← Regulations / Solomon Islands / Operating Models / CEX

Centralized exchange in Solomon Islands

Order-book exchange that takes custody of user assets and matches trades between users.

Conditional AI-Generated · Unreviewed

CEX is conditionally permitted in Solomon Islands without local incorporation, subject to AML obligations and medium licensing burden.

Verdict Details

Permitted
conditional
Local entity required
No
Licensing burden
Medium
Last updated
2026-07-13

AML Obligations

  • CDD required under the AML/CFT Act 2021: obtain and verify full name, date of birth, residential address, nationality, and unique ID for natural persons; legal form and proof of existence for legal persons.
  • Beneficial ownership identification required at 25% or greater ownership/control threshold.
  • Ongoing transaction monitoring for consistency with customer risk profile.
  • Enhanced Due Diligence (EDD) required for PEPs, cross-border correspondent relationships, high-risk jurisdictions, complex/large transactions, and anonymity-enhancing virtual assets.
  • Suspicious Transaction Reports (STRs) must be filed with the Solomon Islands Financial Intelligence Unit (SIFIU) promptly (within 24-48 hours of suspicion per guidance).
  • No-tipping-off prohibition applies regarding STR filings.
  • Recordkeeping: CDD documents, transaction records (including travel-rule information if applicable), and business correspondence must be retained.

Key Restrictions

  • No regulated cryptocurrency exchange framework exists — the CBSI has stated cryptocurrencies are 'unregulated' and 'not recognized by the CBSI'.
  • Any token deemed a security (e.g., investment tokens, pre-functional utility tokens, governance tokens with economic rights, fractionalized NFTs) would trigger prospectus requirements under the Companies Act 2009 if offered to residents.
  • No specific crypto custody license exists; custody of digital assets falls into regulatory vacuum unless activities fall under the Financial Institutions Act 1998 or securities dealing.
  • No Travel Rule obligations formally apply, creating compliance gap with FATF standards.
  • Exchange likely cannot be licensed as a domestic VASP — trading would occur on offshore platforms outside direct regulatory purview.
  • CBSI has warned the public against trading cryptocurrencies due to volatility, speculation, and lack of regulation, creating reputational risk.

Key Risks

  • Regulatory vacuum: No dedicated VASP or exchange framework means enforcement is ad hoc under the Companies Act 2009 or general AML/CFT provisions.
  • CBSI has taken a preventive/warning-based stance, which could shift to enforcement action without warning.
  • Serving Solomon Islands residents without a local presence or clear legal basis creates risk of public enforcement action or negative CBSI public statements.
  • FATF/APG mutual evaluation likely flags VA/VASP risk gaps — pressure to regulate may increase, creating regulatory whiplash.
  • No segregation or insurance rules for client assets means custodial risk is purely contractual/operational.
  • Any token listing involving securities-like features could trigger Companies Act 2009 prospectus liability.

Evidence

This verdict synthesizes the following facts. Each fact links to its primary source(s).

licensing 60% confidence

There are no regulated cryptocurrency exchanges operating under Solomon Islands' jurisdiction. Trading would typically occur on offshore platforms, which are outside the direct regulatory purview of the Solomon Islands authorities.

licensing 60% confidence

The CBSI has warned the public against the risks of trading cryptocurrencies due to their volatility, speculative nature, and lack of regulation.

licensing 60% confidence

Lack of Specific Legislation: Without a dedicated framework, enforcement actions are harder to initiate.

licensing 60% confidence

Focus on Warnings: The CBSI's primary approach has been preventive, issuing general public warnings about the risks of cryptocurrencies, scams, and their non-recognition as legal tender.

licensing 60% confidence

Companies Act 2009: For breaches related to illegal offerings of unregistered securities or failures in disclosure.

custody 60% confidence

No specific crypto custody license: There is no dedicated license for virtual asset custodians.

custody 60% confidence

Potential application of existing licenses: If an entity's activities involving digital assets were deemed to fall under the definition of banking business, financial institution services, or securities trading, it would likely require a license under the Financial Institutions Act 1998 or other relevant financial legislation administered by the CBSI. However, this would depend on how digital assets are legally characterized, which is currently ambiguous for custody.

custody 60% confidence

No specific crypto rules: There are no explicit rules mandating the segregation of client digital assets from the custodian's proprietary assets.

custody 60% confidence

General fiduciary principles: For traditional financial institutions, general principles of fiduciary duty and client asset protection would typically apply, implying segregation. However, without specific legislation for digital assets, the enforceability and interpretation for crypto assets would be unclear.

aml 60% confidence

Anti-Money Laundering and Counter-Terrorist Financing Act 2021 (the AML/CFT Act): This comprehensive legislation aligns the Solomon Islands with international FATF standards, covering customer due diligence, reporting obligations, and broader AML/CFT requirements for financial institutions, which increasingly include VASPs.

aml 60% confidence

Identification and Verification of Identity:

aml 60% confidence

Beneficial Ownership: Identify and verify the identity of the natural person(s) who ultimately own or control the customer (typically 25% or more ownership/control threshold for legal entities).

aml 60% confidence

Ongoing Monitoring: Continuously monitor the business relationship and transactions to ensure they are consistent with the VASP's knowledge of the customer, their business, and risk profile. This includes monitoring for unusual or suspicious activities.

aml 60% confidence

Enhanced Due Diligence (EDD): Apply EDD measures in higher-risk situations, including:

aml 60% confidence

Reporting Obligation: Reports must be submitted to the SIFIU promptly. SIFIU guidance usually specifies a timeframe (e.g., within 24-48 hours of forming suspicion).

aml 60% confidence

No Tipping-Off: VASPs and their employees are strictly prohibited from informing the customer or any third party that an STR has been or will be submitted.

travel-rule 60% confidence

Not Adopted: The Solomon Islands does not have a specific regulatory framework for Virtual Assets (VAs) or Virtual Asset Service Providers (VASPs). Consequently, the FATF Travel Rule (Recommendation 16, as applied to VASPs under Recommendation 15) has not been adopted or made effective.

travel-rule 60% confidence

However, operating any unregulated financial service carries inherent risks, and any entity found to be facilitating money laundering or terrorist financing through virtual assets, if such activities were ever investigated and proven, would likely fall under the general provisions of the Solomon Islands Anti-Money Laundering and Counter-Terrorist Financing Act 2002 (as amended). But this would be for the underlying crime, not for VASP-specific regulatory non-compliance.

Verdict Attribution

Source:
AI-Generated · Unreviewed
AI synthesized:
2026-07-13 (deepseek-chat)
Last updated:
2026-07-13
Confidence:
medium

This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.

Conditional — a centralized exchange cannot be licensed domestically and cryptocurrency is not recognized as legal tender nor regulated, but non-custodial or offshore-based operations serving residents may operate in a legal vacuum subject to general AML/CFT obligations under the AML/CFT Act 2021 and securities-law risk for any token deemed an investment contract.

Questions this verdict aims to answer

  • What exchange / VASP license applies?
  • What custody segregation rules apply to user assets?
  • What market-conduct and listing rules apply?
  • What travel-rule obligations apply on withdrawals?