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title: AG Payments Regulation Monitor | World Payments Monitor
canonical: https://payments.gi/jurisdictions/antigua-and-barbuda/
date_modified: 2026-10-21
publisher: Asymmetric Intelligence

# AG

AG schema world-payments-v1

trajectory: not yet assessed Last updated 2026-10-21 · 14 modules · 59 sourced findings · 114 sources in the cumulative register

14 Modules baseline.modules[]

59 Findings modules[].findings[]

45 Tier-1 sources run_metadata.t1_source_count

Confidence mix (sums to 14 rendered modules; click to filter)

No modules moved this cycle.

## Jurisdiction brief

###### Latest update · 11 October 2026

#### Lead Signal

Antigua and Barbuda's payments-licensing framework is mid-transition this cycle. The Payment Systems and Services Act, 2025, No. 13 of 2025, repeals the Payment System Act, 2007, No. 15 of 2007, and re-licenses payment service providers and payment-system operators under the Central Bank. Crucially, the new Act is not self-executing: it comes into operation only on a date appointed by the Minister by Notice published in the Gazette, and no such commencement notice has been located this cycle. The practical result is that onshore payment service providers continue operating under the legacy 2007 licensing framework for the time being, even though the replacement statute is already enacted, creating a period where the published law and the operative law diverge.

Alongside the uncommenced licensing reform, the Central Bank's supervisory powers over licensed financial institutions, including banks that provide payment services, have already been strengthened. The Banking (Amendment) Act 2025, No. 14 of 2025, inserts a market-conduct-supervision regime that applies to financial services and financial products offered by a licensed financial institution notwithstanding anything contained in the general Consumer Protection Act 2025. This carve-out gives the Banking Act's sector-specific conduct regime primacy over the general consumer-protection statute for licensed financial institutions, which has direct relevance for how payments-sector consumer protection is administered in Antigua and Barbuda going forward.

#### Other Developments

**The repeal-and-replace structure of the 2025 Payment Systems and Services Act leaves existing businesses a 12-month transitional window once it does commence.** Once the Minister's Gazette notice brings the Act into operation, payment service providers and payment-system operators already active under the legacy regime will have 12 months to come into compliance with the new licensing framework. Until that notice is published, the Act's substantive licensing provisions remain latent rather than operative, a distinction with real consequence for any entity assessing its current versus prospective regulatory status in the jurisdiction.

**The Banking (Amendment) Act 2025's market-conduct provisions extend into territory the general Consumer Protection Act 2025 would otherwise occupy.** By disapplying the general consumer-protection statute in favour of its own Part VIIA regime for licensed financial institutions, the Banking Act creates a sector-specific conduct and consumer-protection track for banks and similarly licensed institutions, separate from the protections available to consumers of non-financial goods and services under the general Act.

**The Eastern Caribbean Central Bank has stepped back from its DCash 2.0 CBDC successor project in favour of regional payments infrastructure.** Following the end of the original DCash CBDC pilot in January 2024, the ECCB's Monetary Council, at its 112th meeting on 13 February 2026, suspended the DCash 2.0 successor project, redirecting priority toward a regional Fast Payment System and participation in CARICOM Payments and Settlement System (CAPSS) integration. As an Eastern Caribbean Currency Union member, Antigua and Barbuda is affected by this region-wide strategic reset, which replaces a proprietary CBDC-wallet approach with an emphasis on upgraded bank-rail interoperability across the currency union.

#### Cross-Monitor Connections

The uncommenced Payment Systems and Services Act 2025 and the already-effective Banking (Amendment) Act 2025 together illustrate a jurisdiction sequencing its payments-sector reform: supervisory and conduct powers are being strengthened first, while the core licensing re-architecture waits on ministerial commencement. This sequencing has a financial-integrity dimension, since the Banking Act's expanded information-gathering powers, which allow the Central Bank to request books, records and other documents from licensed institutions, sit adjacent to AML/CTF supervisory capacity even though their immediate statutory basis here is market-conduct supervision rather than anti-money-laundering enforcement.

#### Outlook

The Payment Systems and Services Act 2025's commencement date is the single most consequential variable for Antigua and Barbuda's payments-licensing landscape going forward; until a Ministerial Gazette notice appears, payment service providers should expect to continue operating under the 2007 framework notwithstanding the 2025 Act's enactment. Separately, the ECCB's pivot toward a regional Fast Payment System and CAPSS participation, rather than a proprietary CBDC wallet, signals that Antigua and Barbuda's near-term digital-payments infrastructure development will likely be shaped more by currency-union-wide interoperability initiatives than by a jurisdiction-specific CBDC programme.

###### Standing brief · as of 8 September 2026

_Written before the update above. Where they differ, the update is the more recent position._

#### Lead Signal

Antigua and Barbuda's payments regulatory architecture has reached a structural inflection point. The Payment Systems and Services Act, 2025 (No. 13 of 2025) has been passed by Parliament, establishing a modernised licensing, safeguarding and interoperability framework administered jointly by the Eastern Caribbean Central Bank and the Financial Services Regulatory Commission — but the statute comes into operation only on a date the Minister appoints by Gazette Notice, and no such notice has yet been published. Until that commencement notice appears, the 2008 Payment System Act remains the operative baseline, leaving the country's most consequential payments reform enacted in law but dormant in practice. The gap between enactment and commencement is now the single highest-value forward marker for this jurisdiction, and it sits alongside a codified but equally suspended set of conduct provisions: the same statute defines an "e-float" mechanism requiring electronic-money issuers to segregate customer funds in an account held at the Central Bank or another licensed institution, and it imposes a prior-authorisation requirement before any payment service is extended to consumers through an agent. None of this takes legal effect until the Minister acts.

#### Other Developments

Two other threads moved this cycle. First, the Eastern Caribbean Central Bank's Monetary Council, at its 112th meeting on 4 May 2026, formally suspended further development of "DCash 2.0," the intended commercial successor to the ECCU's completed 2021–2024 DCash retail central bank digital currency pilot. This is a reversal, not a pause on a live rollout, and it comes as the ECCB's institutional attention visibly shifts toward the CARICOM Payment and Settlement System, a PAPSS-modelled scheme intended to enable real-time local-currency settlement across CARICOM and reduce reliance on correspondent banks; the ECCB has signalled it will likely join an expanded pilot bringing in additional central banks. Second, a new United States 1% excise tax on certain remittances took effect on 1 January 2026, and digital-wallet transfer providers serving the US-Antigua corridor report that their services are not subject to the cash-focused levy — a carve-out that favours digital channels over cash remittance without, on current evidence, disrupting the corridor materially. Separately, the country's non-bank licensing perimeter continues to run well ahead of the still-dormant bank-route reform. The Money Services Business Act 2011, administered by the Financial Services Regulatory Commission, already provides a functioning licensing structure for money-services businesses. The Digital Assets Business Act 2020 separately establishes a tiered licensing system covering issuance, exchange and custodial wallet services for digital-asset activity, also administered by the FSRC. Together the two statutes create a visible asymmetry between a mature non-bank perimeter and a bank-route regime still awaiting a start date. The domestic banking sector remains concentrated in Eastern Caribbean Amalgamated Bank, built through the earlier acquisitions of ABI Bank and Scotiabank's Antigua operations. Around it sits a comparatively thin regional fintech layer of roughly forty digital financial-service providers, including the regional payment facilitator WiPay Group. On the consumer side, the Office of National Drug and Money Laundering Control Policy issued a public advisory in August 2025 warning of increased account-compromise and top-up scam activity, a consumer-facing vigilance measure that sits outside any dedicated statutory scheme for reimbursing authorised-push-payment fraud victims.

#### Cross-Monitor Connections

Antigua and Barbuda's continued engagement with the Caribbean Financial Action Task Force — most recently a delegation appearance at the 61st Plenary in December 2025 as the country prepares for its Fifth Round Mutual Evaluation, building on 2018 and 2021 assessment outcomes — has been flagged for continued tracking on the Financial Integrity Monitor's own surface, since the underlying AML/CFT posture questions sit outside this monitor's payments-systems remit even though the preparatory activity is payments-adjacent.

#### Outlook

The forward calendar for Antigua and Barbuda is dominated by two unresolved dates: when the Minister will gazette commencement of the Payment Systems and Services Act, and whether the paused DCash 2.0 track resumes in some form or is formally superseded by the CARICOM Payment and Settlement System as the region's primary modernisation vehicle. Both are currently open, and both will determine whether the licensing, safeguarding and settlement changes now visible in statute and in regional policy statements translate into an operating environment that differs from today's. A third marker worth watching is the correspondent-banking file: Antigua and Barbuda has pressed this issue at CARICOM level for a decade, and the CARICOM Payment and Settlement System is now the clearest institutional vehicle for addressing de-risking exposure directly, rather than through advocacy alone.

trust tier: ai_unverified

_Standing brief, as of 8 September 2026._

#### Regulatory Status

Antigua and Barbuda's payments regulatory status this cycle centres on a statute that is law but not yet in force: the Payment Systems and Services Act, 2025 has been enacted by Parliament but awaits a Ministerial commencement notice in the Gazette, leaving the 2008 Payment System Act as the operative bank-route baseline. In parallel, the country's non-bank licensing perimeter — the Money Services Business Act 2011 and the Digital Assets Business Act 2020, both administered by the Financial Services Regulatory Commission — already functions independently of that pending reform. The ECCB Monetary Council's May 2026 communique suspending further development of 'DCash 2.0' marks a reversal of the region's earlier retail-CBDC trajectory, occurring alongside growing institutional momentum behind the CARICOM Payment and Settlement System, which the ECCB has signalled it will likely join in an expanded pilot. Antigua and Barbuda continues to press correspondent-banking de-risking as a long-standing CARICOM advocacy priority, and CAPSS is now the clearest structural response to that exposure. On the compliance side, the country is preparing for its Fifth Round CFATF Mutual Evaluation, building on 2018 and 2021 assessment outcomes, per Sentinel-fed reporting.

#### Outlook

The jurisdiction's regulatory trajectory is liberalising but incomplete: the PSSA's licensing, safeguarding and sandbox provisions, and the CAPSS settlement rail, are both structurally significant and both still pending full operational realisation. The two dates to watch are the PSSA's Ministerial commencement notice and any formal confirmation of ECCB participation in expanded CAPSS piloting.

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### W1a Licensing, Authorisation & Market Access Confirmed confirmed 2026-09-08

Antigua and Barbuda's payments licensing regime is bifurcated: the ECCB licenses/oversees payment service providers and banks under the newly enacted Payment Systems and Services Act 2025 and the Banking Act 2015, while the FSRC licenses non-bank money services businesses and digital asset businesses under sector-specific statutes. The PSSA 2025 has been passed into law but awaits a Ministerial commencement notice, so the prior 2008 Payment System Act regime remains the operative baseline pending gazettal.

Standing sub-brief · as of 8 September 2026 188 words · last cycle 2026-10-11

#### Licensing, Authorisation & Market Access

Antigua and Barbuda's payments licensing architecture is bifurcated by rail and by institution type. The Payment Systems and Services Act, 2025 has been enacted by Parliament and establishes an ECCB-led licensing and interoperability framework for banks and payment service providers, but it comes into force only once the Minister issues a commencement notice in the Gazette, and no such notice has yet appeared; until then, the 2008 Payment System Act remains the operative bank-route baseline. Running in parallel, and considerably more mature, is the non-bank perimeter: the Money Services Business Act 2011 gives the Financial Services Regulatory Commission a working licensing regime for non-bank money services businesses, independent of the still-dormant PSSA. The result is a visible asymmetry in regulatory readiness — a functioning non-bank licensing perimeter sitting alongside a bank-route regime that exists in statute but not yet in force.

#### Outlook

The defining forward marker for this module is the still-unpublished PSSA commencement date. Until the Minister gazettes that notice, market entrants on the bank/PSP rail continue to operate under the 2008-era baseline even as the modernised framework sits ready in law.

Periodic update · new data 2026-10-11

#### Licensing, Authorisation & Market Access

Antigua and Barbuda's payments-licensing framework has been formally re-architected through the Payment Systems and Services Act, 2025, No. 13 of 2025, which repeals the Payment System Act, 2007, No. 15 of 2007, and establishes a new licensing basis for payment service providers and payment-system operators under the Central Bank. This is a confirmed-tier, directly sourced statutory development, drawn from the Act's own repeal clause.

The critical operative detail is the Act's commencement mechanism: section 1(2) provides that the Act comes into operation on a date appointed by the Minister by Notice published in the Gazette. No such commencement notice has been located as of this cycle, meaning the Act's substantive licensing provisions, though enacted, have not yet taken legal effect. In the interim, entities already carrying on payment-system business in Antigua and Barbuda continue to operate under the 2007 Act's licensing regime, since a repeal that is itself subject to a date-appointed commencement clause does not displace the prior regime until that date arrives. This produces a live divergence between the published statute book, which now shows the 2025 Act as enacted law, and the operative licensing regime actually governing market participants today, which remains the 2007 framework.

Once commencement occurs, the Act provides a 12-month transitional compliance window for existing businesses, during which payment service providers and system operators already active under the legacy regime must come into compliance with the new Central Bank licensing framework. This transitional design is a standard feature of repeal-and-replace payments legislation and signals that the drafters anticipated the need for continuity of service during the changeover rather than an abrupt licensing cliff-edge.

The bank-versus-non-bank distinction matters here only to the extent that the new Act is understood to apply to both categories of payment-services participant; no differential treatment between bank-operated and non-bank payment service providers under the new licensing regime was identified from the sourced provisions, so the Act should be read as establishing a common licensing gateway administered by the Central Bank for both categories, pending commencement.

#### Outlook

The single most important development to track for Antigua and Barbuda's payments-licensing environment is the Minister's Gazette commencement notice. Until it is published, market participants face continued application of the 2007 licensing framework notwithstanding the 2025 Act's enactment, and any assessment of current regulatory status for a payment service provider or payment-system operator in Antigua and Barbuda must account for this gap between enactment and legal effect. Once commencement occurs, the 12-month transitional window will itself become a tracked milestone, as existing businesses work through re-licensing under the Central Bank's new framework.

**Sources and findings (7)**

1. T1 [https://laws.gov.ag/wp-content/uploads/2025/09/No.-13-of-2025-Payment-Systems-and-Services-Act-2025.pdf](https://laws.gov.ag/wp-content/uploads/2025/09/No.-13-of-2025-Payment-Systems-and-Services-Act-2025.pdf) retrieved 2026-09-08
2. T1 [https://laws.gov.ag/wp-content/uploads/2025/09/No.-13-of-2025-Payment-Systems-and-Services-Act-2025.pdf](https://laws.gov.ag/wp-content/uploads/2025/09/No.-13-of-2025-Payment-Systems-and-Services-Act-2025.pdf) retrieved 2026-09-08
3. T1 [https://www.eccb-centralbank.org/blogs/payment-system-integration](https://www.eccb-centralbank.org/blogs/payment-system-integration) retrieved 2026-09-08
4. T1 [https://laws.gov.ag/wp-content/uploads/2019/02/a2011-7.pdf](https://laws.gov.ag/wp-content/uploads/2019/02/a2011-7.pdf) retrieved 2026-09-08
5. T1 [https://www.fsrc.gov.ag/](https://www.fsrc.gov.ag/) retrieved 2026-09-08
6. T1 [https://www.fsrc.gov.ag/images/pdf/digital-assets/No.-16-of-2020-Digital-Assets-Business-Act-2020.pdf](https://www.fsrc.gov.ag/images/pdf/digital-assets/No.-16-of-2020-Digital-Assets-Business-Act-2020.pdf) retrieved 2026-09-08
7. T1 [https://legalaffairs.gov.ag/pdf/bills/Banking_act_2015.pdf](https://legalaffairs.gov.ag/pdf/bills/Banking_act_2015.pdf) retrieved 2026-09-08

### W1b Conduct, Safeguarding & Promotions Confirmed confirmed 2026-09-08

Safeguarding of customer funds under the incoming PSSA regime is structured around a segregated 'e-float' account held at the Central Bank or a licensed financial institution, with agent-based service provision subject to prior ECCB authorisation. General consumer/conduct protection sits outside payments-specific law in the Consumer Protection Act and Fair Trading Act, administered by the Consumer Affairs Division, which is not payments-specific.

Standing sub-brief · as of 8 September 2026 157 words · last cycle 2026-10-11

#### Conduct, Safeguarding & Promotions

Safeguarding of customer funds under the incoming PSSA regime is built around a segregated 'e-float' concept: the statute requires electronic-money issuers to hold customer balances in an account at the Central Bank or another licensed financial institution, separate from the issuer's own operating funds. A second conduct control sits alongside it — where a payment service provider intends to serve consumers through an agent, section 35 of the PSSA requires prior written authorisation from the Central Bank before that channel can be used. Both provisions are drafted and enacted, but neither is yet operative; they take effect only once the PSSA itself is commenced by Ministerial notice, so today's conduct and safeguarding baseline for e-money remains whatever general consumer-protection law otherwise provides.

#### Outlook

Safeguarding and agent-conduct enforcement in Antigua and Barbuda will only become testable once the PSSA is in force; until then, this remains a codified-but-dormant standard rather than a supervised one.

Periodic update · new data 2026-10-11

#### Conduct, Safeguarding & Financial Promotions

Antigua and Barbuda's conduct-of-business landscape for the financial sector has been strengthened through the Banking (Amendment) Act 2025, No. 14 of 2025, which inserts a market-conduct-supervision regime applicable to financial services and financial products offered by a licensed financial institution. The provision carries a notable disapplication clause: it applies notwithstanding anything contained in the general Consumer Protection Act 2025, meaning the Banking Act's sector-specific conduct regime takes precedence over the general consumer-protection statute for licensed financial institutions, rather than operating alongside it as a supplementary layer. This is confirmed-tier, directly sourced from the Act's own text.

The practical effect of this disapplication clause is to create two parallel conduct-and-consumer-protection tracks in Antigua and Barbuda: a general track under the Consumer Protection Act 2025 for consumers of goods and services broadly, and a sector-specific track under the Banking Act's new Part VIIA for consumers of financial services and products from licensed financial institutions. For payment service providers that are also licensed financial institutions, this means conduct obligations will likely be administered under the Banking Act's framework rather than the general consumer-protection statute, though the precise scope of which payment-sector entities fall within the "licensed financial institution" definition for this purpose was not separately confirmed this cycle.

This conduct-supervision development sits alongside, but is analytically distinct from, the Central Bank's new information-gathering powers under the same Part VIIA, which allow it to request books, records, video footage and other documents from licensed financial institutions. Together, these provisions give the Central Bank both the substantive conduct standard to enforce and the investigatory tools to enforce it, a pairing that is structurally significant for how market-conduct supervision will actually operate in practice once exercised.

No separate financial-promotions-specific rule distinct from the general market-conduct provisions was identified this cycle for Antigua and Barbuda's payments sector.

#### Outlook

The disapplication of the general Consumer Protection Act 2025 in favour of the Banking Act's sector-specific regime is now in force for licensed financial institutions, and the degree to which this produces visibly different conduct outcomes, for example in complaint-handling, disclosure, or fee-transparency practice, for payments customers relative to the general consumer-protection track is the item to watch in coming cycles. Clarifying exactly which categories of payment-services participants fall within the Banking Act's "licensed financial institution" definition, as distinct from entities that may instead or additionally be licensed under the still-uncommenced Payment Systems and Services Act 2025, would sharpen this picture considerably once available.

**Sources and findings (5)**

1. T1 [https://laws.gov.ag/wp-content/uploads/2025/09/No.-13-of-2025-Payment-Systems-and-Services-Act-2025.pdf](https://laws.gov.ag/wp-content/uploads/2025/09/No.-13-of-2025-Payment-Systems-and-Services-Act-2025.pdf) retrieved 2026-09-08
2. T1 [https://laws.gov.ag/wp-content/uploads/2025/05/Payment-Systems-and-Services-Bill-2025.pdf](https://laws.gov.ag/wp-content/uploads/2025/05/Payment-Systems-and-Services-Bill-2025.pdf) retrieved 2026-09-08
3. T1 [https://www.eccb-centralbank.org/blogs/payment-system-integration](https://www.eccb-centralbank.org/blogs/payment-system-integration) retrieved 2026-09-08
4. T3 [http://www.lawgratis.com/blog-detail/consumer-law-antigua-and-barbuda](http://www.lawgratis.com/blog-detail/consumer-law-antigua-and-barbuda) retrieved 2026-09-08
5. T1 [https://laws.gov.ag/wp-content/uploads/2019/02/a2011-7.pdf](https://laws.gov.ag/wp-content/uploads/2019/02/a2011-7.pdf) retrieved 2026-09-08

### W2 Stablecoins & Digital Money Confirmed confirmed 2026-09-08

Digital money in Antigua and Barbuda spans two tracks: the FSRC-licensed private digital-asset sector under the Digital Assets Business Act 2020 (extending to digital-asset payment services), and the ECCB-issued DCash retail CBDC. DCash completed a multi-year pilot (2021-2024) across Antigua and Barbuda and three other ECCU states, but the ECCB Monetary Council has since suspended further development of a commercial 'DCash 2.0' as of its May 2026 communique, a pending/horizon reversal that must not be read as a live commercial rollout.

Rules for e-money institutions and payment institutions · from [Cryptoassets.gi](https://cryptoassets.gi) · verified 2026-10-18

- ** depository account definition** — Reporting financial institutions must report accounts holding CBDC and specified e-money products under the extended CRS depository-account definition. _(consultation)_ [source, 2026-09-28](https://www.caribpulse.com/2026/09/28/antigua-and-barbuda-expands-financial-reporting-rules-to-cover-digital-currencies?postId=100763)

_ Not yet covered by Cryptoassets.gi for this jurisdiction: how a fiat-referenced token is classified (e-money, stablecoin, e-money token or asset-referenced token) and the tests that decide it; when a firm issues a stablecoin in the jurisdiction, group and intermediary carve-outs, offer exceptions and local-establishment expectations; e-money token issuance and offer: who may issue, white-paper and reserve requirements, third-country issuer treatment and transitional periods; systemic stablecoin regimes: recognition, backing-asset rules and the joint central bank and conduct regulator regime; cross-border market access for stablecoin and e-money activity between neighbouring regimes and its expiry; what an EMI or PI needs in addition to its licence to offer crypto conversion or stablecoin services, including payment-services treatment of token transfers._

Standing sub-brief · as of 8 September 2026 164 words · last cycle 2026-10-11

#### Stablecoins & Digital Money

Digital money in Antigua and Barbuda runs on two separate tracks. The Digital Assets Business Act 2020 gives the Financial Services Regulatory Commission a tiered licensing system covering issuance, sale and redemption of digital coins, digital-asset payment services, exchange services and custodial wallet services — the operative perimeter for private digital-asset activity. Separately, the ECCB's DCash retail central bank digital currency completed a multi-year pilot from 2021 to 2024 across Antigua and Barbuda and three other ECCU states; but the ECCB Monetary Council's 112th meeting communique of 4 May 2026 officially suspended further development of a commercial 'DCash 2.0', reversing the post-pilot path toward a retail CBDC rollout for the currency union. That reversal should not be read as a live commercial CBDC programme continuing in the background.

#### Outlook

No relaunch or replacement timeline for the DCash 2.0 track has been published. The FSRC-licensed digital-asset perimeter continues to operate independently of that CBDC question and is unaffected by the suspension.

Periodic update · new data 2026-10-11

#### Stablecoins & Digital Money

The most significant digital-money development touching Antigua and Barbuda this cycle originates at the regional, currency-union level rather than from domestic legislation. The Eastern Caribbean Central Bank's Monetary Council, at its 112th meeting on 13 February 2026, suspended the DCash 2.0 project, the successor to the original DCash central-bank-digital-currency pilot that had itself ended in January 2024. In place of continuing the DCash successor programme, the Monetary Council is now prioritising development of a regional Fast Payment System and participation in the CARICOM Payments and Settlement System, CAPSS, integration effort. This is a probable-confidence development, corroborated across two secondary regional sources, though no primary ECCB communique text was directly retrieved this cycle.

As a member of the Eastern Caribbean Currency Union, Antigua and Barbuda is directly affected by this region-wide strategic reset, even though the decision itself was taken at the currency-union level rather than by any Antigua-and-Barbuda-specific authority. The practical significance is a shift in digital-payments-infrastructure strategy away from a proprietary CBDC-wallet model, which DCash and its planned successor represented, and toward upgraded interoperability between existing bank-operated payment rails across the currency union and the wider CARICOM region. This is best read as a structural reset in regional digital-payments strategy rather than an Antigua-and-Barbuda-specific regulatory event, since no AG-specific stablecoin or digital-money legislation or regulatory action was identified this cycle.

No domestic Antigua and Barbuda stablecoin-specific statute, reserve-asset requirement, or redemption-rights framework was identified this cycle; digital-money regulatory development affecting the jurisdiction currently flows through this regional ECCB channel rather than through standalone domestic legislation.

#### Outlook

The ECCB's pivot from DCash 2.0 toward a regional Fast Payment System and CAPSS participation is a multi-year undertaking with a currently uncertain completion horizon; its practical effect on Antigua and Barbuda's payments landscape will depend on how quickly the Fast Payment System and CAPSS integration actually deliver improved bank-rail interoperability relative to the proprietary CBDC-wallet approach they are replacing. This is a development to track at the regional ECCB level going forward, since further Antigua-and-Barbuda-specific digital-money developments are more likely to arrive as downstream implementation of this regional strategy than as independent domestic initiatives.

**Sources and findings (5)**

1. T1 [https://www.fsrc.gov.ag/images/pdf/digital-assets/No.-16-of-2020-Digital-Assets-Business-Act-2020.pdf](https://www.fsrc.gov.ag/images/pdf/digital-assets/No.-16-of-2020-Digital-Assets-Business-Act-2020.pdf) retrieved 2026-09-08
2. T3 [https://charltonsquantum.com/antigua-barbuda-digital-assets-regulation/](https://charltonsquantum.com/antigua-barbuda-digital-assets-regulation/) retrieved 2026-09-08
3. T1 [https://www.dcashec.com/about](https://www.dcashec.com/about) retrieved 2026-09-08
4. T3 [https://www.thenewtodaygrenada.com/letters/from-dcash-to-fast-payments-the-eccbs-quiet-financial-reset/](https://www.thenewtodaygrenada.com/letters/from-dcash-to-fast-payments-the-eccbs-quiet-financial-reset/) retrieved 2026-09-08
5. T1 [https://www.eccb-centralbank.org/frequently-asked-questions](https://www.eccb-centralbank.org/frequently-asked-questions) retrieved 2026-09-08

### W3 Operational Resilience & Critical Infrastructure Confirmed confirmed 2026-09-08

Operational resilience obligations for Antigua-and-Barbuda-licensed banks flow from ECCB prudential standards issued under the Banking Act 2015: a dedicated operational-risk-management standard and an outsourcing standard, both in force since 2020. The ECCB has separately elevated cybersecurity as a top supervisory concern and is coordinating an ECCU-wide data-protection/privacy legislative framework, though this remains at the harmonisation-policy stage rather than enacted national law.

Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. [Open its jurisdiction pages on Dataprotection.gi →](https://dataprotection.gi/jurisdictions/)

Standing sub-brief · as of 8 September 2026 149 words · last cycle 2026-09-08

#### Operational Resilience & Critical Infrastructure

Operational-resilience obligations for Antigua and Barbuda's licensed banks flow from the Eastern Caribbean Central Bank's prudential standards issued under section 184 of the Banking Act 2015: a Prudential Standard for Management of Operational Risk, effective since 1 August 2020, and a Prudential Standard for Outsourcing of Services, effective since 1 October 2020, together govern how banks manage operational and third-party risk. Separately, the ECCB is working with the OECS Commission to develop a harmonised Data Protection and Privacy Bill for the Eastern Caribbean Currency Union, intended to cover personal data, financial-information security and cross-border data transfers; this remains a policy-development item rather than enacted Antiguan law, and no enactment date has been set.

#### Outlook

The operational-risk and outsourcing standards are settled baseline supervision; the item to watch is whether the ECCU data-protection harmonisation effort converts into an enacted bill with an actual commencement date.

no periodic updates on record for this sub-brief

** Sources and findings (4)**

1. T1 [https://www.eccb-centralbank.org/standards](https://www.eccb-centralbank.org/standards) retrieved 2026-09-08
2. T1 [https://www.eccb-centralbank.org/standards](https://www.eccb-centralbank.org/standards) retrieved 2026-09-08
3. T1 [https://www.eccb-centralbank.org/news/governor-antoine-applauds-central-banks-it-specialists-for-safeguarding-regional-financial-systems](https://www.eccb-centralbank.org/news/governor-antoine-applauds-central-banks-it-specialists-for-safeguarding-regional-financial-systems) retrieved 2026-09-08
4. T1 [https://www.eccb-centralbank.org/news/eastern-caribbean-central-bank-publishes-policy-considerations-for-data-protection-and-privacy-legislation-in-the-eastern-caribbean-currency-union](https://www.eccb-centralbank.org/news/eastern-caribbean-central-bank-publishes-policy-considerations-for-data-protection-and-privacy-legislation-in-the-eastern-caribbean-currency-union) retrieved 2026-09-08

### W4 Scheme & Network Compliance 1 gap Probable confirmed 2026-09-08

Antigua and Barbuda has no distinct domestic interchange-regulation or PCI DSS enforcement statute; card-scheme compliance operates through Visa/Mastercard's own network rules as applied by domestic issuing/acquiring banks, layered on top of the general electronic-funds-transfer fraud framework set by statute.

Open gap — wpm-int-4 No dedicated interchange-regulation or PCI DSS enforcement statute identified for Antigua and Barbuda._Merchant-acquiring operational detail is thin for this jurisdiction relative to bias-correction expectations; treat W4/W8 findings as provisional._

Standing sub-brief · as of 8 September 2026 95 words · last cycle 2026-09-08

#### Scheme & Network Compliance

Antigua and Barbuda has no distinct domestic interchange-regulation or PCI DSS enforcement statute. Card and electronic-transfer fraud is instead addressed through the Electronic Transfer of Funds Crimes Act 2006, which defines relevant offences and provides for financial-institution clearing houses; scheme compliance itself runs through Visa and Mastercard network rules as applied by domestic issuing and acquiring banks rather than through a dedicated domestic statute.

#### Outlook

This is a standing structural gap rather than an emerging one; no legislative move toward a dedicated interchange or PCI DSS enforcement regime has been identified.

no periodic updates on record for this sub-brief

** Sources and findings (2)**

1. T1 [https://www.oas.org/juridico/spanish/cyb_ant_transfer_fund_2006.pdf](https://www.oas.org/juridico/spanish/cyb_ant_transfer_fund_2006.pdf) retrieved 2026-09-08
2. T3 [https://antiguanewsroom.com/ecab-launches-mastercard-suite-of-credit-cards/](https://antiguanewsroom.com/ecab-launches-mastercard-suite-of-credit-cards/) retrieved 2026-09-08

### W5 Payment Corridor Dynamics Probable confirmed 2026-09-08

Antigua and Barbuda's principal payment corridors are diaspora remittance flows (US/UK-XCD via MoneyGram, Remitly, Xoom) and intra-CARICOM/ECCU flows. The region is actively building CAPSS, modelled on Africa's PAPSS, intended to enable real-time local-currency settlement and reduce correspondent-bank dependence; the ECCB has signalled likely participation in an expanded pilot. A new US 1% remittance excise tax effective 1 January 2026 is reshaping corridor economics toward digital channels.

Standing sub-brief · as of 8 September 2026 165 words · last cycle 2026-09-08

#### Payment Corridor Dynamics

Antigua and Barbuda's principal payment corridors are diaspora remittance flows on the US/UK-XCD route and intra-CARICOM and ECCU flows. The CARICOM Payment and Settlement System, modelled on Africa's PAPSS, aims to enable real-time local-currency cross-border settlement across CARICOM and reduce correspondent-bank dependence, and the ECCB has signalled it will likely join an expanded pilot bringing on additional central banks. On the remittance side, a new US 1% excise tax on certain transfers took effect on 1 January 2026 under the One Big Beautiful Bill Act; digital-wallet transfer services report that they are not subject to this cash-focused tax, a carve-out that favours digital channels over cash remittance in the US-Antigua corridor, though this reporting comes from vendor commentary rather than confirmed US Treasury guidance.

#### Outlook

CAPSS pilot expansion is the corridor development to track most closely, since it would materially reduce Antigua and Barbuda's correspondent-banking exposure if the ECCB formally joins; the remittance-tax carve-out is a secondary, lower-confidence item pending independent verification.

no periodic updates on record for this sub-brief

** Sources and findings (5)**

1. T1 [https://www.eccb-centralbank.org/blogs/payment-system-integration](https://www.eccb-centralbank.org/blogs/payment-system-integration) retrieved 2026-09-08
2. T1 [https://www.eccb-centralbank.org/news/governor-antoine-highlights-faster-cheaper-transfers-under-caricom-payments-system](https://www.eccb-centralbank.org/news/governor-antoine-highlights-faster-cheaper-transfers-under-caricom-payments-system) retrieved 2026-09-08
3. T3 [https://antigua.news/2026/03/02/afreximbank-expands-caribbean-financing-to-us5-billion-antigua-and-barbuda-poised-to-benefit/](https://antigua.news/2026/03/02/afreximbank-expands-caribbean-financing-to-us5-billion-antigua-and-barbuda-poised-to-benefit/) retrieved 2026-09-08
4. T3 [https://www.xoom.com/antigua-and-barbuda/send-money](https://www.xoom.com/antigua-and-barbuda/send-money) retrieved 2026-09-08
5. T3 [https://www.transfi.com/blog/antigua-barbudas-payment-rails-how-they-work---eccu-systems-mobile-wallets-cross-border-payments](https://www.transfi.com/blog/antigua-barbudas-payment-rails-how-they-work---eccu-systems-mobile-wallets-cross-border-payments) retrieved 2026-09-08

### W6 Industry Structure & Commercial Probable confirmed 2026-09-08

Antigua and Barbuda's payments-adjacent industry is bank-led (Eastern Caribbean Amalgamated Bank as the dominant domestically-owned commercial bank) with a thin but growing regional fintech overlay (~40 fintech/digital financial-service providers, including regional payment aggregator WiPay Group).

Standing sub-brief · as of 8 September 2026 131 words · last cycle 2026-09-08

#### Industry Structure & Commercial Dynamics

Antigua and Barbuda's payments-adjacent industry is bank-led. Eastern Caribbean Amalgamated Bank, founded in 2010, has grown into the dominant domestically-owned commercial bank through the acquisition of ABI Bank and, more recently, Scotiabank's Antigua operations, consolidating indigenous banking and its associated card and payments business. Around this incumbent sits a comparatively thin regional fintech overlay: an estimated 40 fintech and digital financial-service providers serve the market, most operating regionally rather than as Antigua-domestic entities, including WiPay Group, a Trinidad and Tobago-founded licensed payment facilitator active across 12 Caribbean countries including Antigua and Barbuda.

#### Outlook

Structural concentration around ECAB is unlikely to shift in the near term; the more interesting dynamic is whether regional fintechs such as WiPay convert their multi-country licensing footprint into deeper Antigua-specific product distribution.

no periodic updates on record for this sub-brief

** Sources and findings (4)**

1. T1 [https://www.fsrc.gov.ag/](https://www.fsrc.gov.ag/) retrieved 2026-09-08
2. T4 [https://businessviewcaribbean.com/eastern-caribbean-amalgamated-bank-limited-antigua-barbuda/](https://businessviewcaribbean.com/eastern-caribbean-amalgamated-bank-limited-antigua-barbuda/) retrieved 2026-09-08
3. T3 [https://thefintechtimes.com/fintech-landscape-of-antigua-and-barbuda-in-2026/](https://thefintechtimes.com/fintech-landscape-of-antigua-and-barbuda-in-2026/) retrieved 2026-09-08
4. T3 [https://www.wipaygroup.com/](https://www.wipaygroup.com/) retrieved 2026-09-08

### W7 Legal & Litigation 1 gap Uncertain confirmed 2026-09-08

Landmark payments/financial-sector litigation specific to Antigua and Barbuda is sparse in open-source material beyond one notable case involving the FSRC and a licensed international bank; the statutory fraud/EFT liability framework is otherwise the primary legal infrastructure governing payment-related offences.

Open gap — wpm-int-5 Landmark payments/financial-sector litigation register for AG is thin beyond the single BOI Bank/FSRC case identified._no under-indexing note recorded_

Standing sub-brief · as of 8 September 2026 109 words · last cycle 2026-09-08

#### Legal & Litigation

Antigua and Barbuda's payments-related litigation register is thin in open-source material. The one notable identified case involves a St John's court ruling in favour of a depositor who sued BOI Bank, an FSRC-regulated international bank, over an inability to withdraw a US$2.5 million deposit; the court ordered a refund, and a related legal action was separately brought against the FSRC over its handling of the licensee. This is drawn from a single secondary press account, and no primary judgment text has been located.

#### Outlook

Absent further primary-source litigation, the statutory electronic-funds-transfer fraud framework remains the main legal infrastructure governing payment-related disputes and offences in this jurisdiction.

no periodic updates on record for this sub-brief

** Sources and findings (2)**

1. T4 [https://dominicanewsonline.com/news/homepage/news/antiguas-fsrc-in-a-legal-battle/](https://dominicanewsonline.com/news/homepage/news/antiguas-fsrc-in-a-legal-battle/) retrieved 2026-09-08
2. T1 [https://www.oas.org/juridico/spanish/cyb_ant_transfer_fund_2006.pdf](https://www.oas.org/juridico/spanish/cyb_ant_transfer_fund_2006.pdf) retrieved 2026-09-08

### W8 Merchant Acquiring & Risk 1 gap Probable confirmed 2026-09-08

Merchant acquiring is conducted by Banking Act-licensed banks (chiefly ECAB, issuing Visa/Mastercard products) and by regional non-bank payment facilitators such as WiPay, which offers a 'Bank-in-a-Box' acquiring product to deposit-taking institutions. There is no distinct statutory merchant-acquiring or high-risk-MCC regime beyond general Banking Act licensing of the acquiring bank.

Open gap — wpm-int-6 No dedicated high-risk-MCC treatment regime identified for AG merchant acquiring._Merchant-acquiring ops coverage is a known fleet-wide under-indexed area; AG findings here are provisional pending deeper sourcing._

Standing sub-brief · as of 8 September 2026 121 words · last cycle 2026-09-08

#### Merchant Acquiring & Risk

Merchant acquiring in Antigua and Barbuda is conducted by Banking Act-licensed banks, chiefly Eastern Caribbean Amalgamated Bank issuing Visa and Mastercard products, and by regional non-bank payment facilitators. WiPay Services Ltd, a licensed payment facilitator, offers a 'Bank-in-a-Box' product that enables deposit-taking institutions to establish or expand merchant-acquiring business without building acquiring infrastructure from scratch. There is no distinct statutory high-risk-merchant-category-code treatment regime in Antigua and Barbuda beyond the general Banking Act licensing that governs the acquiring bank itself.

#### Outlook

Acquiring capacity will likely keep expanding through bank-partnered non-bank facilitation models such as WiPay's rather than through new dedicated acquiring legislation; the absence of a high-risk-MCC regime remains a standing gap rather than a live legislative debate.

no periodic updates on record for this sub-brief

** Sources and findings (3)**

1. T1 [https://legalaffairs.gov.ag/pdf/bills/Banking_act_2015.pdf](https://legalaffairs.gov.ag/pdf/bills/Banking_act_2015.pdf) retrieved 2026-09-08
2. T3 [https://www.wipaygroup.com/](https://www.wipaygroup.com/) retrieved 2026-09-08
3. T4 [https://cartdna.com/en/shopify-payment-methods/wipay](https://cartdna.com/en/shopify-payment-methods/wipay) retrieved 2026-09-08

### W9 Product Innovation & Market Development Probable confirmed 2026-09-08

Product innovation centres on the ECCB's DCash CBDC programme (now paused at the 'DCash 2.0' commercial stage) and forward-looking regulatory-sandbox provisions embedded in the incoming PSSA 2025, alongside the regional CAPSS instant-payments initiative in pilot expansion.

Standing sub-brief · as of 8 September 2026 138 words · last cycle 2026-09-08

#### Product Innovation & Market Development

Product innovation in Antigua and Barbuda centres on two tracks moving in different directions. The incoming Payment Systems and Services Act embeds regulatory sandbox provisions for fintech innovation alongside mandated system interoperability, positioning fintechs to complement traditional banking for financial-inclusion goals — though these sandbox provisions are prospective and contingent on PSSA commencement. Separately, the CARICOM Payment and Settlement System pilot expansion was announced at the July 2025 AfriCaribbean Trade and Investment Forum in Grenada, incorporating Barbados, the Bahamas and Eastern Caribbean Central Bank states, evidencing institutional momentum toward a live regional instant-payments product even as the ECCB's own DCash CBDC track has been paused at the commercial stage.

#### Outlook

The sandbox provisions cannot be tested until the PSSA is commenced; CAPSS pilot expansion is the nearer-term, currently-moving product-innovation story for this jurisdiction.

no periodic updates on record for this sub-brief

** Sources and findings (4)**

1. T1 [https://www.eccb-centralbank.org/blogs/payment-system-integration](https://www.eccb-centralbank.org/blogs/payment-system-integration) retrieved 2026-09-08
2. T1 [https://www.dcashec.com/about](https://www.dcashec.com/about) retrieved 2026-09-08
3. T3 [https://www.thenewtodaygrenada.com/letters/from-dcash-to-fast-payments-the-eccbs-quiet-financial-reset/](https://www.thenewtodaygrenada.com/letters/from-dcash-to-fast-payments-the-eccbs-quiet-financial-reset/) retrieved 2026-09-08
4. T3 [https://villagevoicenews.com/2025/12/06/caricom-afreximbank-caricom-payment-system-races-against-time-as-china-deploys-operational-alternative/](https://villagevoicenews.com/2025/12/06/caricom-afreximbank-caricom-payment-system-races-against-time-as-china-deploys-operational-alternative/) retrieved 2026-09-08

### W10 Consumer Protection & APP Fraud Probable confirmed 2026-09-08

Consumer protection for payments is anchored in general consumer law (Consumer Protection Act, Fair Trading Act) plus incoming PSSA consumer-protection provisions; APP-fraud/scam vigilance is actively driven by the ONDCP, which issued a public fraud advisory on account-compromise and top-up scams in August 2025, rather than by a dedicated statutory APP-fraud-reimbursement regime.

Standing sub-brief · as of 8 September 2026 126 words · last cycle 2026-10-11

#### Consumer Protection & APP Fraud

Consumer protection for payments in Antigua and Barbuda sits mainly in general consumer law rather than in a dedicated payments-fraud statute. The Office of National Drug and Money Laundering Control Policy issued a public advisory in August 2025 urging heightened vigilance in response to increased reports of account-compromise and top-up scams — an APP-fraud-adjacent, consumer-facing action rather than the exercise of any dedicated statutory reimbursement power. No dedicated APP-fraud reimbursement regime has been identified for this jurisdiction; consumer protection instead sits within general consumer-protection and fair-trading law administered by the Consumer Affairs Division.

#### Outlook

Absent a dedicated reimbursement statute, ONDCP advisory activity is likely to remain the primary visible lever for addressing account-compromise and scam-driven fraud risk in the near term.

Periodic update · new data 2026-10-11

#### Consumer Protection & APP Fraud

Consumer protection for financial-services and payments customers in Antigua and Barbuda has been reshaped this cycle by the Banking (Amendment) Act 2025's market-conduct-supervision provisions, which apply to financial services and financial products offered by a licensed financial institution notwithstanding anything contained in the general Consumer Protection Act 2025. This disapplication clause is confirmed-tier and directly sourced from the Act's own text, and it establishes that, for licensed financial institutions, the sector-specific Banking Act regime governs rather than the general consumer-protection statute.

The consequence for payments customers specifically is that where a payment service provider is also a licensed financial institution, its conduct toward consumers, including fee transparency, disclosure, and complaint-handling, falls to be assessed under the Banking Act's Part VIIA framework rather than the general Consumer Protection Act 2025. This is a structurally significant distinction because it means two different consumer-protection standards could, in principle, apply across Antigua and Barbuda's broader economy: the general standard for most consumer transactions, and the sector-specific Banking Act standard for financial-services consumers. No APP-fraud-specific (authorised-push-payment fraud) provision distinct from the general market-conduct framework was identified this cycle for Antigua and Barbuda.

This development should be read alongside the Central Bank's parallel new information-gathering powers under the same Part VIIA, which allow it to request records and documents from licensed institutions; these powers give the Central Bank a practical mechanism for investigating potential consumer-conduct breaches once the sector-specific standard is in place, even though no specific enforcement action under the new provisions was identified this cycle.

#### Outlook

The practical operation of the Banking Act's sector-specific consumer-protection carve-out, relative to the general Consumer Protection Act 2025, is the item to watch for Antigua and Barbuda's payments customers going forward. Whether the Central Bank begins to exercise its new information-gathering powers specifically in relation to consumer-conduct matters, as distinct from prudential or market-conduct matters more broadly, would be a significant signal of how actively this new consumer-protection track is being supervised in practice.

**Sources and findings (4)**

1. T1 [https://www.eccb-centralbank.org/blogs/payment-system-integration](https://www.eccb-centralbank.org/blogs/payment-system-integration) retrieved 2026-09-08
2. T1 [https://ondcp.gov.ag/](https://ondcp.gov.ag/) retrieved 2026-09-08
3. T3 [http://www.lawgratis.com/blog-detail/consumer-law-antigua-and-barbuda](http://www.lawgratis.com/blog-detail/consumer-law-antigua-and-barbuda) retrieved 2026-09-08
4. T3 [https://en.wikipedia.org/wiki/Office_of_the_Ombudsman_(Antigua_and_Barbuda)](https://en.wikipedia.org/wiki/Office_of_the_Ombudsman_(Antigua_and_Barbuda)) retrieved 2026-09-08

### W11 AML/CFT & Financial Crime 1 gap [Sourced from Sentinel.gi ↗](https://sentinel.gi/) Confirmed confirmed 2026-09-08

Sentinel.gi position: Antigua and Barbuda's AML/CFT regime rests on the Money Laundering (Prevention) Act 1996 (as amended), supervised jointly by the ONDCP (Supervisory Authority) and the FSRC, under CFATF/FATF mutual-evaluation oversight. Following its 2018 CFATF Mutual Evaluation Report and 2021 Follow-Up Report re-ratings, the country is now preparing for its Fifth Round Mutual Evaluation, with continued active CFATF Plenary engagement through late 2025.

Open gap — wpm-int-7 No published schedule exists yet for Antigua and Barbuda's CFATF Fifth Round Mutual Evaluation._no under-indexing note recorded_

Standing sub-brief · as of 8 September 2026 125 words · last cycle 2026-09-08

#### AML/CFT & Financial Crime

This module's intelligence is sourced from the Sentinel.gi feed; WPM does not independently re-analyse illicit-finance activity here. Sentinel reporting identifies the Money Laundering (Prevention) Act 1996, with the ONDCP Director designated Supervisory Authority for financial institutions, as the principal AML/CFT statute in Antigua and Barbuda. Following the 2018 CFATF Mutual Evaluation Report and 2021 Follow-Up re-ratings — Compliant on 11 and Largely Compliant on 25 of the Recommendations — Antigua and Barbuda's delegation demonstrated continued engagement at the CFATF's 61st Plenary in December 2025 while preparing for its Fifth Round Mutual Evaluation.

#### Outlook

No Fifth Round Mutual Evaluation date has yet been published. This has been flagged to the Financial Integrity Monitor for continued AML/CFT posture tracking beyond this Sentinel-fed headline.

no periodic updates on record for this sub-brief

** Sources and findings (6)**

1. T1 sentinel.http://www.commonlii.org/ag/legis/num_reg/mlr2021563.pdf
2. T? FIM (sentinel.gi) per-JID baseline profile — Antigua and Barbuda — AML/CFT governed by the Money Laundering (Prevention) Act 1996 (as amended) and Prevention of Terrorism Act 2005, supervised by ONDCP (Supervisory Authority and FIU) with FSRC co-supervising international banks, insurance, gaming and VASPs under the Digital Business Assets Act. CFATF member; 2018 MER plus 2021 Follow-Up Report show moderate effectiveness with persistent gaps on PF sanctions, NPOs and DNFBP supervision.
3. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-005) — Gap: capacity-deficit
4. T1 FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-003) — Enforcement: OFAC — CICCIO, HOPE 1, JADE, OPAL, PAYA LEBAR (Antigua and Barbuda-flagged cargo/bulk vessels)
5. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: legal-gap
6. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-004) — Gap: enforcement-absence

### W12 Correspondent Banking, Settlement & Access Probable confirmed 2026-09-08

Correspondent-banking de-risking has been a long-standing, PM-level advocacy priority for Antigua and Barbuda within CARICOM, given the jurisdiction's exposure to withdrawal of US/European correspondent relationships; the CAPSS initiative is the region's structural response intended to reduce dependence on correspondent banks for cross-border settlement, alongside ECCB's role as the sole settlement authority for domestic clearing.

Standing sub-brief · as of 8 September 2026 165 words · last cycle 2026-09-08

#### Correspondent Banking, Settlement & Access

The analytical spine of this module is an access asymmetry: bank-route correspondent relationships for Antigua and Barbuda have faced sustained de-risking pressure, while non-bank payment channels typically settle through intermediary banks or card schemes rather than holding correspondent relationships of their own. Correspondent-banking de-risking has been a long-standing, Prime-Minister-level advocacy priority for Antigua and Barbuda within CARICOM, dating to a 2016 conference the country hosted and chaired convening the IMF, World Bank, EU Commission, OECD Global Forum and CARICOM central banks. The CARICOM Payment and Settlement System is the structural response now in motion: it is explicitly designed to reduce reliance on international correspondent banks by enabling real-time local-currency cross-border retail and wholesale settlement across CARICOM member states, addressing this exposure directly rather than through advocacy alone.

#### Outlook

Whether CAPSS materially reduces correspondent-banking dependence will depend on how far the pilot expansion advances and whether the ECCB formally joins; advocacy alone has not resolved the underlying access asymmetry to date.

no periodic updates on record for this sub-brief

** Sources and findings (4)**

1. T3 [https://caricom.org/media-center/communications/press-releases/way-forward-identified-on-correspondent-banking-challenge-pm-browne](https://caricom.org/media-center/communications/press-releases/way-forward-identified-on-correspondent-banking-challenge-pm-browne) retrieved 2026-09-08
2. T3 [https://caricom.org/looming-issue-of-de-risking-in-region-remains-high-on-cfatf-agenda/](https://caricom.org/looming-issue-of-de-risking-in-region-remains-high-on-cfatf-agenda/) retrieved 2026-09-08
3. T1 [https://www.eccb-centralbank.org/blogs/payment-system-integration](https://www.eccb-centralbank.org/blogs/payment-system-integration) retrieved 2026-09-08
4. T1 [https://www.eccb-centralbank.org/frequently-asked-questions](https://www.eccb-centralbank.org/frequently-asked-questions) retrieved 2026-09-08

### W13 Commercial Intelligence (M&A, Investment & Product) Probable confirmed 2026-09-08

Trailing-12-month commercial activity touching Antigua and Barbuda's payments space is dominated by incumbent-bank product launches and regional infrastructure investment rather than domestic M&A; the local fintech sector remains small and largely unfunded at the individual-company level.

Standing sub-brief · as of 8 September 2026 120 words · last cycle 2026-09-08

#### Commercial Intelligence (M&A, Investment & Product)

Eastern Caribbean Amalgamated Bank launched a new suite of Mastercard credit cards on 28 November 2025, in partnership with Mastercard, with the launch event attended by Mastercard executives — a product-release event illustrating the domestic card-scheme relationship structure that also features under scheme compliance. Separately, Afreximbank expanded its total approved Caribbean financing facility to US$5 billion, with Antigua and Barbuda cited as poised to benefit through advancement of the CARICOM Payment and Settlement System; the country-specific allocation was not publicly disclosed.

#### Outlook

Neither event is domestic M&A; both are incumbent-bank product activity and regional infrastructure investment respectively, consistent with a local commercial landscape still dominated by regional players rather than standalone Antigua-based fintech deals.

no periodic updates on record for this sub-brief

** Sources and findings (4)**

1. T3 [https://antiguanewsroom.com/ecab-launches-mastercard-suite-of-credit-cards/](https://antiguanewsroom.com/ecab-launches-mastercard-suite-of-credit-cards/) retrieved 2026-09-08
2. T3 [https://www.thenewtodaygrenada.com/letters/from-dcash-to-fast-payments-the-eccbs-quiet-financial-reset/](https://www.thenewtodaygrenada.com/letters/from-dcash-to-fast-payments-the-eccbs-quiet-financial-reset/) retrieved 2026-09-08
3. T3 [https://antigua.news/2026/03/02/afreximbank-expands-caribbean-financing-to-us5-billion-antigua-and-barbuda-poised-to-benefit/](https://antigua.news/2026/03/02/afreximbank-expands-caribbean-financing-to-us5-billion-antigua-and-barbuda-poised-to-benefit/) retrieved 2026-09-08
4. T4 [https://tracxn.com/d/explore/fintech-startups-in-antigua-and-barbuda/5uA9R5t3F-5kVCCiUmZPpCp9OfgVkMkI_DhwbamjVhc#top-companies](https://tracxn.com/d/explore/fintech-startups-in-antigua-and-barbuda/5uA9R5t3F-5kVCCiUmZPpCp9OfgVkMkI_DhwbamjVhc#top-companies) retrieved 2026-09-08

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## Editorial metadata

Provenance only. Nothing below gates publication or affects the render.

Editorial metadata for AG| Field | Value |
|---|---|
| `trust.lawyer_review.status` | never_reviewed |
| `trust.lawyer_review.reviewer` | no reviewer on record |
| ` trust.content_source` | ai_generated |

## Provenance and declared absence

**Disclosure model:** module cards load OPEN; standing positions render in full; sub-briefs and jurisdiction briefs load as a clamped teaser with an explicit “read full” control carrying the true word count; earlier updates stay collapsed behind a counted summary. No text is hidden without disclosing how much of it there is.

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**Family taxonomy** is renderer-level presentation config, not a JID field. Colour is always duplicated in text and is never the sole carrier of meaning.

**Suppressed by doctrine:** derived risk score; per-module RAG traffic light; `derived_scores` = `{"legal_accessibility": {"per_product": {"account_to_account": "regulated", "cards": "regulated", "prepaid_emoney": "licensed-emi"}}}`.

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**Envelope:** baseline resolved at `jurisdiction_json.baseline`; 14 module(s), 59 finding(s), 114 source(s) in the cumulative register.

**Audit trail**

Machine check Challenged on 6 Oct 2026: not upheld (9 confirmed against the cited source; 3 contradicted by the cited source; 12 could not be checked). An automated, adversarial test run by a second model; no person has assessed the result.

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