2023 Trafficking in Persons Report: Comoros

• Expedite the prosecution of alleged traffickers following case referrals by law enforcement and seek adequate penalties for convicted traffickers, which should involve significant prison terms.
• 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.
• Expand the availability of shelters to victims of all forms of trafficking – including male and foreign victims – and allocate adequate resources and staffing to shelters.
• Continue to increase anti-trafficking training to front-line officials, including law enforcement, social workers, health service providers, prosecutors, judges, and civil society, on Grande Comore, Anjouan, and Mohéli.
• Systematically and proactively identify trafficking victims by screening for trafficking indicators among vulnerable populations across Comoros, including children in domestic work, children attending Quranic schools, and individuals repatriated from the French Department of Mayotte, and refer all victims to appropriate services.
• Develop, implement, and fund a multi-year NAP to combat trafficking.
• Dedicate and allocate funding for NCTIP.
• 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 of Comoros, specifically targeting vulnerable populations on Anjouan and Mohéli.
• Develop a national-level data collection system 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 ($65,000) for crimes involving an adult victim, and 10 to 20 years’ imprisonment and a fine of 30 million Comorian francs ($65,000) 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 for the second consecutive reporting period.

The government investigated four trafficking cases – three for labor trafficking and one for sex and labor trafficking – in 2022, the same number of investigations reported in 2021. The government did not initiate any new prosecutions; however, it referred three new cases for preliminary procedures. In the previous reporting period, the government referred one case for preliminary procedures, which also remained pending, without prosecution yet initiated by the Ministry of Justice. The government has never reported convicting a trafficker. The government investigated and arrested one government employee allegedly complicit in facilitating human trafficking crimes. Police continued to lack basic resources, including vehicles, fuel, and equipment, which limited their ability to investigate trafficking cases outside Moroni. Additionally, the small number of prosecutors in the country – one per island – contributed to severe case backlogs, including trafficking cases referred for prosecution. While discouraged by the government, families or village elders continued to settle many allegations of violence, possibly including sex trafficking and child domestic servitude, informally through traditional means without recourse to the formal court system.

The government established the National Brigade for the Repression of Illegal Migrant Smuggling and Trafficking in Persons (NBTIP), a specialized investigation unit on Grande Comore mandated to investigate cases of human trafficking and migrant smuggling. The NBTIP was composed of 16 officers from the police, gendarmerie, and civil security. In November 2022, the government established an NBTIP on Anjouan. The government, both independently and in partnership with international organizations, trained members of the NBTIPs, police, gendarmerie, immigration authorities, and other officials on victim-centered investigation techniques, child-friendly interviewing, victim identification, and relevant trafficking laws. Comorian authorities collaborated with the Governments of Madagascar and Tanzania on trafficking cases. The government continued to pursue collaboration with the Government of France to investigate trafficking cases on Mayotte; however, reciprocation of these efforts by French officials remained limited.

The government increased victim protection efforts. The government identified 14 trafficking victims in 2022 and referred all victims to care, compared with eight victims identified and referred to care in 2021. Of the 14 victims identified, traffickers exploited 10 in labor trafficking and four in both labor and sex trafficking; traffickers exploited three in Comoros and 11 abroad in Oman and Tanzania. All 14 victims were female; 12 were adults, and two were children; and 12 victims were Comorian nationals, while two were foreign nationals from Cameroon. The government, in partnership with an international organization, continued to disseminate and provide training on its SOPs for victim identification to law enforcement – including the newly established NBTIPs on Grande Comore and Anjouan – and other government stakeholders. Using the SOPs, the government continued to increase efforts to screen vulnerable populations, including foreign migrants and victims of abuse, for trafficking indicators. The government, in partnership with an international organization, finalized and formally adopted an NRM to complement the victim identification SOPs and refer victims to protection services.

The government partnered with international organizations and local NGOs to provide services to all 14 identified victims, including temporary housing, medical care, counseling, job training, and repatriation assistance. The quality of care and availability of services on Anjouan and Mohéli remained limited compared to those available on Grande Comore. The government continued to provide financial support, including salaries for employees and office space, to listening centers (Service d’Ecoute). The listening centers, with assistance from civil society, 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. The listening centers continued to provide assistance to victims of various forms of abuse, some of whom may have been trafficking victims. There was limited shelter availability in the country to assist trafficking victims, which often resulted in government officials or community members providing temporary shelter to victims in their personal homes. The government remained without a systemic victim-witness assistance program. The government did not provide legal alternatives to removal of foreign trafficking victims to countries where they might face hardship or retribution; however, in practice, the government provided foreign victims the same benefits as Comorian nationals. Comorian law allowed victims of crime, including trafficking, to receive restitution from the government or from traffickers through civil suits.

The government maintained efforts to prevent trafficking. The government established the NCTIP to lead the government’s anti-trafficking efforts, replacing the Anti-Trafficking Task Force. The government appointed representatives from relevant government agencies, listening centers, and civil society to NCTIP. NCTIP coordinated on trafficking cases and held its first formal meeting in February 2023; however, the government did not allocate dedicated funding to NCTIP. The government remained without an anti-trafficking NAP; however, it continued to reference the 2020 action plan, which delegated specific, short-term actions to relevant government agencies. The government, in partnership with international organizations, conducted awareness campaigns targeting local authorities, religious leaders, and the general public on Grande Comore; the government did not report conducting awareness campaigns on Anjouan or Mohéli. The government continued to fund two toll-free emergency lines on Grande Comore, Anjouan, and Mohéli, which were used to report crimes to the listening centers; however, the government did not track call data related to potential trafficking victims.

The Ministry of Labor employed three labor inspectors to enforce child labor laws; however, the inspectors did not receive training on relevant trafficking laws and did not receive sufficient operational resources to conduct proactive labor inspections of informal work sites, where children were especially vulnerable to forced labor. Labor inspectors responded to complaints across Comoros, primarily in hotels, restaurants, and the construction sector; however, the government did not report efforts to identify potential trafficking crimes during these inspections. There were no formal labor recruitment agencies in the country, and the government remained without effective policies or laws to monitor labor migration. The government did not prohibit worker-paid recruitment fees. Unregistered recruitment agencies continued to operate and facilitate recruitment through informal channels, and some agents used predatory tactics, including charging recruitment fees and fraudulent job advertising. A 2012 ban on labor migration to several Gulf states the government considered high-risk remained in place; the policy restricted Comorians’ access to safe and legal migration, subsequently increasing their vulnerability to trafficking. In 2022, police reported arresting one individual acting as an informal, fraudulent recruiter. The government began drafting bilateral labor agreements with the Governments of Kuwait, Madagascar, Oman, and the United Arab Emirates to enhance protections for migrant workers. An informal task force continued to oversee working conditions of Comorians living and working abroad, including assisting in the repatriation of trafficking victims. 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, particularly from rural areas, in domestic servitude and sex trafficking on Grande Comore and Anjouan. Traffickers on Anjouan may subject children, some of whom were left behind by parents in pursuit of economic opportunities in other countries, to labor trafficking in domestic service, roadside and market vending, baking, fishing, and agriculture. Families living in rural areas, 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 domestic servitude and sex trafficking. 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 labor trafficking as field hands or domestic servants to supplement payment for instruction. The estimated 3,000 to 4,000 unaccompanied Comorian children on Mayotte are especially vulnerable to domestic servitude and sex trafficking. Traffickers exploit Comorian adults in forced labor in agriculture, construction, and domestic work on Mayotte and continental Africa. Traffickers exploit Comorian women in domestic servitude in Gulf states, particularly Oman. Traffickers exploit Malagasy women and girls in domestic servitude and sex trafficking in Comoros. Economic migrants and asylum-seekers from other African countries, including Burundi, Cameroon, the Democratic Republic of the Congo, Madagascar, Tanzania, and Uganda, attempting to reach Europe via Mayotte are increasingly transiting Comoros; traffickers often exploit these migrants in labor or sex trafficking in transit or on Mayotte.