--- title: "MH Crypto Regulation Monitor | cryptoassets.gi" canonical: https://cryptoassets.gi/jurisdictions/mh-crypto-digital-asset-regulation/ source_html: /jurisdictions/marshall-islands/index.html description: "MH crypto asset regulation: 8 categories, 31 sourced findings, updated 2026-10-25. Licensing, token classification, stablecoins, tax treatment." generated_at: 2026-11-07T14:19:44Z content_sha256: ee59ef9fd36e984b730f41190cc6d4338e793c6ca0a44075d6bd23bcfa9cf8d7 generator: "fe-fleet/md-twin@1.0" --- # MH Crypto Regulation Monitor | cryptoassets.gi No domestic primary official source retrieved yet. None of the sources retrieved for this jurisdiction is the official instrument or regulator publication itself (tier 1). No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved. # MH Crypto & Digital Asset Regulation schema crypto-v2.0.0 trajectory: not yet assessed unregulated gap overlaps: [Sentinel (AML/CFT)](https://sentinel.gi/jurisdictions/marshall-islands/), [World Payments](https://payments.gi/jurisdictions/marshall-islands/) Last updated 2026-10-25 · 8 categories · 31 sourced findings · 14 sources in the cumulative register Download report (PDF) Expand all Evidence re-verified: 2026-10-25 · Position last changed: 2026-10-25 · Record history & provenance ▾ Methodology & record provenance: Module confidence is derived from the underlying claims (source tier and primary excerpt retention), while statutory legal force is tracked independently. Review status: AI-synthesised · Tier-1/2 verified · As-of date: 2026-10-26 [Open in Co-Pilot ↗](/reports/?type=copilot&j=MARSHALL-ISLANDS)[Build Report](/reports/?j=MARSHALL-ISLANDS)[Compare](/compare/?j=MARSHALL-ISLANDS) Framework posture Unregulated gap 8 of 9 modules populated · AI-synthesised · Tier-1/2 verified Lead supervisory authority Asia/Pacific Group on Money Laundering (APG) / FATF Primary statutory & supervisory perimeter Next milestone (> 2026-10-26) 2026-Q4 MIMA rulebook for USDM1 reserve/redemption/disclosure Module coverage & confidence 8 / 9 modules assessed 0 Confirmed · 8 Probable · 0 Uncertain · 1 Not yet assessed 8 Categories 0 Moved this cycle 0 Key judgments 4 Open gaps 31 Findings 3 Tier-1 sources Confidence mix 8 unpopulated (sums to 8 rendered categories; click to filter) No categories moved this cycle. ## Jurisdiction lead brief ###### Latest update · 25 October 2026 #### Lead Signal The Marshall Islands' crypto-adjacent regulatory posture remains an unregulated gap outside of narrow statutory recognition for decentralized autonomous organisations, and the principal development sits outside that perimeter entirely: continued institutional-finance uptake of the jurisdiction's government-issued sovereign-bond token, USDM1. On 23 October 2026, Ascend Markets, LLC and M1X Global completed what is reported as the first institutional repurchase transaction on the Stellar network using USDM1 as collateral. The transaction's value was not disclosed. USDM1 is characterised by the Marshall Islands' own description of the programme as a fully collateralized, USD-denominated sovereign bond issued natively on-chain, explicitly not a wrapped instrument and not marketed as a stablecoin or legal-tender cryptocurrency, which is the reason it is tracked here under the stablecoin-adjacent module rather than as a token-classification or licensing matter. #### Other Developments USDM1's institutional backing arrangement is now confirmed by a primary international source. The International Monetary Fund's September 2025 Article IV concluding statement for the Marshall Islands confirms that proceeds from the programme are earmarked entirely for purchase of short-term United States Treasury bills as collateral. This is a materially stronger evidentiary basis than the vendor-only sourcing available for most other claims about the jurisdiction's crypto-adjacent environment, and it anchors the one finding in the record that rests on Tier 1 sourcing rather than commercial vendor commentary. #### Cross-Monitor Connections The USDM1 programme and its growing institutional-finance footprint intersect with sanctions and beneficial-ownership tracking of the Marshall Islands' registered-agent corporate sector, though the two are structurally distinct: the sovereign-bond programme is a government-issued instrument with Treasury-bill backing, while the enabler-jurisdiction concern documented elsewhere relates to the opacity of ordinary non-resident company formation exploited by third-party sanctioned networks. Nothing in the available record connects USDM1 itself to sanctions-evasion or ownership-concealment use, and the two should not be conflated. Readers tracking payments-infrastructure developments on the same jurisdiction will see the identical repo transaction recorded from a commercial-infrastructure angle; here the emphasis is on the instrument's classification status and its position just outside the crypto regulatory perimeter. #### Outlook The Marshall Islands' absence of a dedicated digital-asset statute means USDM1's continued institutional uptake is occurring without a bespoke supervisory framework attaching to it; whether any framework specific to sovereign-issued digital-bond instruments emerges remains an open question for future cycles. Continued institutional transactions using USDM1 as collateral, and whether further primary-source confirmation of the instrument's backing or classification becomes available, are the developments most worth tracking going forward. 1 earlier update not shown here. ###### Standing brief · as of 5 October 2026 Written before the update above. Where they differ, the update is the more recent position. #### Lead Signal The Marshall Islands' sole statutory stablecoin framework, the Declaration and Issuance of the Sovereign Currency Act 2018 (P.L. 2018-53), is reported repealed as of August 2025. The SOV Act had declared a blockchain-based digital token, SOV, as second legal tender alongside the US dollar, and had drawn sustained IMF concern over financial-integrity exposure from the prior administration's second-legal-tender design. The repeal report rests on a single tertiary source, Wikipedia, and no primary Nitijela repeal instrument was retrieved this cycle to confirm the exact citation or date. The result is a liberalising but unconfirmed signal: a previously flagged financial-innovation risk vector appears to have been removed from the statute book, but the removal itself is not yet corroborated at source. #### Other Developments A successor sovereign-currency initiative remains at policy stage only. A Human Rights Foundation CBDC tracker entry records that the RMI cabinet endorsed, in principle, a public-private partnership with MIBOND Global LLC toward a new sovereign digital currency and citizen digital wallet concept referred to as Lomalo, reportedly linked to a universal basic income programme. This sits well short of an enacted issuance statute and should be read as an early-stage policy signal rather than a live regime. No activity-based licensing architecture has emerged to fill the gap. Separately from the stablecoin-specific repeal, the jurisdiction continues to lack any cryptocurrency-exchange licence or virtual-asset-service-provider registration regime; this module remains outside this cycle's write scope but forms the backdrop against which the stablecoin repeal should be read: the RMI's digital-asset posture generally is one of statutory absence rather than active permissiveness or active prohibition. #### Cross-Monitor Connections The SOV Act's repeal is a shared factual anchor with the financial-integrity monitor, which tracks the same reported repeal as a reduction in a longstanding IMF-flagged financial-integrity risk vector tied to the RMI's digital-asset architecture. Both monitors note the identical evidentiary limitation: the repeal is sourced only to tertiary reporting, corroborated by the IMF's historical repeal recommendation rather than by a primary legislative text retrieved this cycle. Where the financial-integrity monitor frames this as a sanctions/AML-adjacent risk reduction, the crypto monitor frames it as the lapse of the jurisdiction's only prior stablecoin-adjacent statutory framework, leaving a regulatory vacuum rather than a replacement regime. #### Outlook The near-term question for this module is evidentiary rather than substantive: whether a primary Nitijela repeal instrument surfaces to confirm the citation and exact date, which would move the finding from Probable to Confirmed. On the substantive side, the MIBOND Global LLC public-private partnership is the only visible successor track, and it remains, as scheduled, at a pre-enactment, pre-pilot policy stage, with no confirmed timeline for a wallet launch or an issuance statute. Absent either a confirmed repeal citation or a concrete successor filing, the stablecoin module in the Marshall Islands sits in a confirmed-direction, unconfirmed-detail state: a liberalising trajectory without a settled legal text behind it. Read full brief · 915 words Key regulatory facts for MH Regulatory Dimension MH Standing Position Jurisdiction MH (MH) Regulatory Scope Crypto & Digital Asset Regulation (8 modules, 31 sourced findings) Crypto Licensing The Marshall Islands has no dedicated virtual-asset-service-provider (VASP) licensing statute. Token Classification No dedicated token-taxonomy statute exists. On-Chain Activity Regime No Marshall Islands statute or regulator guidance addresses staking, DeFi lending, mining, validator operation, node operation, or tokenization as distinct regulated activities. Stablecoin Regime No general stablecoin statute exists. Primary Instruments Cited Asia/Pacific Group on Money Laundering (APG) / FATF, CoinDesk, Decentralized Autonomous Organization Act 2022, Marshall Islands Monetary Authority (successor to Banking Commission), CoinDesk Last Confirmed / Updated 2026-10-25 (14 sources in cumulative register) 8 of 8 categories Signal Moved Judgment Gap Density Comfortable Compact Expand all sources Reset all Selections OR within a group, AND across groups. Press / to search. ### MH: C1 Crypto LicensingRedEnacted in forceModule confidence: Probable▾ The Marshall Islands has no dedicated virtual-asset-service-provider (VASP) licensing statute. The Banking Commission is the general financial-sector regulator under the Banking Act 1987 (market entry, licensing, prudential supervision, and the home of the FIU), but FATF's November 2024 mutual evaluation found no VASP-specific licence category and poor supervisory visibility over VASPs and DAO-operated VASPs. Separately, the Registrar for Non-Resident Domestic Entities (NRDE), the private company TCMI, actively enforces a prohibition on NRDE conducting VASP, banking, trust or insurance business. The Decentralized Autonomous Organization Act 2022 (amended 2023) provides a registration pathway (via MIDAO as registered agent) for DAOs as LLCs, with a 30-day maximum processing time, but this is a corporate-form registration, not a crypto-activity licence. Open gap — crypto-int-1 Whether the Monetary Authority Act 2025's exact repeal provision for the Sovereign Currency Act has been located in primary text (section/article number) remains unresolved. no under-indexing note recorded Open gap — crypto-int-2 Whether MH's NBFI licensing regime under the Banking Act 1987 / Monetary Authority Act 2025 explicitly names virtual-asset service providers, or whether this is purely a vendor inference, is unresolved. no under-indexing note recorded No sub-brief written this cycle The module carries open gaps but no narrative analysis was authored this cycle. Flagged for the next research pass. No periodic updates recorded in this cycle Sources and findings (8) - T3[Decentralized Autonomous Organization Act 2022](https://blockspot.io/country/marshall-islands/) — Grants DAOs legal entity status as domestic LLCs, letting an entity incorporate and self-identify as a 'DAO LLC' without a separate crypto-services licence. - T3[Sovereign Currency Act 2018](https://blockspot.io/country/marshall-islands/) — Repealed by the Monetary Authority Act 2025 in August 2025, following repeated IMF Article IV recommendations to repeal it. - T3[Marshall Islands Monetary Authority (successor to Banking Commission)](https://www.consulting24.co/marshall-islands-crypto-license/) — VASPs operating from or through MH are treated as falling within the broader Non-Bank Financial Institution licensing framework, rather than under a dedicated digital-asset statute. ### MH: C2 Token ClassificationAmberEnacted in forceModule confidence: Probable▾ No dedicated token-taxonomy statute exists. Classification treatment arises piecemeal: the amended DAO Act 2023 carves governance tokens out of securities treatment where they confer no economic rights; the Declaration and Issuance of the Sovereign Currency Act 2018 declares the never-issued SOV a digital decentralized currency and second legal tender; and the 2025 USDM1 instrument (part of the ENRA UBI program) is structured as a Treasury-backed digital bond under New York law rather than under any Marshall Islands token statute. C2 · Token Classification — Full Module Record 0 sub-modules · 180 words · 4 traced claims · Re-verified 2026-10-25 The decision headline, regulatory posture (Amber), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month , or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products) . [Unlock with Free Pass / Sign In](https://a-i.gi/auth/login) [View Pro & Firm Plans (£39 / £199)](https://a-i.gi/licensing/#plans)[View Open Exemplar (Gibraltar)](/jurisdictions/gi/) ### MH: C3 On-Chain Activity RegimeRedEnacted in forceModule confidence: Probable▾ No Marshall Islands statute or regulator guidance addresses staking, DeFi lending, mining, validator operation, node operation, or tokenization as distinct regulated activities. The DAO Act supplies only a corporate wrapper (LLC-equivalent legal personhood) for entities that may conduct such activities (e.g., a registered DAO operating a decentralized-exchange software business), without activity-specific prudential or conduct rules. C3 · On-Chain Activity — Full Module Record 0 sub-modules · 180 words · 2 traced claims · Re-verified 2026-10-25 The decision headline, regulatory posture (Red), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month , or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products) . [Unlock with Free Pass / Sign In](https://a-i.gi/auth/login)[View Pro & Firm Plans (£39 / £199)](https://a-i.gi/licensing/#plans)[View Open Exemplar (Gibraltar)](/jurisdictions/gi/) ### MH: C4 Stablecoin RegimeAmberEnacted in forceModule confidence: Probable▾ No general stablecoin statute exists. Two distinct instruments are relevant: (1) the Declaration and Issuance of the Sovereign Currency Act 2018, which remains in force authorizing the Ministry of Finance to issue the SOV digital currency via an ICO as second legal tender, though SOV has never been issued; and (2) USDM1, a 2025 Treasury-backed digital bond issued as part of the government's ENRA universal-basic-income program but structured and governed under New York law rather than Marshall Islands statute. Horizon · 2027 (± more than a year) MIBOND Global LLC sovereign digital currency PPP Proposed · Tier 3 source Horizon · 2026-Q4 (± six months) MIMA rulebook for USDM1 reserve/redemption/disclosure Adopted, not yet in force · Tier 1 source Periodic update · new data 2026-10-25 #### Stablecoin Regime The Marshall Islands has no dedicated stablecoin statute, and USDM1, the jurisdiction's government-issued digital sovereign-bond token, is explicitly not marketed or classified as a stablecoin by its issuer. It is instead characterised as a fully collateralized, USD-denominated sovereign bond issued natively on-chain across multiple networks, distinguished from a wrapped instrument. This classification matters for how the instrument should be read against a stablecoin framework: it sits adjacent to, rather than inside, the regulatory category that the module is nominally built to track, and the jurisdiction's traffic-light assessment for this module reflects an escalating trajectory precisely because the instrument's institutional footprint continues to grow even though no stablecoin-specific regulatory architecture has developed to accompany it. The strongest evidentiary anchor available is the International Monetary Fund's September 2025 Article IV concluding statement, which confirms that proceeds from the programme are earmarked entirely for the purchase of short-term United States Treasury bills as collateral. This is Tier 1 sourcing, materially stronger than the vendor-only commentary that supports most other characterisations of the instrument, including its basic classification description, which continues to rest on a single commercial vendor source describing the programme's custody and settlement infrastructure. The principal development is commercial rather than regulatory: on 23 October 2026, Ascend Markets, LLC and M1X Global completed what is reported as the first institutional repurchase transaction on the Stellar network using USDM1 as collateral, with the transaction's value undisclosed. The event does not itself change the instrument's regulatory classification or supervisory status, but it is evidence that the instrument's credit and settlement characteristics are being treated as acceptable for institutional repo purposes, which is a meaningful signal about market confidence in the Treasury-bill-backed collateral structure that the IMF statement confirms. No change was identified in the jurisdiction's absence of a dedicated stablecoin or broader digital-asset statute. The instrument continues to operate in a space the jurisdiction's own statutory framework does not explicitly address, relying instead on general corporate and monetary-authority law for whatever oversight exists. #### Outlook The variable most worth tracking is whether continued institutional uptake -- now including repo-market acceptance -- creates pressure for a dedicated supervisory or disclosure framework specific to the instrument, or whether the programme continues to operate under the jurisdiction's general corporate and monetary-authority law indefinitely. Any further primary-source confirmation of the instrument's backing arrangement or classification, beyond the IMF's September 2025 statement, would materially strengthen the evidentiary basis for future assessment. C4 · Stablecoins & EMTs — Full Module Record 0 sub-modules · 180 words · 5 traced claims · Re-verified 2026-10-25 The decision headline, regulatory posture (Amber), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month , or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products) . [Unlock with Free Pass / Sign In](https://a-i.gi/auth/login)[View Pro & Firm Plans (£39 / £199)](https://a-i.gi/licensing/#plans)[View Open Exemplar (Gibraltar)](/jurisdictions/gi/) ### MH: C5 Consumer ProtectionRedEnacted in forceModule confidence: Probable▾ No crypto-specific consumer-protection statute (custody/segregation, market-abuse, marketing/promotions, complaint-handling, or suitability rules) was identified. FATF's November 2024 mutual evaluation found the Marshall Islands vulnerable to investors proposing virtual-asset and 'Web 3.0' schemes, presenting significant ML/TF and reputational risk, with no corresponding consumer-facing risk-disclosure regime for crypto products. Absence reason not determinable No sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason. No periodic updates recorded in this cycle Sources and findings (4) ### MH: C6 Tax TreatmentGreenEnacted in forceModule confidence: Probable▾ The Marshall Islands operates a well-documented tax-exemption regime for its offshore corporate sector, confirmed by FATF's November 2024 mutual evaluation and multiple SEC EDGAR filings. Resident companies are taxed at 3% of turnover, while Non-Resident Domestic Entities (NRDE) and Non-Profit Organisations (which include DAO LLCs, registered under the amended Non-Profit Entities Act) are exempt from tax and from routine filing obligations. The EU briefly grey-listed the Marshall Islands in February 2023 over zero/nominal corporate tax rates and economic-substance enforcement, removing it in October 2023 after remediation. C6 · Tax Treatment — Full Module Record 0 sub-modules · 180 words · 5 traced claims · Re-verified 2026-10-25 The decision headline, regulatory posture (Green), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month , or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products) . [Unlock with Free Pass / Sign In](https://a-i.gi/auth/login)[View Pro & Firm Plans (£39 / £199)](https://a-i.gi/licensing/#plans)[View Open Exemplar (Gibraltar)](/jurisdictions/gi/) ### MH: C7 Cross-Border TransferAmberEnacted in forceModule confidence: Probable▾ No crypto-specific cross-border transfer regime was identified. A general corporate-law position is well-evidenced: the Marshall Islands imposes no exchange controls on non-resident corporations. Crypto-specific travel-rule/reporting-threshold obligations fall within the subscribed FIM aml_ctf baseline and are noted here only as disambiguation context. C7 · Cross-Border & Travel Rule — Full Module Record 0 sub-modules · 180 words · 2 traced claims · Re-verified 2026-10-25 The decision headline, regulatory posture (Amber), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month , or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products) . [Unlock with Free Pass / Sign In](https://a-i.gi/auth/login)[View Pro & Firm Plans (£39 / £199)](https://a-i.gi/licensing/#plans)[View Open Exemplar (Gibraltar)](/jurisdictions/gi/) ### MH: C8 AML/CFT RegimeAmberEnacted in forceModule confidence: Probable▾ Out of scope for this crypto baseline by design: AML/CFT crypto obligations for MH are produced by the subscribed Financial Integrity Monitor (FIM) aml_ctf baseline. Disambiguation context only: the Banking Commission (which includes the Financial Intelligence Unit) is MH's AML/CFT regulator and supervisor for financial institutions and DNFBPs under the Banking Act 1987, and the AML Regulations 2002 (amended August 2023) are the centrepiece AML/CFT instrument; FATF's November 2024 mutual evaluation rated Recommendation 15 (New technologies) as Partially Compliant, citing unsupervised VASPs and DAO-operated VASPs. C8 · AML/CFT Regime — Full Module Record 0 sub-modules · 180 words · 1 traced claims · Re-verified 2026-10-25 The decision headline, regulatory posture (Amber), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month , or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products) . [Unlock with Free Pass / Sign In](https://a-i.gi/auth/login)[View Pro & Firm Plans (£39 / £199)](https://a-i.gi/licensing/#plans)[View Open Exemplar (Gibraltar)](/jurisdictions/gi/)