Samoa
Retail_Trading_Status
- Analysis ID
- #776
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- 2025-12-12 05:12
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Executive Summary
Retail cryptocurrency trading in Samoa operates in a regulatory "Allowed-Unregulated" status. While the Money Laundering Prevention Amendment Act 2018 legally classifies cryptocurrency promoters and dealers as financial institutions requiring a license, the Central Bank of Samoa (CBS) has adopted a 'cautious approach' and has not yet issued any active licenses, effectively freezing the legal local market. The government explicitly stated in 2023 that it would not endorse or license any exchanges until a feasibility study is completed, a stance maintained through late 2025. Additionally, the CBS has previously issued directives blocking foreign exchange transactions related to crypto assets to protect national reserves, and commercial banks are advised to treat crypto-related transactions with extreme caution.
Key Pillars
Primary Regulator: Central Bank of Samoa (CBS)
Financial Intelligence Unit (FIU): Enforces AML/CTF rules under the Money Laundering Prevention Act
Licensing Requirement: Promoters and dealers are legally defined as 'Financial Institutions' and require a valid business license (though none are currently issued)
Banking Restrictions: CBS has authority to block foreign exchange transactions involving crypto to protect foreign currency reserves
Landmark Laws
Money Laundering Prevention Amendment Act 2018 (Act No. 13 of 2018) - Enacted: 2018-06-22
- Amended the principal act to include 'dealers or promoters of virtual or digital currency' as Financial Institutions, subjecting them to AML/KYC reporting and licensing requirements.
- Source
CBS Directive on Foreign Exchange Transactions (Press Release / Directive) - Enacted: 2018-05-07
- Blocked all foreign exchange transactions related to the OneCoin cryptocurrency promotion to protect foreign reserves; set a precedent for blocking crypto outflows.
- Source
Government Statement on Unapproved Digital Asset Exchanges (Press Release) - Enacted: 2023-06-16
- Clarified that the 'Samoa Digital Asset Exchange' launched in Hong Kong was not approved. Stated no licenses would be issued until a feasibility study is completed.
- Source
Considerations
Licensing Freeze: Although the law allows for licensed crypto businesses, the government has placed a moratorium on issuing licenses pending a feasibility study.
Banking Blockade: Banks are instructed to block transactions linked to crypto scams, and general crypto purchases may be caught under foreign exchange controls.
Legal Tender Status: Crypto is explicitly not legal tender in Samoa.
Scam Sensitivity: Regulation is heavily influenced by the OneCoin pyramid scheme, leading to a presumption of high risk for all crypto activities.
Notes
The 2018 Amendment Act created a legal paradox where crypto businesses are defined but cannot operationally exist due to the lack of issued licenses. This is a common pattern in Pacific Island nations attempting to comply with FATF standards without necessarily wanting to host a crypto industry.
Remaining Uncertainties
- Status of the 'Feasibility Study' announced in 2023: Has it concluded internally without public release?
- Specifics of current banking enforcement: Do banks automatically block all transfers to known crypto exchanges (Binance, Coinbase), or only those linked to specific scams?
- Timeline for actual license issuance: Will the government eventually activate the licensing regime created by the 2018 Act?
Detailed Explanation
Detailed Explanation
Retail cryptocurrency trading in Samoa operates in an 'Allowed-Unregulated' status, characterized by a legal framework that exists but is not actively implemented. The primary regulatory instrument is the Money Laundering Prevention Amendment Act 2018, enacted on June 22, 2018. This law amended the principal act to legally classify 'dealers or promoters of virtual or digital currency' as Financial Institutions, thereby subjecting them to Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and Know Your Customer (KYC) reporting obligations, and requiring them to obtain a valid business license from the Central Bank of Samoa (CBS). The Financial Intelligence Unit (FIU) is responsible for enforcing these AML/CTF rules. However, the government and the CBS have adopted a cautious and restrictive stance in practice. In a 2023 statement dated June 16, the government clarified it would not endorse or license any digital asset exchanges until a feasibility study is completed, a position maintained through late 2025. Consequently, while the law provides for licensed crypto businesses, the CBS has not issued any active licenses, effectively creating a licensing freeze and preventing the legal operation of a local cryptocurrency market. This creates a regulatory paradox where the activity is defined but cannot legally commence. The regulatory approach is heavily influenced by past experiences with cryptocurrency scams, notably the OneCoin pyramid scheme. In response to OneCoin, the CBS issued a directive on May 7, 2018, blocking all foreign exchange transactions related to that promotion to protect Samoa's foreign currency reserves. This action set a precedent, and the CBS retains the authority to block foreign exchange transactions involving crypto assets more broadly. Commercial banks are advised to treat all crypto-related transactions with extreme caution, and general purchases may be caught under these foreign exchange controls. Cryptocurrency is explicitly not recognized as legal tender in Samoa. The overall regulatory posture is one of high-risk presumption and containment, aimed at protecting national financial stability and complying with international standards like those from the Financial Action Task Force (FATF), without actively fostering a domestic cryptocurrency industry.
Summary Points
I. Regulatory Status
* Allowed-Unregulated: Retail cryptocurrency trading is permitted in principle but operates without active regulatory oversight or licensing.
* The legal framework exists but is not implemented, creating a licensing freeze.
* The government and Central Bank of Samoa (CBS) maintain a 'cautious approach', effectively freezing the legal local market.
II. Key Regulatory Bodies
* Central Bank of Samoa (CBS):
* Primary regulator for cryptocurrency promoters and dealers.
* Has authority to block foreign exchange transactions involving crypto.
* Issues directives to commercial banks regarding crypto transactions.
* Financial Intelligence Unit (FIU):
* Enforces Anti-Money Laundering/Counter-Terrorist Financing (AML/CTF) rules under the Money Laundering Prevention Act.
III. Important Legislation
* Money Laundering Prevention Amendment Act 2018 (Act No. 13 of 2018):
* Enacted: June 22, 2018.
* Amended principal act to define 'dealers or promoters of virtual or digital currency' as Financial Institutions.
* Subjects them to AML/KYC reporting and licensing requirements.
* CBS Directive on Foreign Exchange Transactions:
* Issued: May 7, 2018.
* Blocked all foreign exchange transactions related to the OneCoin cryptocurrency promotion.
* Set a precedent for the CBS to block crypto-related outflows to protect foreign reserves.
* Government Statement on Unapproved Digital Asset Exchanges:
* Issued: June 16, 2023.
* Clarified that a proposed 'Samoa Digital Asset Exchange' was not approved.
* Stated no licenses would be issued until a feasibility study is completed.
IV. Compliance Requirements
* Licensing: By law, cryptocurrency promoters and dealers must obtain a valid business license from the CBS as Financial Institutions.
* Important Note: No active licenses have been issued, creating a de facto moratorium.
* AML/CTF/KYC: Licensed entities would be subject to standard AML, CTF, and KYC reporting obligations enforced by the FIU.
V. Notable Restrictions or Limitations
* Licensing Freeze: The government has placed a moratorium on issuing licenses pending a feasibility study.
* Banking and Foreign Exchange Blockade:
* The CBS has authority to block foreign exchange transactions related to crypto assets.
* Commercial banks are advised to treat crypto-related transactions with extreme caution and may block them.
* Legal Tender: Cryptocurrency is explicitly not legal tender in Samoa.
* Scam Sensitivity: Regulation is heavily influenced by the OneCoin pyramid scheme, leading to a presumption of high risk for all crypto activities.
VI. Recent Developments or Notes
* The government's 2023 stance of not issuing licenses remained in effect through late 2025.
* The 2018 Amendment Act created a legal paradox where crypto businesses are defined but cannot operationally exist due to the lack of issued licenses.
* This regulatory pattern is common in some Pacific Island nations seeking FATF compliance without actively hosting a crypto industry.
Full Analysis Report
Full Analysis Report
Samoa's regulatory environment for cryptocurrency is characterized by a disconnect between legislative text and operational reality, placing it firmly in the 'Allowed-Unregulated'. Legally, the Money Laundering Prevention Amendment Act 2018 brought cryptocurrency explicitly under the regulatory umbrella by classifying 'dealers or promoters of virtual or digital currency' as Financial Institutions. This amendment theoretically paved the way for a regulated market where exchanges could operate with a valid license and adherence to AML/CFT reporting standards.
However, in practice, the Central Bank of Samoa (CBS) has enforced a restrictive policy. As of late 2025, no Virtual Asset Service Provider (VASP) licenses have been publicly issued. The regulatory stance was clarified in June 2023, when the government issued a strong rebuttal to a Hong Kong-based entity claiming to launch the 'Samoa Digital Asset Exchange.' The Prime Minister's office and CBS stated unequivocally that no endorsement or approval had been given and that the government would not issue any license approvals until a comprehensive feasibility study on the financial sector was completed. This effectively created a moratorium on legal crypto business operations.
For retail investors, this means that while the act of holding cryptocurrency is not explicitly criminalized in the penal code, the means to acquire it locally are nonexistent or legally perilous. The CBS has previously exercised its powers to block foreign exchange transactions related to crypto assets, citing the protection of Samoa's foreign currency reserves. This precedent, established during the OneCoin crisis in 2018, indicates that the regulator is willing and able to cut off banking access for crypto-related outflows. Consequently, individual traders face significant friction, as local banks are likely to decline transfers to international crypto exchanges to comply with CBS directives.
Detailed warnings from the CBS continue to categorize cryptocurrency alongside 'scams' on their official website. The regulator's primary focus remains on consumer protection and preventing capital flight rather than fostering innovation. Until the feasibility study concludes and a formal licensing framework is operationalized (moving beyond the mere definition in the AML Act), retail trading remains a high-risk activity conducted in a legal gray area without regulatory protection.
Samoa's regulatory environment for cryptocurrency is characterized by a disconnect between legislative text and operational reality, placing it firmly in the 'Allowed-Unregulated'. Legally, the *Money Laundering Prevention Amendment Act 2018* brought cryptocurrency explicitly under the regulatory umbrella by classifying 'dealers or promoters of virtual or digital currency' as Financial Institutions. This amendment theoretically paved the way for a regulated market where exchanges could operate with a valid license and adherence to AML/CFT reporting standards. However, in practice, the Central Bank of Samoa (CBS) has enforced a restrictive policy. As of late 2025, no Virtual Asset Service Provider (VASP) licenses have been publicly issued. The regulatory stance was clarified in June 2023, when the government issued a strong rebuttal to a Hong Kong-based entity claiming to launch the 'Samoa Digital Asset Exchange.' The Prime Minister's office and CBS stated unequivocally that no endorsement or approval had been given and that the government would not issue any license approvals until a comprehensive feasibility study on the financial sector was completed. This effectively created a moratorium on legal crypto business operations. For retail investors, this means that while the act of holding cryptocurrency is not explicitly criminalized in the penal code, the means to acquire it locally are nonexistent or legally perilous. The CBS has previously exercised its powers to block foreign exchange transactions related to crypto assets, citing the protection of Samoa's foreign currency reserves. This precedent, established during the OneCoin crisis in 2018, indicates that the regulator is willing and able to cut off banking access for crypto-related outflows. Consequently, individual traders face significant friction, as local banks are likely to decline transfers to international crypto exchanges to comply with CBS directives. Detailed warnings from the CBS continue to categorize cryptocurrency alongside 'scams' on their official website. The regulator's primary focus remains on consumer protection and preventing capital flight rather than fostering innovation. Until the feasibility study concludes and a formal licensing framework is operationalized (moving beyond the mere definition in the AML Act), retail trading remains a high-risk activity conducted in a legal gray area without regulatory protection.
Source Evidence
Primary and secondary sources cited in this analysis
"The Government will not endorse or give any license approvals of such proposals before [the feasibility study is completed]."
"Dealers or Promoters of virtual or digital currency... are considered under the Money Laundering prevention Amendment Act 2018 as a Financial Institution."
"Cryptocurrencies... are not currencies issued or regulated by the Central Bank. They do not have any legal tender status."
"The FIU also continues to work on improving Samoa's adherence to the FATF standards... and work on amendments to its money laundering legislation."
"The government said it was taking a 'cautious approach' concerning any proposals related to Digital Assets... Exchanges."
"The Samoan government had not given any endorsement or approval for the ventures, which were only proposals."
Web Sources (7)
Sources discovered via web search grounding
Search queries used (9)
- Samoa crypto retail trading legality
- Central Bank of Samoa cryptocurrency regulation status
- Samoa Central Bank crypto ban notice
- Samoa Money Laundering Prevention Amendment Act 2018 virtual assets
- Samoa Virtual Asset Service Provider regulation
- Samoa Money Laundering Prevention Amendment Act 2018 crypto license issued
- Samoa Digital Asset Exchange license status
- Central Bank of Samoa annual report 2024 cryptocurrency
- Samoa Central Bank crypto feasibility study results 2024 2025
https://www.ccn.com/central-bank-of-samoa-crypto-companies-will-be-treated-as-financial-institutions/
https://www.samoaobserver.ws/category/samoa/41128
https://cryptoblockwire.com/samoa-bans-digital-currencies/
https://samoaglobalnews.com/cryptocurrency-promoters/
https://coingeek.com/crypto-firms-samoa-get-treatment-financial-institutions/
https://cbs.gov.ws/media/Media-Release-Proposed-Samoa-Stock-Exchange-Samoa-Digital-Asset-Exchange-and-Oceania-Special-Economic-Zone.pdf
https://www.rnz.co.nz/international/pacific-news/492118/samoa-govt-raises-alarm-over-unapproved-overseas-business-ventures