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Micronesia (Federated States of)

Retail_Trading_Status

Gray-Zone Medium Confidence
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Analysis ID
#728
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Archived
Created
2025-12-12 04:52
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Step 1

Executive Summary

Retail cryptocurrency trading in the Federated States of Micronesia (FSM) exists in a regulatory gray zone. While the possession and trading of digital assets by individuals are not explicitly criminalized, the financial sector is effectively restricted from facilitating these transactions. The FSM Banking Board and the Department of Finance and Administration have indicated that the country is 'not ready' to entertain virtual assets due to the lack of a legal framework, and reports indicate a 2021 clarification prohibiting financial institutions from transacting in crypto-assets.

Key Pillars

FSM Banking Board (Primary Regulator for banking sector)
Department of Finance and Administration (Government financial policy)
Federal Deposit Insurance Corporation (FDIC) oversight (due to Compact of Free Association with the US, covering Bank of FSM and Bank of Guam)

Landmark Laws

FSM Banking Act (Title 29 of the FSM Code) (29 FSMC) - Enacted: 1980-01-01
- Governs the licensing and regulation of banking business. While not mentioning crypto explicitly, it gives the Banking Board broad powers to determine permissible activities. The Board has used this authority to deem the jurisdiction 'not ready' for virtual assets.
- Source

Considerations

Banking Blockade: Local banks (Bank of FSM and Bank of Guam) are hesitant or prohibited from processing crypto-related transactions, making fiat on/off-ramping difficult.
US Dollar Legal Tender: FSM uses the USD, and regulators emphasize this as the only legal tender, rejecting crypto as a substitute.
FDIC Influence: As FSM banks are FDIC insured, they likely adhere to strict US-style risk management, further discouraging engagement with unregulated crypto entities.
No Local Exchanges: There are no licensed domestic Virtual Asset Service Providers (VASPs).

Notes

FSM is a member of the Asia/Pacific Group on Money Laundering (APG). Its banking system is heavily integrated with the US financial system due to the Compact of Free Association, meaning US regulatory trends (like SEC/OCC guidance) indirectly influence local bank policies.

Remaining Uncertainties

  • The exact text of the 2021 Finance Ministry clarification is not available in the public domain, only referenced by secondary legal sources.
  • Whether individual peer-to-peer trading is actively monitored or ignored by authorities.
  • If the FSM Banking Board plans to introduce a sandbox or regulation in the near future, given their participation in IMF/World Bank meetings on the topic.

Full Analysis Report

The regulatory status of cryptocurrency in the Federated States of Micronesia (FSM) is best characterized as a 'Gray-Zone'. While there is no penal code criminalizing the individual ownership or trade of cryptocurrencies, the government has taken a restrictive stance regarding the integration of virtual assets into the formal financial system. The primary regulator, the FSM Banking Board, has explicitly stated in its Annual Reports (notably 2022 and 2023) that the country is 'not ready to entertain digital currencies and virtual assets' due to the absence of a legal framework. This position effectively acts as a regulatory barrier, preventing local banks from offering crypto services or facilitating payments to crypto exchanges.

In 2021, the Ministry of Finance reportedly clarified that financial institutions are not permitted to use or transact in crypto-assets. This directive aligns with the Banking Board's conservative approach, which prioritizes the stability of the banking sector and the US Dollar's status as the sole legal tender. Consequently, the two commercial banks operating in the country—Bank of Guam and Bank of the FSM—do not service crypto businesses. Both banks are FDIC-insured and subject to US banking standards under the Compact of Free Association, which adds another layer of compliance pressure against dealing with unregulated entities.

For retail investors, this means that while they are not breaking the law by holding Bitcoin or other assets, they face significant operational hurdles. There are no domestic exchanges, and funding international exchange accounts via local bank transfers is likely to be blocked or scrutinized. The regulatory environment is stagnant; despite acknowledging the global rise of crypto, the Banking Board has not moved to create a licensing regime, leaving the sector in a state of indefinite restriction without a total ban.

Source Evidence

Primary and secondary sources cited in this analysis

2023-12-31

"The Board believes FSM is not ready to entertain digital currencies and virtual assets as there is no legal framework in place for governing these alternative forms of payments."

2022-12-31

"The Board; however, still has much to learn about cryptocurrency... especially in view of important public interest issues such as safety, confidentiality, stability, among many others."

FSM Banking Act (Title 29) primary (law_text)
1980-01-01

"No person shall engage in the business of accepting deposits... unless it has been granted a license."

2024-01-01

"In 2021, the Finance Ministry clarified that financial institutions are not permitted to use or transact in crypto-assets."

Investment Climate Statements: Micronesia secondary (official_government)
2021-07-21

"The only two commercial banks operating in the country at present are the Bank of Guam and the Bank of the FSM, both of which were FDIC insured."

Web Sources (2)

Sources discovered via web search grounding

Search queries used (10)
  • Micronesia crypto legal status
  • Federated States of Micronesia cryptocurrency regulation
  • FSM Banking Act virtual currency
  • APG Mutual Evaluation Report Micronesia virtual assets
  • FSM Banking Board cryptocurrency circular
  • Micronesia crypto tax laws
  • "FSM Banking Board" cryptocurrency circular
  • "Bank of Guam" FSM cryptocurrency restrictions
  • "Bank of the FSM" cryptocurrency policy
  • Federated States of Micronesia Finance Ministry crypto 2021
bankingboard.gov.fm

https://bankingboard.gov.fm/PDF/Annual%20Report/2024/2024%20Annual%20Report_FINAL.pdf

bankingboard.gov.fm

https://bankingboard.gov.fm/PDF/Annual%20Report/2022/2022%20Annual%20Report%20(Final).pdf

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