title: MH Payments Regulation Monitor | World Payments Monitor canonical: https://payments.gi/jurisdictions/marshall-islands/ date_modified: 2026-10-21 publisher: Asymmetric Intelligence # MH MH schema world-payments-v1 trajectory: not yet assessed Last updated 2026-10-21 · 14 modules · 60 sourced findings · 129 sources in the cumulative register 14 Modules baseline.modules[] 60 Findings modules[].findings[] 25 Tier-1 sources run_metadata.t1_source_count Confidence mix (sums to 14 rendered modules; click to filter) ## Jurisdiction brief ###### Latest update · 11 October 2026 #### Lead Signal The Marshall Islands' payments and banking supervisory architecture was materially restructured this cycle with the establishment of the Marshall Islands Monetary Authority, MIMA, under the Monetary Authority Act, 2025 (PL 2025-32). MIMA consolidates oversight of banks, money-service businesses and payment systems into a single independent regulator, superseding what had previously been a split role held by the Banking Commission. The citation is confirmed via the Nitijela public-law index, with narrative detail drawn from the RMI Ministry of Finance's own whitepaper; the full statute text was not opened this cycle, so MIMA's exact commencement date and the precise boundaries of its supervisory perimeter remain to be confirmed. This restructuring sits against a backdrop the Ministry of Finance itself frames explicitly as a response to correspondent-banking de-risking pressure, and it coincides with the launch of USDM1, a US Treasury-collateralised digital sovereign bond that the issuer insists is not a stablecoin, CBDC, or cryptocurrency, a classification disputed by third-party trackers that describe the instrument in functional CBDC or stablecoin terms. #### Other Developments **Severe correspondent-banking concentration.** The Marshall Islands' access to the international payments system now runs through a single correspondent banking relationship, held by the Bank of Marshall Islands via First Hawaiian Bank and BNP Paribas. The Ministry of Finance's own whitepaper states that Pacific remittance costs average around ten percent, roughly triple the UN Sustainable Development Goal target, and that international USD wires cost four to five times the global average with settlement taking up to a week. In response, the Marshall Islands has become one of four pilot countries, alongside Fiji, Samoa and Tonga, in a World Bank and Pacific Islands Forum project building a CBR Resilience Index intended to secure temporary correspondent-banking-relationship access for eligible Pacific institutions. **USDM1 and the Lomalo UBI disbursement.** USDM1, developed with Stellar Development Foundation support, underpins the ENRA universal basic income programme, which the Stellar Development Foundation describes as the world's first onchain disbursement of universal basic income, launched in November 2025. In April 2026, Anchorage Digital, a federally chartered US digital-asset bank, announced it had begun providing institutional custody for USDM1, framing the instrument as secured sovereign debt issued under New York law. Commercial terms for both the Stellar Development Foundation's involvement and the Anchorage Digital custody arrangement were not publicly disclosed. #### Cross-Monitor Connections The correspondent-banking access crisis documented here connects directly to the financial-integrity monitor's tracking of the Marshall Islands' open ship and corporate registry, which has repeatedly surfaced in OFAC sanctions-evasion designations; a jurisdiction facing this scale of de-risking pressure has structural incentive to pursue institutional reforms such as MIMA's establishment, even as the underlying registry-enabler dynamics that help drive de-risking in the first place persist independently. The crypto monitor's tracking of USDM1's unresolved classification dispute, sovereign bond versus functional stablecoin or CBDC, bears directly on this monitor's own stablecoin and digital-money coverage, since the applicable regulatory and reserve framework for the instrument depends substantially on which characterisation prevails. #### Outlook MIMA's full supervisory build-out is expected through the fourth quarter of 2026, as scheduled, and the central question for this jurisdiction's licensing and market-access posture is whether that build-out produces a published, confirmable supervisory perimeter, particularly for USDM1, or whether the institutional architecture continues to run ahead of its documented rules. On the corridor and correspondent-banking side, the CBR Resilience Index pilot's progress will be the clearest indicator of whether multilateral intervention can meaningfully ease the single-correspondent dependency and associated cost burden documented this cycle, a structural vulnerability that is unlikely to resolve on the timescale of a single reporting cycle. ###### Standing brief · as of 8 September 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Lead Signal The Marshall Islands enters this cycle with its payments architecture in transition on three fronts at once: a consolidated regulator moving toward operational status, a single correspondent banking relationship under sustained threat, and a state-issued digital instrument facing explicit multilateral resistance to its intended scale. Public Law 2025-32, the Monetary Authority Act 2025, passed by the Nitijela, creates the legal basis for a new consolidated regulator, the Marshall Islands Monetary Authority (MIMA), to absorb banking, MSB and payment-systems oversight; implementation is in transition and not yet fully operational. Until MIMA displaces it, banks and financial services providers must be Cabinet-approved-licensed by the Banking Commissioner under 17 MIRC Ch.1 §156 of the Banking Act 1987, per the Banks and FSPs Licensing and Fees Regulations 2020, before transacting business in RMI. That produces a near-term period of overlapping authority between the incoming and incumbent licensing regimes. The most acute vulnerability sits in correspondent banking: the Bank of the Marshall Islands' only remaining correspondent relationship is with First Hawaiian Bank, which has sought to end the relationship since 2014 and retains it only until BOMI finds another correspondent bank, against a backdrop in which RMI has lost approximately 700 correspondent banking relationships since 2008. That fragility is the direct backdrop to USDM1, the digital sovereign bond distributed via the Lomalo wallet from November-December 2025 to pay the ENRA universal basic income. The IMF's 2025 Article IV Consultation characterises USDM1 as a 'digital sovereign bond' distinct from a privately issued stablecoin, and recommends the authorities not proceed with its planned global launch given insufficient capacity to mitigate associated risks. The initiative follows the repeal, in August 2025, of the Sovereign Currency Act of 2018, which had declared the Sovereign (SOV) legal tender, after years of IMF opposition and non-implementation. Early uptake data reinforces the IMF's caution: of the first round of ENRA disbursements, about 60% went out as direct bank deposits and the remainder as bank checks, with only about 12 people opting to receive payment in USDM1 itself. #### Other Developments Away from the correspondent-banking and digital-currency headline, the FDIC adopted a final rule, effective 22 April 2026, providing that it will insure deposits of all branches of U.S.-insured depository institutions in the Federated States of Micronesia, the Republic of the Marshall Islands, and the Republic of Palau. Card infrastructure remains a separate point of fragility: the Bank of the Marshall Islands' card system functions as a closed-loop domestic network unsupported by Visa or Mastercard and cannot accept international cards, contributing to card-transaction costs far above global averages. No domestic PCI DSS mandate, interchange regulation, or card-scheme technical-standards regime was identified. Merchant acquiring is correspondingly thin and largely informal: only larger hotels, restaurants and stores in Majuro accept cards, and Bank of Guam provides the main card-acceptance and dispute/chargeback infrastructure available locally. Consumer protection in payments is similarly underdeveloped: there is no dedicated APP-fraud reimbursement scheme, financial ombudsman, or standalone consumer-protection statute, with safeguards arising indirectly from AML/KYC account-opening requirements and voluntary payment-method choice in the ENRA programme design. On financial-crime standing, RMI is an APG member subject to mutual evaluation of its AML/CFT/CPF measures and is not currently on the FATF grey or black lists, with core domestic AML measures dating to the early 2000s, including the USD 10,000 cash-transaction reporting threshold enforced by the Banking Commission. On the commercial side, Crossmint closed a Series A-II funding round on 24 September 2025, with Flourish Ventures among the investors, and the Stellar Development Foundation issued a multimillion-dollar grant in December 2025 to fund USDM1's development. #### Cross-Monitor Connections The IMF's Article IV recommendations tie continued correspondent-banking access to AML/CFT strengthening, and the AML/CFT position carried here is sourced from the Sentinel feed as payments-context only. The original analysis of illicit-finance risk and the drivers of correspondent-bank de-risking behind the Bank of the Marshall Islands' single remaining relationship belongs to the Financial Intelligence Monitor rather than to this brief. #### Outlook The signals to watch next are the implementation timeline for MIMA and whether it pursues direct U.S. Federal Reserve master account access, the outcome of BOMI's search for a replacement or additional correspondent banking relationship beyond First Hawaiian Bank, the status of a proposed US funding amendment that would permit direct USDM1 UBI disbursement rather than routing through paper checks, and the passage or enactment status of RMI's draft Cyber Security Act and Cyber Crimes Act. Each bears directly on whether RMI's payments system stabilises around the new consolidated regulator and a diversified settlement channel, or remains dependent on a single correspondent relationship and a digital-bond pilot that the IMF has so far declined to endorse for wider use. trust tier: ai_unverified _Standing brief, as of 8 September 2026._ #### Regulatory Status The Marshall Islands regulates banks and financial services providers under Cabinet-approved licensing by the Banking Commissioner pursuant to the Banking Act 1987, with a new consolidated regulator, the Marshall Islands Monetary Authority, created by the Monetary Authority Act 2025 and currently in transition toward operational status. Correspondent banking access is the jurisdiction's most acute payments vulnerability: the Bank of the Marshall Islands' sole remaining correspondent relationship, with First Hawaiian Bank, has been under threat of termination since 2014, following the loss of approximately 700 correspondent banking relationships since 2008. The jurisdiction's principal digital-money initiative, USDM1, distributed via the Lomalo wallet, has drawn an IMF recommendation against global scaling, while RMI's earlier Sovereign Currency Act of 2018 was repealed in August 2025. RMI is an APG member subject to AML/CFT mutual evaluation and is not on the FATF grey or black lists. #### Outlook The implementation trajectory of the Monetary Authority Act 2025, the outcome of BOMI's search for a replacement correspondent banking relationship, and the scale of USDM1 adoption are the three variables most likely to define the jurisdiction's payments risk profile over the coming cycles. 14 of 14 modules Signal Density Selections OR within a group, AND across groups. Press / to search. ### W1a Licensing, Authorisation & Market Access moved 1 gap Confirmed confirmed 2026-09-08 The Marshall Islands Monetary Authority (MIMA) was established by the Monetary Authority Act, 2025 (PL 2025-32) as an independent regulator consolidating oversight of banks, money-service businesses and payment systems, superseding the Banking Commission's split supervisory role. Movement — NEW MIMA established under PL 2025-32._First-time surfacing of MIMA establishment for MH in this monitor._ Open gap — wpm-int-5 Primary legislative text of the Monetary Authority Act 2025 (PL 2025-32) could not be retrieved live (rminitijela.com throttled, HTTP 503); claim relies on secondary Ministry of Finance corroboration._no under-indexing note recorded_ Standing sub-brief · as of 8 September 2026 180 words · last cycle 2026-10-11 #### Licensing, Authorisation & Market Access Banks and financial services providers must be Cabinet-approved-licensed by the Banking Commissioner under 17 MIRC Ch.1 §156 of the Banking Act 1987, per the Banks and FSPs Licensing and Fees Regulations 2020, before transacting business in RMI; this licensing gate applies to both bank and non-bank payments entrants seeking market access. Public Law 2025-32, the Monetary Authority Act 2025, passed by the Nitijela, creates the legal basis for a new consolidated regulator, the Marshall Islands Monetary Authority (MIMA), to absorb banking, MSB and payment-systems oversight; implementation is in transition and not yet fully operational. Because MIMA has not yet displaced the Banking Commissioner structure, licensing and prudential authority currently sits in a near-term period of overlapping regimes, with the primary legislative text of the Monetary Authority Act itself not independently retrievable this cycle and the claim resting on secondary Ministry of Finance corroboration. #### Outlook The implementation timeline for MIMA, including whether it pursues direct U.S. Federal Reserve master account access, is the determining near-term variable for how licensing and market-access authority is exercised going forward. Periodic update · new data 2026-10-11 #### Licensing, Authorisation & Market Access The Marshall Islands' licensing and market-access architecture underwent a material restructuring this cycle with the establishment of the Marshall Islands Monetary Authority, MIMA, under the Monetary Authority Act, 2025 (PL 2025-32). MIMA is established as an independent regulator consolidating oversight of banks, money-service businesses and payment systems, replacing what had been a split arrangement under the Banking Commission. The citation for this reform is confirmed via the Nitijela public-law index, and the narrative description of MIMA's mandate and rationale comes from the RMI Ministry of Finance's own whitepaper, though the primary statute text itself was not independently opened this cycle. As a result, MIMA's exact commencement date and the precise scope of its supervisory perimeter across bank, non-bank and payment-system licensees remain to be confirmed from the primary legal text rather than from secondary disclosure alone. For firms seeking market access in the Marshall Islands, whether as banks, money-service businesses, or payment companies, this consolidation is likely to mean a single point of licensing and supervisory contact going forward, replacing what had been a more fragmented structure. However, because the full statute and any implementing regulations have not yet been independently reviewed, firms cannot yet rely on a confirmed, documented licensing process or timeline under the new authority. The Ministry of Finance's own framing situates this reform explicitly as a response to correspondent-banking de-risking pressure facing the jurisdiction, suggesting that part of MIMA's institutional purpose is to present a more credible, consolidated supervisory counterpart to international correspondent banks and counterparties. #### Outlook MIMA's full supervisory build-out is expected through the fourth quarter of 2026, as scheduled. The key development to watch is whether that build-out is accompanied by published licensing rules, application procedures and a confirmed supervisory perimeter for bank, non-bank payment and money-service-business licensees, or whether the institutional architecture continues to outpace documented rules. Firms with existing or prospective Marshall Islands licensing exposure should treat the current period as transitional, with the practical content of MIMA's licensing regime not yet fully ascertainable from primary sources. **Sources and findings (6)** 1. T1 [https://rmicourts.org/wp-content/uploads/2020/11/Banks-and-FSPs-Licensing-Regulations-Final-9-23-2020.pdf](https://rmicourts.org/wp-content/uploads/2020/11/Banks-and-FSPs-Licensing-Regulations-Final-9-23-2020.pdf) retrieved 2026-09-08 2. T1 [https://rminitijela.com/public-law-communication/](https://rminitijela.com/public-law-communication/) retrieved 2026-09-08 3. T1 [https://mof.gov.mh/usdm1-whitepaper/](https://mof.gov.mh/usdm1-whitepaper/) retrieved 2026-09-08 4. T3 [https://www.consulting24.co/marshall-islands-crypto-license/](https://www.consulting24.co/marshall-islands-crypto-license/) retrieved 2026-09-08 5. T4 [https://www.jarniascyril.com/expatriation/moving-to-the-marshall-islands-a-complete-expat-guide/expat-banking-services-marshall-islands/](https://www.jarniascyril.com/expatriation/moving-to-the-marshall-islands-a-complete-expat-guide/expat-banking-services-marshall-islands/) retrieved 2026-09-08 6. T4 [https://www.glofsa.org/](https://www.glofsa.org/) retrieved 2026-09-08 ### W1b Conduct, Safeguarding & Promotions Probable confirmed 2026-09-08 Conduct and AML-linked safeguarding sit with the Banking Commissioner under the Banking Act 1987 framework: cash transactions/transfers over USD 10,000 must be reported, shell banks and correspondent relationships with them are banned, and licences can be suspended/revoked (with Cabinet approval) on suspicion of money laundering. There is no dedicated financial-promotions statute; enforcement of mis-promotion is largely externalised to foreign regulators (e.g. UK FCA) warning against unauthorised RMI-registered entities. Standing sub-brief · as of 8 September 2026 104 words · last cycle 2026-09-08 #### Conduct, Safeguarding & Promotions Cash transactions and transfers exceeding USD 10,000 are reported by banks to the Banking Commission, which has authority to investigate financial records when necessary. This reporting duty sits within the Banking Act 1987 framework and applies specifically to bank-PSP conduct rather than to non-bank payment institutions, for which no distinct conduct or safeguarding regime was identified this cycle. No dedicated financial-promotions statute was identified for RMI-registered payment entities. #### Outlook Whether the incoming Monetary Authority Act 2025 framework extends conduct and safeguarding obligations to non-bank payment institutions, distinct from the bank-focused reporting duty currently in force, remains an open near-term question. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://www.state.gov/reports/2023-investment-climate-statements/marshall-islands](https://www.state.gov/reports/2023-investment-climate-statements/marshall-islands) retrieved 2026-09-08 2. T4 [https://www.jarniascyril.com/expatriation/moving-to-the-marshall-islands-a-complete-expat-guide/expat-banking-services-marshall-islands/](https://www.jarniascyril.com/expatriation/moving-to-the-marshall-islands-a-complete-expat-guide/expat-banking-services-marshall-islands/) retrieved 2026-09-08 3. T4 [https://valsen-corporate.com/marshall-islands-banking-licence/](https://valsen-corporate.com/marshall-islands-banking-licence/) retrieved 2026-09-08 4. T1 [https://www.fca.org.uk/news/warnings/mti24](https://www.fca.org.uk/news/warnings/mti24) retrieved 2026-09-08 ### W2 Stablecoins & Digital Money moved Confirmed confirmed 2026-09-08 RMI's 2018 Sovereign Currency Act (creating the decentralised legal-tender 'SOV' crypto-asset) was repealed in August 2025 after years of IMF opposition and non-implementation. In its place, the government launched (Nov-Dec 2025) the Lomalo digital wallet and USDM1 -- a US-Treasury-collateralised, New York-law-governed digital sovereign bond used to distribute the ENRA universal basic income -- which the IMF has characterised as a 'digital sovereign bond' rather than a private stablecoin, and against whose global scaling the IMF's 2025 Article IV explicitly recommended the authorities not proceed. Movement — NEW USDM1 classification dispute surfaced._First-time surfacing of USDM1 and its classification dispute._ Standing sub-brief · as of 8 September 2026 98 words · last cycle 2026-10-11 #### Stablecoins & Digital Money The Sovereign Currency Act of 2018, which declared the Sovereign (SOV) legal tender, was repealed in August 2025 after years of IMF opposition and non-implementation. The IMF's 2025 Article IV Consultation characterises USDM1 as a 'digital sovereign bond' distinct from a privately issued stablecoin, and recommends the authorities not proceed with its planned global launch given insufficient capacity to mitigate associated risks. #### Outlook Whether RMI pursues USDM1's global launch against the IMF's explicit recommendation, or confines the instrument to its current domestic UBI-disbursement role, is the key determinant of how this tracker develops next. Periodic update · new data 2026-10-11 #### Stablecoins & Digital Money USDM1 is the central digital-money development for the Marshall Islands this cycle, and it arrives with an unresolved classification dispute at its core. The RMI Ministry of Finance states that USDM1 is a US dollar-denominated sovereign obligation backed one-to-one by US Treasury instruments, and explicitly describes it as not a cryptocurrency, not a central bank digital currency, and not a stablecoin. The Ministry further states that USDM1 is supervised by the newly established Marshall Islands Monetary Authority, MIMA. This self-characterisation is contested: third-party trackers describe the instrument in functional terms consistent with a stablecoin or CBDC, on the basis that it is issued directly by the Marshall Islands government and circulates with properties resembling those categories, regardless of the issuer's preferred legal label. This classification question is not merely semantic. Whether USDM1 is treated as a sovereign bond, a stablecoin, or a CBDC-equivalent instrument has direct implications for which regulatory framework, reserve requirements, redemption rights and disclosure obligations properly apply, and for how other monitors, including the crypto monitor's parallel coverage, should characterise the instrument going forward. No published MIMA rulebook specifically governing USDM1's reserve composition, redemption mechanics or disclosure requirements was located this cycle, which means that regardless of how the classification dispute ultimately resolves, the practical content of USDM1's governing framework remains undocumented from a primary regulatory source at this time. USDM1 underpins the ENRA universal basic income disbursement programme, which the Stellar Development Foundation, a key technical partner in the instrument's development, described as the world's first onchain disbursement of universal basic income when it launched in November 2025. This product use case is a genuinely novel application of a government-issued digital-money instrument for direct social-transfer purposes, distinguishing USDM1 from most other sovereign digital-asset initiatives globally regardless of how its core legal classification is ultimately resolved. #### Outlook The classification dispute between the issuer and third-party trackers is unlikely to resolve quickly, since it touches on fundamental questions about how government-issued digital-dollar instruments should be categorised globally, not just in the Marshall Islands. The more immediate and tractable development to watch is whether MIMA publishes a specific rulebook governing USDM1's reserve, redemption and disclosure requirements; expected through the fourth quarter of 2026, as scheduled, this would materially clarify the instrument's actual operating framework regardless of which classification label ultimately prevails. **Sources and findings (6)** 1. T2 [https://en.wikipedia.org/wiki/Sovereign_Currency_Act_of_2018](https://en.wikipedia.org/wiki/Sovereign_Currency_Act_of_2018) Applies beyond this jurisdiction (IMF) retrieved 2026-09-08 2. T1 [https://www.imf.org/en/news/articles/2025/12/04/pr-25406-republic-of-the-marshall-islands-imf-concludes-2025-article-iv-consultation](https://www.imf.org/en/news/articles/2025/12/04/pr-25406-republic-of-the-marshall-islands-imf-concludes-2025-article-iv-consultation) retrieved 2026-09-08 3. T2 [https://www.lowyinstitute.org/the-interpreter/stablecoins-universal-basic-income-pacific-islands-model](https://www.lowyinstitute.org/the-interpreter/stablecoins-universal-basic-income-pacific-islands-model) retrieved 2026-09-08 4. T3 [https://cbdctracker.hrf.org/currency/marshall-islands](https://cbdctracker.hrf.org/currency/marshall-islands) retrieved 2026-09-08 5. T3 [https://grokipedia.com/page/sovereign_currency_act_of_2018](https://grokipedia.com/page/sovereign_currency_act_of_2018) retrieved 2026-09-08 6. T3 [https://www.rnz.co.nz/news/pacific/589678/marshall-islands-digital-currency-debuts-this-month-in-limited-form](https://www.rnz.co.nz/news/pacific/589678/marshall-islands-digital-currency-debuts-this-month-in-limited-form) retrieved 2026-09-08 ### W3 Operational Resilience & Critical Infrastructure Probable confirmed 2026-09-08 RMI has no enacted operational-resilience, critical-infrastructure or cybersecurity statute specific to payments; a draft Cyber Security Act and Cyber Crimes Act remain unpassed. Operational fragility in practice is driven by the payments infrastructure itself -- a closed-loop domestic card network, unreliable/cash-limited ATMs, and power-outage exposure across dispersed atolls. 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 63 words · last cycle 2026-09-08 #### Operational Resilience & Critical Infrastructure BOMI's card system functions as a closed-loop domestic network unsupported by Visa or Mastercard and cannot accept international cards, contributing to card-transaction costs far above global averages. No enacted cyber or critical-infrastructure statute was identified this cycle. #### Outlook Passage of RMI's draft Cyber Security Act and Cyber Crimes Act remains unconfirmed and is a dated item to track. no periodic updates on record for this sub-brief ** Sources and findings (3)** 1. T3 [https://www.mvariety.com/news/regional_world/marshall-islands-at-high-risk-of-cyber-attack/article_6773f8e4-ef89-11ef-8662-97eae9f4eb9e.html](https://www.mvariety.com/news/regional_world/marshall-islands-at-high-risk-of-cyber-attack/article_6773f8e4-ef89-11ef-8662-97eae9f4eb9e.html) retrieved 2026-09-08 2. T1 [https://mof.gov.mh/usdm1-whitepaper-the-rmi-and-the-correspondent-banking-crisis-in-the-pacific/](https://mof.gov.mh/usdm1-whitepaper-the-rmi-and-the-correspondent-banking-crisis-in-the-pacific/) retrieved 2026-09-08 3. T4 [https://www.jarniascyril.com/expatriation/moving-to-the-marshall-islands-a-complete-expat-guide/expat-banking-services-marshall-islands/](https://www.jarniascyril.com/expatriation/moving-to-the-marshall-islands-a-complete-expat-guide/expat-banking-services-marshall-islands/) retrieved 2026-09-08 ### W4 Scheme & Network Compliance Uncertain confirmed 2026-09-08 There is no evidence of a domestic PCI DSS mandate, interchange regulation, or card-scheme technical-standards regime in RMI. The dominant domestic card infrastructure operates as a closed-loop network outside the Visa/Mastercard schemes, while Bank of Guam provides limited scheme-branded ATM/debit access under US scheme rules. Standing sub-brief · as of 8 September 2026 59 words · last cycle 2026-09-08 #### Scheme & Network Compliance The dominant domestic card infrastructure operates as a closed-loop network outside the Visa/Mastercard schemes; no domestic PCI DSS mandate, interchange regulation, or card-scheme technical-standards regime was identified. #### Outlook Any scheme engagement with RMI's domestic network would first require the absent technical-standards regime to be built out, a gap unlikely to close in the near term. no periodic updates on record for this sub-brief ** Sources and findings (2)** 1. T1 [https://mof.gov.mh/usdm1-whitepaper/](https://mof.gov.mh/usdm1-whitepaper/) retrieved 2026-09-08 2. T4 [https://explore.atmfeesaver.com/blog/money-currency-in-marshall-islands/](https://explore.atmfeesaver.com/blog/money-currency-in-marshall-islands/) retrieved 2026-09-08 ### W5 Payment Corridor Dynamics Probable confirmed 2026-09-08 RMI's principal payment corridor is USD-denominated flow with the United States, supplemented by Western Union/MoneyGram cash-based remittance corridors. Pacific remittance-corridor fees average roughly 10% and international USD wires can take up to a week to settle, prompting a push toward digital-wallet-based distribution (Lomalo/USDM1) as an alternative settlement channel. Standing sub-brief · as of 8 September 2026 82 words · last cycle 2026-10-11 #### Payment Corridor Dynamics Pacific remittance-corridor fees average roughly 10% (triple the UN SDG target) and international USD wires can take up to a week to settle because of correspondent-banking constraints. This corridor friction sits on top of RMI's structural correspondent-banking fragility, with the US-MH USD corridor dependent on a single correspondent relationship. #### Outlook The Lomalo/USDM1 pilot is being tested as an alternative settlement channel for this corridor, though its uptake so far has been modest relative to conventional bank deposits and checks. Periodic update · new data 2026-10-11 #### Payment Corridor Dynamics The Marshall Islands faces a severe and well-documented payment corridor crisis this cycle, driven by extreme correspondent-banking concentration. The jurisdiction's access to the international payments system now relies on a single correspondent banking relationship, held by the Bank of Marshall Islands via First Hawaiian Bank and BNP Paribas, according to the RMI Ministry of Finance's own whitepaper. The practical consequences for payment corridors into and out of the Marshall Islands are substantial: remittance costs across Pacific corridors average around ten percent, roughly triple the United Nations Sustainable Development Goal target for remittance costs, and international US dollar wire transfers cost four to five times the global average, with settlement taking up to a week to complete. These figures describe a corridor environment in which both the cost and the speed of cross-border payment flows are materially worse than global norms, with direct implications for remittance-dependent households, trade finance and the broader cost of doing business internationally from the Marshall Islands. The single-correspondent dependency is the structural root of this dynamic: with only one correspondent relationship supporting international settlement, the jurisdiction has little negotiating leverage on pricing and limited resilience against disruption should that relationship come under strain, a vulnerability directly connected to the correspondent-banking de-risking pressure that the Ministry of Finance itself cites as a motivating factor behind MIMA's establishment. In response, the Marshall Islands has become one of four pilot countries, together with Fiji, Samoa and Tonga, in a World Bank and Pacific Islands Forum Secretariat project building a Correspondent Banking Relationship Resilience Index. The project's stated aim is to support data collection that can help secure temporary correspondent-banking-relationship access for eligible Pacific institutions, an explicit multilateral response to the kind of single-correspondent dependency documented in the Marshall Islands' own disclosure. #### Outlook The corridor dynamics documented this cycle are unlikely to improve rapidly, given that correspondent-banking relationships for small, remote jurisdictions typically take considerable time and sustained diplomatic and institutional effort to diversify. The CBR Resilience Index pilot's progress across its four participating countries will be the clearest indicator of whether multilateral intervention can meaningfully ease the dependency; a positive signal would be the addition of a second correspondent relationship or demonstrable improvement in remittance-cost or settlement-time metrics in subsequent reporting. **Sources and findings (5)** 1. T1 [https://mof.gov.mh/usdm1-whitepaper-the-rmi-and-the-correspondent-banking-crisis-in-the-pacific/](https://mof.gov.mh/usdm1-whitepaper-the-rmi-and-the-correspondent-banking-crisis-in-the-pacific/) retrieved 2026-09-08 2. T2 [https://www.lowyinstitute.org/publications/reducing-remittance-costs-pacific-islands](https://www.lowyinstitute.org/publications/reducing-remittance-costs-pacific-islands) retrieved 2026-09-08 3. T3 [https://www.westernunion.com/us/en/send-money-to-marshall-islands.html](https://www.westernunion.com/us/en/send-money-to-marshall-islands.html) retrieved 2026-09-08 4. T4 [https://www.infomarshallislands.com/banks/](https://www.infomarshallislands.com/banks/) retrieved 2026-09-08 5. T3 [https://www.mbjguam.com/marshall-islands-initiates-move-monetary-authority](https://www.mbjguam.com/marshall-islands-initiates-move-monetary-authority) retrieved 2026-09-08 ### W6 Industry Structure & Commercial Probable confirmed 2026-09-08 RMI's domestic banking market is a duopoly of BOMI and a Bank of Guam branch. Non-bank fintech entrants are recent and externally driven: Crossmint built the Lomalo wallet and the Stellar Development Foundation funded USDM1's blockchain rail, marking the first substantive private/foreign fintech presence in RMI's payments market. Standing sub-brief · as of 8 September 2026 89 words · last cycle 2026-09-08 #### Industry Structure & Commercial Dynamics Crossmint, an infrastructure provider, and the Stellar Development Foundation, a grant funder, built and funded the Lomalo wallet and USDM1 blockchain rail, marking the first substantive private or foreign fintech presence in RMI's payments market. This entry sits against a domestic banking market otherwise limited to a small number of established bank incumbents. #### Outlook Whether Crossmint and Stellar's involvement deepens into a durable non-bank market presence, or remains confined to the single Lomalo/USDM1 deployment, is the structural question for RMI's payments industry going forward. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T2 [https://www.griffith.edu.au/data/assets/pdf_file/0028/1705375/RMI-monetary-authority-policy-brief-web.pdf](https://www.griffith.edu.au/data/assets/pdf_file/0028/1705375/RMI-monetary-authority-policy-brief-web.pdf) retrieved 2026-09-08 2. T2 [https://stellar.org/press/world-s-first-on-chain-disbursement-of-universal-basic-income-delivered-on-the-stellar-network-via-digital-sovereign-bond-usdm1](https://stellar.org/press/world-s-first-on-chain-disbursement-of-universal-basic-income-delivered-on-the-stellar-network-via-digital-sovereign-bond-usdm1) retrieved 2026-09-08 3. T3 [https://www.register-iri.com/corporate/](https://www.register-iri.com/corporate/) retrieved 2026-09-08 4. T4 [https://www.companycheck.biz/en/marshall-islands-companies-registry/](https://www.companycheck.biz/en/marshall-islands-companies-registry/) retrieved 2026-09-08 ### W7 Legal & Litigation Probable confirmed 2026-09-08 No active court litigation targeting RMI payments/banking regulation was identified this run; regulatory/legal pressure has come via international soft-law channels -- repeated IMF Article IV critiques, the EU's on-off blacklist listing, and a historic FDIC alert against fraudulent RMI-issued bank guarantee instruments. Standing sub-brief · as of 8 September 2026 74 words · last cycle 2026-09-08 #### Legal & Litigation In 1996 the FDIC issued Special Alert FIL-57-96 after banks received inquiries about fraudulent 'Bank Guarantee' instruments issued by the Marshall Islands Development Bank; RMI subsequently announced the instruments were withdrawn and voided. No active domestic court litigation targeting RMI payments or banking regulation was identified this cycle. #### Outlook This remains a dated historical reference point rather than a live litigation risk; no near-term developments are expected absent a new filing. no periodic updates on record for this sub-brief ** Sources and findings (3)** 1. T1 [https://www.consilium.europa.eu/en/policies/eu-list-of-non-cooperative-jurisdictions/timeline-eu-list-of-non-cooperative-jurisdictions/](https://www.consilium.europa.eu/en/policies/eu-list-of-non-cooperative-jurisdictions/timeline-eu-list-of-non-cooperative-jurisdictions/) retrieved 2026-09-08 2. T1 [https://www.imf.org/-/media/Files/Publications/CR/2023/English/1MHLEA2023001.ashx](https://www.imf.org/-/media/Files/Publications/CR/2023/English/1MHLEA2023001.ashx) retrieved 2026-09-08 3. T1 [https://archive.fdic.gov/view/fdic/7963/fdic_7963_DS1.pdf](https://archive.fdic.gov/view/fdic/7963/fdic_7963_DS1.pdf) retrieved 2026-09-08 ### W8 Merchant Acquiring & Risk Uncertain confirmed 2026-09-08 Merchant acquiring in RMI is thin and largely informal: cash dominates retail commerce, only larger hotels/restaurants/stores accept cards, and Bank of Guam provides the main card-acceptance and dispute/chargeback infrastructure available locally. Standing sub-brief · as of 8 September 2026 49 words · last cycle 2026-09-08 #### Merchant Acquiring & Risk Merchant acquiring is thin and largely informal: only larger hotels, restaurants and stores in Majuro accept cards, and Bank of Guam provides the main card-acceptance and dispute/chargeback infrastructure available locally. #### Outlook Thin acquiring infrastructure signals limited near-term addressable market for any merchant-acquiring vendor considering entry. no periodic updates on record for this sub-brief ** Sources and findings (2)** 1. T4 [https://www.infomarshallislands.com/banks/](https://www.infomarshallislands.com/banks/) retrieved 2026-09-08 2. T1 [https://bankofguam.com/contact-us](https://bankofguam.com/contact-us) retrieved 2026-09-08 ### W9 Product Innovation & Market Development Probable confirmed 2026-09-08 The dominant product-innovation story in RMI payments is the Lomalo digital wallet / USDM1 sovereign-bond-token pairing, launched November 2025 to distribute the ENRA universal basic income and positioned as a workaround to correspondent-banking fragility; uptake of the digital-asset option has been modest relative to direct deposit and cheques. Standing sub-brief · as of 8 September 2026 93 words · last cycle 2026-10-11 #### Product Innovation & Market Development Following the November 2025 launch distributing the ENRA universal basic income, about 60% of first-round payments were direct bank deposits, the remainder bank checks, and only about 12 people opted to receive payments in USDM1. This product sits at the centre of RMI's correspondent-banking workaround strategy, testing whether a digital-wallet rail can substitute for cash-based and correspondent-dependent distribution in a dispersed-atoll context. #### Outlook Subsequent disbursement rounds will show whether USDM1 uptake grows beyond its initial small base or whether direct deposit and cheques remain the dominant payment choice. Periodic update · new data 2026-10-11 #### Product Innovation & Market Development The USDM1/Lomalo universal basic income disbursement programme is the Marshall Islands' standout product-innovation development this cycle. The Stellar Development Foundation, which supported the technical development of USDM1 and the associated Lomalo infrastructure, described the programme's November 2025 launch as the world's first onchain disbursement of universal basic income. The underlying programme, known as ENRA, uses USDM1 to deliver direct social transfers to Marshall Islands residents, representing a genuinely novel use case for a government-issued digital-dollar instrument: rather than functioning primarily as a store of value, trading instrument or settlement rail, USDM1 here operates as the delivery mechanism for a national social-policy programme. The product's significance should be read with appropriate caution given the sourcing available this cycle: both the Stellar Development Foundation's press characterisation and related commercial details were press-sourced rather than confirmed through RMI government disclosure of programme-level operational data, such as disbursement amounts, beneficiary counts or ongoing programme performance metrics. The grant or funding arrangement supporting the Stellar Development Foundation's involvement was not publicly disclosed, limiting visibility into the commercial structure underpinning the product's development. Nonetheless, the novelty of the use case, a sovereign digital-asset instrument built specifically to support a national UBI disbursement programme on a public blockchain network, positions the Marshall Islands as an early mover in a product category with limited global precedent, regardless of how USDM1's underlying legal classification is ultimately resolved. This distinguishes the Marshall Islands' initiative from more conventional sovereign stablecoin or CBDC pilots elsewhere, which have typically focused on payments or reserve-management use cases rather than direct social-transfer delivery. #### Outlook The key indicator for this product's development trajectory will be whether RMI authorities or the Stellar Development Foundation publish operational performance data on the ENRA programme, such as disbursement volumes, beneficiary reach or programme costs, which would allow an independent assessment of the product's actual function and scale beyond the initial launch announcement. Given the limited sourcing available this cycle, any such disclosure would materially improve the evidentiary basis for assessing this as a product-innovation case study. **Sources and findings (4)** 1. T3 [https://finance.yahoo.com/news/marshall-islands-launches-worlds-first-020103712.html](https://finance.yahoo.com/news/marshall-islands-launches-worlds-first-020103712.html) retrieved 2026-09-08 2. T3 [https://www.rnz.co.nz/international/pacific-news/580187/marshall-islands-introduces-world-s-first-crypto-based-universal-income-scheme](https://www.rnz.co.nz/international/pacific-news/580187/marshall-islands-introduces-world-s-first-crypto-based-universal-income-scheme) retrieved 2026-09-08 3. T3 [https://www.coindesk.com/business/2025/12/16/marshall-islands-launches-world-s-first-blockchain-based-ubi-on-stellar-blockchain](https://www.coindesk.com/business/2025/12/16/marshall-islands-launches-world-s-first-blockchain-based-ubi-on-stellar-blockchain) retrieved 2026-09-08 4. T1 [https://www.imf.org/-/media/Files/Publications/CR/2023/English/1MHLEA2023001.ashx](https://www.imf.org/-/media/Files/Publications/CR/2023/English/1MHLEA2023001.ashx) retrieved 2026-09-08 ### W10 Consumer Protection & APP Fraud 1 gap Uncertain confirmed 2026-09-08 RMI has no dedicated APP-fraud reimbursement scheme, financial ombudsman, or standalone consumer-protection statute for payments; consumer safeguards are indirect, arising from AML/KYC account-opening requirements and voluntary payment-method choice built into the ENRA UBI programme design. Open gap — wpm-int-4 No dedicated APP-fraud mandatory reimbursement scheme or financial ombudsman identified for RMI consumers._Emerging/micro-jurisdiction consumer-protection infrastructure remains under-covered relative to Anglosphere/EU frameworks per bias-correction guidance._ Standing sub-brief · as of 8 September 2026 61 words · last cycle 2026-09-08 #### Consumer Protection & APP Fraud There is no dedicated APP-fraud reimbursement scheme, financial ombudsman, or standalone consumer-protection statute for payments in RMI; safeguards are indirect, arising from AML/KYC account-opening requirements and voluntary payment-method choice in the ENRA UBI programme design. #### Outlook This remains an under-indexed area of RMI's payments framework, with no announced plans this cycle to introduce dedicated consumer-protection legislation. no periodic updates on record for this sub-brief ** Sources and findings (2)** 1. T4 [https://weformonline.com/opening-a-payment-account-for-marshall-islands/](https://weformonline.com/opening-a-payment-account-for-marshall-islands/) retrieved 2026-09-08 2. T3 [https://www.rnz.co.nz/international/pacific-news/580187/marshall-islands-introduces-world-s-first-crypto-based-universal-income-scheme](https://www.rnz.co.nz/international/pacific-news/580187/marshall-islands-introduces-world-s-first-crypto-based-universal-income-scheme) 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: RMI is an APG member subject to APG-conducted mutual evaluation of its AML/CFT/CPF measures; it is not currently on the FATF grey or black lists. Core domestic AML measures date to the early 2000s. No original illicit-finance analysis is performed here; this is the Sentinel-fed payments-context position only. Open gap — wpm-int-6 IMF 2025 Article IV press release and FATF/APG mutual evaluation report pages returned HTTP 403 on fetch; claims rely on cached/secondary corroboration rather than primary-document quotation._no under-indexing note recorded_ Standing sub-brief · as of 8 September 2026 97 words · last cycle 2026-09-08 #### AML/CFT & Financial Crime This position is sourced from the Sentinel.gi feed as payments-context only; no original illicit-finance analysis is performed here. RMI is an APG member subject to mutual evaluation of its AML/CFT/CPF measures and is not currently on the FATF grey or black lists; core domestic AML measures date to the early 2000s, including the USD 10,000 cash-transaction reporting threshold, a shell-bank prohibition, and licence suspension or revocation powers tied to money-laundering suspicion. #### Outlook Readers seeking the underlying illicit-finance analysis and de-risking drivers behind this standing should consult the Financial Intelligence Monitor's Sentinel-fed coverage directly. no periodic updates on record for this sub-brief ** Sources and findings (10)** 1. T1 sentinel.https://www.imf.org/-/media/Files/Publications/CR/2023/English/1MHLEA2023001.ashx Applies beyond this jurisdiction (FATF) 2. T? FIM (sentinel.gi) per-JID baseline profile — Marshall Islands — AML/CFT governed by the Banking Act 1987 and AML Regulations 2002 (amended Aug 2023), with the Banking Commission (incorporating the FIU) as sole financial/DNFBP supervisor. DAO Act 2022 creates a bespoke DAO LLC regime. Generally strong technical compliance but weak effectiveness on beneficial ownership transparency, VASP/DAO supervision and ML prosecution. 3. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-005) — Gap: sourcing-thinness 4. T1 FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-001) — Sanctions: OFAC listing 5. T1 FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-003) — Sanctions: OFAC wind-down 6. T1 FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-005) — Enforcement: OFAC — Aare Lines, Hansa Shipping, Hope 1 Shipping, Sea Lead Shipping Marshall Islands Ltd 7. T1 FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-004) — Enforcement: OFAC — Anka Energy and Logistics Company, Mihir Shipping Inc, Patriot Inc, Reayou Company Limited, tanker EDOR (Marshall Islands flag/registration) 8. T1 FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-003) — Enforcement: OFAC — Anika Lines, Aura Lines, Hapuka Marine, Nardie International, Shipza Shipping (Marshall Islands entities linked to Mohammad Hossein Shamkhani) 9. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: legal-gap 10. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: enforcement-absence ### W12 Correspondent Banking, Settlement & Access Confirmed confirmed 2026-09-08 Correspondent banking access is RMI's single most acute payments-infrastructure vulnerability: since 2008 RMI has lost approximately 700 correspondent banking relationships, and BOMI's sole remaining CBR has been under threat of termination since 2014. A March 2026 FDIC final rule extended deposit-insurance coverage clarity to US-bank branches in RMI/FSM/Palau, effective 22 April 2026. Standing sub-brief · as of 8 September 2026 128 words · last cycle 2026-10-11 #### Correspondent Banking, Settlement & Access The defining asymmetry in this module is access: BOMI's only remaining correspondent banking relationship is with First Hawaiian Bank, which has sought to end the relationship since 2014 and retains it only until BOMI finds another correspondent bank, against a backdrop in which RMI has lost approximately 700 correspondent banking relationships since 2008. The FDIC adopted a final rule, effective 22 April 2026, providing that it will insure deposits of all branches of U.S.-insured depository institutions in the Federated States of Micronesia, the Republic of the Marshall Islands, and the Republic of Palau. #### Outlook The outcome of BOMI's search for a replacement or additional correspondent banking relationship beyond First Hawaiian Bank is the single most consequential near-term variable for continued USD clearing access. Periodic update · new data 2026-10-11 #### Correspondent Banking, Settlement & Access Correspondent banking access for the Marshall Islands is concentrated to a degree that represents a structural vulnerability rather than a transient operational issue. According to the RMI Ministry of Finance's own whitepaper, the jurisdiction's international settlement access now runs through a single correspondent banking relationship, held by the Bank of Marshall Islands via First Hawaiian Bank and BNP Paribas. This is a sharp reduction from a more diversified correspondent-banking landscape, and it reflects the broader global phenomenon of correspondent de-risking, in which international banks withdraw from relationships with small, remote or perceived higher-risk jurisdictions, leaving local institutions with fewer, more concentrated channels for settling international transactions. The practical settlement consequences are material: international US dollar wire transfers cost four to five times the global average, and settlement can take up to a week to complete, figures that reflect both the pricing power the sole remaining correspondent can exercise and the operational friction inherent in routing all international settlement through a single channel. For a jurisdiction as dependent on remittances and international trade finance as the Marshall Islands, this level of settlement friction has direct economic consequences for households and businesses alike, independent of any single payment-service-provider's business model. The Marshall Islands' institutional response includes participation as one of four pilot countries, alongside Fiji, Samoa and Tonga, in a World Bank and Pacific Islands Forum Secretariat project constructing a Correspondent Banking Relationship Resilience Index. This project is explicitly aimed at helping secure temporary correspondent-banking-relationship access for eligible Pacific institutions, representing a multilateral, data-driven approach to a problem that individual small Pacific jurisdictions have limited unilateral capacity to resolve. Separately, the establishment of MIMA as a consolidated financial regulator may also be read, per the Ministry of Finance's own framing, as part of a broader institutional effort to present a more credible supervisory counterpart to international correspondent banks. #### Outlook The CBR Resilience Index pilot's data-collection and advocacy work across its four participating Pacific countries will be the clearest indicator of whether multilateral intervention can meaningfully diversify the Marshall Islands' correspondent-banking access beyond its current single-relationship dependency. Given the structural and multi-year nature of correspondent de-risking trends globally, material improvement is unlikely to be visible within a single reporting cycle, but any addition of a second correspondent relationship, or documented improvement in settlement cost or speed metrics, would represent a meaningful positive development worth tracking closely. **Sources and findings (5)** 1. T2 [https://www.griffith.edu.au/data/assets/pdf_file/0028/1705375/RMI-monetary-authority-policy-brief-web.pdf](https://www.griffith.edu.au/data/assets/pdf_file/0028/1705375/RMI-monetary-authority-policy-brief-web.pdf) retrieved 2026-09-08 2. T3 [https://finance.yahoo.com/news/marshall-islands-launches-worlds-first-020103712.html](https://finance.yahoo.com/news/marshall-islands-launches-worlds-first-020103712.html) retrieved 2026-09-08 3. T1 [https://www.federalregister.gov/documents/2026/03/23/2026-05652/clarification-of-deposit-insurance-coverage-for-branches-of-us-banks-in-the-federated-states-of](https://www.federalregister.gov/documents/2026/03/23/2026-05652/clarification-of-deposit-insurance-coverage-for-branches-of-us-banks-in-the-federated-states-of) retrieved 2026-09-08 4. T3 [https://www.mbjguam.com/marshall-islands-initiates-move-monetary-authority](https://www.mbjguam.com/marshall-islands-initiates-move-monetary-authority) retrieved 2026-09-08 5. T1 [https://mof.gov.mh/usdm1-whitepaper-the-rmi-and-the-correspondent-banking-crisis-in-the-pacific/](https://mof.gov.mh/usdm1-whitepaper-the-rmi-and-the-correspondent-banking-crisis-in-the-pacific/) retrieved 2026-09-08 ### W13 Commercial Intelligence (M&A, Investment & Product) Probable confirmed 2026-09-08 Trailing-12-month commercial activity in RMI payments centres on the Lomalo/USDM1 build-out: Crossmint closed a Series A-II funding round in September 2025 shortly before deploying Lomalo, and the Stellar Development Foundation issued an undisclosed-amount grant in December 2025 to fund USDM1's development, alongside passage of the Monetary Authority Act 2025. Standing sub-brief · as of 8 September 2026 139 words · last cycle 2026-10-11 #### Commercial Intelligence (M&A, Investment & Product) Crossmint's latest funding round was a Series A-II on 24 September 2025, with Flourish Ventures among the investors; the company has raised USD 23.6M cumulatively over 8 rounds, though the amount for the September 2025 round itself was not publicly disclosed. The Stellar Development Foundation issued a multimillion-dollar grant in December 2025 to fund the development of USDM1, the RMI's digitally issued sovereign bond; the grant amount was not publicly disclosed. The Lomalo wallet and USDM1 launched in November-December 2025, replacing a cash-delivery UBI model in which physical dollars arrived quarterly by shipping container subject to purchase caps and withdrawal limits. #### Outlook The Lomalo/USDM1 launch stands as the first blockchain-based UBI disbursement product globally, and its continued build-out will depend on further disclosed or undisclosed funding from Crossmint and the Stellar Development Foundation. Periodic update · new data 2026-10-11 #### Commercial Intelligence & Fintech Two discrete commercial events define this cycle's fintech activity in the Marshall Islands, both connected to the USDM1 sovereign digital-bond programme. First, the Stellar Development Foundation partnered with the Republic of the Marshall Islands on the development of USDM1 and its associated Lomalo infrastructure, culminating in the completed launch of the ENRA universal basic income disbursement programme in November 2025, which Stellar described as the world's first onchain disbursement of universal basic income. The financial terms of the Stellar Development Foundation's involvement, including any grant amount, were not publicly disclosed. Second, in April 2026, Anchorage Digital, a federally chartered US digital-asset bank, announced that it had begun providing institutional custody services for USDM1. Anchorage Digital characterised the arrangement as providing custody for secured sovereign debt issued under New York law, a framing that itself bears on the ongoing classification dispute over whether USDM1 is properly understood as a sovereign bond or as a stablecoin-equivalent instrument. As with the Stellar Development Foundation partnership, the commercial terms of the Anchorage Digital custody arrangement, including any fees or contract value, were not publicly disclosed. Both events should be read as evidence of USDM1 attracting engagement from established US digital-asset infrastructure providers, which lends a degree of institutional credibility to the programme regardless of how its underlying legal classification is ultimately resolved. However, the press-sourced nature of both developments, and the absence of disclosed commercial terms for either arrangement, means the actual scale and significance of this institutional engagement cannot be independently verified from primary-source disclosure at this time. #### Outlook Further commercial engagements involving USDM1, whether in custody, market-making, technical infrastructure or distribution, would be a natural continuation of the pattern observed this cycle and should be watched for as indicators of the programme's broader institutional traction. Disclosure of commercial terms for either the Stellar Development Foundation partnership or the Anchorage Digital custody arrangement, should it occur, would materially improve the evidentiary basis for assessing the programme's commercial scale. **Sources and findings (4)** 1. T3 [https://www.cbinsights.com/company/crossmint/financials](https://www.cbinsights.com/company/crossmint/financials) retrieved 2026-09-08 2. T2 [https://stellar.org/press/world-s-first-on-chain-disbursement-of-universal-basic-income-delivered-on-the-stellar-network-via-digital-sovereign-bond-usdm1](https://stellar.org/press/world-s-first-on-chain-disbursement-of-universal-basic-income-delivered-on-the-stellar-network-via-digital-sovereign-bond-usdm1) retrieved 2026-09-08 3. T1 [https://rminitijela.com/public-law-communication/](https://rminitijela.com/public-law-communication/) retrieved 2026-09-08 4. T3 [https://www.blockhead.co/2025/12/18/marshall-islands-launches-blockchain-based-universal-basic-income/](https://www.blockhead.co/2025/12/18/marshall-islands-launches-blockchain-based-universal-basic-income/) retrieved 2026-09-08 ** No modules match.** Filters combine as OR inside a group and AND across groups. ## Editorial metadata Provenance only. Nothing below gates publication or affects the render. Editorial metadata for MH| 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. **Sentinel-fed modules** receive no special rendering treatment. `sentinel_feed` is an attribution chip only: it does not suppress content, does not generate an absence reason code, and does not exclude the module from any count, filter, search index or export on this page. **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", "stablecoin": "emerging-regime"}}}`. **Band honesty:** uncertainty bands are computed against a frozen build clock of 2026-10-21. A year-precision row is never promoted into a tighter band. **Orphan deltas:** 0 cycle_delta row(s) target non-module objects and are listed in the rail rather than attached to a card. **Envelope:** baseline resolved at `jurisdiction_json.baseline`; 14 module(s), 60 finding(s), 129 source(s) in the cumulative register. Think something on this page is wrong? [Report an error](https://payments.gi/legal/#contact).