VU

VU schema world-payments-v1 trajectory: not yet assessed

Last updated · 14 modules · 62 sourced findings · 101 sources in the cumulative register

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.

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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.
Key judgment — Probable · impact ELEVATEDVanuatu's payment-regulation architecture is being materially reshaped through the pending RBV Act No. 37 of 2025, which brings non-bank e-money and digital-wallet providers under central-bank prudential oversight for the first time, creating an unresolved regulatory boundary with VFSC's existing VASP remit.claims: wpm-2026-W42-001, wpm-2026-W42-004
Open gap — wpm-int-1RBV Act No. 37 of 2025 commencement date not confirmed; gazette notice awaited.no under-indexing note recorded
Horizon · 2026-Q4 (± six months)RBV Act No. 37 of 2025 commencement pendingAdopted · Tier 1 source
Horizon · 2026-Q4 (± six months)RBV Act No. 37 of 2025 expected commencementAdopted, not yet in force · Tier 3 source
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.

no periodic updates on record for this sub-brief

Sources and findings (6)
  1. T1https://www.rbv.gov.vu/index.php/en/financial-stability/prudential-framework/70-legislation-for-banking-industryretrieved
  2. T4https://www.offshore-protection.com/vanuatu-international-banking-licenceretrieved
  3. T1https://www.rbv.gov.vu/index.php/en/?view=category&id=2&resetfilters=0&clearordering=0&clearfilters=0&group_by=exchange_rates___aud&start=20&limitstart1=160retrieved
  4. T1https://www.rbv.gov.vu/images/Financial_Inclusion/2025/Vanuatu%20MMSP%20Operating%20Guidlines.pdfretrieved
  5. T3https://www.pln.vu/single-post/modernising-the-resrve-bank-of-vanuaturetrieved
  6. T1https://www.vfsc.vu/virtual-asset-service-provider/retrieved

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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.

no periodic updates on record for this sub-brief

Sources and findings (5)
  1. T1https://www.rbv.gov.vu/images/Financial_Inclusion/2025/Vanuatu%20MMSP%20Operating%20Guidlines.pdfretrieved
  2. T1https://www.rbv.gov.vu/images/Press_Releases/2018/PR10%20-RBV%20Stance%20on%20the%20cryptocurrencies.pdfretrieved
  3. T3https://en.wikipedia.org/wiki/Vanuatu_Financial_Services_Commissionretrieved
  4. T1https://www.vfsc.vu/virtual-asset-service-provider/retrieved
  5. T1https://www.rbv.gov.vu/retrieved

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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.

no periodic updates on record for this sub-brief

Sources and findings (5)
  1. T1https://www.vfsc.vu/wp-content/uploads/2025/06/Virtual-Asset-Services-Providers-Act-No-3-of-2025.pdfretrieved
  2. T3https://www.pln.vu/single-post/modernising-the-resrve-bank-of-vanuaturetrieved
  3. T1https://www.vfsc.vu/wp-content/uploads/2025/11/VFSC-Risk-Assessment-for-Virtual-Assets-2025.pdfretrieved
  4. T4https://www.zitadelleag.com/services/vasp-licensing/vanuatu-vaspretrieved
  5. T4https://www.zitadelleag.com/services/vasp-licensing/vanuatu-vaspretrieved

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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.

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 →

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 periodic updates on record for this sub-brief

Sources and findings (5)
  1. T1https://www.rbv.gov.vu/index.php/en/?view=category&id=2&resetfilters=0&clearordering=0&clearfilters=0&group_by=exchange_rates___aud&start=20&limitstart1=160retrieved
  2. T1http://www.paclii.org/vu/legis/num_act/ca2021112.pdfretrieved
  3. T3https://dig.watch/resource/the-vanuatu-national-cyber-security-strategy-2030retrieved
  4. T1https://www.vfsc.vu/virtual-asset-service-provider/retrieved
  5. T1https://cert.gov.vu/images/ressources/Cybercrime_Act_n_of_2021.pdfretrieved

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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.

no periodic updates on record for this sub-brief

Sources and findings (2)
  1. T4https://www.bred.vu/business-banking/merchant-solutions-and-facilities/retrieved
  2. T3https://vbr.vu/feature/vanklia-the-nationalpayment-system/retrieved

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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.

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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 periodic updates on record for this sub-brief

Sources and findings (4)
  1. T1https://www.rbv.gov.vu/index.php/en/financial-stability/authorised-banks-supervised-financial-institutions?view=article&layout=edit&id=309retrieved
  2. T4https://goldenharbors.com/articles/vanuatu-banksretrieved
  3. T3https://www.uncdf.org/article/8730/mobile-financial-services-in-vanuatu-three-critical-challenges-and-how-to-solve-themretrieved
  4. T4https://www.zitadelleag.com/services/vasp-licensing/vanuatu-vaspretrieved

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.

no periodic updates on record for this sub-brief

Sources and findings (1)
  1. T3https://fca.vu/vanuatu-and-the-eu-list-of-high-risk-third-countries-a-timeline-of-events-that-we-know-of/retrieved

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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.

no periodic updates on record for this sub-brief

Sources and findings (4)
  1. T1https://www.rbv.gov.vu/index.php/en/?view=category&id=2&resetfilters=0&clearordering=0&clearfilters=0&group_by=exchange_rates___aud&start=20&limitstart1=160retrieved
  2. T4https://www.bred.vu/business-banking/merchant-solutions-and-facilities/retrieved
  3. T4https://www.anz.com/vanuatu/en/business/merchant-services/retrieved
  4. T4https://payatlas.com/countries/vanuatu-vuretrieved

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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.

no periodic updates on record for this sub-brief

Sources and findings (5)
  1. T1https://rbv.gov.vu/index.php/en/about-payments-system/vanklia-systemretrieved
  2. T2https://www.centralbanking.com/central-banks/payments/7959681/vanuatu-launches-new-automated-payments-networkretrieved
  3. T1https://www.vfsc.vu/virtual-asset-service-provider/retrieved
  4. T4https://www.dailypost.vu/news/tvl-to-pilot-new-mobile-money-platform/article_b9f54136-f891-5806-8bd8-99e8dffd4d85.htmlretrieved
  5. T3https://www.uncdf.org/article/8403/unleashing-the-potential-of-mobile-money-in-vanuaturetrieved

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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.

no periodic updates on record for this sub-brief

Sources and findings (4)
  1. T1https://www.rbv.gov.vu/retrieved
  2. T1https://www.vfsc.vu/virtual-asset-service-provider/retrieved
  3. T3https://www.uncdf.org/article/8730/mobile-financial-services-in-vanuatu-three-critical-challenges-and-how-to-solve-themretrieved
  4. T1https://www.rbv.gov.vu/images/Financial_Inclusion/2025/Vanuatu%20MMSP%20Operating%20Guidlines.pdfretrieved

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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.

no periodic updates on record for this sub-brief

Sources and findings (8)
  1. T4sentinel.zitadelleag.com/services/vasp-licensing/vanuatu-vasp
  2. 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.
  3. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-004) — Gap: sourcing-thinness
  4. T1FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-004) — Sanctions: OFAC listing
  5. T1FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-003) — Enforcement: OFAC — Individuals holding Vanuatu passports linked to Cambodia-based networks (e.g. Grand Legend International Asset Management)
  6. T1FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-004) — Enforcement: OFAC — SEEKER 8 (Vanuatu-flagged crude oil tanker)
  7. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: legal-gap
  8. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: regulatory-failure

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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.

Open gap — wpm-int-2Substantive content of the International Banking Act amendment was not retrievable this cycle.no under-indexing note recorded
Open gap — wpm-int-3Correspondent banking access events this window not located (W12).Correspondent banking and de-risking data for small-island jurisdictions is structurally under-indexed.
Horizon · 2026-10-30 (± a quarter)Financial Institutions Act and International Banking Act amendment debateProposed · Tier 2 source
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.

no periodic updates on record for this sub-brief

Sources and findings (5)
  1. T1https://www.imf.org/-/media/Files/Publications/CR/2023/English/1VUTEA2023001.ashxretrieved
  2. T2https://forumsec.org/sites/default/files/2024-05/CBR%20Report_FINAL.pdfretrieved
  3. T1https://www.rbv.gov.vu/index.php/en/?option=com_content&view=article&id=32:banking&catid=8&lang=en-GBretrieved
  4. T4https://goldenharbors.com/articles/vanuatu-banksretrieved
  5. T2https://forumsec.org/sites/default/files/2024-05/CBR%20Report_FINAL.pdfretrieved

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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.

no periodic updates on record for this sub-brief

Sources and findings (3)
  1. T3https://www.pln.vu/single-post/modernising-the-resrve-bank-of-vanuaturetrieved
  2. T4https://www.zitadelleag.com/services/vasp-licensing/vanuatu-vaspretrieved
  3. T1https://www.vfsc.vu/wp-content/uploads/2025/11/VFSC-Risk-Assessment-for-Virtual-Assets-2025.pdfretrieved
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