Not publishable as-is. 1 of 6 publication_gate checks fail. The renderer displays the gate rather than suppressing it. Legal review and sub-brief approval are informational and are not part of this test.
VU
VUschema crypto-v2.0.0trajectory: not yet assessedunregulated gapoverlaps: FIM
Last updated · 8 categories · 18 sourced
findings · 5 sources in the cumulative register
8Categoriesbaseline.
18Findings.claims[]
1Tier-1 sourcesrun_metadata.t1_source_count
Confidence mix(sums to 8 rendered categories; click to filter)
No categories moved this cycle.
Jurisdiction lead brief
Standing brief, as of 18 October 2026.
Lead Signal
Vanuatu's crypto regime enters this cycle with its licensing architecture intact and operational, but with two structural uncertainties converging: a scheduled legislative amendment to the Virtual Asset Service Providers Act No. 3 of 2025, and the Stablecoins Act's supervisory apparatus now staffed with its first Commissioner. The VFSC continues to process VASP licence applications within a 90-working-day statutory window under section 13 of the Act, a standing and unchanged requirement. What has moved is the legislative horizon: Parliament's First Extraordinary Session, sitting 19 to 30 October 2026, will debate amendments touching Virtual Asset Service Providers among a package of 28 bills, though the substantive content of those amendments has not been located this cycle.
Other Developments
Stablecoin supervisory commission now staffed. The Stablecoins Act No. of 2025 established a Stablecoin Supervisory Commission, appointed by the Minister of Finance on recommendation of the Reserve Bank, to regulate, supervise and oversee specified stablecoins. Jackson Miake took office as Vanuatu's first Commissioner of Stablecoins in July 2026, moving the regime from an enacted-but-unstaffed posture toward operational capacity. The Act defines a specified reserve assets pool as a dedicated, separate collection of highly liquid and stable assets fully backing a specific type of stablecoin, a reserve-adequacy requirement that sits at the core of the regime's prudential design.
VASP Act amendment scheduled, substance unknown. Press reporting confirms that amendments concerning Virtual Asset Service Providers are on the agenda for Parliament's 19-30 October 2026 session, alongside amendments to Company and Trust Service Providers, International Companies, Companies and Unit Trust legislation. No primary bill text has been retrieved, so the direction and scope of the VASP amendment remains an open question for the next research window.
Cross-Monitor Connections
The same AML/CTF (Amendment) Bill scheduled for this Parliament session, and reported independently in financial-integrity channels, is being debated alongside the VASP amendment, suggesting Vanuatu's legislative push this session is coordinated across its anti-money-laundering and digital-asset frameworks rather than confined to one sector. The Stablecoins Act's reinforcement of AML/CTF Act No. 13 of 2014 obligations on stablecoin licensees is a further point of overlap between the crypto and financial-integrity regimes, both of which are watching the same 19-30 October sitting for enactment outcomes.
Outlook
The principal date to watch is the close of the First Extraordinary Session on 30 October 2026, when the substantive content of the VASP Act amendment will become known. Until then, the standing licensing and reserve-asset framework continues to apply unchanged, and the operational Stablecoin Supervisory Commission under Commissioner Miake is the clearest sign of forward movement in implementation capacity this cycle.
8 of 8 categories
Signal
Density
Selections OR within a group, AND across groups. Press / to search.
Vanuatu has no stand-alone virtual-asset/crypto-asset-service-provider licensing Act. The only government-issued market-entry gate that could capture a crypto exchange or brokerage is the Dealers in Securities Act, under which the Minister of Finance (on advice of the VFSC) grants securities-dealer licences; a second, informal gate is VFIU registration for money/value-transfer or currency-changing reporting entities under the AML/CTF Act. Neither instrument was designed for virtual assets, and the VFSC's name has repeatedly been invoked without authorisation by offshore brokers that were never licensed, as confirmed in at least one US CFTC consent order.
Standing sub-brief · as of 18 October 2026335 words · last cycle 2026-10-18
Crypto Licensing
Vanuatu's Virtual Asset Service Providers Act No. 3 of 2025 remains the standing licensing framework, administered by the VFSC. Under the Act, a company must apply to the VFSC Commissioner for a VASP licence, with a decision due within 90 working days of application — a confirmed, unchanged statutory provision carried forward from the Act's commencement. This licensing mechanism has not altered this cycle.
What has entered the picture is a scheduled legislative amendment: Parliament's First Extraordinary Session, sitting 19 to 30 October 2026, will consider amendments concerning Virtual Asset Service Providers as part of a 28-bill package that also touches Company and Trust Service Providers, International Companies, Companies and Unit Trust legislation, and the Anti-Money Laundering and Counter-Terrorism Financing Act. Press reporting confirms the amendment is scheduled but does not state its substantive content, so whether the amendment tightens, clarifies, or extends the existing VASP licensing regime cannot yet be determined.
Separately, vendor commentary not independently verified against the Act's own text states that VASP licence applicants must already hold all four classes of Financial Dealers Licence (A through D) before a VASP application can be submitted. This would, if accurate, impose a substantial prudential and operational prerequisite ahead of VASP authorisation, but the claim rests on advisory-firm commentary rather than the statutory text itself, and should be treated with that caveat. Similarly, no penalty provisions for unauthorised VASP activity or breach of the Act have been located this cycle, leaving the enforcement consequences of non-compliance unconfirmed.
Outlook
The amendment scheduled for the 19-30 October 2026 session is the development to watch: its substantive content, once available, will determine whether Vanuatu's VASP licensing regime is being tightened in line with the broader coordinated legislative push evident elsewhere in this session (the parallel AML/CTF amendment Bill), or whether the changes are more technical in nature. Confirmation of the reported Financial Dealers Licence prerequisite against the Act's own text, and location of the Act's penalty provisions, remain open research priorities for the next cycle.
no periodic updates on record for this sub-brief
Sources and findings (5)
T2 · FATF / Asia-Pacific Group on Money Laundering (APG)FATF / Asia-Pacific Group on Money Laundering (APG) — Dealers in Securities Act: a person carrying on business as a dealer in securities in or from Vanuatu must hold a licence granted by the Minister of Finance on the advice of the VFSC; this is the only government-issued authorisation route through which a Vanuatu entity offering crypto-asset dealing/brokerage could obtain a formal licence, as no dedicated virtual-asset licence category exists.retrieved M4bindingin force
T1 · U.S. Commodity Futures Trading CommissionU.S. Commodity Futures Trading Commission — A US CFTC consent order confirms the VFSC as Vanuatu's financial regulatory authority and records that the VFSC never registered or licensed certain entities that marketed themselves abroad as VFSC-licensed brokers, evidencing a pattern of unlicensed actors invoking the VFSC's name rather than any dedicated Vanuatu crypto-enforcement framework.retrieved M3non-binding
T2 · FATF / Asia-Pacific Group on Money Laundering (APG)FATF / Asia-Pacific Group on Money Laundering (APG) — Under the AML/CTF Act, all reporting entities, including providers of a money or value transfer service or a money/currency-changing service, must register with the Vanuatu Financial Intelligence Unit (VFIU); absent a dedicated crypto-asset Act, this registration duty is the primary formal gate applicable to Vanuatu entities conducting crypto-to-fiat exchange or value-transfer activity.retrieved M4bindingin force
T2 · FATF / Asia-Pacific Group on Money Laundering (APG)FATF / Asia-Pacific Group on Money Laundering (APG) — No crypto-asset-service-provider own-funds or prudential-capital regime has been identified in Vanuatu law; the Dealers in Securities Act's fit-and-proper/market-entry checks are not accompanied by any published minimum-capital schedule specific to virtual-asset activity.retrieved M3non-bindinga fact about the regime
T1 · U.S. Commodity Futures Trading CommissionU.S. Commodity Futures Trading Commission — No published fixed administrative-fine schedule, turnover-based penalty, or criminal maximum sentence specific to unauthorised virtual-asset-service provision in Vanuatu has been located; enforcement to date relies on the VFSC issuing public confirmations that it has not licensed a given entity rather than a published penalty regime.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run
Vanuatu has not published any statutory or regulatory taxonomy classifying crypto-assets/tokens (security token, e-money token, asset-referenced token, utility token, stablecoin, NFT). The only theoretically applicable test is a case-by-case assessment of whether a token meets the Dealers in Securities Act's definition of 'securities', but no VFSC interpretive guidance, consultation paper, or published determination applying that test to crypto-assets has been identified.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
no periodic updates on record for this sub-brief
Sources and findings (1)
T2 · FATF / Asia-Pacific Group on Money Laundering (APG)FATF / Asia-Pacific Group on Money Laundering (APG) — No VFSC guidance, regulation, or published case law applies the Dealers in Securities Act's definition of 'securities' to crypto-assets/tokens, so whether a given token is treated as a security token, utility token, stablecoin, or other instrument in Vanuatu remains formally undetermined.retrieved M3non-bindinga fact about the regime
No Vanuatu statute or VFSC/VFIU guidance addresses staking, DeFi lending, DEX operation, mining, node operation, validator activity, or tokenisation. None of these on-chain activities are mentioned in the Dealers in Securities Act, the International Banking Act, or the AML/CTF Act framework identified in the sources reviewed.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
no periodic updates on record for this sub-brief
Sources and findings (1)
T2 · FATF / Asia-Pacific Group on Money Laundering (APG)FATF / Asia-Pacific Group on Money Laundering (APG) — No Vanuatu statute or VFSC/VFIU guidance addresses DeFi lending, staking, DEX operation, mining, node operation, validator activity, or tokenisation; these on-chain activities fall outside every Vanuatu financial-services instrument identified in this research pass.retrieved M2non-bindinga fact about the regime
No stablecoin-specific issuance-authorisation, reserve-requirement, redemption-right, or systemic-designation regime has been identified in Vanuatu law; no e-money-token or asset-referenced-token framework analogous to MiCA exists.
Standing sub-brief · as of 18 October 2026283 words · last cycle 2026-10-18
Stablecoin Regime
The Stablecoins Act No. of 2025, passed by Parliament on 10 November 2025, establishes the core architecture for stablecoin regulation in Vanuatu. The Act defines a specified reserve assets pool as a dedicated and separate collection of highly liquid and stable assets that fully backs a specific type of stablecoin, a direct statutory requirement confirmed against the primary Bill text. The Act also establishes a Stablecoin Supervisory Commission, appointed by the Minister of Finance on recommendation of the Reserve Bank, with the function of regulating, supervising and overseeing specified stablecoins.
The material development this cycle is that this supervisory architecture has moved from enacted to staffed: Jackson Miake was named Vanuatu's first Commissioner of Stablecoins, with the appointment taking effect in July 2026. Trade-press coverage of the appointment notes that key operational questions remain unanswered, though the specific gaps are not detailed in the source available this cycle. The appointment nonetheless represents the regime's first concrete step from statutory design toward active supervision.
It is worth noting, from the VFSC's own public statement, that the separate Virtual Asset Service Providers Act does not extend to stablecoins, tokenized securities, or central bank digital currencies — confirming that the Stablecoins Act operates as a dedicated, parallel instrument rather than a subset of the general VASP licensing regime.
Outlook
With a Commissioner now in office, the next development to watch is whether the Stablecoin Supervisory Commission begins issuing licences, guidance, or enforcement action under the reserve-asset-pool requirement. The unanswered operational questions flagged by trade press at the time of the appointment are a signal that implementation detail — rather than the statutory framework itself — is the open variable for this regime going forward.
no periodic updates on record for this sub-brief
Sources and findings (1)
T2 · FATF / Asia-Pacific Group on Money Laundering (APG)FATF / Asia-Pacific Group on Money Laundering (APG) — No Vanuatu statute establishes an issuance-authorisation, reserve-requirement, redemption-right, or systemic-designation regime for stablecoins, e-money tokens, or asset-referenced tokens; stablecoin issuance in or from Vanuatu is not addressed by the Dealers in Securities Act, the International Banking Act, or the AML/CTF Act as identified in the sources reviewed.retrieved M3non-bindinga fact about the regime
Vanuatu has no crypto-specific consumer-protection code: no custody-segregation rule for virtual assets, no crypto market-abuse regime beyond general (and incomplete) criminalisation of insider trading/market manipulation as ML predicates, no crypto promotions/marketing rule, and no complaint-handling or suitability regime specific to virtual-asset services. General Dealers in Securities Act fit-and-proper requirements apply only to the narrow class of entities that obtain a securities-dealer licence.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
no periodic updates on record for this sub-brief
Sources and findings (4)
T2 · FATF / Asia-Pacific Group on Money Laundering (APG)FATF / Asia-Pacific Group on Money Laundering (APG) — No Vanuatu law requires segregation of client virtual assets from a service provider's own assets, defines custodian liability caps, or sets rules for sub-custody/delegation of client crypto-assets; the custody/safekeeping limb of virtual-asset activity is unaddressed by any Vanuatu instrument identified.retrieved M4non-bindinga fact about the regime
T2 · Asia/Pacific Group on Money Laundering (APG) / FATFAsia/Pacific Group on Money Laundering (APG) / FATF — No crypto-specific market-abuse regime (insider dealing, unlawful disclosure, or market-manipulation rules applied to virtual assets) has been identified in Vanuatu law; Vanuatu's APG mutual evaluation separately found that insider trading and market manipulation had not yet been criminalised as money-laundering predicate offences generally.retrieved M4non-binding
T2 · FATF / Asia-Pacific Group on Money Laundering (APG)FATF / Asia-Pacific Group on Money Laundering (APG) — No Vanuatu statute sets lawful routes for approving a crypto-asset promotion, mandates risk warnings or cooling-off periods for retail crypto marketing, or creates an offence for unapproved crypto financial promotions; no analogue to a financial-promotions regime for virtual assets has been identified.retrieved M3non-bindinga fact about the regime
T2 · FATF / Asia-Pacific Group on Money Laundering (APG)FATF / Asia-Pacific Group on Money Laundering (APG) — No Vanuatu instrument sets a complaints-handling procedure, response deadline, or ombudsman-access right specific to virtual-asset-service clients; the VFSC/VFIU's general supervisory powers do not include a published crypto-consumer complaints process.retrieved M3non-bindinga fact about the regime
Vanuatu levies no income tax, capital gains tax, or withholding tax on companies, trusts, or individuals (crypto gains included by extension, since no crypto-specific carve-out exists), though indirect taxes (VAT and import levies) apply. This reflects Vanuatu's long-standing status as a zero-direct-tax offshore financial centre rather than any crypto-specific tax rule; no domestic analogue to the OECD Crypto-Asset Reporting Framework has been confirmed.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
no periodic updates on record for this sub-brief
Sources and findings (4)
T2 · Asia/Pacific Group on Money Laundering (APG) / FATFAsia/Pacific Group on Money Laundering (APG) / FATF — Vanuatu does not levy any capital gains tax on companies, trusts, or individuals; by extension, no capital-gains charge applies to crypto-asset disposals in Vanuatu absent any crypto-specific carve-out.retrieved M4bindingin force
T2 · Asia/Pacific Group on Money Laundering (APG) / FATFAsia/Pacific Group on Money Laundering (APG) / FATF — No income tax applies to companies, trusts, or individuals in Vanuatu, which extends by default to any income characterised from crypto-asset trading, mining, or staking activity absent a specific carve-out.retrieved M4bindingin force
T2 · Asia/Pacific Group on Money Laundering (APG) / FATFAsia/Pacific Group on Money Laundering (APG) / FATF — Indirect taxes, including value-added tax (VAT) and import levies, are charged in Vanuatu notwithstanding the absence of direct income or capital-gains taxation; whether VAT attaches to crypto-asset supplies specifically has not been confirmed by any VFSC or tax-office guidance identified.retrieved M3bindingin force
T2 · Asia/Pacific Group on Money Laundering (APG) / FATFAsia/Pacific Group on Money Laundering (APG) / FATF — No Vanuatu-specific crypto-asset tax-reporting obligation (e.g., a domestic analogue to the OECD Crypto-Asset Reporting Framework, CARF) has been identified; Vanuatu's participation status in CARF/international tax-transparency exchange for crypto-assets was not confirmed in any source reviewed.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run
Vanuatu has no crypto-specific passporting regime, reverse-solicitation rule, or outbound-restriction specific to virtual-asset transfers. General AML/CTF Act registration and VFIU information-sharing powers are the only cross-border-relevant levers identified, and a Vanuatu Dealers-in-Securities licence or VFIU registration confers no recognised access to the EU MiCA regime, the UK's future cryptoasset regime, or any other major-market third-country-access arrangement.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
no periodic updates on record for this sub-brief
Sources and findings (2)
T2 · FATF / Asia-Pacific Group on Money Laundering (APG)FATF / Asia-Pacific Group on Money Laundering (APG) — No Vanuatu statute restricts outbound crypto-asset transfers, sets a cross-border reporting threshold specific to virtual assets, or creates a Travel-Rule cross-border mechanism; the VFIU's general AML/CTF Act information-sharing powers are the only identified cross-border-relevant instrument, and they are not crypto-specific.retrieved M3non-bindinga fact about the regime
T2 · FATF / Asia-Pacific Group on Money Laundering (APG)FATF / Asia-Pacific Group on Money Laundering (APG) — A Vanuatu Dealers-in-Securities licence or VFIU registration confers no recognised passporting or equivalence access to the EU MiCA regime or the UK's future cryptoasset regime; no mutual-recognition or third-country-access arrangement between Vanuatu and either regime has been identified.retrieved M3non-bindinga fact about the regime
Crypto subscribes to the fleet's financial-integrity (FIM aml_ctf) producer for AML/CFT content; this baseline therefore does not duplicate aml_cft_regime claims. For disambiguation context only: Vanuatu's AML/CFT framework runs through the AML/CTF Act and the Vanuatu Financial Intelligence Unit (VFIU), which registers money/value-transfer and currency-changing reporting entities; Vanuatu is an APG (Asia/Pacific Group on Money Laundering) member subject to FATF mutual evaluation. No aml_cft_regime claims are emitted here by design.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
no periodic updates on record for this sub-brief
No categories match.
Filters combine as OR inside a group and AND across
groups.
Publication gate
Blocking. 1 failing check(s).
schema_valid
pass
source_tier_integrity_ok
pass
every_practical_object_has_source_id
n/a — no subject in this jurisdiction
min_quoted_text_present
waived — floor 0%
egress_verified
pass
manual_override
FAIL
jurisdiction_source_floor_met
pass
tier_a_b_national_primary_pct
100.0
aggregator_only_jurisdiction_count
0
Editorial metadata
Provenance only. Nothing below gates publication or affects the render.
Editorial metadata for VU
Field
Value
trust.lawyer_review.status
never_reviewed
trust.lawyer_review.reviewer
no reviewer on record
trust.content_source
ai_generated
Provenance and declared absence
Disclosure model: module cards load OPEN; standing positions render in full; sub-briefs and jurisdiction briefs load as a clamped teaser with an explicit “read full” control carrying the true word count; earlier updates stay collapsed behind a counted summary. No text is hidden without disclosing how much of it there is.
Sentinel-fed modules receive no special rendering treatment. sentinel_feed is an attribution chip only: it does not suppress content, does not generate an absence reason code, and does not exclude the module from any count, filter, search index or export on this page.
Family taxonomy is renderer-level presentation config, not a JID field. Colour is always duplicated in text and is never the sole carrier of meaning.
Band honesty: uncertainty bands are computed against a frozen build clock of 2026-10-20. A year-precision row is never promoted into a tighter band.
Orphan deltas: 0 cycle_delta row(s) target non-module objects and are listed in the rail rather than attached to a card.
Envelope: baseline resolved at jurisdiction_json.baseline; 8 module(s), 18 finding(s), 5 source(s) in the cumulative register.
Audit trail
Machine checkChallenged on 6 Oct 2026: nothing tested (no claim on this page was eligible for an automated test). An automated, adversarial test run by a second model; no person has assessed the result.