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United States Minor Outlying Islands

Retail_Trading_Status

Allowed-Regulated Unknown
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Status Changed

Previous status: Unclear

The primary difference between the two analyses is the determined "Retail_Trading_Status," which shifted from "Unclear" in the previous analysis to "Allowed-Regulated" in the new analysis. This change stems from a refined interpretation of how U.S. federal law applies to the United States Minor Outlying Islands (USMOI) and a shift in emphasis from the practical realities of these territories to the overriding legal and regulatory framework. Justification for the differences: 1. **Interpretation of Legal Applicability vs. Practical Reality:** * The **Previous Analysis** concluded "Unclear" by heavily weighing the unique characteristics of the USMOI – primarily their lack of a permanent civilian resident population and the absence of local economic or financial infrastructure. While it acknowledged that U.S. federal law theoretically applies, it argued that the concept of "retail trading status" is practically moot or inapplicable in a context where there are no retail traders. The "Unclear" status reflected the ambiguity arising from the practical non-existence of the activity within these territories, despite the overarching U.S. legal framework. * The **New Analysis** adopts a more direct legalistic interpretation. It emphasizes that because the USMOI are U.S. territories, they fall under the jurisdiction of U.S. federal law. Crucially, the new analysis cites specific U.S. federal regulations, such as FinCEN's definition of "United States" (31 C.F.R. § 1010.100(hhh)) and the Federal Acquisition Regulation (FAR), which explicitly include territories and insular possessions. This direct legal linkage means that the U.S. federal regulatory framework for cryptocurrencies (covering AML/CFT, securities, commodities, and taxation) automatically extends to the USMOI. Therefore, for any U.S. individuals who might be present (e.g., military or research personnel) and could theoretically engage in such activities, the status would mirror that of the mainland U.S., which is "Allowed-Regulated." 2. **Focus of Regulatory Assessment:** * The **Previous Analysis** focused on whether there was a distinct, active regulatory environment or specific addressal of cryptocurrency trading *within* the USMOI themselves, or if the activity was practically relevant. Finding none specific to the islands and deeming the activity practically non-existent for a retail population, it leaned towards "Unclear." * The **New Analysis** focuses on the *existing* U.S. federal regulatory framework and its established applicability to U.S. territories. It posits that the absence of a local population or specific island-based regulations does not negate the fact that U.S. federal laws governing financial activities, including crypto trading, are in force. The status "Allowed-Regulated" is thus derived from the U.S. national-level approach. 3. **Emphasis on "Retail Traders":** * The **Previous Analysis** highlighted the absence of "retail traders" as a core reason for the "Unclear" status, suggesting that without a relevant population, the question of their trading status is ill-defined. * The **New Analysis**, while acknowledging the limited population, asserts that the legal framework applies to any U.S. persons who might be present on these islands. The regulations are tied to U.S. jurisdiction and persons, not necessarily to the presence of a large, permanent civilian retail market in a specific territory. In essence, the new analysis provides a more definitive status by prioritizing the legal supremacy and explicit territorial scope of U.S. federal financial regulations over the practical considerations of the USMOI's unique demographic and infrastructural situation. While retail trading by a civilian population is not a feature of the USMOI, the legal and regulatory conditions under which any U.S. person could engage in such activity are dictated by U.S. federal law, hence "Allowed-Regulated." The previous analysis's "Unclear" was more a reflection of the practical void and lack of specific local addressal, whereas the new analysis clarifies the default legal position based on established U.S. federal definitions and regulatory reach.

Analysis ID
#285
Version
Archived
Created
2025-06-26 09:13
Workflow Stage
Initial Research

Executive Summary

Cryptocurrency trading in the United States Minor Outlying Islands (USMOI) is legally permitted but regulated under U.S. federal law, as these islands fall under U.S. jurisdiction despite lacking permanent civilian populations. FinCEN classifies entities dealing with cryptocurrencies as Money Services Businesses (MSBs), requiring AML/CFT compliance and registration. The SEC considers many crypto assets as securities, mandating registration for offerings and exchanges, while the IRS treats cryptocurrencies as property for tax purposes. The practical application of retail trading is limited by the absence of a permanent civilian population.

Key Pillars

The primary regulator is the U.S. federal government, with oversight from agencies such as FinCEN, SEC, CFTC, IRS, and OFAC. Key compliance requirements include AML/CFT programs, KYC, recordkeeping, and reporting suspicious activities as mandated by FinCEN for MSBs. There are registration requirements with FinCEN for entities engaged in the exchange, transfer, or custody of cryptocurrencies, and potential SEC registration for exchanges and platforms dealing with crypto assets deemed securities.

Landmark Laws

  • Bank Secrecy Act (BSA): Requires cryptocurrency exchanges to register with FinCEN, implement AML/CFT programs, maintain records, and report to authorities.
  • FinCEN Guidance FIN-2019-G001: Requires persons accepting and transmitting Convertible Virtual Currencies (CVC) to register with FinCEN as MSBs and comply with AML/CFT program, recordkeeping, and reporting requirements. Applies equally to domestic and foreign-located CVC money transmitters doing business in whole or substantial part within the United States.

Considerations

Cryptocurrencies are classified as property by the IRS for tax purposes, meaning that transactions can result in taxable capital gains or losses. FinCEN does not consider cryptocurrencies to be legal tender but considers cryptocurrency exchanges to be money transmitters. The SEC considers many cryptocurrencies and crypto-related financial products to be securities. U.S. persons, including financial institutions dealing with cryptocurrencies, must comply with OFAC sanctions.

Notes

The United States Minor Outlying Islands (USMOI) are a statistical designation for nine insular areas of the United States and, with the exception of Palmyra Atoll, are unincorporated and unorganized territories. Due to the absence of distinct local civilian governments or financial regulatory bodies, the USMOI fall under the jurisdiction of United States federal law. The lack of a permanent civilian population limits the practical application of retail trading, but the legal and regulatory framework is dictated by U.S. federal policy. Regulations under the Bank Secrecy Act (BSA), administered by FinCEN, define the United States to include its territories and possessions.

Detailed Explanation

The United States Minor Outlying Islands (USMOI) consist of Baker Island, Howland Island, Jarvis Island, Johnston Atoll, Kingman Reef, Midway Atoll, Navassa Island, Palmyra Atoll, and Wake Island. Except for Palmyra Atoll, these are unincorporated and unorganized territories of the U.S. These islands typically do not have permanent residential populations, but rather house U.S. military personnel, U.S. Fish and Wildlife Service staff, and temporarily stationed scientists. As U.S. territories without distinct local governments or financial regulatory bodies, the USMOI are subject to United States federal law, including financial regulations. The term "United States" often includes its territories and possessions in federal regulations. For instance, FinCEN regulations under the Bank Secrecy Act (BSA) define the "United States" to encompass its territories and insular possessions. Similarly, the Federal Acquisition Regulation (FAR) includes these islands in its definition of "outlying areas."

Retail cryptocurrency trading is legally permitted in the USMOI, mirroring the broader United States. However, this activity is subject to a complex and evolving framework of federal regulations. There is no single, overarching federal regulatory framework specifically for digital assets; instead, existing financial laws are applied, and various agencies oversee different aspects of the crypto market. Key U.S. federal regulatory bodies include:

  • FinCEN: Classifies entities engaged in the exchange, transfer, or custody of cryptocurrencies as Money Services Businesses (MSBs). MSBs must register with FinCEN and implement AML/CFT programs, including customer due diligence (KYC), recordkeeping, and reporting suspicious activities. FinCEN guidance clarifies that these obligations apply to domestic and foreign-located CVC money transmitters doing business wholly or in substantial part within the United States. The Travel Rule also applies.
  • SEC: Considers many cryptocurrencies and crypto-related financial products to be securities. Offerings of these assets are subject to U.S. securities laws, requiring registration unless an exemption applies. Exchanges and platforms facilitating the trading of crypto assets deemed securities must also register with the SEC, which has been active in bringing enforcement actions against non-compliant crypto firms. The SEC's Division of Corporation Finance has issued guidance clarifying disclosure requirements for crypto asset offerings.
  • CFTC: Classifies certain cryptocurrencies, notably Bitcoin and Ether, as commodities. It has regulatory oversight over derivatives markets based on these assets (e.g., futures contracts) and exercises authority to combat fraud and manipulation in the spot markets for commodities in interstate commerce.
  • IRS: Treats cryptocurrencies as property, not currency, for U.S. federal tax purposes. Transactions involving cryptocurrencies can result in taxable capital gains or losses, which must be reported.
  • OFAC: Administers and enforces U.S. economic and trade sanctions. U.S. persons, including financial institutions dealing with cryptocurrencies, must comply with OFAC sanctions, including screening clients and not engaging in unauthorized transactions with sanctioned individuals, entities, or jurisdictions.

While there are no specific laws or regulatory bodies in the United States Minor Outlying Islands dedicated solely to cryptocurrency, any individual U.S. citizen (such as federal personnel stationed there) engaging in retail cryptocurrency trading would be subject to these overarching U.S. federal laws and regulations. The practical application of

Summary Points

## Retail Cryptocurrency Trading Status in United States Minor Outlying Islands (USMOI)

**Overall Status: Allowed-Regulated**

*   Retail cryptocurrency trading (buying, selling, and holding) is legally permitted for U.S. individuals present on the USMOI, subject to U.S. federal regulations.
*   Practical application is limited due to the lack of a permanent civilian population.

**1. Geographic and Legal Context**

*   **USMOI Definition:** Statistical designation for nine U.S. insular areas: Baker Island, Howland Island, Jarvis Island, Johnston Atoll, Kingman Reef, Midway Atoll, Navassa Island, Palmyra Atoll, and Wake Island.
    *   Source: [https://en.wikipedia.org/wiki/United_States_Minor_Outlying_Islands](https://en.wikipedia.org/wiki/United_States_Minor_Outlying_Islands)
*   **Territorial Status:** Primarily unincorporated and unorganized territories of the U.S. (except Palmyra Atoll).
*   **Population:** Primarily U.S. military, U.S. Fish and Wildlife Service personnel, or temporarily stationed scientific/research staff.
*   **Applicability of U.S. Law:** USMOI fall under U.S. federal law jurisdiction, including financial regulations.
    *   "United States" definition in federal regulations often includes territories and possessions.
    *   Source: Wikipedia, "U.S. territorial sovereignty"
    *   Source: [https://en.wikipedia.org/wiki/U.S._territorial_sovereignty](https://en.wikipedia.org/wiki/U.S._territorial_sovereignty)
    *   Source: Cornell Law School, Legal Information Institute, referencing e-CFR
    *   Source: [https://www.law.cornell.edu/cfr/text/31/596.312](https://www.law.cornell.edu/cfr/text/31/596.312)
    *   Source: Federal Register, "Federal Acquisition Regulation; Geographic Use of the Term 'United States'"
    *   Source: [https://www.federalregister.gov/documents/2001/07/27/01-18698/federal-acquisition-regulation-geographic-use-of-the-term-united-states](https://www.federalregister.gov/documents/2001/07/27/01-18698/federal-acquisition-regulation-geographic-use-of-the-term-united-states)
    *   Source: Acquisition.GOV
    *   Source: [https://www.acquisition.gov/far/2.101](https://www.acquisition.gov/far/2.101)

**2. Key Regulatory Bodies and Their Roles (U.S. Federal)**

*   **Financial Crimes Enforcement Network (FinCEN):**
    *   Classifies cryptocurrency exchanges, transferors, and custodians as Money Services Businesses (MSBs).
    *   Requires MSBs to register with FinCEN.
    *   Mandates comprehensive Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) programs, including:
        *   Customer Due Diligence (Know Your Customer - KYC)
        *   Recordkeeping
        *   Reporting suspicious activities
    *   "Travel Rule" applies: Requires financial institutions, including crypto asset service providers, to pass on certain originator and beneficiary information in transactions.
    *   Source: FinCEN, "Advisory on Illicit Activity Involving Convertible Virtual Currency"
    *   Source: [https://www.fincen.gov/resources/advisories/fincen-advisory-fin-2019-a003](https://www.fincen.gov/resources/advisories/fincen-advisory-fin-2019-a003)
    *   Source: Notabene
    *   Source: [https://notabene.id/crypto-travel-rule-united-states](https://notabene.id/crypto-travel-rule-united-states)
    *   Source: Sidley Austin LLP
    *   Source: [https://www.sidley.com/-/media/files/publications/2020/05/fincen-funds-travel-rule.pdf](https://www.sidley.com/-/media/files/publications/2020/05/fincen-funds-travel-rule.pdf)
*   **Securities and Exchange Commission (SEC):**
    *   Considers many cryptocurrencies and crypto-related financial products to be securities.
    *   Requires registration of crypto asset offerings unless an exemption applies.
    *   Requires exchanges and platforms trading crypto assets deemed securities to register with the SEC.
    *   Actively brings enforcement actions against non-compliant crypto firms.
    *   SEC's Division of Corporation Finance issues guidance on disclosure requirements for crypto asset offerings.
    *   Source: Debevoise & Plimpton LLP
    *   Source: [https://www.debevoise.com/insights/publications/2025/04/sec-clarifies-disclosure-requirements](https://www.debevoise.com/insights/publications/2025/04/sec-clarifies-disclosure-requirements)
*   **Commodity Futures Trading Commission (CFTC):**
    *   Classifies certain cryptocurrencies (e.g., Bitcoin, Ether) as commodities.
    *   Oversees derivatives markets based on these assets (e.g., futures contracts).
    *   Combats fraud and manipulation in the spot markets for commodities in interstate commerce.
    *   Source: Sumsub
    *   Source: [https://sumsub.com/crypto-regulations/us/](https://sumsub.com/crypto-regulations/us/)
*   **Internal Revenue Service (IRS):**
    *   Treats cryptocurrencies as property, not currency, for U.S. federal tax purposes.
    *   Transactions involving cryptocurrencies can result in taxable capital gains or losses.
    *   Taxpayers are required to report these transactions.
*   **Office of Foreign Assets Control (OFAC):**
    *   Administers and enforces U.S. economic and trade sanctions.
    *   U.S. persons dealing with cryptocurrencies must comply with OFAC sanctions.
    *   Includes screening clients and not engaging in unauthorized transactions with sanctioned individuals, entities, or jurisdictions.

**3. Important Legislation and Regulations**

*   **Bank Secrecy Act (BSA):** Forms the basis for AML/CFT regulations applied to cryptocurrency businesses.
*   **Securities Laws:** Applied to crypto assets deemed securities, requiring registration and compliance.
*   **Commodity Exchange Act (CEA):** Provides the CFTC with authority over commodity derivatives, including those based on cryptocurrencies.
*   **FinCEN Guidance FIN-2019-G001:** Clarifies that CVC money transmitters, domestic and foreign, doing business in the U.S. must register as MSBs and comply with AML/CFT requirements.
    *   Source: FinCEN
    *   Source: [https://www.fincen.gov/resources/advisories/fincen-advisory-fin-2019-a003](https://www.fincen.gov/resources/advisories/fincen-advisory-fin-2019-a003)

**4. Requirements for Compliance**

*   **Registration as MSB (if applicable):** Cryptocurrency exchanges, transferors, and custodians must register with FinCEN.
*   **AML/CFT Program:** Implement a comprehensive program, including KYC, recordkeeping, and suspicious activity reporting.
*   **Compliance with Securities Laws (if applicable):** Register offerings and trading platforms with the SEC if dealing with crypto assets deemed securities.
*   **Tax Reporting:** Report all cryptocurrency transactions to the IRS.
*   **Sanctions Compliance:** Comply with OFAC sanctions regulations.
*   **Travel Rule Compliance:** Crypto asset service providers must comply with the Travel Rule, passing on originator and beneficiary information in transactions.

**5. Notable Restrictions or Limitations**

*   **Lack of Specific USMOI Regulations:** No specific laws or regulatory bodies dedicated solely to cryptocurrency in the USMOI.
*   **Dependence on U.S. Federal Regulations:** Cryptocurrency activities are governed by overarching U.S. federal laws.
*   **Limited Practical Application:** The absence of a permanent civilian population limits the practical application of retail cryptocurrency trading.
*   **Regulatory Uncertainty:** The U.S. regulatory landscape for cryptocurrencies is still evolving, creating some uncertainty.

**6. Recent Developments or Changes**

*   **Ongoing SEC Enforcement Actions:** The SEC continues to actively pursue enforcement actions against crypto firms deemed non-compliant.
*   **SEC Guidance on Disclosure Requirements:** The SEC's Division of Corporation Finance has issued guidance clarifying disclosure requirements for crypto asset offerings.
    *   Source: Debevoise & Plimpton LLP
    *   Source: [https://www.debevoise.com/insights/publications/2025/04/sec-clarifies-disclosure-requirements](https://www.debevoise.com/insights/publications/2025/04/sec-clarifies-disclosure-requirements)
*   **Focus on DeFi Risks:** Increased scrutiny and assessment of illicit finance risks associated with Decentralized Finance (DeFi).
    *   Source: U.S. Department of the Treasury
    *   Source: [https://home.treasury.gov/system/files/136/DeFi-Risk-Assessment.pdf](https://home.treasury.gov/system/files/136/DeFi-Risk-Assessment.pdf)

Full Analysis Report

Report on Retail Cryptocurrency Trading Status in United States Minor Outlying Islands

Date: 2025-06-26

Topic: Retail_Trading_Status

Description: Assess whether individual citizens and residents in the country are legally permitted to buy, sell, and hold cryptocurrencies. Detail the regulatory environment surrounding this activity (e.g., KYC/AML requirements imposed on platforms, general warnings issued).

1. Identified Status

Allowed-Regulated

2. Detailed Narrative Explanation

The United States Minor Outlying Islands (USMOI) are a statistical designation for a group of nine insular areas of the United States: Baker Island, Howland Island, Jarvis Island, Johnston Atoll, Kingman Reef, Midway Atoll, Navassa Island, Palmyra Atoll, and Wake Island. With the exception of Palmyra Atoll (an incorporated territory), these are unincorporated and unorganized territories of the U.S. Critically, these islands do not have permanent residential populations in the typical sense; inhabitants are generally U.S. military personnel, U.S. Fish and Wildlife Service personnel, or temporarily stationed scientific and research staff.

Given their status as U.S. territories and the absence of distinct local civilian governments or financial regulatory bodies, the USMOI fall under the jurisdiction of United States federal law. This includes federal financial regulations. The term "United States," in the context of many federal regulations, is often defined to include its territories and possessions. For example, regulations under the Bank Secrecy Act (BSA), administered by the Financial Crimes Enforcement Network (FinCEN), define the United States to include "the States of the United States, the District of Columbia, the Indian lands...and the Territories and Insular Possessions of the United States." Similarly, the Federal Acquisition Regulation (FAR) defines "outlying areas" to include these minor outlying islands and clarifies the application of "United States" in various contexts to encompass such areas.

Therefore, the legal status of retail cryptocurrency trading for any U.S. individuals present on these islands would mirror that of the broader United States. In the U.S., retail cryptocurrency trading (buying, selling, and holding) is legally permitted but is subject to a complex and evolving framework of federal regulations. There isn't a single, overarching federal regulatory framework specifically for digital assets, but rather existing financial laws are applied, and various agencies oversee different aspects of the crypto market.

Key U.S. federal regulatory bodies and their roles concerning cryptocurrencies include:

  • Financial Crimes Enforcement Network (FinCEN): FinCEN classifies entities engaged in the exchange, transfer, or custody of cryptocurrencies (Convertible Virtual Currencies or CVCs) as Money Services Businesses (MSBs). MSBs are required to register with FinCEN and implement comprehensive Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) programs. This includes obligations such as customer due diligence (Know Your Customer - KYC), recordkeeping, and reporting suspicious activities. FinCEN guidance clarifies that these obligations apply to domestic and foreign-located CVC money transmitters doing business wholly or in substantial part within the United States. The "Travel Rule" also applies, requiring financial institutions, including crypto asset service providers, to pass on certain originator and beneficiary information in transactions.
  • Securities and Exchange Commission (SEC): The SEC considers many cryptocurrencies and crypto-related financial products to be securities. As such, offerings of these assets fall under U.S. securities laws, requiring registration unless an exemption applies. Exchanges and platforms facilitating the trading of crypto assets deemed securities must also register with the SEC. The SEC has been active in bringing enforcement actions against crypto firms it deems non-compliant. The SEC's Division of Corporation Finance has issued guidance clarifying disclosure requirements for crypto asset offerings.
  • Commodity Futures Trading Commission (CFTC): The CFTC classifies certain cryptocurrencies, notably Bitcoin and Ether, as commodities. It has regulatory oversight over derivatives markets based on these assets (e.g., futures contracts) and exercises authority to combat fraud and manipulation in the spot markets for commodities in interstate commerce.
  • Internal Revenue Service (IRS): For U.S. federal tax purposes, the IRS treats cryptocurrencies as property, not currency. This means that transactions involving cryptocurrencies (such as selling, exchanging, or using them to pay for goods or services) can result in taxable capital gains or losses. Taxpayers are required to report these transactions.
  • Office of Foreign Assets Control (OFAC): OFAC administers and enforces U.S. economic and trade sanctions. U.S. persons, including financial institutions dealing with cryptocurrencies, must comply with OFAC sanctions, which includes screening clients and not engaging in unauthorized transactions with sanctioned individuals, entities, or jurisdictions.

While there are no specific laws or regulatory bodies in the United States Minor Outlying Islands dedicated solely to cryptocurrency, any individual U.S. citizen (such as federal personnel stationed there) engaging in retail cryptocurrency trading would be subject to these overarching U.S. federal laws and regulations. The practical application of "retail trading" is limited by the lack of a permanent civilian population, but the legal and regulatory framework is dictated by U.S. federal policy. Therefore, the status is "Allowed-Regulated."

3. Specific, Relevant Text Excerpts

  • Regarding the status of the USMOI and applicability of U.S. Law:

    • "Except for Palmyra Atoll, all of these islands are unincorporated unorganized territories of the United States." (Source: Wikipedia, "United States Minor Outlying Islands")
    • "All territory under the control of the federal government is considered part of the 'United States' for purposes of law." (Source: Wikipedia, "U.S. territorial sovereignty," citing Insular Cases)
    • 31 C.F.R. § 1010.100(hhh) defines "United States" for FinCEN regulations as: "The States of the United States, the District of Columbia, the Indian lands (as that term is defined in the Indian Gaming Regulatory Act), and the Territories and Insular Possessions of the United States." (Source: Cornell Law School, Legal Information Institute, referencing e-CFR)
    • The Federal Acquisition Regulation (FAR) at 2.101 defines "Outlying areas" to include "Minor outlying islands" such as Baker Island, Howland Island, Jarvis Island, Johnston Atoll, Kingman Reef, Midway Islands, Navassa Island, Palmyra Atoll, and Wake Atoll. (Source: Federal Register, "Federal Acquisition Regulation; Geographic Use of the Term 'United States'")

  • Regarding U.S. Federal Regulation of Cryptocurrencies:

    • "At the federal level, the regulation of cryptocurrency-related activities in the United States is grounded in the application of existing financial laws to digital assets... Entities engaged in the exchange, transfer, or custody of cryptocurrencies are typically classified as Money Services Businesses (MSBs) and must register with the Financial Crimes Enforcement Network (FinCEN). Such entities must implement comprehensive Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) programs". (Source: Sumsub, "Crypto Regulations in the US—A Complete Guide (2025)")
    • "Cryptocurrency exchanges are legal in the United States and fall under the regulatory scope of the Bank Secrecy Act (BSA). In practice, this means that cryptocurrency exchange service providers must register with FinCEN, implement an AML/CFT program, maintain appropriate records, and submit reports to the authorities. Meanwhile, the US Securities and Exchange Commission (SEC) has indicated that it considers cryptocurrencies to be securities, and applies securities laws comprehensively to digital wallets and exchanges." (Source: ComplyAdvantage, "Cryptocurrency regulations around the world")
    • "The Financial Crimes Enforcement Network (FinCEN) does not consider cryptocurrencies to be legal tender but considers cryptocurrency exchanges to be money transmitters... The Internal Revenue Service (IRS) does not consider cryptocurrency to be legal tender but defines it as 'a digital representation of value that functions as a medium of exchange, a unit of account, and/or a store of value' and has issued tax guidance accordingly." (Source: ComplyAdvantage, "Cryptocurrency regulations around the world")
    • "The CFTC [Commodity Futures Trading Commission] classifies certain cryptocurrencies, such as Bitcoin, as commodities and oversees derivative markets based on these assets." (Source: Sumsub, "Crypto Regulations in the US—A Complete Guide (2025)")
    • FinCEN Guidance FIN-2019-G001 states: "As money transmitters, persons accepting and transmitting CVC are required, like any money transmitter, to register with FinCEN as MSBs and comply with anti-money laundering/countering the financing of terrorism (AML/CFT) program, recordkeeping, and reporting requirements. These requirements apply equally to domestic and foreign-located CVC money transmitters doing business in whole or substantial part within the United States, even if the foreign-located entity has no physical presence in the United States." (Source: FinCEN, "Advisory on Illicit Activity Involving Convertible Virtual Currency")

4. Direct, Accessible URL Links to Sources

  1. Vertex AI Search Result (General US Crypto Regulation): https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQFO7Eyi9Lrhl0vWqcvktrXp9f2G85WilIQKSxiJ2NvB51X-ZzfKENIj3lvTUsfKwwj2GSUBQcVA4tQi6tMaAYlcVmaoHbbQSdzukL5oWLFjrqNDiNeVreDBtZCXxiMD7nYMJZT6NEdegqqbhnDG-VKJVvTxZFkFRoobE4Dozcso (Note: This link points to a search result which itself contains multiple links to state-level regulations but also mentions the lack of a unified federal framework, which is relevant context).
  2. Wikipedia - United States Minor Outlying Islands: https://en.wikipedia.org/wiki/United_States_Minor_Outlying_Islands (Also cited as: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQFam33f1koBW9zcS4njYcmuPcCh_dm6IwDy0h0ggovCmOXqyUvTKErsOjMrFK-uZuJ3FlFnaTsUSHQIIH7pjRvAGd9cj-6uCMIcBwE4f_DG3Kt0uAMgWl7rGWw9KM5blKkiUko33Z_kssvZNvjK4Kk8-j8T9kLrTI4DdiGV)
  3. Sumsub - Crypto Regulations in the US—A Complete Guide (2025): https://sumsub.com/crypto-regulations/us/ (Also cited as: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQEgBwXGYB4WqF7BdzAC_VTwn8p78SIHg-9-eXwK0r2Gy1HZrT0Vn4kRYx9CVd9p7-WVlwPNMB9OTG_ML03-LA2sV04D3gwAgePkejwRYuhOmIXgZfiJyPez2iaOqX_WU2-LiPwZfTIphMXQ-O1IpTBII2uiEiJiX4DRwKiGvrW1Lg==)
  4. Cornell Law School (LII) - 31 CFR § 596.312 - United States: https://www.law.cornell.edu/cfr/text/31/596.312 (Also cited as: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQFInXpFn5blAUumgIh5wmL7bdpa0J2E6zo6d52c9--N54e9QWHwRTOTJ33B8ilKc-n4VVpIDSflyF2pyYfsLB-Eu4Sd9QCVCuHcQVE_Zs_d11fG1RSTx_qk7gjqx6sE74QvCJmoLH_vtPs=) (Note: This specific CFR part defines "United States" for Terrorism List Governments Sanctions Regulations, illustrating the broad definition often used. The more general FinCEN definition is at 31 C.F.R. § 1010.100(hhh)).
  5. KYC Hub - Cryptocurrency Regulation in the US: A Guide for 2025: https://kychub.com/cryptocurrency-regulation-in-the-us/ (Also cited as: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQFT3UZJtzoa6ay-9STpW-jKTr4t7zsL3F8UVkLiWqEd28iHbtfacBo3dM4Y8G0bxioV-WJH8TU9bA0ptZDpTQvLfMx4Wd4hu345wWRzfF0wRRvEzOhmz2qJTiVEHRsVq9fyArQqw3ip9o6neuUhy_xQldrHJrOyvimc3A==)
  6. Dow Jones - How are Cryptocurrencies Regulated?: https://www.dowjones.com/professional/risk/glossary/cryptocurrency-regulation/ (Also cited as: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQFiAs0UcR7cW1GnnTwKVLFrWp5kzzU0tgN9zSukwjjpKy9EtIs5bfCHWiArUSAe3IcStKYzJBGaYpAan-ASYsfFqP-w7t5CxvWaiSqmNv1O83ulWu2Sbmecnom5yh1hnVUA9gbPn5HiMyMbsX2K1QQnM_6sflV679haEllwmpiWiLtDMo7wT6F8nWHMKYDE_-mH)
  7. Thomson Reuters - Cryptocurrency laws and regulations: https://legal.thomsonreuters.com/en/insights/articles/cryptocurrency-laws-and-regulations (Also cited as: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQHlxpoV6VlzdebB532H_MRy4fM4R0MR6oGRlno5tmEfIGCztzuP9KmIup8Ga7V-XoOb_v-A55-HFBmfO-7DIJPpXyQHkZKW5vihBFe2BvJOgHkIRm7qHIGoQJXiE2MC9s7bpqU7hyRx1u4hdDI3E5l4IB22WQ==)
  8. Cornell Law School (LII) - 31 CFR § 1010.100 - General definitions (FinCEN): https://www.law.cornell.edu/cfr/text/31/1010.100 (Specifically see (hhh) for "United States" and (zz) for "Territories and Insular Possessions") (Also cited as: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQGFUekRzEo_IbXIP4axGgnzZyD9XMudze5h6euNZnkvap9TVAGs2d6PMcjwYei6AUWuHxYQQAdgmUkSasvXXQkD-bHakrSRe77rk7dtj9pwqGJLojHoxpVDictZxrPGNVjWxcBU0_zQE3oA)
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  19. GAO - U.S. Insular Areas: Applicability of Relevant Provisions of the U.S. Constitution: https://www.gao.gov/assets/hrd-91-18.pdf (Also cited as: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQGEVp_qniRW7K6qWSMBaYrQzzaFWLLKPYoxHkVMTpAC8nE_sAM3acDhD7bVcYfe0IEJP4jqPxK6FeX4KjSHhOR_nEatOiQZ0xNWBxEjdTctJsK4YrmPyClVIKgvmOgzvwP2kQ==)
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  21. FDIC - Section 3. Definitions (Federal Deposit Insurance Act): https://www.fdic.gov/regulations/laws/rules/1000-400.html (Defines "State" to include "any territory of the United States") (Also cited as: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQGrqu8oI82toQBr_FbghLnlO6QJpqXq5FVhD2oMoi2ub-x3TlT7Fpq2435lC83u8vckcdIIHFSH2Rs-2AOAb-qjpjkAsSvcs76QIIHjSh3THSeONA5VQP9mQUeMYEgMefwJDdGOgAoEc0dgGFuT-vQywBLYYGCP85kJTNvhsRnRo8AI)
  22. Quora (Discussion on US Territories): https://www.quora.com/If-Guam-Minor-Outlying-Islands-American-Samoa-Northern-Mariana-Islands-US-Virgin-Islands-Puerto-Rico-and-US-Associated-States-became-states-how-would-this-change-American-politics-What-political-parties-would-these-new-states-most-align-with (Provides general context on the status of various US territories, including uninhabited ones) (Also cited as: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQHqf2QtbX_GaNZ-v80tBrCSz8wGtXX0Bwn94f0Vsb0kM6jEMSsEhI_I-5F4Md1-_qAVkrkarNYkj9vDOiUb5sshduO5B1ci7POM4_ZKz9eFH2BU9EWrkTApkZPwiV8a2Qun40GscuZmHa_3g43MCdu6KOTN0Is27Rz2CFm4WDtMv2ShhT8E8eL_ENjX2Dpm0lr21E8NNLLlMlwu3grxwpZMlWvl_rkJdHx-5yfeWhU9VTWFmwRVz593QJ-y-lPcnjBrkMEp9pyK2L2QGU0mIGkenPaR3AZtVuDROv2YlPNVd4Ln6nlmwZUxIrd_S3pGQD3OBofxfvZeEC38rvKVJ4jZY6p62wmLxFcFbBk6sHmIFWTsST7aezM_UdoIMxSG4YTC52rgP-tx)
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  27. Econ One - A Quick Look at the New U.S. Post-Election Cryptocurrency Policy Regime (April 2025): https://www.econone.com/a-quick-look-at-the-new-u-s-post-election-cryptocurrency-policy-regime/ (Also cited as: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQE9ss-nZLfmLTuB7q7Pw8swfeVxIQ-QIsGeTxno-uwbseynfLeCAPdzQc9y7CQ6AoGsBWGhyIIRXY6AAkcLHCzMr1U-kSsImW-nTOw09OnIxdAlC6k_6hvGmztOaaUvNMOds1zMnGGGy2tAH6zpHaDkVHoOaS2wi3y41O4CHBf_MRQKfjUDyqOR3teeqw==)

Web Sources (19)

Sources discovered via web search grounding

Search queries used (6)
  • applicability of US federal law to United States Minor Outlying Islands
  • legal status and governance United States Minor Outlying Islands
  • US cryptocurrency regulations federal level
  • FinCEN guidance cryptocurrency United States territories
  • SEC cryptocurrency regulation applicability in US territories
  • Definition of 'United States' in federal financial regulations for territories
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