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Micronesia (Federated States of)

Retail_Trading_Status

Allowed-Unregulated High Confidence
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Status Changed

Previous status: Gray-Zone

Reconciled from live analysis after human review confirmed status as Allowed-Unregulated. The latest analysis incorrectly classified the status as Gray-Zone, which typically implies legal ambiguity or de facto restrictions short of a ban. However, the evidence confirms no law prohibits individual trading, aligning with Allowed-Unregulated. New factual information from the latest analysis—specifically the FSM Banking Board's statements and the banking restrictions—was incorporated as it details the practical challenges and regulatory stance but does not alter the fundamental legal status of individual activity. The banking restrictions are a policy implementation under existing banking law, not a crypto-specific prohibition.

Analysis ID
#858
Version
Latest
Created
2025-12-13 07:17
Workflow Stage
Reconciled

Executive Summary

Retail cryptocurrency trading is legal but unregulated in the Federated States of Micronesia (FSM). There are no specific laws prohibiting individuals from buying, selling, or holding cryptocurrencies. The government has not established a dedicated regulatory framework, leaving no specific consumer protections, licensing requirements for exchanges, or crypto-focused AML/KYC rules. Key financial regulators, including the FSM Banking Board, have stated the country is 'not ready' for virtual assets due to the absence of a legal framework, effectively restricting the formal banking sector from facilitating crypto transactions. This creates practical challenges but does not constitute a legal ban on individual activity.

Key Pillars

The primary regulatory pillar is the absence of a specific regulatory framework for cryptocurrencies in the FSM. There is no dedicated crypto regulator. The FSM Banking Board (primary regulator for the banking sector) and the Department of Finance and Administration set financial policy and have indicated the jurisdiction is not ready to entertain virtual assets due to the lack of a legal framework. This results in local banks being hesitant or prohibited from processing crypto-related transactions. International exchanges serving residents may adhere to compliance standards from their home jurisdictions.

Landmark Laws

Financial Management Regulations of the FSM (Updated May 2021): Govern public financial management but contain no specific provisions or mentions of cryptocurrencies or digital assets, underscoring the absence of a formal regulatory framework. FSM Banking Act (Title 29 of the FSM Code, enacted 1980-01-01): Governs the licensing and regulation of banking business. While not mentioning crypto explicitly, it grants the Banking Board broad powers to determine permissible activities. The Board has used this authority to deem the jurisdiction 'not ready' for virtual assets.

Considerations

Cryptocurrencies are legally recognized in the sense they are not banned, but the lack of a clear regulatory framework creates uncertainty. Local banks (Bank of FSM and Bank of Guam) are effectively restricted from processing crypto-related transactions, making fiat on/off-ramping difficult for residents. The FSM uses the U.S. dollar as its sole legal tender, and its financial system is heavily influenced by the U.S. due to the Compact of Free Association. Users must exercise caution and choose reputable platforms due to the absence of specific local consumer protections. Discussions around cybersecurity have highlighted the need for user awareness regarding digital risks, including cryptocurrency.

Notes

Some sources incorrectly conflate the Federated States of Micronesia (FSM) with the Marshall Islands, which has passed comprehensive Web3 legislation; the FSM has not taken such steps. The FSM is a member of the Asia/Pacific Group on Money Laundering (APG). Its FDIC-insured banking system's adherence to U.S.-style risk management further discourages engagement with unregulated crypto entities. There are no licensed domestic Virtual Asset Service Providers (VASPs).

Remaining Uncertainties

  • The exact text and legal authority of the reported 2021 Finance Ministry clarification on financial institutions and crypto-assets is not available in the public domain.
  • Whether individual peer-to-peer trading is actively monitored or ignored by authorities.
  • If the FSM Banking Board plans to introduce a regulatory sandbox or formal crypto regulations in the near future.

Detailed Explanation

Retail cryptocurrency trading is legally allowed but entirely unregulated in the Federated States of Micronesia (FSM). There are no specific laws that prohibit individuals from buying, selling, or holding cryptocurrencies, meaning personal activity is legal. However, the government has not established any dedicated regulatory framework for virtual assets. This absence of specific rules means there are no local licensing requirements for cryptocurrency exchanges, no crypto-focused consumer protections, and no tailored anti-money laundering (AML) or know-your-customer (KYC) regulations for the sector. The primary regulatory pillar is this lack of a formal framework, creating a legal environment of permissiveness coupled with significant uncertainty and practical challenges for users and businesses. The key financial regulators in the FSM are the FSM Banking Board, which oversees the banking sector, and the Department of Finance and Administration, which sets financial policy. These bodies have explicitly stated that the jurisdiction is 'not ready' for virtual assets due to the absence of a legal framework. This position is supported by the broad powers granted to the Banking Board under the FSM Banking Act (Title 29 of the FSM Code, enacted 1980-01-01). While this act does not mention cryptocurrencies, it allows the Board to determine permissible activities for banks, and it has used this authority to effectively restrict the formal banking sector from engaging with crypto. Consequently, local banks like the Bank of FSM and Bank of Guam are hesitant or prohibited from processing cryptocurrency-related transactions, which severely complicates the conversion of fiat currency to and from digital assets for residents. The Financial Management Regulations of the FSM (Updated May 2021) govern public finance but contain no provisions for digital assets, further underscoring the regulatory gap. The FSM uses the U.S. dollar as its sole legal tender, and its financial system's close ties to the U.S., including FDIC-insured banking practices, reinforce a risk-averse stance towards unregulated crypto entities. Therefore, while not illegal, cryptocurrency activity operates in a practical vacuum, reliant on international exchanges that apply their home jurisdiction's compliance standards, with users bearing all risks due to the lack of local safeguards.

Summary Points

I. Regulatory Status
* Retail cryptocurrency trading is legally allowed but unregulated.
* No specific laws prohibit individuals from buying, selling, or holding cryptocurrencies.
* There is no dedicated regulatory framework for virtual assets, resulting in no local licensing for exchanges and no specific consumer protections or crypto-focused AML/KYC rules.

II. Key Regulatory Bodies
* FSM Banking Board: The primary regulator for the banking sector. It has stated the FSM is 'not ready' for virtual assets and uses its authority to restrict banks from facilitating crypto transactions.
* Department of Finance and Administration: Sets financial policy and has indicated the jurisdiction lacks a legal framework for virtual assets.

III. Important Legislation
* FSM Banking Act (Title 29 of the FSM Code, enacted 1980-01-01): Governs banking business. While not mentioning crypto, it grants the Banking Board broad powers to determine permissible activities, which it has used to deem the jurisdiction unprepared for virtual assets.
* Financial Management Regulations of the FSM (Updated May 2021): Governs public financial management but contains no specific provisions or mentions of cryptocurrencies or digital assets.

IV. Compliance Requirements
* There are no specific local compliance requirements for cryptocurrency activities due to the absence of a regulatory framework.
* Residents using international exchanges are subject to the compliance standards (e.g., AML/KYC) of those platforms' home jurisdictions.

V. Notable Restrictions or Limitations
* The FSM Banking Board's position effectively restricts the formal banking sector from processing cryptocurrency-related transactions.
* Local banks (Bank of FSM and Bank of Guam) are hesitant or prohibited from providing fiat on/off-ramping services, creating a major practical barrier.
* The FSM uses the U.S. dollar as its sole legal tender, and its FDIC-insured banking system's adherence to U.S.-style risk management discourages engagement with unregulated crypto entities.
* There are no licensed domestic Virtual Asset Service Providers (VASPs).

VI. Recent Developments or Notes
* The government has acknowledged discussions around cybersecurity, highlighting a need for user awareness regarding digital risks, including those related to cryptocurrency.
* It is important to distinguish the FSM from the Marshall Islands, which has passed comprehensive Web3 legislation; the FSM has not taken such steps.
* The FSM is a member of the Asia/Pacific Group on Money Laundering (APG).
* Users must exercise significant caution and choose reputable platforms due to the complete absence of specific local consumer protections.

Full Analysis Report

Report on Retail Cryptocurrency Trading Status in Micronesia (Federated States of)

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.


Retail_Trading_Status

Status: Allowed-Unregulated

Narrative Explanation:

Cryptocurrency trading by individuals in the Federated States of Micronesia (FSM) is currently legal, primarily because there are no specific laws or regulations prohibiting it. The FSM has not established a dedicated regulatory framework for cryptocurrencies. This means that while individuals are generally free to buy, sell, and hold digital assets, they do so in an environment lacking specific consumer protections, licensing requirements for exchanges, or crypto-focused AML/KYC rules directly imposed by the FSM government.

The primary financial regulator, the FSM Banking Board, has explicitly stated in its Annual Reports (2022, 2023) that the country is 'not ready to entertain digital currencies and virtual assets' due to the absence of a legal framework. This position, derived from its powers under the FSM Banking Act (Title 29), effectively restricts local banks (Bank of Guam and Bank of the FSM) from offering crypto services or facilitating payments to crypto exchanges. A 2021 clarification from the Finance Ministry, referenced by secondary sources, also indicated that financial institutions are not permitted to use or transact in crypto-assets.

Consequently, retail investors face significant practical hurdles in moving fiat currency to and from crypto exchanges, as the domestic banking system is effectively closed to crypto-related transactions. There are no licensed domestic cryptocurrency exchanges. However, this banking blockade is a restriction on financial institutions, not a ban on individual possession or trading. Individuals may still use international exchanges, which often require ID verification for KYC compliance based on their home jurisdiction rules.

The FSM relies on the U.S. dollar, and its financial laws are influenced by the U.S. The lack of a clear regulatory framework creates uncertainty. The government's stance is one of caution and observation, with discussions around cybersecurity highlighting the need for user awareness regarding risks in the digital space, including cryptocurrency. The Financial Management Regulations of the FSM (May 2021) contain no crypto provisions, further underscoring the regulatory void.

In essence, retail cryptocurrency trading is allowed because it is not illegal, but it is unregulated and operates in a challenging practical environment due to banking restrictions.

Supporting Excerpts and Sources:

  • FSM Banking Board, 2023 Annual Report: "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."
  • FSM Banking Board, 2022 Annual Report: "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): Provides the Banking Board with broad powers to regulate banking business.
  • Financial Management Regulations of the FSM (May 2021): Contains no specific provisions for cryptocurrencies or digital assets.
  • Proelium Law LLP (Cryptocurrency Regulation Tracker): References a 2021 Finance Ministry clarification that financial institutions are not permitted to use or transact in crypto-assets.
  • UEEx Technology (Best Crypto Exchanges in Micronesia 2025): "Yes, crypto exchanges are legal in Micronesia, but the country does not have clear regulations specifically for cryptocurrencies... there are no local government-backed crypto regulations or licensing requirements."
  • UPay Blog (Crypto Adoption Around the World: Micronesia): "Cryptocurrencies are legal in Micronesia, though no specific regulations currently govern their use, indicating an open but cautious approach to digital assets."
  • Invezz (7 Best Exchanges to Buy Bitcoin in Micronesia 2025): "Yes, buying Bitcoin is legal in Micronesia... However, many cryptocurrency exchanges aren't regulated in Micronesia, as the legislation has yet to catch up with the reality of the crypto market."
  • UNDP Pacific Office in Fiji (Empowering Digital Resilience in the FSM): Highlights the "increasing prevalence of... cryptocurrency" and the need for user awareness of digital risks.
  • U.S. Department of State, 2021 Investment Climate Statements: Notes the two commercial banks (Bank of Guam and Bank of the FSM) are FDIC-insured.

Source Evidence

Primary and secondary sources cited in this analysis

"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."

"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."

1980-01-01

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

"Regulations governing public financial management; no mention of cryptocurrencies or digital assets."

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

"Yes, crypto exchanges are legal in Micronesia, but the country does not have clear regulations specifically for cryptocurrencies."

"Cryptocurrencies are legal in Micronesia, though no specific regulations currently govern their use, indicating an open but cautious approach to digital assets."

"Yes, buying Bitcoin is legal in Micronesia. You can safely buy and sell cryptocurrency using a Micronesian crypto exchange. However, many cryptocurrency exchanges aren't regulated in Micronesia..."

"'We are making strides in making education accessible through technology, but we need to make sure everyone knows how to stay safe, especially with the increasing prevalence of Artificial Intelligence (AI) and cryptocurrency,' he said."

"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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