2018年-IMF国际货币组织全球_Republic_of_the_Marshall_Islands_Selected_Issues_21页_660kb

Summary of Selected Issues on the Republic of the Marshall Islands

Core Content

This document provides an analysis of two key issues facing the Republic of the Marshall Islands (RMI): correspondent banking relationship (CBR) pressures and the introduction of the Sovereign (SOV), a decentralized digital currency. The report is prepared by the International Monetary Fund (IMF) as background for a consultation with the RMI government and outlines the challenges, implications, and potential actions to address these issues.

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Correspondent Banking Relationship Pressures

A. Background

• The RMI uses the U.S. dollar as legal tender and lacks a central monetary authority.
• The U.S. provides annual grants averaging $36 million (20% of GDP) under the 2003 Compact Agreement, which rely on correspondent banking relationships.
• The Bank of the Marshall Islands (BOMI) is the only domestic bank, operating five branches, including on the Kwajalein Atoll.
• First Hawaiian Bank (FHB), a subsidiary of BNP Paribas, is the only remaining U.S. correspondent bank for BOMI.
• Bank of Guam (BoG), a foreign-owned bank, offers an alternative but is subject to foreign ownership risks.

B. Trends and Drivers of CBR Pressures

• BNP Paribas was fined $8.9 billion in 2011 for AML/CFT violations, leading to a 24-month ban on U.S. dollar clearing services, including for FHB.
• FHB terminated its CBR with BOMI in 2014, but was granted a temporary exemption due to RMI’s strategic importance.
• Weak AML/CFT implementation by RMI authorities contributes to the perceived risks of CBRs.
• Offshore corporate and maritime registries are also a source of reputation risk, due to lack of transparency and bearer share issuance.

C. Impact of CBR Pressures

• Termination of BOMI’s CBR with FHB would have significant negative economic effects, particularly for remittances and salary payments to Marshallese citizens working for the U.S. military and U.S.-based companies.
• BoG could provide some relief, but its foreign ownership and limited branch presence pose risks.
• Money transfer operators (Western Union and Moneygram) continue to support remittances, and no significant changes in volume or value have been observed.
• CBR termination could increase financial integrity risks and impact macroeconomic stability.

D. Actions to Address CBR Pressures

• BOMI is seeking alternative CBR arrangements, including establishing a clearing house in Hawaii.
• AML/CFT compliance is being strengthened with technical support from FHB.
• RMI authorities are enhancing the AML/CFT framework by amending the Banking Act and developing supervisory manuals.
• A Monetary Authority is being explored, but its effectiveness in addressing CBR pressures is uncertain.
• Amendments to the Associations Law now require bearer share issuers to maintain beneficial ownership records.
• The World Bank is assisting with the first money laundering and terrorist financing risk assessment.

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The Sovereign (SOV) – RMI’s Decentralized Digital Currency

A. Introduction

• The SOV Act was passed in February 2018, aiming to establish a digital decentralized currency based on blockchain technology.
• The SOV is intended to be legal tender alongside the U.S. dollar.
• The Ministry of Finance will issue the SOV, which will be introduced via an initial coin offering (ICO) managed by a private sector organizer.
• The SOV will be non-redeemable and peer-to-peer.

B. Background on Virtual Currencies

• Virtual currencies can offer efficiency in financial transactions and secure data storage via distributed ledger technology (DLT).
• However, they also raise AML/CFT risks due to anonymity, decentralization, and lack of regulation.
• The FATF has issued guidance on risk-based approaches to virtual currencies, focusing on convertible virtual currency exchangers.

C. The SOV

• The SOV is not a central bank digital currency (CBDC), as it does not meet the criteria of being a central bank liability or convertible at par with USD.
• The initial issuance is 24 million SOV units, with 12 million allocated to the RMI and 12 million to the appointed organizer.
• The RMI’s 12 million SOV units will be distributed to trust funds, including the Green Climate Fund (GCF) and National Trust Fund.
• The supply of SOV units will grow at 4% annually, based on the previous year’s supply.

D. Potential Benefits and Risks

• The SOV is intended to generate revenue for the government, particularly to offset future reductions in U.S. aid.
• However, the IMF staff notes that financial integrity risks and macroeconomic challenges are significant.
• The lack of clarity on how the SOV will be regulated and implemented raises concerns.
• The FATF standards and U.S. regulations must be met before the SOV can be issued, which may delay its launch.

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Conclusion

• The CBR pressures pose a serious threat to the RMI’s financial system and economic stability, particularly given the country's heavy reliance on U.S. aid and limited banking infrastructure.
• The SOV represents a bold step towards financial innovation, but its implementation and regulatory compliance remain uncertain.
• The RMI authorities are taking steps to strengthen AML/CFT frameworks and address CBR risks, but more action is needed to ensure long-term financial integrity and monetary stability.