Crypto ATM / kiosk operator in Vanuatu
Physical kiosks that exchange cash for crypto (and sometimes vice versa). High-cash AML risk profile.
Crypto ATM is conditionally permitted in Vanuatu with a local entity, subject to AML obligations and medium licensing burden.
Verdict Details
- Permitted
- conditional
- Local entity required
- Yes
- Licensing burden
- Medium
- Last updated
- 2026-07-13
AML Obligations
- VASP license required under the Virtual Asset Providers Act No. 27 of 2023 (VAPA 2023), regulated by the Vanuatu Financial Services Commission (VFSC).
- AML/CTF obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act [CAP 264] — mandatory registration with the Vanuatu Financial Intelligence Unit (FIU).
- Customer due diligence (CDD) and ongoing monitoring required per AML/CTF Act obligations for VASPs.
- Enhanced KYC obligations for cash-in/cash-out transactions given high-cash AML risk profile — though specific cash-transaction reporting thresholds (e.g., USD/VUV amounts) are not publicly detailed in available facts.
- Reporting of suspicious transactions to the FIU is required.
- Maintain records clearly identifying ownership of each client's virtual assets (Section 22, VAPA 2023).
- Proposed AML/CTF compliance policies and procedures must be submitted as part of the VASP license application (Section 17, VAPA 2023).
Key Restrictions
- VASP license from VFSC is required under VAPA 2023 — no dedicated kiosk/ATM-specific license exists; crypto ATM operators fall under the general VASP framework.
- Cryptocurrencies are not legal tender in Vanuatu (RBV statement, November 2022).
- Minimum unimpaired paid-up capital requirements apply (Section 18, VAPA 2023) — specific thresholds not yet fully detailed by Ministerial regulation.
- Client virtual assets must be held separately from the operator's own assets and those of other clients (Sections 20-22, VAPA 2023).
- Directors and senior management must meet 'fit and proper' criteria (Section 14, VAPA 2023).
- Robust internal controls, risk management systems, and cybersecurity framework required (Section 19, VAPA 2023).
Key Risks
- No publicly available enforcement actions specific to cryptocurrency entities in Vanuatu over the past three years — regulatory enforcement posture is untested for crypto ATM/kiosk operators.
- Cash-transaction reporting thresholds and specific enhanced-KYC rules for cash-based crypto transactions are not clearly delineated in public sources, creating compliance ambiguity.
- Capital requirements remain undefined (subject to future Ministerial regulation), creating uncertainty for licensing applications.
- Small offshore jurisdiction with evolving regulatory framework — risk of sudden rule changes or FATF scrutiny.
- General AML classification as 'virtual assets' under AML/CTF Act [CAP 264] may not fully address kiosk-specific cash-to-crypto risks without additional guidance.
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
Virtual Asset Providers Act No. 27 of 2023 (VAPA 2023): This is the cornerstone legislation for virtual assets, including custody services. It defines "virtual assets," "virtual asset service providers" (VASPs), and sets out licensing and operational requirements.
Vanuatu Financial Services Commission - Virtual Asset Providers Act No. 27 of 2023 (PDF link on VFSC website)
Financial Dealers Licensing Act [CAP 70]: While the VAPA 2023 is specific, the general principles and licensing framework of financial dealing can be considered complementary.
Anti-Money Laundering and Counter-Terrorism Financing Act No. 13 of 2017 (as amended):
Application Requirements (Section 12, VAPA 2023): An applicant for a VASP license must submit to the VFSC:
Capital Requirements (Section 18, VAPA 2023): A VASP must at all times maintain a minimum unimpaired paid-up capital as prescribed by the Minister through regulation. This regulation is yet to be fully detailed.
Fit and Proper Persons (Section 14, VAPA 2023): Directors and senior management must meet "fit and proper" criteria established by the VFSC, demonstrating competence, integrity, and financial soundness.
Evidence fact vu.licencing.client-assets-sections-20-21 not found (may have been renamed).
Risk Management and Internal Controls (Section 19, VAPA 2023): A licensed VASP must implement robust risk management systems and internal controls designed to ensure the security, integrity, and operational resilience of its services, which could implicitly encourage or require consideration of insurance.
Virtual Assets: The most likely general classification is "Virtual Assets" or "Digital Assets" under the Anti-Money Laundering and Counter-Terrorism Financing Act (AML/CTF Act) [CAP 264]. This act defines "virtual asset" broadly and mandates AML/CTF obligations for Virtual Asset Service Providers (VASPs).
Reference: Anti-Money Laundering and Counter-Terrorism Financing Act [CAP 264] (accessible via PacLII: http://www.paclii.org/vu/legis/consol_act/a-mlact2019318/ - Note: This link points to the 2019 version which often incorporates previous amendments.)
Virtual Asset Service Provider (VASP) Obligations: The AML/CTF Act [CAP 264] mandates that entities providing "virtual asset services" (which would include stablecoin exchanges, transfers, custody, etc.) are considered VASPs and must comply with AML/CTF obligations, including registration with the Vanuatu Financial Intelligence Unit (FIU) and implementing robust KYC/CDD procedures.
Reference: Vanuatu Financial Intelligence Unit (FIU) website: http://www.fiu.gov.vu/
The Reserve Bank of Vanuatu (RBV) has issued clarifications regarding the legal status of cryptocurrencies. In November 2022, the RBV reiterated that cryptocurrencies are not legal tender in Vanuatu. While this is a regulatory stance and not an enforcement action against a specific entity, it sets the legal framework within which crypto activities operate.
General Regulatory Stance and Warnings:
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 — Crypto ATM/kiosk operators may operate in Vanuatu under a VASP license from the VFSC under VAPA 2023, subject to AML/CTF obligations under [CAP 264], but specific cash-transaction reporting thresholds and enhanced-KYC rules for cash-based crypto transactions are not publicly detailed, creating compliance uncertainty.
Questions this verdict aims to answer
- What money-transmitter / kiosk-specific license is required?
- What cash-transaction reporting thresholds apply?
- What enhanced-KYC obligations attach to cash-in / cash-out?