaire. The government disseminated the SOPs and provided training to law enforcement authorities and listening centers (Service d’ecoute) on all three islands in late 2021. Using the newly established SOPs, the government increased efforts to screen vulnerable populations, including foreign migrants and victims of abuse, for trafficking indicators; in previous years, the government regularly deported potential victims without screening for trafficking indicators. The government remained without an NRM to refer victims to protection services; however, officials, in partnership with an international organization, began drafting an NRM to complement the new victim identification SOPs.

The government partnered with international organizations and local NGOs to offer assistance to all eight identified victims, including temporary housing, medical care, counseling, job training, and voluntary repatriation for foreign victims; however, the services on Anjouan and Mohéli were limited compared with services available on Grand Comore. The government continued to provide financial support, including salaries for employees and office space, to the listening centers. For the first time, the government provided anti-trafficking training to listening center staff. The listening centers, with assistance from civil society, provided temporary housing to one trafficking victim and continued to offer 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 Mohéli. In 2021, the listening centers reported providing assistance to at least 186 women and children on Grande Comore, compared with at least 256 in 2020. The listening centers recorded these persons as victims of abuse; however, some of these victims may have been trafficking victims. There were no trafficking-specific shelters available to victims in the country. Due to the recent development of victim identification SOPs in late 2021, some victims may have remained unidentified within the law enforcement system during the reporting period. Comorian law allowed victims of crime, including trafficking, to receive restitution from the government or from traffickers through civil suits; however, there were no reports that trafficking victims received restitution. Despite requirements of the 2015 child labor law, the government did not establish a support fund for children vulnerable to trafficking.

The government maintained efforts to prevent trafficking. The Secretary General continued to oversee the interagency Anti-Trafficking Task Force, composed of representatives of relevant government agencies, the listening centers, and international organizations, to lead the government’s anti-trafficking efforts. The task force met regularly in 2021 to plan awareness campaigns, coordinate on trafficking cases, and develop plans to establish an anti-trafficking department within the government. The federal budget did not include a dedicated allocation for anti-trafficking programs led by the task force; however, the task force received funds on an ad hoc basis from the Ministry of Foreign Affairs and international organizations to conduct anti-trafficking activities. The government did not have a long-term, multi-year anti-trafficking NAP; however, the task force continued to implement the 2020 NAP, which delegated specific, short-term actions to relevant government agencies. The task force reported drafting an updated multi-year NAP but did not complete a final version by the end of the reporting period. For the first time in three years, the government, in partnership with international organizations, conducted awareness campaigns targeting local authorities, religious leaders, and the general public on Grand Comore; however, the government did not report conducting awareness campaigns targeting vulnerable populations on Anjouan or Mohéli. The government continued to fund two toll-free emergency lines for all three islands, which were used to report crimes to the listening centers; 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; however, 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. 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. In 2016, the labor ministry signed an agreement with several labor recruitment agencies to facilitate review of the transnational recruitment processes and monitor job advertisements in an effort to identify recruitment activities that might endanger Comorians seeking overseas employment; however, the government has made minimal efforts to regulate labor recruitment agencies since then. In February 2022, the government established an informal task force to oversee working conditions of Comorians living and working abroad. The government did not provide anti-trafficking training to its diplomatic personnel, nor did it make efforts to reduce demand for commercial sex acts.

As reported over the past five years, human traffickers exploit domestic and foreign victims in Comoros, and traffickers exploit victims from Comoros abroad. Traffickers exploit women and children from rural areas in urban cities, such as Moroni, in forced labor; these individuals may also be vulnerable to sex trafficking. Traffickers exploit Comorian adults in forced labor in agriculture, construction, and domestic work on Mayotte, a French department, and continental Africa. Traffickers exploit Comorians in domestic servitude in the Middle East. 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 in domestic service, roadside and market vending, baking, fishing, and agriculture. Poor rural families, often on Anjouan and Mohéli, 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 ages 3 to 7 (and some as old as 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. These children may also be subject to physical and sexual abuse. The estimated 3,000-4,000 unaccompanied Comorian children on Mayotte are especially vulnerable to domestic servitude and sex trafficking. Comorians may be at high risk for 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. Traffickers exploit Malagasy girls in domestic servitude in Comoros; these individuals often also experience sexual abuse and may be vulnerable to sex trafficking. Economic migrants and asylum-seekers attempting to reach Mayotte from other African countries, primarily Madagascar, Burundi, and the Democratic Republic of the Congo, are increasingly transiting Comoros; traffickers may exploit these irregular migrants in forced labor or sex trafficking in various transit points.

U.S. Department of State

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