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Fintech & payments regulation in Marshall Islands (2026)

Fintech and digital payments in Marshall Islands: partial.

The Marshall Islands regulates payment-adjacent activity primarily through its Banking Act and 2020 amendments that introduced VASP/money-services licensing aligned with FATF standards, overseen by the Office of the Banking Commission. The Monetary Authority Act 2025 established the new Marshall Islands Monetary Authority (MIMA) as an independent regulator with an explicit mandate over banks, money-service businesses, and payment systems. No dedicated standalone payment-institution or e-money (EMI) licensing law yet exists, and MIMA is newly operational; the regime is therefore partially in place but not yet fully built out.

Last verified Official sources first · MethodologyCompare Marshall Islands with other countries

Legal framework

Banking Act 1987 (as amended 2019, 2020) administered by Office of the Banking Commission; Marshall Islands Monetary Authority Act 2025 (establishing MIMA with payment-systems oversight)

Key points: digital payments & fintech in Marshall Islands

  1. Primary Regulator Transition

    The Monetary Authority Act 2025 (enacted September 2025) replaced the Office of the Banking Commission with the Marshall Islands Monetary Authority (MIMA), an independent body mandated to supervise banks, money-service businesses, and payment systems, and to align RMI's regulatory architecture with international prudential norms.

    rmiparliament.org mimamh.org

  2. Money Services & VASP Licensing

    The Banking (Amendment) Act 2020 (P.L. 2020-24) introduced licensing requirements for virtual-asset service providers (VASPs), defining 'virtual asset' and requiring any entity conducting fiat-crypto exchange, VA-to-VA exchange, or VA transfers to hold a licensed financial services provider authorization; unlicensed operation is prohibited.

    rmicourts.org paclii.org

  3. AML/CFT Compliance Framework

    The Office of the Banking Commission's Financial Intelligence Unit (FIU) supervises banks and financial services providers against FATF-aligned AML/CFT obligations; the 2023 AML/CFT Guidelines for Banks and FSPs set out KYC, suspicious transaction reporting, and VASP-specific requirements.

    rmicourts.org rmiobc.com

  4. Sovereign Digital Bond & Instant Payments Pilot

    In December 2025 the RMI Ministry of Finance launched USDM1, a US-dollar sovereign digital bond fully backed by short-term US Treasury bills and issued on the Stellar blockchain, used to disburse Universal Basic Income (ENRA) via the Lomalo digital wallet. The pilot is limited in scale and vendor acceptance is still being established.

    stellar.org mof.gov.mh mof.gov.mh

  5. No Open Banking or BNPL Regime

    The RMI has no open-banking mandate (no API access or data-sharing requirements imposed on banks) and no specific regulatory framework for Buy Now Pay Later (BNPL) products. These gaps reflect the country's nascent overall financial-services market rather than an explicit policy choice.

    adb.org mof.gov.mh

  6. IMF Warnings on Fintech Risks

    The IMF has repeatedly cautioned that several RMI fintech initiatives, including the 2022 Decentralized Autonomous Organizations Act allowing registration of digital-asset DAOs, pose risks to financial integrity, and has urged stronger supervisory capacity and FATF compliance before expanding digital-asset activities.

    centralbanking.com imf.org

Sources

  1. rmiparliament.org/cms/images/LEGISLATION/PRINCIPAL/2025/2025-0032A/2025-0032A_1.pdf
  2. rmicourts.org/wp-content/uploads/2020/12/PL-2020-24-BANKING-AMENDMENT-ACT2020.pdf
  3. rmicourts.org/wp-content/uploads/2023/11/RMI-AML-CFT-Guidelines-for-Banks-FSPs-2023
  4. mimamh.org/
  5. mof.gov.mh/usdm1-whitepaper/
  6. mof.gov.mh/wp-content/uploads/2025/12/Financial-Access-and-the-Path-to-USDM1-Lin
  7. stellar.org/press/world-s-first-on-chain-disbursement-of-universal-basic-income-d
  8. centralbanking.com/central-banks/financial-market-infrastructure/7962245/marshall-island
  9. centralbanking.com/central-banks/currency/digital-currencies/7959243/imf-repeats-warning
  10. rmiobc.com/fiu
  11. paclii.org/mh/legis/num_act/ba2020pl242020242.pdf
  12. adb.org/publications/pacific-finance-sector-marshall-islands
  13. mof.gov.mh/
  14. imf.org/-/media/Files/Publications/CR/2018/cr18271.ashx

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Orientation, not legal advice: verify against the primary sources linked above. Last verified 25 May 2026. Methodology & how to cite · State of Technology Regulation 2026