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Is Crypto Legal in Micronesia?

No Guidance Risk: unknown Updated 6 days ago Research: Grade A

Overview

Micronesia, specifically the Federated States of Micronesia (FSM), is a member of the Asia/Pacific Group on Money Laundering (APG) and is committed to implementing the Financial Action Task Force (FATF) Recommendations. While the FSM's regulatory framework for virtual assets is still evolving, its AML/CFT obligations extend to virtual asset service providers (VASPs) based on international standards and its existing general AML/CFT legislation.

VASP/CASP Registry: None — no registry data for this jurisdiction

Regulatory Bodies

FSM Banking Commission

Ongoing Development: The APG report indicates that the FSM Banking Commission was in the process of developing a VASP Code of Practice at the time of the report (July 2022), which would further detail practical guidance for compliance.

Primary Legislation

Law / Regulation Year Scope
Likely Implicit Application of Common Law Principles Likely Implicit Application of Common Law Principles: Due to historical ties and influence, the FSM's legal system often draws from U.S. common law principles.
Application of General Securities Law (if applicable) Application of General Securities Law (if applicable): If a token were classified as a security under existing FSM law, then the issuer would theoretically be subject to any existing general securities registration and disclosure…

Licensing Requirements

80%

No Explicit Test: The FSM does not have an explicit "Howey Test equivalent" for cryptocurrency tokens.

licensingno-explicit-test-the-fsm
Verified Aug 30, 2026 Report Issue
80%

Likely Implicit Application of Common Law Principles: Due to historical ties and influence, the FSM's legal system often draws from U.S. common law principles. Therefore, if a court or regulator in the FSM were to assess whether a crypto token constitutes a security, it would most likely implicitly apply a functional test very similar to the U.S. Howey Test.

licensinglikely-implicit-application-of-common
Verified Aug 30, 2026 Report Issue
80%

The Howey Test (U.S. Standard): An "investment contract" (and thus a security) exists if there is:

licensingthe-howey-test-us-standard
Verified Aug 30, 2026 Report Issue
80%

An investment of money (or other assets).

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Verified Aug 30, 2026 Report Issue
80%

With an expectation of profits.

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Verified Aug 30, 2026 Report Issue
80%

To be derived solely from the efforts of others.

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Verified Aug 30, 2026 Report Issue
80%

This test is widely adopted or mirrored in various common law jurisdictions globally to determine what constitutes an "investment contract" or "security."

licensingthis-test-is-widely-adopted
Verified Aug 30, 2026 Report Issue
80%

Investment/Security Tokens: Tokens that represent ownership in a company, a share of profits, fractional ownership of real assets, or provide rights akin to traditional securities (e.g., dividends, voting rights) would almost certainly be considered securities. This would include most tokens issued through Initial Coin Offerings (ICOs) where the primary purpose is capital raising from investors expecting a return from the issuer's efforts.

licensinginvestmentsecurity-tokens-tokens-that-represent
Verified Aug 30, 2026 Report Issue
80%

Utility Tokens: Tokens intended to provide access to a product or service within an ecosystem might not be considered securities if they have immediate utility and their primary value is derived from that use, rather than from speculative appreciation based on the efforts of others. However, many "utility tokens" have been found to be securities if they are marketed as investments, lack immediate functionality, or if their value is primarily speculative based on the development team's efforts.

licensingutility-tokens-tokens-intended-to
Verified Aug 30, 2026 Report Issue
80%

Payment Tokens (e.g., Bitcoin, stablecoins): Tokens primarily designed and used as a medium of exchange or store of value, without a "common enterprise" or expectation of profits from the efforts of others (beyond general market forces), are generally less likely to be considered securities.

licensingpayment-tokens-eg-bitcoin-stablecoins
Verified Aug 30, 2026 Report Issue
80%

No Specific Crypto Requirements: There are no specific registration or exemption requirements published by the FSM for token issuers.

licensingno-specific-crypto-requirements-there
Verified Aug 30, 2026 Report Issue
80%

Application of General Securities Law (if applicable): If a token were classified as a security under existing FSM law, then the issuer would theoretically be subject to any existing general securities registration and disclosure requirements. Given the nascent nature of crypto regulation in the FSM, it is highly improbable that existing securities laws would be practically adaptable to digital asset offerings without explicit guidance or amendments. Issuers would likely find themselves in a regulatory vacuum or an unworkable compliance scenario.

licensingapplication-of-general-securities-law
Verified Aug 30, 2026 Report Issue
80%

No Specific Crypto Rules: Similar to issuance, there are no specific rules governing the secondary trading of cryptocurrency tokens in the FSM.

licensingno-specific-crypto-rules-similar
Verified Aug 30, 2026 Report Issue
80%

Application of General Securities Trading Law (if applicable): If a token were deemed a security, secondary trading would technically be subject to general rules for securities exchanges, broker-dealers, and market conduct. However, these rules are not designed for decentralized or global crypto trading platforms, making practical application extremely difficult without tailored legislation.

licensingapplication-of-general-securities-trading
Verified Aug 30, 2026 Report Issue
80%

No Publicly Available Examples: There are no publicly available enforcement examples or legal cases specifically related to cryptocurrency securities violations in the Federated States of Micronesia. This lack of enforcement data underscores the absence of a clear regulatory framework in this area.

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Verified Aug 30, 2026 Report Issue
80%

The classification of cryptocurrency tokens as securities.

licensingthe-classification-of-cryptocurrency-tokens
Verified Aug 30, 2026 Report Issue
80%

Specific legal tests for determining if a crypto token is a security.

licensingspecific-legal-tests-for-determining
Verified Aug 30, 2026 Report Issue
80%

Registration, licensing, or exemption requirements for crypto token issuers or exchanges.

licensingregistration-licensing-or-exemption-requirements
Verified Aug 30, 2026 Report Issue
80%

Secondary trading rules for crypto assets.

licensingsecondary-trading-rules-for-crypto
Verified Aug 30, 2026 Report Issue
80%

FSM National Government Website: This is the primary portal for government information.

licensingfsm-national-government-website-this
Verified Aug 30, 2026 Report Issue
80%

FSM Department of Finance & Administration: This department oversees financial matters but has not published crypto-specific guidance.

licensingfsm-department-of-finance-administration
Verified Aug 30, 2026 Report Issue
80%

FSM National Code: The compilation of FSM national laws. While it contains general financial and banking laws, it does not specifically address digital assets or their classification as securities.

licensingfsm-national-code-the-compilation
Verified Aug 30, 2026 Report Issue

(17 more unverified fact(s) )

AML/KYC Requirements

No verified facts yet. 38 unverified fact(s) in explorer

Travel Rule

70%

Micronesia (Federated States of Micronesia, FSM) has no specific cryptocurrency or digital asset legislation, and no dedicated regulatory authority for virtual assets has been established as of 2025–2026 FSM Government – FSM Government

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70%

No licensing or registration regime exists for cryptocurrency businesses, and no entity has been licensed to conduct virtual asset activities in the jurisdiction FSM Government – FSM Government

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70%

The country's financial regulatory framework is limited to traditional banking oversight under the Department of Finance and Administration, which has issued no guidance on digital assets FSM Government – FSM Government

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70%

Micronesia's foreign affairs capacity includes banking, commercial, and economic relations conducted in its own name, but no virtual asset treaty or international agreement has been concluded The Compact of Free Association between the United States of America and the Federated States of Micronesia

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70%

The practical reality is that there is no operational pathway for crypto businesses to achieve regulatory compliance, and no travel-rule implementation exists for virtual asset transfers

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50%

The FSM Social Security Administration, the FSM Development Bank, and the National Fisheries Corporation are the only financial-adjacent public bodies listed, and none has jurisdiction over digital asset AML compliance FSM Government – FSM Government

travel-rulethe-fsm-social-security-administration
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70%

No enforcement actions, penalties, fines, arrests, or cases involving cryptocurrency or digital asset businesses have been reported by the FSM Government FSM Government – FSM Government

travel-ruleno-enforcement-actions-penalties-fines
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70%

The Department of Justice has not published any virtual asset-related enforcement actions, and no court rulings on digital assets from the FSM judiciary are available FSM Government – FSM Government

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70%

No administrative fines or sanctions have been imposed on any entity for unlicensed crypto activity, because no licensing regime exists to violate FSM Government – FSM Government

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70%

The FSM Government's news archive, covering events through August 2026, contains no reports of cryptocurrency-related prosecutions or regulatory actions FSM Government – FSM Government

travel-rulethe-fsm-governments-news-archive
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70%

The U.S. Customs and Border Protection FOIA notice is unrelated to FSM domestic enforcement and does not apply to Micronesian crypto regulation Freedom of Information Act (FOIA) | U.S. Customs and Border Protection

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Tax Reporting

Tax reporting data collection in progress.

Custody Requirements

Custody regulation data collection in progress.

Stablecoin Regulation

98%

No specific classification: Stablecoins are not explicitly classified as e-money, payment tokens, or securities under any specific FSM legislation.

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Verified Aug 25, 2026 Report Issue
95%

E-money/Payment Tokens: If a stablecoin were to function purely as a digital representation of fiat currency for payment purposes, it might, in theory, be viewed through the lens of general payment services or e-money regulations, if such specific regulations existed outside of traditional banking. However, FSM's framework primarily focuses on licensed deposit-taking institutions.

stablecoine-moneypayment-tokens-if-a-stablecoin
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Verified Aug 25, 2026 Report Issue
100%

Securities: If a stablecoin were structured to represent an investment, a share in profits, or carried specific rights that qualify it as an investment contract, it could potentially fall under broader securities principles, although FSM's securities laws are less developed compared to major economies.

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Verified Aug 25, 2026 Report Issue
100%

Commodity/Property: In the absence of specific financial instrument definitions, stablecoins could potentially be treated as digital property or commodities, subject to general contract and property law.

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Verified Aug 25, 2026 Report Issue
95%

No specific reserve requirements: Given the absence of specific stablecoin regulation, there are no statutory reserve requirements for stablecoin issuers in the FSM.

stablecoinno-specific-reserve-requirements-given
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Verified Aug 25, 2026 Report Issue
70%

General principles: If an entity were to issue a stablecoin that in any way resembled a deposit-taking activity, it would likely fall under the FSM Banking Act and be subject to the reserve requirements for licensed financial institutions. However, this would entail meeting the full requirements of a traditional bank.

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Verified Aug 27, 2026 Report Issue
40%

No specific stablecoin issuer license: There is no distinct licensing regime for stablecoin issuers in the FSM.

stablecoinno-specific-stablecoin-issuer-license
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85%

Existing financial institution licensing: Any entity wishing to operate in a manner that resembles banking, money transmission, or other regulated financial services (e.g., taking deposits, transmitting funds on behalf of others) would be subject to the existing licensing requirements under the FSM Banking Act (Title 30 of the FSM National Code). Obtaining a banking license is a complex and capital-intensive process designed for traditional financial institutions.

stablecoinexisting-financial-institution-licensing-any
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Verified Aug 27, 2026 Report Issue
90%

The FSM National Code, Title 30, Chapter 1 has been largely repealed (except for Section 122) by PL 8-47; the current regulatory framework for banks and financial institutions is administered by the FSM Banking Board under its statutes and regulations, not comprehensively contained in Title 30.

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Verified Aug 27, 2026 Report Issue
90%

Reference (via PacLII): https://www.paclii.org/fm/legis/fsm_act/fsmc1980362/ (This links to the FSM Code via the Pacific Islands Legal Information Institute, which is a common resource for FSM laws. You would navigate to Title 30).

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Verified Aug 27, 2026 Report Issue
80%

While not specific to stablecoins, any activity that falls within the scope of "banking business" or "financial institution" as defined in this Act would require a license from the FSM Banking Board.

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Verified Aug 29, 2026 Report Issue
40%

No specific statutory redemption rights: Since there are no specific stablecoin laws, there are no explicit statutory provisions governing redemption rights for stablecoin holders in the FSM.

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40%

Contractual basis: Redemption rights would primarily be governed by the terms and conditions agreed upon between the stablecoin issuer and the holder (i.e., the stablecoin's whitepaper, user agreement, or other contractual documents). Enforcement would rely on general contract law.

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40%

None: As there are no specific rules for stablecoins in general, there are absolutely no specific regulations or prohibitions concerning algorithmic stablecoins in the FSM.

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40%

No current interaction: The Federated States of Micronesia has not publicly announced any plans, research, or initiatives regarding a Central Bank Digital Currency (CBDC). Given its economic size and resources, it is highly unlikely to be pursuing a CBDC in the near future. Therefore, there is no existing or anticipated regulatory framework for how stablecoins would interact with a Micronesian CBDC.

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Securities Classification

Securities classification data collection in progress.

Sanctions & Restrictions

Sanctions data collection in progress.

Enforcement Actions

No verified facts yet. 13 unverified fact(s) in explorer

Regulatory Forecast

high confidence

Likely enforcement action expected around 2026-07-14

Based on 81 historical regulatory events for Micronesia, averaging every 2 days, with increasing regulatory activity.

Trend: Increasing Data points: 81 Avg frequency: 2 days Last action: 2026-07-12

Recent Updates

2026-04-13(4 months ago)
high FM

None identified for cryptocurrencies. General financial oversight may fall under bodies like the FSM Banking Board, b...

None identified for cryptocurrencies. General financial oversight may fall under bodies like the FSM Banking Board, but no crypto-specific authority is mentioned in available sources.

2026-04-22(4 months ago)
high FM

No bans or endorsements exist, unlike neighbors (e.g., Palau supports use; Marshall Islands recognizes DAOs).

No bans or endorsements exist, unlike neighbors (e.g., Palau supports use; Marshall Islands recognizes DAOs).

2026-04-22(4 months ago)
high FM

None identified for crypto: No central bank, financial authority, or agency oversees virtual assets, as confirmed...

None identified for crypto: No central bank, financial authority, or agency oversees virtual assets, as confirmed by multiple trackers noting the absence of regulation.

2026-04-22(4 months ago)
high FM

FSM Banking Act 1980 (Title 29 of the FSM Code): This act provides the general legal framework for banking and fi...

FSM Banking Act 1980 (Title 29 of the FSM Code): This act provides the general legal framework for banking and financial services. While it does not specifically regulate VASPs, any VASP that offers services resembling traditional financial services (e.g., custody of fiat currency, remittances) might fall under the purview or interpretation of this act or require specific licensing.

2026-04-22(4 months ago)
medium FM

Federated States of Micronesia (FSM) Financial Intelligence Unit (FIU): This is the primary authority responsible...

Federated States of Micronesia (FSM) Financial Intelligence Unit (FIU): This is the primary authority responsible for anti-money laundering and combating the financing of terrorism (AML/CFT) in the FSM. While they address financial crimes, specific crypto enforcement requires a clear regulatory basis for virtual assets.

2026-04-22(4 months ago)
medium FM

Investment/Security Tokens: Tokens that represent ownership in a company, a share of profits, fractional ownershi...

Investment/Security Tokens: Tokens that represent ownership in a company, a share of profits, fractional ownership of real assets, or provide rights akin to traditional securities (e.g., dividends, voting rights) would almost certainly be considered securities. This would include most tokens issued through Initial Coin Offerings (ICOs) where the primary purpose is capital raising from investors expecting a return from the issuer's efforts.

2026-04-22(4 months ago)
medium FM

No Specific Crypto Requirements: There are no specific registration or exemption requirements published by the FS...

No Specific Crypto Requirements: There are no specific registration or exemption requirements published by the FSM for token issuers.

2026-04-22(4 months ago)
medium FM

Application of General Securities Law (if applicable): If a token were classified as a security under existing FS...

Application of General Securities Law (if applicable): If a token were classified as a security under existing FSM law, then the issuer would theoretically be subject to any existing general securities registration and disclosure requirements. Given the nascent nature of crypto regulation in the FSM, it is highly improbable that existing securities laws would be practically adaptable to digital asset offerings without explicit guidance or amendments. Issuers would likely find themselves in a regulatory vacuum or an unworkable compliance scenario.

2026-04-22(4 months ago)
medium FM

No Publicly Available Examples: There are no publicly available enforcement examples or legal cases specifically ...

No Publicly Available Examples: There are no publicly available enforcement examples or legal cases specifically related to cryptocurrency securities violations in the Federated States of Micronesia. This lack of enforcement data underscores the absence of a clear regulatory framework in this area.

enforcement View article →
2026-04-22(4 months ago)
medium FM

FSM Department of Finance & Administration: This department oversees financial matters but has not published cryp...

FSM Department of Finance & Administration: This department oversees financial matters but has not published crypto-specific guidance.

2026-04-22(4 months ago)
high FM

FSM National Code: The compilation of FSM national laws. While it contains general financial and banking laws, it...

FSM National Code: The compilation of FSM national laws. While it contains general financial and banking laws, it does not specifically address digital assets or their classification as securities.

2026-04-22(4 months ago)
high FM

General principles: If an entity were to issue a stablecoin that in any way resembled a deposit-taking activity, ...

General principles: If an entity were to issue a stablecoin that in any way resembled a deposit-taking activity, it would likely fall under the FSM Banking Act and be subject to the reserve requirements for licensed financial institutions. However, this would entail meeting the full requirements of a traditional bank.

2026-04-22(4 months ago)
medium FM

No specific stablecoin issuer license: There is no distinct licensing regime for stablecoin issuers in the FSM.

No specific stablecoin issuer license: There is no distinct licensing regime for stablecoin issuers in the FSM.

2026-04-22(4 months ago)
high FM

Existing financial institution licensing: Any entity wishing to operate in a manner that resembles banking, money...

Existing financial institution licensing: Any entity wishing to operate in a manner that resembles banking, money transmission, or other regulated financial services (e.g., taking deposits, transmitting funds on behalf of others) would be subject to the existing licensing requirements under the FSM Banking Act (Title 30 of the FSM National Code). Obtaining a banking license is a complex and capital-intensive process designed for traditional financial institutions.

2026-04-22(4 months ago)
medium FM

Contractual basis: Redemption rights would primarily be governed by the terms and conditions agreed upon between ...

Contractual basis: Redemption rights would primarily be governed by the terms and conditions agreed upon between the stablecoin issuer and the holder (i.e., the stablecoin's whitepaper, user agreement, or other contractual documents). Enforcement would rely on general contract law.

enforcement View article →
2026-04-22(4 months ago)
high FM

No current interaction: The Federated States of Micronesia has not publicly announced any plans, research, or ini...

No current interaction: The Federated States of Micronesia has not publicly announced any plans, research, or initiatives regarding a Central Bank Digital Currency (CBDC). Given its economic size and resources, it is highly unlikely to be pursuing a CBDC in the near future. Therefore, there is no existing or anticipated regulatory framework for how stablecoins would interact with a Micronesian CBDC.

2026-04-22(4 months ago)
high FM

Undefined/Indirect: The FSM currently lacks a comprehensive and explicit regulatory framework specifically for cr...

Undefined/Indirect: The FSM currently lacks a comprehensive and explicit regulatory framework specifically for cryptocurrencies and virtual assets. The approach can be characterized as largely undefined or operating in a "grey area."

enforcement View article →
2026-04-22(4 months ago)
high FM

No Explicit Ban: There is no public record of a ban on cryptocurrencies or virtual assets in the FSM.

No Explicit Ban: There is no public record of a ban on cryptocurrencies or virtual assets in the FSM.

2026-04-22(4 months ago)
high FM

Individual Trading: There is no explicit ban on individuals trading cryptocurrencies within the FSM. Citizens are...

Individual Trading: There is no explicit ban on individuals trading cryptocurrencies within the FSM. Citizens are generally free to buy, sell, and hold cryptocurrencies using international platforms.

2026-04-22(4 months ago)
high FM

Ongoing Development: The APG report indicates that the FSM Banking Commission was in the process of developing a ...

Ongoing Development: The APG report indicates that the FSM Banking Commission was in the process of developing a VASP Code of Practice at the time of the report (July 2022), which would further detail practical guidance for compliance.

2026-04-22(4 months ago)
medium FM

License Revocation/Suspension: VASPs failing to comply may have their registration or license suspended or revoke...

License Revocation/Suspension: VASPs failing to comply may have their registration or license suspended or revoked, effectively preventing them from operating.

2026-04-22(4 months ago)
high FM

Supervisory Actions: The FSM Banking Commission can impose various administrative sanctions and remedial actions.

Supervisory Actions: The FSM Banking Commission can impose various administrative sanctions and remedial actions.

enforcement View article →
2026-04-22(4 months ago)
high FM

Source: General knowledge of AML/CFT legislation and implied from the APG report's assessment of FSM's overall AM...

Source: General knowledge of AML/CFT legislation and implied from the APG report's assessment of FSM's overall AML/CFT framework effectiveness and sanctions regime (though not specifically itemized for Travel Rule in the provided excerpt). Accessing the full FSM AML/CFT Act 2011 (as amended 2020) would provide precise details. Finding an online, publicly accessible version of the consolidated FSM AML/CFT Act with 2020 amendments can be challenging for smaller jurisdictions.

2026-04-30(4 months ago)
medium FM

The FSM enacted the Anti-Money Laundering and Counter-Terrorist Financing Act 2011 (as amended 2020), which serve...

The FSM enacted the Anti-Money Laundering and Counter-Terrorist Financing Act 2011 (as amended 2020), which serves as the primary legal framework for AML/CFT compliance. The 2020 amendments specifically addressed FATF Recommendations on Virtual Assets (VAs) and Virtual Asset Service Providers (VASPs), including Travel Rule obligations, requiring VASPs to register, be licensed, and comply with AML/CFT obligations APG Enhanced Follow-Up Report

2026-04-30(4 months ago)
high FM

The FSM Banking Act 1980 (Title 29 of the FSM Code) provides the general legal framework for banking and financia...

The FSM Banking Act 1980 (Title 29 of the FSM Code) provides the general legal framework for banking and financial services. While it does not specifically regulate VASPs, any VASP that offers services resembling traditional financial services (e.g., custody of fiat currency, remittances) might fall under the purview or interpretation of this act or require specific licensing FSM FIU Official Site

2026-04-30(4 months ago)
medium FM

Identification and Verification for Natural Persons: VASPs must obtain and verify identity using reliable, indepe...

Identification and Verification for Natural Persons: VASPs must obtain and verify identity using reliable, independent source documents, data, or information such as government-issued ID, passport, or driver's license FSM FIU Official Site

2026-04-30(4 months ago)
medium FM

Finding an online, publicly accessible version of the consolidated FSM AML/CFT Act with 2020 amendments can be challe...

Finding an online, publicly accessible version of the consolidated FSM AML/CFT Act with 2020 amendments can be challenging for smaller jurisdictions. The APG report serves as the most reliable publicly available source for understanding FSM's regulatory stance on VASPs and Travel Rule obligations APG Enhanced Follow-Up Report

2026-04-30(4 months ago)
high FM

The interaction between the Anti-Money Laundering and Counter-Terrorist Financing Act 2011 (as amended 2020) and the ...

The interaction between the Anti-Money Laundering and Counter-Terrorist Financing Act 2011 (as amended 2020) and the Banking Act 1980 creates a layered regulatory approach: VASPs offering services resembling traditional banking may require dual compliance, while the AML/CFT Act provides the specific virtual asset framework FSM FIU Official Site

2026-04-30(4 months ago)
high FM

The Federated States of Micronesia (FSM) operates under a financial regulatory system primarily governed by Title 3...

The Federated States of Micronesia (FSM) operates under a financial regulatory system primarily governed by Title 30 of the FSM National Code, which addresses banking and financial institutions. The FSM Banking Act (codified in Title 30) was most recently updated in 2014, as reflected in the version available through the Pacific Islands Legal Information Institute FSM National Code Title 30 via PacLII. This 2014 update predates the widespread emergence of stablecoins and digital assets, meaning the law contains no specific provisions for these innovations.

2026-04-30(4 months ago)
high FM

The FSM Banking Board, established under Section 303 of Title 30, serves as the primary financial regulator, but has ...

The FSM Banking Board, established under Section 303 of Title 30, serves as the primary financial regulator, but has issued no public guidance, press releases, or rulemakings related to stablecoins as of April 2026 FSM Banking Board Official Website.

2026-04-30(4 months ago)
high FM

World Bank Pacific Financial Regulation Report 2023

World Bank Pacific Financial Regulation Report 2023

2026-04-30(4 months ago)
high FM

FSM Banking Board Official Website

FSM Banking Board Official Website

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