VUschema world-payments-v1trajectory: not yet assessed
Last updated · 14 modules · 62 sourced
findings · 101 sources in the cumulative register
14Modulesbaseline.modules[]
62Findingsmodules[].findings[]
22Tier-1 sourcesrun_metadata.t1_source_count
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Jurisdiction brief
Standing brief, as of 18 October 2026.
Lead Signal
Vanuatu's payment-regulation architecture is in a holding pattern between enactment and commencement. The Reserve Bank of Vanuatu Act No. 37 of 2025, passed 6 November 2025 and repealing the old RBV Act [CAP 125], would bring payment system operators and e-money/digital-wallet providers within the Reserve Bank's licensing and prudential purview for the first time, but the Act has not yet commenced pending a gazette notice expected during 2026. A December 2025 RBV board-vacancy notice confirms the Act is already being acted on for board-appointment purposes despite the substantive licensing provisions remaining dormant, an unusual split-commencement posture that leaves the market in a genuine interim state rather than a simple pre- or post-reform one.
Other Developments
Regulatory overlap between RBV and VFSC left unresolved. Law-firm analysis of the new Act flags that e-money and digital-wallet providers would fall within the Reserve Bank's purview once the Act commences, while the Vanuatu Financial Services Commission continues as the regulator for virtual asset service providers under its own separate Act. The boundary between these two regulatory perimeters — where a digital-wallet provider's activity shades into virtual-asset-service territory — is not resolved in the sources available this cycle, and the uncertainty sits with non-bank providers specifically rather than banks, which already operate under established prudential supervision.
Correspondent-banking legislative package scheduled. Parliament's First Extraordinary Session, sitting 19 to 30 October 2026, will debate amendments to the Financial Institutions Act and International Banking Act, alongside Trust Act, Company/Trust Service Providers and VASP amendments on the same 28-bill agenda. Substantive content of the International Banking Act amendment has not been retrieved this cycle, so its implications for correspondent access and settlement arrangements remain to be established once enacted text is available.
Cross-Monitor Connections
The same Parliament session carrying the Financial Institutions and International Banking Act amendments is also debating an Anti-Money Laundering and Counter-Terrorism Financing (Amendment) Bill, a coordinated legislative push that financial-integrity's coverage reads through an AML/CTF-effectiveness lens ahead of a possible APG assessment. The VASP amendments on the same agenda are being tracked separately by the crypto monitor for their licensing-regime implications.
Outlook
Two dates anchor the outlook: the expected 2026 gazette notice that would commence the RBV Act's substantive payment-system and e-money licensing provisions, and the close of Parliament's First Extraordinary Session on 30 October 2026, when the Financial Institutions and International Banking Act amendments will either pass or not. Until the RBV Act commences, non-bank payment and e-money providers continue to operate without the clarified RBV/VFSC regulatory boundary the new Act is intended to establish, and until the correspondent-banking package is enacted, its practical effect on settlement and correspondent access for Vanuatu-licensed PSPs cannot be assessed.
trust tier: ai_unverified
Standing brief, as of 18 October 2026.
Regulatory Status
Vanuatu's payment-regulation architecture is being reshaped by the Reserve Bank of Vanuatu Act No. 37 of 2025, passed 6 November 2025, which would bring payment system operators and e-money/digital-wallet providers within RBV's licensing and prudential purview for the first time, pending commencement via a gazette notice expected during 2026. A December 2025 RBV board-vacancy notice shows the Act is already partially in effect for governance purposes despite the market-facing licensing provisions remaining dormant. Legal commentary flags an unresolved regulatory boundary between the RBV's new remit over e-money/digital-wallet providers and the VFSC's continuing role as regulator of virtual asset service providers.
Separately, Parliament's First Extraordinary Session, sitting 19 to 30 October 2026, will debate amendments to the Financial Institutions Act and International Banking Act — relevant to correspondent-banking and settlement arrangements — alongside Trust Act, Company/Trust Service Providers, VASP and AML/CTF amendments on the same 28-bill agenda. Substantive content of the International Banking Act amendment has not been retrieved this cycle.
Outlook
The 2026 gazette notice commencing the RBV Act's substantive provisions, and the 30 October 2026 close of the Parliament session carrying the Financial Institutions and International Banking Act amendments, are the two dates that will determine whether Vanuatu's payment-licensing and correspondent-banking frameworks move from pending to operative this year.
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Vanuatu's payment-system licensing and supervisory architecture is being re-founded: the Reserve Bank of Vanuatu Act No. 37 of 2025 (passed 6 November 2025, repealing RBV Act [CAP 125]) expressly brings payment system operators, e-money and digital-wallet providers within RBV's direct supervisory remit for the first time, but the Act had not commenced as of this cycle.
Movement — CHANGEDRBV Act No. 37 of 2025 pending commencement; payment-system operators and e-money providers to come under RBV purviewNew law firm analysis and RBV board-vacancy notice confirm the Act's passage and pending commencement.
Standing sub-brief · as of 18 October 2026351 words · last cycle 2026-10-18
Licensing, Authorisation & Market Access
The Reserve Bank of Vanuatu Act No. 37 of 2025, passed by Parliament on 6 November 2025, repeals the previous RBV Act [CAP 125] and would bring payment system operators and e-money/digital-wallet providers within the Reserve Bank's licensing and prudential purview for the first time. This is a structurally significant expansion of RBV's regulatory remit into a market segment previously outside central-bank prudential oversight. As at this cycle, the Act has been passed but has not yet commenced: commencement is expected during 2026 once a gazette notice is published, and no such notice has been confirmed. A December 2025 RBV board-vacancy notice indicates the Reserve Bank is already acting on provisions of the new Act for governance purposes such as board appointments, even while the substantive payment-system and e-money licensing provisions remain dormant pending commencement — a split-commencement state worth noting precisely because it means some parts of the Act are live while the market-facing licensing provisions are not.
A distinct and so-far-unresolved issue flagged by legal commentary is the regulatory boundary this creates between the Reserve Bank and the Vanuatu Financial Services Commission. Once the RBV Act commences, e-money and digital-wallet providers would fall under RBV's licensing and prudential purview, while the VFSC continues to regulate virtual asset service providers under its own separate statute. Where an entity's digital-wallet or e-money activity overlaps with virtual-asset-service activity, which regulator's licensing regime takes precedence, or whether dual licensing would be required, has not been resolved in the material available this cycle. This overlap bears specifically on non-bank payment and e-money providers; banks already operating under established Reserve Bank prudential supervision are less directly affected by the boundary question.
Outlook
The gazette notice expected to commence the RBV Act's substantive provisions during 2026 is the development to watch for market access: its publication would activate the Reserve Bank's new licensing authority over payment-system operators and e-money/digital-wallet providers, and would be the point at which the unresolved RBV/VFSC regulatory boundary becomes a live operational question rather than a prospective one for non-bank providers entering or operating in this space.
Conduct and safeguarding obligations are split across RBV (mobile money/PSP trust-account safeguarding, AML/CTF conduct duties, external dispute resolution) and VFSC (VASP fit-and-proper, cybersecurity, complaints and travel-rule guidance). Financial promotion policy toward cryptocurrency has moved from an outright dealing ban (2019) to a licensed pathway (2021, formalised 2025).
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
Vanuatu became the first Pacific nation with comprehensive virtual-asset legislation via the VASP Act No.3 of 2025, covering exchange, transfer, custody and ITO/stablecoin-adjacent activity under VFSC, while the 2025 RBV Act separately brings e-money issuance under RBV prudential licensing and opens the door to central bank digital currency exploration alongside the Vatu.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
Operational resilience of Vanuatu's payments infrastructure rests on the National Payment System Act 2021 (RBV oversight of VANKLIA), the Cybercrime Act 2021, and a national cyber-security strategy through 2030, reinforced by VFSC's VASP-specific cybersecurity guideline and CERT Vanuatu's incident-response mandate.
Vanuatu has no dedicated interchange, surcharging or PCI DSS regulatory instrument identified; card scheme compliance (Visa, Mastercard, UnionPay) operates via commercial-bank EFTPOS interoperability agreements rather than a codified national scheme-access regime.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
Vanuatu's dominant payment corridor is inbound remittances from Australia and New Zealand tied to seasonal-worker labour mobility schemes; this corridor carries among the highest transaction costs in the world, remains heavily cash-reliant at the last mile, and is a policy priority for cost reduction by RBV and development partners.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
Vanuatu's payments-relevant industry comprises five RBV-licensed commercial/international banks, a two-operator mobile-money duopoly (Digicel MyCash, Vodafone/TVL M-Vatu) with historically low uptake, and an emerging VASP-licensed digital-asset segment following the 2025 legislative reform.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
No payments-specific court litigation or RBV/VFSC payments-sector enforcement action was identified for Vanuatu; the principal legal/regulatory friction on record is diplomatic rather than judicial — Vanuatu's continued inclusion on the EU's AML-CFT high-risk third-countries list despite FATF delisting in 2018.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
Merchant acquiring in Vanuatu is bank-led (ANZ, BRED, NBV) rather than governed by a dedicated acquiring licence; card penetration among locals is low with cash dominant outside tourism-facing merchants, and high-risk verticals such as gaming and crypto are generally underserved or restricted by acquirers.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
The September 2023 VANKLIA launch (RTGS, ACH and CSD) is the central product/infrastructure innovation reshaping Vanuatu payments, complemented by a VFSC fintech sandbox for VASP innovation, earlier mobile-money pilots (M-Vatu, MyCash), and an ongoing RBV-led financial-inclusion strategy.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
Consumer protection is anchored by RBV's External Dispute Resolution Scheme and emerging MMSP consumer-protection policy work (with UNCDF support), plus VFSC's VASP complaints-handling guidance; no dedicated APP-fraud mandatory-reimbursement regime (of the UK PSR type) was identified, and mobile-money data-protection practice remains under-defined.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
Sentinel.gi payments-context position: Vanuatu's AML/CFT framework, built on the AML/CTF Act No.13 of 2014, saw the country FATF grey-listed in February 2016 and delisted in June 2018 following a significant compliance overhaul; it nonetheless remains on the EU's own high-risk third-countries list, and the 2025 VASP Act extends AML/CFT (including Travel Rule) obligations to virtual-asset activity following a 2024 sector risk assessment.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
T?FIM (sentinel.gi) per-JID baseline profile — Vanuatu — Vanuatu's AML/CFT regime rests on the Anti-Money Laundering and Counter-Terrorism Financing Act No.13 of 2014 (as amended), the Counter Terrorism and Transnational Organised Crime Act, the Proceeds of Crime Act, and the Companies/International Companies Acts governing beneficial ownership. The Vanuatu Financial Intelligence Unit (VFIU) is the FIU and frontline AML/CFT supervisor; the Reserve Bank of Vanuatu supervises banks/insurers; the Vanuatu Financial Services Commission (VFSC) supervises international companies, TCSPs, financial dealers and, since 2025, VASPs. The National AML&CTF Coordinating Committee (NCC) coordinates policy. Vanuatu is autonomous — bound by no supranational AML bloc.
Vanuatu's cross-border payment access runs through a small number of correspondent banking relationships (CBRs) that IMF assessment and Pacific Islands Forum research both flag as under de-risking pressure, while domestically RBV administers Exchange Settlement Accounts and SWIFT-based international payment processing and participates in the regional PIRI regulatory network.
Standing sub-brief · as of 18 October 2026294 words · last cycle 2026-10-18
Correspondent Banking, Settlement & Access
Vanuatu's correspondent-banking and settlement framework faces a scheduled legislative review this cycle. Parliament's First Extraordinary Session, sitting 19 to 30 October 2026, will debate amendments to the Financial Institutions Act and the International Banking Act, alongside amendments to the Trust Act, Company and Trust Service Providers legislation, and the Virtual Asset Service Providers Act, all on the same 28-bill agenda for that sitting. The International Banking Act amendment is of particular relevance to how correspondent access and cross-border settlement arrangements function for internationally active banks licensed in Vanuatu, but the substantive content of the amendment — whether it touches licensing conditions, capital requirements, or correspondent-relationship rules specifically — has not been retrieved this cycle; only the scheduling of the debate is confirmed.
This correspondent-banking legislative activity sits alongside, and appears coordinated with, the separate Anti-Money Laundering and Counter-Terrorism Financing (Amendment) Bill scheduled for the same session. Correspondent banking relationships are frequently sensitive to a jurisdiction's AML/CTF framework strength, since correspondent banks conduct due diligence on respondent banks' home-jurisdiction AML/CTF regimes as part of de-risking and account-maintenance decisions; a coordinated review of both the International Banking Act and the AML/CTF Act in the same sitting may reflect an intent to address both dimensions together, though this reading is an inference from the scheduling pattern rather than a stated legislative purpose confirmed in the sources available.
Outlook
The close of the First Extraordinary Session on 30 October 2026 is the date by which the Financial Institutions Act and International Banking Act amendments will either have passed or not, and their enacted text, once available, will be the basis for assessing any actual change to correspondent-banking and settlement-access conditions for Vanuatu-licensed institutions. Until then, the existing correspondent-banking framework continues to apply unchanged.
Trailing-12-month commercial activity for Vanuatu (Sept 2025-Sept 2026) is dominated by regulatory/institutional product launches rather than disclosed M&A or funding transactions: the Reserve Bank of Vanuatu Act 2025 institutional overhaul, the VASP Act's January 2026 fee-schedule gazettal, and VFSC's 2025 VASP risk assessment publication.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
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Envelope: baseline resolved at jurisdiction_json.baseline; 14 module(s), 62 finding(s), 101 source(s) in the cumulative register.
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Machine checkChallenged on 6 Oct 2026: nothing tested (no claim on this page was eligible for an automated test). An automated, adversarial test run by a second model; no person has assessed the result.