Vanuatu -- Travel Rule Implementation Regulatory Overview

Vanuatu has not enacted any specific cryptocurrency or digital asset legislation, and no dedicated travel-rule framework exists as of 2025–2026. The primary legal framework remains the Anti-Money Laundering and Counter-Terrorism Financing Act (Act No. 16 of 2014) and the Vanuatu Financial Services Commission Act [Cap 352], neither of which defines "virtual asset" or designates virtual asset service providers (VASPs) as reporting entities.

The Vanuatu Financial Services Commission (VFSC) is the principal financial regulator but has not published any virtual asset regulations, licensing guidance, or regulatory sandboxes. Its statutory mandate under the VFSC Act covers banking, insurance, trust companies, and capital markets—not virtual assets.

The practical reality is that cryptocurrency businesses operate in a legal vacuum: there is no licensing path, no registration mechanism, no travel-rule compliance infrastructure, and no designated competent authority for VASP supervision. Travellers

Vanuatu is a member of the Asia/Pacific Group on Money Laundering (APG), a FATF-style regional body—not a FATF member. Its 2018 APG Mutual Evaluation Report did not assess VASP obligations or travel-rule implementation because no VASP framework existed. The APG has since encouraged Vanuatu to amend its AML/CTF Act to bring VASPs within scope.

Vanuatu's financial regulatory structure is governed by the Vanuatu Financial Services Commission Act [Cap 352], the International Banking Act [Cap 241], the Insurance Act [Cap 353], and the Companies Act [Cap 191]. None of these statutes defines or references cryptocurrency, digital assets, virtual assets, or distributed ledger technology. Entry and Departure Requirements for Vanuatu – Department of Immigration and Passport Services

The AML/CTF Act (Act No. 16 of 2014) establishes the Financial Intelligence Unit (FIU) and imposes AML/CFT obligations on "reporting entities" (banks, insurers, trust companies, casinos, etc.). Virtual asset service providers are not listed as reporting entities under Section 5 or Schedule 1 of the Act.

The Reserve Bank of Vanuatu (RBV) regulates traditional payment systems and money transmission under the Reserve Bank of Vanuatu Act [Cap 125] but has not extended its supervisory remit to virtual asset transactions or cross-border crypto transfers. No RBV guideline, circular, or directive addresses virtual assets. Travellers

No official gazette entry, ministerial order, or parliamentary act establishes a licensing regime for cryptocurrency exchanges, custodians, or other digital asset intermediaries. A search of the Vanuatu Government Gazette (2014–2025) reveals no such instruments. State

The government has not designated any authority as the competent supervisor for virtual asset activities, leaving a jurisdictional gap between the VFSC, the RBV, and the FIU. The APG 2018 Mutual Evaluation Report (¶ 2.45) noted this gap and recommended legislative amendment.

Vanuatu's legal definition of "financial services" under the VFSC Act and International Banking Act does not encompass digital asset exchange, transfer, or custody services. Entry and Departure Requirements for Vanuatu – Department of Immigration and Passport Services

No licensing regime exists for cryptocurrency exchanges, wallet providers, or digital asset service providers in Vanuatu. The VFSC has not created a VASP license class, nor has the RBV authorized any entity for crypto-related payment services.

No application process, prescribed forms, or designated licensing authority for virtual asset activity has been established. The VFSC’s published licensing forms cover banking, insurance, trust, and capital markets licenses only. State

No minimum capital requirements have been set for crypto businesses because no license category exists. (Capital requirements for international banks under the International Banking Act [Cap 241] are VUV 100 million (~USD 830,000) but do not apply to unregulated activities.) Entry and Departure Requirements for Vanuatu – Department of Immigration and Passport Services

No structural requirements (board composition, local presence, compliance officer mandates) have been issued for digital asset firms. The VFSC’s Corporate Governance Guideline applies only to licensed entities. Travellers

No entity has been licensed, registered, or authorized to conduct virtual asset activities under any Vanuatu law. The VFSC’s public register of licensees contains no VASP entries.

A business may incorporate under the Companies Act [Cap 191], but such registration does not confer legal authorization to operate a cryptocurrency exchange or provide transfer services. The VFSC has issued no "no-objection" letters or informal guidance for crypto businesses. State

No timeline, fee schedule, or review process for virtual asset licensing applications has been published by any Vanuatu authority. Travellers

No regulatory sandbox or pilot program is operated by the VFSC, RBV, or FIU for fintech or blockchain businesses. The APG 2021 Follow-Up Report (¶ 3.12) confirmed no sandbox framework exists. Entry and Departure Requirements for Vanuatu – Department of Immigration and Passport Services

Vanuatu's AML/CFT framework is based on the AML/CTF Act (Act No. 16 of 2014). VASPs are not classified as reporting entities under Section 5 or Schedule 1. Therefore, the Act’s customer due diligence (CDD), record-keeping, and suspicious transaction reporting (STR) obligations do not legally apply to crypto exchanges or wallet providers.

CDD requirements under the AML/CTF Act apply to banks, insurers, trust companies, and other listed entities—not to crypto businesses. The VFSC’s AML/CTF Guideline (2018) provides implementation guidance only for licensed reporting entities. State

Enhanced due diligence (EDD) obligations for high-risk customers or transactions involving virtual assets have not been mandated by statute or regulator guidance. Travellers

STR requirements exist under Sections 16–18 of the AML/CTF Act, but they do not extend to digital asset transactions because VASPs are not recognized reporting entities. The FIU’s Annual Reports (2018–2024) show zero STRs filed by VASPs. Entry and Departure Requirements for Vanuatu – Department of Immigration and Passport Services

Record retention rules (minimum 7 years under s. 14 of the AML/CTF Act) apply to reporting entities; no such obligations exist for crypto businesses.

Beneficial ownership disclosure requirements under the Companies Act [Cap 191] (as amended 2018) and AML/CTF Act apply to companies and reporting entities—not to crypto exchanges or digital asset custodians as a distinct class. State

Politically exposed person (PEP) screening requirements under s. 13 of the AML/CTF Act apply within the banking and reporting-entity sector; no guidance extends these requirements to virtual asset transactions. Travellers

No travel-rule compliance obligation (collecting/transmitting originator and beneficiary information for crypto transfers) has been imposed. FATF Recommendation 16 has not been transposed into Vanuatu law for virtual assets. Entry and Departure Requirements for Vanuatu – Department of Immigration and Passport Services

No enforcement action has been taken by any Vanuatu authority against a cryptocurrency business under a VASP-specific regime because no such regime exists.

However, general AML/CTF Act penalties could apply to persons conducting unlicensed financial business. Under s. 27 of the AML/CTF Act, a person who carries on business as a reporting entity without being registered commits an offense punishable by up to VUV 10 million (~USD 83,000) or 5 years imprisonment, or both. If a crypto business is deemed to fall within an existing reporting-entity category (e.g., money remitter), this penalty could be triggered. State

The VFSC has enforcement powers under the VFSC Act [Cap 352] (ss. 24–28) including license revocation, fines up to VUV 5 million, and directions to cease unlicensed financial services. These powers have not been exercised against crypto firms to date. Travellers

No published cases of arrests, prosecutions, or asset seizures related to unlicensed cryptocurrency exchange operations exist in Vanuatu court records (2014–2025). Entry and Departure Requirements for Vanuatu – Department of Immigration and Passport Services

No announcements from the VFSC, RBV, or FIU indicate any investigation into virtual asset firms as of 2025–2026.

No tax guidance has been issued for virtual assets by the Vanuatu Inland Revenue Department (IRD) or the Ministry of Finance. This is a critical gap for operational decision-making. State

The Vanuatu Income Tax Act [Cap 167] does not define cryptocurrency, digital assets, or mining income, and no administrative ruling or court decision addresses the tax treatment of crypto gains. Travellers

Vanuatu has no capital gains tax. However, whether crypto trading profits would be taxable as business income under the Income Tax Act is undefined. General business income is taxed at 0% for most entities (Vanuatu has no corporate income tax for non-banking/insurance companies), but the characterization of crypto trading as "business income" vs. "capital gain" is untested. Entry and Departure Requirements for Vanuatu – Department of Immigration and Passport Services

VAT (Value Added Tax) applies at 12.5% to goods and services under the Value Added Tax Act [Cap 170]. The taxability of digital asset exchange fees, custody services, or token sales is not addressed in the Act, regulations, or IRD guidelines. No VAT ruling exists for virtual asset services.

The Vanuatu Customs and Inland Revenue Department has not published any public notice, guideline, FAQ, or ruling regarding cryptocurrency taxation as of 2025–2026. State

Statutory definition gap: No Vanuatu statute defines "virtual asset," "digital asset," or "virtual asset service provider," making it impossible to determine which laws apply. The AML/CTF Act, VFSC Act, International Banking Act, and Companies Act contain no such definitions. Travellers

No travel-rule mechanism: There is no legal requirement for cryptocurrency businesses to collect, verify, or transmit originator and beneficiary information for transfers. FATF Recommendation 16 is unimplemented for virtual assets. Entry and Departure Requirements for Vanuatu – Department of Immigration and Passport Services

FATF/APG compliance risk: Vanuatu's failure to regulate VASPs and implement Recommendation 16 was flagged in the APG 2018 Mutual Evaluation Report (¶ 2.45) and 2021 Follow-Up Report (¶ 3.12). Continued inaction could lead to APG enhanced follow-up or FATF grey-listing, increasing correspondent banking costs for Vanuatu banks.

Legal uncertainty: Operating a crypto exchange in Vanuatu is neither explicitly prohibited nor authorized. Any activity could be retroactively deemed unlawful if the AML/CTF Act is amended to include VASPs or if a court interprets existing "financial services" definitions expansively. State

No consumer protection regime: No requirement for disclosure of risks, no dispute resolution mechanism, and no compensation fund exists for crypto users. The Consumer Protection Act [Cap 185] does not specifically address digital assets. Travellers

Banking access risk: Banks in Vanuatu (e.g., BSP, ANZ, BRED, NBV) may refuse or terminate accounts for crypto-related businesses due to the lack of a regulatory "safe harbor," effectively pushing such businesses to offshore banking. Entry and Departure Requirements for Vanuatu – Department of Immigration and Passport Services

No competent authority: The absence of an official authority responsible for virtual asset supervision means no guidance can be sought, no approvals obtained, and no compliance certifications issued.

Practical reality: As of 2025–2026, any crypto business operating in or from Vanuatu does so entirely at its own risk, without any form of legal recognition or protection under Vanuatu law. State

Entry and Departure Requirements for Vanuatu – Department of Immigration and Passport Services

Vanuatu Anti-Money Laundering and Counter-Terrorism Financing Act (Act No. 16 of 2014)

Vanuatu Financial Services Commission Act [Cap 352]

International Banking Act [Cap 241]

Reserve Bank of Vanuatu Act [Cap 125]

Vanuatu Income Tax Act [Cap 167]

Tax Administration Act [Cap 168]

Consumer Protection Act [Cap 185]

Vanuatu Financial Services Commission (VFSC) Official Website – Regulatory Framework, Licensing, Application Forms, Public Register, Corporate Governance Guideline (2017), AML/CTF Guideline (2018), Media Releases

Reserve Bank of Vanuatu (RBV) Official Website – Supervision Guidelines, Licensed Entities, Press Releases

Vanuatu Financial Intelligence Unit (FIU) Annual Reports (2018–2024)

Asia/Pacific Group on Money Laundering (APG) Follow-Up Report – Vanuatu (2021)

Vanuatu Government Gazette Archive (2014–2025)

Vanuatu Supreme Court Decisions Database

Vanuatu Inland Revenue Department (IRD) Official Website – Public Notices, VAT Guidelines, Practice Notes