Self-custodial wallet / non-custodial software in Solomon Islands
Publisher of software where users hold their own private keys. The publisher never holds, controls, or has access to user funds.
Self-custodial wallet is conditionally permitted in Solomon Islands without local incorporation, subject to AML obligations and none licensing burden.
Verdict Details
- Permitted
- conditional
- Local entity required
- No
- Licensing burden
- None
- Last updated
- 2026-07-13
AML Obligations
- No AML obligations attach — the publisher does not hold, control, or access user funds, so it does not meet the definitions of a 'financial institution' or 'VASP' under the AML/CFT Act 2021 or Financial Transactions Reporting Act 2010.
- The SIFIU's CDD/EDD/STR obligations (under the AML/CFT Act 2021 and Financial Intelligence Unit Act 2021) are structured for entities that conduct financial transactions on behalf of customers; a non-custodial software publisher is not captured.
Key Restrictions
- The CBSI has warned the public against cryptocurrency risks and does not recognize crypto as legal tender, but this is a consumer advisory, not a prohibition on software publishing.
- No specific regulatory framework exists for non-custodial wallet software; the publisher operates in a regulatory vacuum.
- If the wallet software were bundled with financial services (e.g., staking pools, token swaps that route through the publisher's infrastructure), it could trigger licensing under the Financial Institutions Act 1998 or securities laws.
Key Risks
- Regulatory ambiguity — the absence of a defined VASP/MSB classification means a future legislative change (e.g., adopting FATF Recommendation 15 more explicitly) could retroactively impose obligations.
- CBSI public warnings create reputational risk for any entity associated with crypto in the Solomon Islands, even if the software is non-custodial.
- If a token accessible through the wallet is later deemed a security under the Howey-like test (investment of money, common enterprise, expectation of profit from efforts of others), the publisher could face ancillary risk if it facilitated the offering.
- No FATF Mutual Evaluation Report specifically addressing virtual assets for Solomon Islands was provided; the framework is nascent and enforcement capacity is limited.
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
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.
Lack of Specific Legislation: Without a dedicated framework, enforcement actions are harder to initiate.
The CBSI has warned the public against the risks of trading cryptocurrencies due to their volatility, speculative nature, and lack of regulation.
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.
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.
Solomon Islands Financial Intelligence Unit (SIFIU)
No specific crypto custody license: There is no dedicated license for virtual asset custodians.
Pure Utility Tokens: Tokens that primarily provide immediate access to a product or service, with no reasonable expectation of profit from the efforts of others, and are not marketed as an investment.
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 non-custodial wallet publisher can operate without licensing or AML obligations because it never holds or controls user funds and does not fall under any existing VASP/MSB/financial-institution definition, but the complete lack of a dedicated framework, CBSI anti-crypto warnings, and potential future FATM-driven regulation create meaningful ambiguity.
Questions this verdict aims to answer
- Does software publishing trigger VASP / MSB classification?
- Do AML obligations attach when no custody exists?
- What disclosure or consumer-protection rules apply?