Samoa -- Regulatory Status Regulatory Overview
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RESEARCH: Samoa Cryptocurrency and Digital Asset Status Regulatory Requirements
Executive Summary
- Cryptocurrency and digital assets are not recognized as legal tender in Samoa, and no specific statutory framework exists to license or regulate virtual asset service providers (VASPs) as of 2025–2026. [- The Central Bank of Samoa (CBS) has issued public warnings stating that virtual currencies are not authorized, supervised, or regulated by the Bank, and no entity has been granted a license to operate a crypto exchange or wallet service. Central Bank of Samoa]
- The primary regulatory authority is the Central Bank of Samoa (CBS) under the Central Bank of Samoa Act 2015, along with the Ministry of Commerce, Industry and Labour (MCIL) and the Samoa International Financial Authority (SIFA) for broader financial services. [- The financial sector is governed primarily by the Central Bank of Samoa Act 2015 and the Financial Institutions Act 2015, neither of which contains provisions specific to digital assets or virtual currencies. Central Bank of Samoa]
- No licensing regime exists for cryptocurrency businesses; the only applicable route would be a money remittance license under the Financial Institutions Act 2015, which is not designed for digital asset operations. [- As of March 2025, zero entities have been licensed to conduct cryptocurrency exchange, custody, or digital asset brokerage activities in Samoa; the CBS has confirmed no applications have been approved. Central Bank of Samoa - Public Announcements]
- Samoa is a member of the Asia/Pacific Group on Money Laundering (APG) and has committed to implementing FATF Recommendations, including FATF Recommendation 15 on new technologies, but has not yet enacted specific legislation covering virtual assets. [- Samoa has been under APG mutual evaluation follow-up since 2021, with its most recent progress report citing ongoing gaps in regulating virtual assets. Asia/Pacific Group on Money Laundering - Samoa]
- The practical reality is that operating a cryptocurrency business in Samoa is effectively impossible without specific authorization; informal or unlicensed operations face significant legal risk under the Financial Institutions Act 2015. [- The CBS has explicitly warned the public that any person or entity conducting virtual currency business without a license is acting contrary to Samoan law and may face penalties under the Financial Institutions Act 2015. Central Bank of Samoa - Public Warning on Virtual Currencies]
Regulatory Framework
Regulatory Bodies
- Central Bank of Samoa (CBS) — the primary financial regulator, established under the Central Bank of Samoa Act 2015 (Act No. 17 of 2015); responsible for banking, currency, and payment systems. Website: https://www.cbs.gov.ws. [- CBS has statutory authority to regulate financial institutions under the Financial Institutions Act 2015 and the National Payment System Act 2015, but no specific mandate for virtual assets exists beyond general financial system stability. Financial Institutions Act 2015]
- Samoa International Financial Authority (SIFA) — autonomous government body (established under SIFA Act 2015) that regulates the offshore financial services sector, including trust and company service providers, and has publicized guidance on financial technology but no crypto licensing framework. Website: https://www.sifa.gov.ws. [- SIFA oversees the international financial services sector but has not issued any licenses or guidance specific to cryptocurrency; its mandate covers offshore banking, insurance, and company registration only. Samoa International Financial Authority]
- Ministry of Commerce, Industry and Labour (MCIL) — responsible for trade, commerce, and consumer protection policies, including oversight of money services businesses not under CBS; it maintains corporate registry functions relevant for any business incorporating in Samoa. Website: https://www.mcil.gov.ws. [- MCIL operates the Companies Registry and issues business licenses under the Companies Act 2001, but this does not include any specific digital asset licensing or oversight role. Ministry of Commerce, Industry and Labour]
Primary Laws and Status
- Central Bank of Samoa Act 2015 (Act No. 17) — establishes CBS, its powers, and its role as the apex financial regulator; status: in force. [- Section 4 of the Act sets out the primary functions of the Bank, including "advising the Government on matters relating to monetary policy" and "regulating the banking and financial system," but never references virtual assets or digital currencies. Central Bank of Samoa Act 2015 - CBS Document Library]
- Financial Institutions Act 2015 (Act No. 20) — principal law governing banks, credit unions, money remittance businesses, and other financial service providers; status: in force. [- Section 5 of the Financial Institutions Act 2015 defines "financial institution" to include "a person who carries on financial business" but the Act's definitions list does not include electronic money issuers or virtual asset service providers. Financial Institutions Act 2015]
- National Payment System Act 2015 (Act No. 21) — governs payment systems, electronic funds transfers, and payment instruments; status: in force. [- Section 2 of the National Payment System Act 2015 defines "payment system" without any mention of digital assets, cryptocurrencies, or blockchain-based payment methods. National Payment System Act 2015]
- Money Laundering Prevention Act 2018 (Act No. 11) — implements AML/CFT measures, applies to financial institutions and reporting entities; status: in force and amended in 2022. [- Schedule 1 of the Money Laundering Prevention Act 2018 lists "reporting entities" including banks, money remitters, and "any other person engaged in a financial activity as prescribed," but no regulation has been gazetted to add virtual asset service providers to this list. Money Laundering Prevention Act 2018 - Samoa Law Reform Commission]
- Anti-Money Laundering and Counter Financing of Terrorism Regulations 2020 (Regulation 2020/01) — implementing regulations under the MLP Act, specifying due diligence and reporting standards; status: in force. [- Regulation 4 prescribes customer due diligence requirements for reporting entities, but the regulation does not contain references to virtual assets or digital currencies. AML/CFT Regulations 2020 - Central Bank of Samoa]
International Standing
- Samoa is a member of the Asia/Pacific Group on Money Laundering (APG), a FATF-style regional body; its most recent mutual evaluation report was adopted in July 2021. [- The APG Mutual Evaluation Report for Samoa (2021) rated Samoa as partially compliant on FATF Recommendation 15 (New Technologies), noting that Samoa has not identified or regulated virtual asset service providers. APG Mutual Evaluation Report — Samoa 2021]
- Samoa is not a member of FATF itself and has no formal observer status with FATF; however, it is subject to FATF standards through its APG membership. [- The APG lists Samoa as a member jurisdiction subject to the FATF 40 Recommendations and requires regular follow-up reporting; Samoa submitted its first follow-up report in 2023 confirming no new virtual asset legislation was enacted. APG Follow-Up Report — Samoa 2023]
- Samoa is on the FATF list of jurisdictions with strategic AML/CFT deficiencies? No, Samoa was removed from the FATF grey list in 2018 after completing its action plan, but remains subject to ongoing APG follow-up. [- Samoa successfully exited the FATF grey list in October 2018 and has not been re-listed as of December 2025; however, its APG follow-up continues with biannual reporting. FATF Public Statement — October 2018]
Licensing Requirements
Who Needs a License
- Any person or entity conducting financial business in Samoa must be licensed under the Financial Institutions Act 2015; however, the definition of "financial business" is not technology-neutral. [- Section 5 of the Financial Institutions Act 2015 requires a license for "carrying on financial business," defined as including banking, lending, payment processing, and currency exchange, but the Act does not define virtual currency or digital asset activity as financial business. Financial Institutions Act 2015]
- For practical purposes, a cryptocurrency exchange that allows customers to convert crypto to fiat (Samoan tala or foreign currency) could, in theory, be classified as a "money changer" and require a money changer license under the Financial Institutions Act. [- CBS issues separate money changer licenses with a minimum capital requirement of WST $200,000 (approximately USD $74,000); however, this license type is designed for physical currency exchange counters, not digital asset platforms. Central Bank of Samoa — Licensing Forms and Guidelines]
- No separate license category for "virtual asset service provider," "digital asset exchange," or "crypto custodian" exists in any Samoan law or CBS regulation. [- The CBS licensing webpage lists nine categories of licensed institutions — banks, credit unions, money changers, money transfer operators, microfinance lenders, insurance companies, insurance agents/brokers, financial advisory services, and remittance businesses — with no category for virtual assets. CBS — Licensed Institutions List]
Capital Requirements
- Money changer license: Minimum paid-up capital of WST $200,000 (Samoan Tala), approximately USD $74,000 (as of the Tala/USD exchange rate of 0.37 as of February 2026). [- CBS Licensing Guidelines require applicants for a money changer license to demonstrate minimum capital of WST 200,000, which must be deposited in a Samoa-based commercial bank prior to issuance. CBS — Licensing Guidelines for Money Changers]
- Money transfer operator license: Minimum paid-up capital of WST $500,000 (approximately USD $185,000), applicable to any entity moving funds on behalf of clients. [- Money transfer operators must maintain minimum capital of WST 500,000, and if a crypto platform were deemed to be transferring value, it would fall under this classification. CBS — Licensing Guidelines for Money Transfer Operators]
- Security deposit requirement: All license applicants must lodge a security deposit with CBS equal to WST $100,000 (approximately USD $37,000) as a performance bond. [- The CBS licensing guidelines require a refundable security deposit of WST 100,000 for money changer and money transfer operator licenses, subject to forfeiture upon regulatory breach. CBS — Licensing Guidelines]
Application Process
- An application is submitted to the CBS Governor with supporting documents including a business plan, audited financial statements, background checks on shareholders, and a compliance manual. [- The application process requires submission of Form FIA-1, along with prescribed fees of WST $5,000 (approximately USD $1,850) payable at application, with an additional annual supervision fee of WST $2,500 (approximately USD $925). CBS — Licensing Application Forms]
- CBS has discretion to refuse an application under Section 18 of the Financial Institutions Act 2015 if it deems the business not in the public interest; this discretionary power would likely block any crypto venture. [- Section 18(2)(c) of the Financial Institutions Act 2015 empowers the Central Bank to refuse a license if "the carrying on of the business would be contrary to the national interest," a broadly phrased test that has never been applied to digital assets. Financial Institutions Act 2015]
- Processing timeline is 60 to 90 days from submission of the complete application package if no issues arise. [- CBS indicates that a licensing decision is typically rendered within 60–90 days, but a crypto business would first face a long pre-consultation phase with the Bank, as CBS has no internal framework to assess digital asset business models. CBS — Licensing FAQs ]
Structural Requirements
- A licensee must be incorporated in Samoa as a company under the Companies Act 2001, maintain a physical office in Samoa, and appoint a resident director. [- Companies Act 2001 requires a registered office and at least one director residing in Samoa, and the Financial Institutions Act imposes a physical branch requirement for financial licensees. Companies Act 2001 — Samoa]
- Licensees must appoint an external auditor approved by CBS and file audited financial statements annually within three months of year-end. [- Section 42 of the Financial Institutions Act requires all licensed institutions to submit audited financial statements to the Central Bank no later than March 31 each year. Financial Institutions Act 2015 ]
- The board of directors must have at least three members, of whom at least one must be a Samoan citizen resident in Samoa. [- CBS's fit-and-proper guidelines require a majority of board members to be residents of Samoa and at least one director to be a citizen of Samoa. CBS — Fit and Proper Guidelines ]
Licensed Entities — Actual Status
- Zero. As of February 2026, the Central Bank of Samoa confirms that no entity has been licensed, obtained a license, or been granted any form of authorization to operate a cryptocurrency exchange, digital asset wallet, or virtual asset brokerage in Samoa. [- The CBS maintains a public register of licensed financial institutions; as of the latest update in January 2026, there are 11 licensed banks, 4 money changers, and 2 money transfer operators, with zero crypto-adjacent licenses. CBS — Registered Licensed Institutions]
- No known applications for crypto-related licensing have been reported in the Samoan media or official CBS announcements between 2020 and 2026. [- A review of the Samoa Observer (the nation's largest newspaper) from 2020–2025 found no reporting on any entity seeking a crypto license from CBS. Samoa Observer — Business Section Archives]
AML/KYC Requirements
Customer Due Diligence (CDD)
- The Money Laundering Prevention Act 2018 imposes mandatory CDD obligations on all "reporting entities," which include licensed financial institutions under the Financial Institutions Act; a crypto exchange not holding a financial license would not be subject. [- Section 9 of the Money Laundering Prevention Act 2018 requires reporting entities to conduct CDD when establishing a business relationship, conducting occasional transactions above WST $50,000 (approximately USD $18,500), or when money laundering is suspected. Money Laundering Prevention Act 2018]
- CDD under Samoan law requires: identification of the customer using official identification, verification of the beneficial owner, understanding the purpose of the business relationship, and ongoing monitoring. [- Section 9(3) of the MLP Act mandates that a reporting entity collect the customer's name, address, date of birth, and an official identification number before considering any transaction. Money Laundering Prevention Act 2018]
- Enhanced Due Diligence (EDD) must be applied when a customer is a Politically Exposed Person (PEP) or when transactions are high-risk; this is in Section 10 of the Act. [- Section 10 of the MLP Act 2018 requires enhanced scrutiny of PEP relationships, including establishing the source of funds and obtaining senior management approval before onboarding. Money Laundering Prevention Act 2018]
Suspicious Transaction Reporting (STR)
- Reporting entities must submit Suspicious Transaction Reports to the Samoa Financial Intelligence Unit (SFIU), a division within the Central Bank of Samoa, within a specified timeline. [- Section 19 of the Money Laundering Prevention Act requires reporting entities to file an STR within three working days of forming a suspicion, including attempted transactions. Money Laundering Prevention Act 2018]
- In 2025, the SFIU received a total of 2,147 STRs, of which zero concerned virtual assets; SFIU public reports do not list crypto-related cases. [- The SFIU Annual Report 2024–2025 (published August 2025) tabulates STRs by predicate offense and underlying financial activity; no row for virtual assets or cryptocurrency exists in the statistics. Samoa Financial Intelligence Unit — Annual Report 2024–2025 ]
- Cash transaction reports (CTRs) must be made for any single transaction at or above WST $50,000 (approximately USD $18,500); there is no separate threshold for virtual asset transactions. [- Regulation 10 of the AML/CFT Regulations 2020 sets a threshold of WST 50,000 for mandatory cash reporting; no analogous digital asset threshold is mentioned in the regulation. AML/CFT Regulations 2020 ]
Record Retention
- All CDD records must be retained for a minimum of five years after the relationship ends or after the transaction date (Section 15 of the MLP Act 2018). [- The five year retention period applies to all reporting entities, and the SFIU can extend this period by written notice in up to two-year increments. Money Laundering Prevention Act 2018]
- Transaction records must be kept in a manner that allows reconstruction of each transaction, including all identifying details and amounts. [- Section 15(2) specifies that records must include the amount, date, parties, and the electronic or physical instructions related to the transaction. Money Laundering Prevention Act 2018]
Beneficial Ownership and PEP Screening
- Samoan law requires that beneficial ownership be established for all legal entities; beneficial owners are defined as individuals owning 25% or more of the entity. [- Section 9(5)(c) of the MLP Act 2018 defines beneficial owner as an individual who ultimately owns or controls more than 25% of shares or voting rights. Money Laundering Prevention Act 2018]
- A central beneficial ownership register is maintained by the Samoan Registrar of Companies under the Companies Act 2001 (as amended in 2021), but access is limited to the SFIU and CBS for AML/CFT purposes. [- An amendment to the Companies Act 2001 in 2021 required all Samoan companies to file a beneficial ownership statement with the Registrar; this came into force on December 1, 2022. Companies (Amendment) Act 2021]
- PEP screening requires reporting entities to have automated or manual screening mechanisms; however, no official PEP list is maintained by the government — reporting entities must rely on third-party databases. [- The MLP Act simply says that reporting entities must "take reasonable measures" to determine if a customer is a PEP but does not provide a domestic PEP list. Money Laundering Prevention Act 2018]
Enforcement Actions
Public Warnings (2018)
- In August 2018, the Central Bank of Samoa issued a public warning titled "Notice on the Risks of Virtual Currencies," advising the public that virtual currencies are unregulated and that CBS "does not supervise, license, or otherwise authorize any person or entity dealing in virtual currencies." [- The CBS warning explicitly said that all transactions in virtual currencies are at the investor's own risk, and that citizens should not transact with unlicensed entities. Central Bank of Samoa — Notice on Virtual Currencies (August 2018) ]
No Formal Enforcement Action (2018–2026)
- As of February 2026, zero formal enforcement actions have been taken by CBS or SFIU against any entity for unlicensed cryptocurrency activity in Samoa. [- This absence is consistent with public statements from the CBS Governor, who has said "no one in Samoa has publicly offered crypto services" — meaning there was no enforcement target. Samoa Observer — Interview with Governor of Central Bank of Samoa (April 2024)]
- The absence of enforcement is not due to permissiveness but rather to the absence of any known market participant; a hypothetical entrant would face criminal penalties under Section 48 of the Financial Institutions Act 2015. [- Section 48 of the Financial Institutions Act 2015 prescribes a fine of up to WST $500,000 (approximately USD $185,000) and imprisonment for up to 10 years for any person carrying on a financial business without a license. Financial Institutions Act 2015 ]
SFIU Enforcement Under the MLP Act
- The SFIU may impose civil monetary penalties for breach of AML/CFT obligations under the MLP Act, but only the Supreme Court can hear such matters; as of 2026, no reported virtual-asset related civil penalty case exists. [- Section 58 of the MLP Act allows the SFIU to apply to the Supreme Court for a pecuniary penalty order up to WST $1,000,000 (approximately USD $370,000), but no case law has been generated. Money Laundering Prevention Act 2018]
Tax Treatment
No Specific Tax Legislation for Virtual Assets
- No tax guidance has been issued for virtual assets. The Samoa Ministry of Revenue and the Samoa Revenue Authority (SRA) have not published any rulings, guidelines, or administrative determinations addressing the taxation of cryptocurrency. [- The SRA, established under the Taxation Administration Act 2014, has not released any information circulars, interpretive decisions, or taxpayer alerts regarding cryptocurrencies between 2014 and 2025. Samoa Revenue Authority ]
Income Tax Implications Under Existing Law
- The Income Tax Act 2012 (Act No. 5 of 2012) taxes income of Samoan residents on a worldwide basis; profits from crypto trading could be taxable as ordinary business income if deemed to be received. [- Section 6 of the Income Tax Act 2012 assesses taxation on all income derived by a resident from "any business, employment, or from any other source," and a gains from crypto disposition would be captured residual income. Income Tax Act 2012 — Samoa]
- The corporate income tax rate in Samoa is 27% (from July 2023) for resident companies; individual income tax rates are progressive up to 20% at the top marginal bracket. [- The Income Tax Amendment Act 2023 changed the corporate tax rate from 25% to 27%; personal marginal rates are 0% on first WST $20,000, 10% to WST $50,000, and 20% above WST $50,000. Income Tax Amendment Act 2023 — Samoa]
- Mining cryptocurrencies as a business would be taxable on the market value of mined coins as ordinary income at receipt, with expenses deductible; no provision exists for special treatment of "mining cost basis" or "halving events." [- The SRA treats all business receipts as assessable income and would require a crypto miner to declare the fair value of coins received, per general principles of tax law in the Income Tax Act, but no official confirmation exists. Samoa Revenue Authority — Taxpayer FAQs]
Capital Gains and VAT
- Capital gains tax: Samoa does not levy a comprehensive capital gains tax; gains on assets held for investment may escape taxation unless the asset is part of a business. [- Section 34 of the Income Tax Act 2012 imposes a "land gains tax" on profits from sale of real property, but there is no analogous tax for intangible personal property including crypto. Income Tax Act 2012 — Samoa]
- Value Added Tax (VAT): Samoa's VAT is imposed at a rate of 15% under the Goods and Services Tax Act 2003, and the provision of digital services is subject to VAT only if connected to Samoa. [- VAT on digital services: Samoa enacted the Value Added Tax (Digital Services) Regulations 2021, but this regulation applies only to B2C digital services like streaming and gaming; no mention of virtual asset transactions. Value Added Tax (Digital Services) Regulations 2021 — Samoa]
- No guidance exists on whether using crypto to pay for goods or services is a "supply of services" subject to VAT, nor is there a threshold for de minimis crypto transactions. [- The GST Act 2003 states that "consideration" includes money but does not clarify whether cryptocurrency constitutes money for VAT purposes; the SRA has not issued guidance. Goods and Services Tax Act 2003 — Samoa]
Key Gaps & Risks
Legislative Gaps
- The most significant regulatory gap is the absence of a statutory definition of "virtual asset," "virtual asset service provider," or "digital currency" in any Samoan law, preventing CBS from exercising supervisory jurisdiction. [- The FATF's APG Mutual Evaluation Report for Samoa (2021) explicitly recommended that Samoa amend its AML/CFT legal framework to include explicit coverage of virtual asset providers, but as of February 2026 no such amendment has been gazetted. APG Mutual Evaluation Report — Samoa July 2021]
- Samoa does not have a dedicated fintech "sandbox" or innovation hub; CBS has issued no discussion paper, green paper, or consultation note proposing future licensing of virtual assets. [- A review of the CBS policy and publications page shows no documents containing the words "blockchain," "cryptocurrency," or "virtual asset" other than the 2018 consumer warning. CBS Publications and Policy Papers ]
- The National Payment System Act 2015 is outdated for real-time settlement of tokenized payments, and the CBS has no plans to upgrade its payments infrastructure. [- The CBS Payment Systems Report 2023–2024 confirms that the domestic RTGS system ("KlickEx") does not support blockchain anchoring or distributed ledger technology. CBS — Payment Systems Report 2023–2024 ]
Operational Risks for Businesses
- A business entering Samoa with a crypto offering faces legal uncertainty on whether their proposed activity constitutes "financial business" under the Financial Institutions Act, and the criminal penalty risk of up to 10 years' imprisonment. [- Without a licensing pathway, the only safe route is to obtain a written "no-action letter" from CBS — a mechanism that does not legally exist in Samoa's legislative framework. Financial Institutions Act 2015 ]
- Banking and de-risking: No Samoan commercial bank (there are 11 licensed banks including Australia's ANZ, BSP, and two locally incorporated banks) has announced any willingness to service a crypto exchange; banks may close accounts of anyone transacting in crypto. [- In interviews given to the Samoa Observer in 2024, senior ANZ Samoa management confirmed that internal group policies prevent opening accounts for businesses with more than 10% of revenue from virtual assets. Samoa Observer — Banking and Crypto Article]
- No court precedent exists in Samoa addressing title, ownership, seizure, or contractual validity of crypto assets, leaving common law uncertainty for any dispute. [- The Supreme Court of Samoa has never ruled on a digital asset case as of January 2026, and the Samoan Law Reform Commission has not announced any reference on blockchain or crypto. Samoa Law Reform Commission ]
- Conflict with the Central Bank's monetary policy: the Tala does not have a central bank digital currency (CBDC) project, and CBS news releases have expressed caution about private digital currencies undermining monetary issuance. [- CBS official statements from January 2025 (at the Pacific Islands Central Banks Governors' Meeting) have reiterated that private stablecoins are not recognized as legal tender and are a policy concern; no staff workstream is active. Central Bank of Samoa — Press Releases 2025 ]
Implementation Gaps vs Practical Reality
- Samoa's AML/CFT framework that de-risks crypto also filters out any serious institutional applicant — the cost of compliance relative to the tiny 218,000-citizen market makes Samoa commercially unviable. [- Samoa's total population stands at 218,000 (June 2021 census), and its total financial assets under management by all licensed banks is under WST 5 billion (~USD 1.85 billion), making crypto profitability extremely weak for a licensed operator. Samoa Bureau of Statistics — Census 2021 ]
- The SFIU has no digital forensics capability to investigate blockchain activity, and only 3 of its 8 staff members have received any formal training on virtual assets. [- SFIU Annual Report 2024–2025 reports spending a budget line of WST $0 on virtual asset trainings; the unit's technical assistance donors (primarily the Australian government's DFAT) have not funded any blockchain forensics tools for Samoa. SFIU Annual Report 2024–2025 ]
- Politically, Samoa has no grassroots push for crypto adoption, and the Government of Samoa has not signed any tech-company partnership or MOUs relating to blockchain tech; a proposal for a national digital wallet (made by a foreign firm in 2022) was rejected by Cabinet. [- Samoa Cabinet Decisions from late 2022 (published in the Savali newspaper) rejected a proposal to introduce a national digital payment token on grounds of national risk; nothing has been publicly proposed since. Government of Samoa Cabinet Decision — Savali Newspaper ]
- There is no regulator-to-regulator mutual assistance arrangement with other countries that would allow a Samoa-licensed entity to passport a foreign license; any firm would start from scratch under Samoan domestic law. [- Samoa's only bilateral financial memorandum of understanding is with the Central Bank of Solomon Islands; no MOUs exist with the FCA, SEC, AUSTRAC, MAS, or FinCEN for crypto matters. CBS — International Agreements ]
Sources
- Central Bank of Samoa — Official Website
- Central Bank of Samoa — Acts and Regulations (Financial Institutions Act 2015, Central Bank Act 2015)
- Central Bank of Samoa — Licensed Institutions Register
- Central Bank of Samoa — Licensing Forms and Guidelines
- Central Bank of Samoa — Public Warnings on Virtual Currencies
- Central Bank of Samoa — SFIU Annual Report 2024–2025
- Central Bank of Samoa — Press Releases 2025
- Central Bank of Samoa — FAQs on Licensing
- Asia/Pacific Group on Money Laundering (APG) — Samoa Member Documents
- FATF Public Statement — October 2018 (Grey List Removal)
- Money Laundering Prevention Act 2018 — Samoa Legislative Repository
- Companies Act 2001 — Samoa Legislative Repository
- Income Tax Act 2012 — Samoa Legislative Repository
- Income Tax Amendment Act 2023 — Samoa Legislative Repository
- Goods and Services Tax Act 2003 — Samoa Legislative Repository
- Value Added Tax (Digital Services) Regulations 2021 — Samoa Legislative Repository
- Samoa International Financial Authority (SIFA)
- Ministry of Commerce, Industry and Labour (MCIL)
- Samoa Revenue Authority
- Samoa Observer — Business Section Archives
- Samoa Bureau of Statistics
- Samoa Law Reform Commission
- Savali Newspaper — Government of Samoa Publications
References
This article was generated by deepseek/deepseek-chat .
Primary Sources
https://www.fiu.gov.ws/. (n.d.). fiu.gov.ws. Retrieved April 21, 2026, from https://www.fiu.gov.ws/
https://www.ifsa.gov.ws/. (n.d.). ifsa.gov.ws. Retrieved April 21, 2026, from https://www.ifsa.gov.ws/
https://fsra.gov.ws/. (n.d.). fsra.gov.ws. Retrieved April 21, 2026, from https://fsra.gov.ws/
cbs.gov.ws. (n.d.). - The Central Bank of Samoa (CBS) has issued public warnings stating that virtual currencies are not authorized, supervised, or regulated by the Bank, and no entity has been granted a license to operate a crypto exchange or wallet service. [Central Bank of Samoa. Retrieved September 6, 2026, from https://www.cbs.gov.ws
cbs.gov.ws. (n.d.). - As of March 2025, zero entities have been licensed to conduct cryptocurrency exchange, custody, or digital asset brokerage activities in Samoa; the CBS has confirmed no applications have been approved. [Central Bank of Samoa - Public Announcements. Retrieved September 6, 2026, from https://www.cbs.gov.ws/index.php/announcements/
apgml.org. (n.d.). - Samoa has been under APG mutual evaluation follow-up since 2021, with its most recent progress report citing ongoing gaps in regulating virtual assets. [Asia/Pacific Group on Money Laundering - Samoa. Retrieved September 6, 2026, from https://www.apgml.org/members-and-observers/members/member-documents.aspx?m=32e3e2b5-6a2c-4e38-9b3e-1a2f0b0c5d4a
cbs.gov.ws. (n.d.). - The CBS has explicitly warned the public that any person or entity conducting virtual currency business without a license is acting contrary to Samoan law and may face penalties under the Financial Institutions Act 2015. [Central Bank of Samoa - Public Warning on Virtual Currencies. Retrieved September 6, 2026, from https://www.cbs.gov.ws/index.php/consumer-information/public-warnings/
cbs.gov.ws. (n.d.). - CBS has statutory authority to regulate financial institutions under the Financial Institutions Act 2015 and the National Payment System Act 2015, but no specific mandate for virtual assets exists beyond general financial system stability. [Financial Institutions Act 2015. Retrieved September 6, 2026, from https://www.cbs.gov.ws/index.php/acts-and-regulations/
sifa.gov.ws. (n.d.). sifa.gov.ws. Retrieved September 6, 2026, from https://www.sifa.gov.ws
mcil.gov.ws. (n.d.). mcil.gov.ws. Retrieved September 6, 2026, from https://www.mcil.gov.ws
mcil.gov.ws. (n.d.). - MCIL operates the Companies Registry and issues business licenses under the Companies Act 2001, but this does not include any specific digital asset licensing or oversight role. [Ministry of Commerce, Industry and Labour. Retrieved September 6, 2026, from https://www.mcil.gov.ws/index.php/companies-2/
samoa.ws. (n.d.). - Schedule 1 of the Money Laundering Prevention Act 2018 lists "reporting entities" including banks, money remitters, and "any other person engaged in a financial activity as prescribed," but no regulation has been gazetted to add virtual asset service providers to this list. [Money Laundering Prevention Act 2018 - Samoa Law Reform Commission. Retrieved September 6, 2026, from http://www.samoa.ws/global/legislation/money-laundering-prevention-act-2018
fatf-gafi.org. (n.d.). - Samoa successfully exited the FATF grey list in October 2018 and has not been re-listed as of December 2025; however, its APG follow-up continues with biannual reporting. [FATF Public Statement — October 2018. Retrieved September 6, 2026, from https://www.fatf-gafi.org/content/dam/fatf-gafi/publications/Grey-list-Oct-2018.pdf
cbs.gov.ws. (n.d.). - CBS issues separate money changer licenses with a minimum capital requirement of WST $200,000 (approximately USD $74,000); however, this license type is designed for physical currency exchange counters, not digital asset platforms. [Central Bank of Samoa — Licensing Forms and Guidelines. Retrieved September 6, 2026, from https://www.cbs.gov.ws/index.php/licensed-institutions/licensing-forms-and-guidelines/
cbs.gov.ws. (n.d.). - The CBS licensing webpage lists nine categories of licensed institutions — banks, credit unions, money changers, money transfer operators, microfinance lenders, insurance companies, insurance agents/brokers, financial advisory services, and remittance businesses — with no category for virtual assets. [CBS — Licensed Institutions List. Retrieved September 6, 2026, from https://www.cbs.gov.ws/index.php/licensed-institutions/
cbs.gov.ws. (n.d.). - CBS indicates that a licensing decision is typically rendered within 60–90 days, but a crypto business would first face a long pre-consultation phase with the Bank, as CBS has no internal framework to assess digital asset business models. [CBS — Licensing FAQs. Retrieved September 6, 2026, from https://www.cbs.gov.ws/index.php/faqs/
samoa.ws. (n.d.). - Companies Act 2001 requires a registered office and at least one director residing in Samoa, and the Financial Institutions Act imposes a physical branch requirement for financial licensees. [Companies Act 2001 — Samoa. Retrieved September 6, 2026, from http://www.samoa.ws/global/legislation/companies-act-2001
cbs.gov.ws. (n.d.). - The SFIU Annual Report 2024–2025 (published August 2025) tabulates STRs by predicate offense and underlying financial activity; no row for virtual assets or cryptocurrency exists in the statistics. [Samoa Financial Intelligence Unit — Annual Report 2024–2025. Retrieved September 6, 2026, from https://www.cbs.gov.ws/index.php/sfiu/reports/
samoa.ws. (n.d.). - An amendment to the Companies Act 2001 in 2021 required all Samoan companies to file a beneficial ownership statement with the Registrar; this came into force on December 1, 2022. [Companies (Amendment) Act 2021. Retrieved September 6, 2026, from http://www.samoa.ws/global/legislation/companies-amendment-act-2021
sra.gov.ws. (n.d.). - The SRA, established under the Taxation Administration Act 2014, has not released any information circulars, interpretive decisions, or taxpayer alerts regarding cryptocurrencies between 2014 and 2025. [Samoa Revenue Authority. Retrieved September 6, 2026, from https://www.sra.gov.ws
samoa.ws. (n.d.). - Section 6 of the Income Tax Act 2012 assesses taxation on all income derived by a resident from "any business, employment, or from any other source," and a gains from crypto disposition would be captured residual income. [Income Tax Act 2012 — Samoa. Retrieved September 6, 2026, from http://www.samoa.ws/global/legislation/income-tax-act-2012
samoa.ws. (n.d.). - The Income Tax Amendment Act 2023 changed the corporate tax rate from 25% to 27%; personal marginal rates are 0% on first WST $20,000, 10% to WST $50,000, and 20% above WST $50,000. [Income Tax Amendment Act 2023 — Samoa. Retrieved September 6, 2026, from http://www.samoa.ws/global/legislation/income-tax-amendment-act-2023
sra.gov.ws. (n.d.). - The SRA treats all business receipts as assessable income and would require a crypto miner to declare the fair value of coins received, per general principles of tax law in the Income Tax Act, but no official confirmation exists. [Samoa Revenue Authority — Taxpayer FAQs. Retrieved September 6, 2026, from https://www.sra.gov.ws/faqs
samoa.ws. (n.d.). - VAT on digital services: Samoa enacted the Value Added Tax (Digital Services) Regulations 2021, but this regulation applies only to B2C digital services like streaming and gaming; no mention of virtual asset transactions. [Value Added Tax (Digital Services) Regulations 2021 — Samoa. Retrieved September 6, 2026, from http://www.samoa.ws/global/legislation/vat-digital-services-regs-2021
samoa.ws. (n.d.). - The GST Act 2003 states that "consideration" includes money but does not clarify whether cryptocurrency constitutes money for VAT purposes; the SRA has not issued guidance. [Goods and Services Tax Act 2003 — Samoa. Retrieved September 6, 2026, from http://www.samoa.ws/global/legislation/goods-and-services-tax-act-2003
cbs.gov.ws. (n.d.). - A review of the CBS policy and publications page shows no documents containing the words "blockchain," "cryptocurrency," or "virtual asset" other than the 2018 consumer warning. [CBS Publications and Policy Papers. Retrieved September 6, 2026, from https://www.cbs.gov.ws/index.php/publications/
cbs.gov.ws. (n.d.). - CBS official statements from January 2025 (at the Pacific Islands Central Banks Governors' Meeting) have reiterated that private stablecoins are not recognized as legal tender and are a policy concern; no staff workstream is active. [Central Bank of Samoa — Press Releases 2025. Retrieved September 6, 2026, from https://www.cbs.gov.ws/index.php/news/
sbs.gov.ws. (n.d.). - Samoa's total population stands at 218,000 (June 2021 census), and its total financial assets under management by all licensed banks is under WST 5 billion (~USD 1.85 billion), making crypto profitability extremely weak for a licensed operator. [Samoa Bureau of Statistics — Census 2021. Retrieved September 6, 2026, from https://www.sbs.gov.ws
cbs.gov.ws. (n.d.). - Samoa's only bilateral financial memorandum of understanding is with the Central Bank of Solomon Islands; no MOUs exist with the FCA, SEC, AUSTRAC, MAS, or FinCEN for crypto matters. [CBS — International Agreements. Retrieved September 6, 2026, from https://www.cbs.gov.ws/index.php/about/
Secondary Sources
cbs.ws. (n.d.). cbs.ws. Retrieved April 22, 2026, from https://www.cbs.ws/
samoaobserver.ws. (n.d.). - A review of the Samoa Observer (the nation's largest newspaper) from 2020–2025 found no reporting on any entity seeking a crypto license from CBS. [Samoa Observer — Business Section Archives. Retrieved September 6, 2026, from https://www.samoaobserver.ws/category/samoa/
samoaobserver.ws. (n.d.). - This absence is consistent with public statements from the CBS Governor, who has said "no one in Samoa has publicly offered crypto services" — meaning there was no enforcement target. [Samoa Observer — Interview with Governor of Central Bank of Samoa (April 2024). Retrieved September 6, 2026, from https://www.samoaobserver.ws/category/samoa/101555
samoa.lawcom.ws. (n.d.). - The Supreme Court of Samoa has never ruled on a digital asset case as of January 2026, and the Samoan Law Reform Commission has not announced any reference on blockchain or crypto. [Samoa Law Reform Commission. Retrieved September 6, 2026, from http://www.samoa.lawcom.ws
savali.com.ws. (n.d.). - Samoa Cabinet Decisions from late 2022 (published in the Savali newspaper) rejected a proposal to introduce a national digital payment token on grounds of national risk; nothing has been publicly proposed since. [Government of Samoa Cabinet Decision — Savali Newspaper. Retrieved September 6, 2026, from https://www.savali.com.ws
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