Why Choose Marshall Islands for Crypto?
The Marshall Islands is the world’s first sovereign jurisdiction to grant decentralised autonomous organisations full corporate legal personality. The DAO LLC, introduced by the Decentralized Autonomous Organization Act 2022 and refined by the DAO Regulations 2024, gives token-holder members limited liability without requiring each holder to undergo KYC. For DeFi protocols, AI agent operators, and on-chain treasuries, no other jurisdiction offers an equivalent legal wrapper.[1][4]
First-in-the-World DAO LLC Statute
The Marshall Islands enacted the Decentralized Autonomous Organization Act on , becoming the first sovereign state to recognise a DAO as a legal person at the national level.[4][15][22] The 2023 amendments added Series DAO LLCs and reinforced smart-contract recognition; the 2024 DAO Regulations introduced a Beneficial Owner Information Report regime and clarified KYC thresholds. As of late 2024, MIDAO Directory Services Inc., the sole authorised registered agent for DAO LLCs, reported more than 200 DAO LLCs registered or under registration.[3] Real-world adopters include the Pyth Network oracle (Pyth DAO LLC) and Shipyard Software’s Admiralty DAO, the first DAO LLC formed under the Act.[21][18][19] Unlike Wyoming’s DAO LLC, which subjects every governance-token holder to Corporate Transparency Act reporting, the Marshall Islands requires KYC only for beneficial owners controlling 25% or more of governance rights.[4]
Tax Neutrality with Honest Qualifiers
Non-profit DAO LLCs and standard non-resident domestic entities pay zero corporate income tax on foreign-source income. For-profit DAO LLCs pay 3% Gross Revenue Tax on earned revenue and interest, excluding capital gains and dividends.[4][20] The Marshall Islands has no capital gains tax, no withholding tax, and no stamp duty on share transfers. Unlike the deepest offshore fund centres, which charge USD 75,000 or more in legal and government fees for a regulated foundation structure capable of holding crypto, a Marshall Islands DAO LLC formation costs USD 9,500 through MIDAO’s standard package.[1] The tax position does not displace US Subpart F, GILTI, or PFIC rules for US-person members; that calculation belongs to the home-country tax adviser, not the RMI structure.
Member Liability Protection without Member Identification
The DAO Act 2022 grants members of a DAO LLC the same limited liability protection as members of a standard Limited Liability Company under the LLC Act 1996.[4][16] In the wake of the CFTC’s default judgement against Ooki DAO in , which held an unincorporated DAO and its token-holder members jointly liable for unregistered swap activity, the Marshall Islands DAO LLC provides the cleanest available shield against the unincorporated-association liability theory.[12] The protection is statutory and prospective: it has not yet been tested in litigation analogous to Ooki DAO, but the underlying legal mechanism is well-established LLC law.
US Dollar Settlement without US Legal Nexus
The Marshall Islands uses the US dollar as legal tender under the Compact of Free Association with the United States, most recently amended on and entered into force .[10] US-touch counterparties accept RMI entities as a routine matter, and dollar settlement does not trigger US federal jurisdiction over the entity itself. The structure does mean every counterparty transaction is exposed to US OFAC sanctions screening; OFAC has repeatedly designated Marshall Islands-incorporated shell companies (most recently in a Federal Register notice listing Iran-related shipping entities at “Trust Company Complex, Ajeltake Road, Majuro”).[11] Sanctions screening on every counterparty is therefore part of the operational baseline, not an optional add-on.
Regulatory Framework
Marshall Islands crypto entities operate under five interlocking instruments: the DAO Act 2022 with its 2023 amendments and 2024 regulations, the LLC Act 1996 (modelled on Delaware), the Non-Profit Entities Act with its 2021 DAO amendment, the Banking Act 1987 for AML/CFT supervision, and the Economic Substance Regulations 2018. There is no separate VASP licensing regime in operation as of .[2][4][6]
Definition: Marshall Islands DAO LLC
A DAO LLC is a limited liability company that elects to be treated as a Decentralized Autonomous Organization under the DAO Act 2022 of the Republic of the Marshall Islands. The entity must include “DAO LLC” in its name, maintain a registered agent in the Republic (MIDAO Directory Services Inc. for all DAO LLCs by statute), and operate under either a member-managed or algorithmically-managed governance structure. Tax treatment: 0% for non-profit DAO LLCs, 3% Gross Revenue Tax for for-profit DAO LLCs.
Regulatory History
The Marshall Islands’ offshore programme dates from the 1990s, originally built around shipping (the RMI is the world’s third-largest flag state by deadweight tonnage at 305 million DWT as of , behind Liberia and Panama).[14] The DAO statute emerged from a partnership between the RMI government and MIDAO Directory Services Inc.; the original DAO Act passed on and was signed into law on .[4][22] In , Parliament strengthened the framework with amendments introducing Series DAO LLCs and clarifying the smart-contract operating agreement model.[22] The 2024 DAO Regulations followed the Asia/Pacific Group on Money Laundering on-site visit and tightened beneficial-ownership reporting and KYC thresholds for DAO LLC registered agents.[7]
Recent Regulatory Developments
- : OFAC designations of RMI-incorporated entities. The US Treasury’s Office of Foreign Assets Control published a Federal Register notice designating multiple Marshall Islands-incorporated shipping shell companies under Executive Order 13902 (Iran).[11] No RMI DAO LLCs were named; the action highlights OFAC’s continued attention to the RMI registry’s use as a vehicle for sanctions evasion in maritime shipping.
- : APG 3rd Round Mutual Evaluation Report published. The Asia/Pacific Group on Money Laundering adopted the Marshall Islands’ 3rd Round Mutual Evaluation Report in September 2024 and published it in November 2024. The MER identifies the DAO sector and the non-resident-domestic-entity sector as priority risk areas not yet well understood by all relevant authorities, and notes that MIDAO was only subject to AML/CFT requirements as a designated non-financial business and profession (DNFBP) at the end of the on-site visit.[7]
- : COFA 2023 Amendment enters into force. The 2023 amendment to the Compact of Free Association between the United States and the Marshall Islands (TIAS 24-501.2) entered into force, extending the economic and security relationship for a further 20 years and reaffirming RMI’s use of the US dollar.[10]
- : DAO Regulations adopted. The DAO Regulations 2024 introduced the Beneficial Owner Information Report (BOIR) regime, formalised the 25%-governance-rights KYC threshold, and added enforcement powers including revocation of the certificate of formation for non-compliance.[2][4]
- : Marshall Islands removed from EU list of non-cooperative jurisdictions. The Council of the European Union delisted the RMI after substantiating enforcement of its economic substance regime; the RMI had been listed on and remained off the EU blacklist through 2026.[9]
- : DAO Act amendments enacted. Series DAO LLC provisions, smart-contract recognition clauses, and member-identification refinements added to the DAO Act.[22]
Regulatory Overlap
The framework intersects with four other regimes that operators must screen against. The Banking Act 1987 supplies AML/CFT obligations applicable to any financial-services activity, including the dormant VASP definition.[6] The Proceeds of Crime Act criminalises laundering and predicate offences. The United Nations Sanctions (Implementation) Act 2020 and the United Nations Targeted Financial Sanctions (Terrorism and Proliferation) Regulations 2020 implement UN-level sanctions and tie into US OFAC screening through correspondent-banking and counterparty exposure.[11] The Economic Substance Regulations 2018 (as amended through August 2019) apply to entities engaged in “relevant activities”, a category that captures pure equity holding companies under a reduced-substance test but does not typically capture DAO LLC governance activity.[17][20]
Entity Types and Activities Covered
The Marshall Islands does not issue VASP or CASP licences as a routine matter. Operators do not choose between licence categories; they choose between entity types. The four operative structures are the non-profit DAO LLC, the for-profit DAO LLC, the standard LLC, and the IBC. Each accommodates a different combination of governance, tax treatment, and member-identification obligations.[2][4]
Covered Entity Types and Activities
- Non-profit DAO LLC. Formed under the DAO Act 2022 and the Non-Profit Entities (Amendment) Act 2021. No economic owners; governance rights are not equity. Use case: protocol governance, on-chain treasuries, grant DAOs, public-goods coordination. Tax: 0% on all income. Examples include the Pyth DAO LLC and Shipyard Software’s Admiralty DAO LLC.[18][19][21]
- For-profit DAO LLC. Same statutory framework but with distributable economic interests. Use case: investment DAOs, revenue-generating protocols, on-chain funds. Tax: 3% Gross Revenue Tax on earned revenue and interest, excluding capital gains and dividends.[4]
- Series DAO LLC. Added by the 2023 amendments. Allows ring-fenced sub-DAOs under a parent DAO LLC with internal asset and liability segregation. Use case: multi-product protocols, sub-treasury structures.[22]
- Standard LLC (non-resident domestic entity). Formed under the LLC Act 1996; modelled on Delaware. Use case: token-issuance SPV, OpCo, holding entity. Administered by International Registries Inc. rather than MIDAO.[5]
- International Business Company (IBC). Formed under the Business Corporations Act 1990. Use case: holding company, trading entity. Notably, more than 40 NYSE- and NASDAQ-listed shipping companies use the RMI IBC form.[3][14]
What Does NOT Require Registration
Holding a token. Issuing a token from a DAO LLC treasury where the issuer does not also operate a custody, exchange, or transfer service for third parties. Operating a non-custodial DeFi protocol front-end where users retain self-custody throughout. Running governance votes via a smart contract referenced in the DAO LLC’s operating agreement. None of these activities trigger the dormant VASP definition in the Banking Act.[2] What the dormant VASP definition would capture, and what is therefore not legally operable from the RMI under current law: a centralised exchange custodying client funds; a custodial wallet provider; a token transfer service exchanging virtual assets for fiat or other virtual assets on behalf of identifiable counterparties.[2]
Guidance on DAO, DeFi, and AI Agent Structures
MIDAO’s own documentation, which the RMI government has endorsed through the public-private partnership, is the operative practitioner guidance.[3] The guidance confirms that a DAO LLC may hold and govern protocol assets, issue governance tokens, operate front-ends, and contract with developer entities, without triggering the VASP definition, provided the DAO LLC does not itself act as custodian or exchange for third parties. The guidance also addresses AI agent structures: an autonomous software agent may be granted legal personality through the DAO LLC wrapper, which makes the Marshall Islands the only sovereign jurisdiction currently offering a clean legal-person structure for AI agents as of .
Requirements
Marshall Islands DAO LLC requirements are minimal compared with EU CASP or even Caribbean VASP regimes. There is no minimum capital, no local director, no local office, and no local employee requirement. The two non-negotiable requirements are a Marshall Islands-resident registered agent and a Beneficial Owner Information Report identifying every 25%-plus governance-rights holder.[2][4]
| Requirement | Detail |
|---|---|
| Minimum capital | None. No fixed minimum across any entity type. |
| Local director | Not required. |
| Local office | Not required. |
| Local employees | Not required. |
| Registered agent | Mandatory and continuous. MIDAO Directory Services Inc. is the sole statutory registered agent for DAO LLCs. International Registries Inc. for standard LLC and IBC. |
| Member identification (KYC) | DAO LLC: only beneficial owners controlling 25% or more of governance rights. Standard LLC / IBC: every member or beneficial owner. |
| Beneficial Owner Information Report | Mandatory for DAO LLCs under the 2024 DAO Regulations. Updated annually and within 30 days of a triggering change. |
| Name | DAO LLC: must include “DAO LLC” in the entity name. |
| Operating agreement | DAO LLC: may reference governance smart contracts (Pyth pattern). Standard LLC: written agreement among members. |
| Foreign Investment Business License (FIBL) | Required at formation for non-resident-owned entities. Application is part of the standard package. |
| Annual report | Filing window 1 January to 31 March. Updates beneficial ownership, leadership, community engagements, financial activities. |
| Economic substance | Pure equity holding test only for DAO LLCs not engaged in “relevant activities”. Reduced test satisfied by maintaining registered agent and compliance with statutory filings.[17][20] |
Fit-and-Proper Assessment
The Marshall Islands does not run a centralised fit-and-proper assessment for DAO LLC formation. The substantive fit-and-proper screen is conducted by MIDAO under its DNFBP obligations: identity verification of every 25%-plus beneficial owner, sanctions screening against UN, US OFAC, EU, and UK lists, and source-of-wealth review where the AML risk profile warrants it.[2][7] The common mistake is treating the MIDAO intake as administrative. MIDAO is now formally a DNFBP under the 2024 DAO Regulations and the September 2023 AML/CFT Guidelines, which means MIDAO’s intake is the entity’s primary AML/CFT gate, not a back-office check.
Local Representation
The registered agent is the entity’s mandatory point of contact with the Marshall Islands government and the Banking Commission. For DAO LLCs, this role is reserved by statute to MIDAO Directory Services Inc.; there is no choice of agent. For standard LLCs and IBCs, International Registries Inc. and its network of authorised agents handle the registered-agent function. The agent receives all government correspondence, maintains the statutory register, files the annual report, and operates the BOIR pipeline for DAO LLCs.[2][5]
AML/CFT and Travel Rule
The Marshall Islands operates a FATF-aligned AML/CFT framework under the Banking Act 1987 (as amended in 2002), the Anti-Money Laundering Regulations 2002, and the Proceeds of Crime Act.[6][7] Sanctions screening is required against UN, US OFAC, EU, and UK consolidated lists, with the COFA relationship making OFAC compliance commercially indispensable rather than merely advisable.[11] The FATF Recommendation 16 Travel Rule applies to VASPs as defined in the Banking Act, but since the VASP licensing regime is dormant, Travel Rule obligations are operative only where an entity self-identifies as conducting VASP activity; in practice, RMI DAO LLCs are structured to fall outside the VASP definition entirely.
Application Process
The Marshall Islands DAO LLC formation runs through MIDAO Directory Services Inc. as the sole statutory registered agent. The standard timeline is three to five working days from the moment the BOIR and KYC pack are complete and clear. MIDAO’s TurboDAO 24-hour express track is available for time-critical formations at a higher fee.[1]
Application language: English. All filings, the operating agreement, and the BOIR are submitted in English.
Pre-application engagement: MIDAO conducts a preliminary intake call before formal submission. This is the practical stage at which the DAO LLC structure is sense-checked against the dormant VASP definition and the AML risk profile is calibrated.
Marshall Islands Entity Formation
Forming a Marshall Islands entity is the first step. See the full Marshall Islands company formation guide for entity selection mechanics. The licensing-relevant decisions at this stage are the choice between DAO LLC (non-profit or for-profit), standard LLC, or IBC; the operating-agreement design (member-managed, algorithmically managed, or hybrid); and the selection of beneficial owners to identify in the BOIR. KYC documents (certified passport copy, residential proof within 3 months) are collected for each 25%-plus beneficial owner.
Operating Agreement and BOIR Preparation
The operating agreement is the substantive document. For algorithmically managed DAO LLCs, the agreement references the governance smart contracts by address (the Pyth Network pattern); for member-managed DAO LLCs, the agreement specifies voting thresholds, proposal mechanics, treasury controls, and fiduciary defaults. The BOIR is drafted in parallel and includes every beneficial owner controlling 25% or more of governance rights, voting rights, or distribution rights.
MIDAO Intake and AML Risk Assessment
MIDAO conducts the DNFBP-level intake: identity verification, sanctions screening, source-of-wealth review where applicable, and an AML risk-scoring exercise against the intended activities. Where the intended activities approach the dormant VASP definition (custody, exchange, transfer for third parties), MIDAO will either redirect the structure or decline. This is the substantive gate, not the certificate filing.
Certificate of Formation, FIBL, and Registry Filing
MIDAO files the certificate of formation with the Registrar of Resident Domestic and Authorized Foreign Corporations, accompanied by the Foreign Investment Business License application and the Consent to Act as Representative Agent. TurboDAO compresses this stage to 24 hours where the upstream stages have been pre-cleared.[1]
Post-Formation Setup
Banking applications, EU reverse-solicitation defence documentation (where EU users are anticipated), US tax structuring (where US-person beneficial owners are involved), and operational onboarding of the governance smart contracts. Banking is the rate-limiting step; institutional approval typically takes 6 to 12 weeks for the first account.
Jagelski & Partners’ specialist compliance partners draft Marshall Islands-specific AML/CFT policy manuals, sanctions screening procedures, BOIR documentation, and operating agreements (including smart-contract-referenced governance structures) as part of the DAO LLC engagement. The compliance documentation is the most time-intensive component of any Marshall Islands DAO LLC formation: 4 to 8 weeks of specialist work that cannot be shortcut with generic templates ported from another jurisdiction. The MIDAO intake and the AML risk profile are both designed against this documentation, not the other way around.
Experienced applicants begin US tax structuring in parallel with formation, not after. The home-country tax memo is the document that determines whether the structure delivers economic value for US-person members, and starting it late is the most common reason a structurally sound DAO LLC fails to deliver the projected tax benefit.
Required Documents
The Marshall Islands DAO LLC documentation set is lighter than EU CASP or Caribbean VASP applications, but the BOIR and the operating agreement carry the entire substantive weight of the formation. The 2024 DAO Regulations and MIDAO’s published intake checklist together define the document baseline; the compliance documentation suite is built on top of that baseline.[2]
Corporate Documents
- Certificate of Formation (drafted by MIDAO, signed by the organiser)
- Operating Agreement (for algorithmically managed DAO LLCs: smart-contract address references; for member-managed: full written agreement)
- Consent to Act as Representative Agent (MIDAO)
- Foreign Investment Business License (FIBL) application
Personal Documents (all 25%-plus beneficial owners)
- Certified passport copy (non-expired)
- Residential address proof within 3 months (utility bill or bank statement)
- Description of source of wealth where AML risk profile warrants
- Wallet address (BOIR requirement under the 2024 DAO Regulations)[4]
Compliance Documentation
The compliance documentation is the most heavily scrutinised component of any Marshall Islands DAO LLC formation. Jagelski & Partners’ specialist compliance partners draft each of these documents as part of the engagement: bespoke and Marshall Islands-specific, calibrated to the dormant VASP definition in §102(ii) of the Banking Act and the DNFBP obligations applicable to MIDAO under the September 2023 AML/CFT Guidelines. Each document must reflect the applicant’s specific governance model, treasury structure, and operational footprint.
AML/CFT Policy Manual
ML/TF, sanctions, and PEP risk identification across the DAO LLC’s intended activities. Marshall Islands-specific procedures referencing the Banking Act 1987 as amended, the Anti-Money Laundering Regulations 2002, and the September 2023 AML/CFT Guidelines for Banks and Financial Service Providers. This is the document MIDAO’s intake reviews most closely under its DNFBP obligations. Generic templates fail because they do not address the §102(ii) VASP definition or the BOIR pipeline. The APG 3rd Round MER specifically flagged the DAO sector as a priority risk area where compliance documentation is uneven.
Enterprise-Wide Risk Assessment
ML/TF, operational, technology, jurisdictional, and protocol-specific risk identification. For DAO LLCs operating DeFi protocols, the risk assessment must cover smart-contract risk, governance attack vectors, and the protocol’s exposure to OFAC-sanctioned addresses. For AI agent DAO LLCs, the assessment must address autonomous-decision-making controls.
Sanctions Screening Procedures
UN, US OFAC, EU, and UK consolidated lists. OFAC screening is operationally indispensable for RMI entities because of the COFA dollar relationship. The 22 December 2025 OFAC designations of RMI-incorporated shipping shells underline the consequence of compliance failure; OFAC has a documented pattern of designating RMI entities, and counterparties screen accordingly.
Beneficial Owner Information Report (BOIR)
Identification of every beneficial owner controlling 25% or more of governance, voting, or distribution rights, with wallet address. Introduced by the 2024 DAO Regulations and reinforced by the APG 3rd Round MER findings. Annual refresh; 30-day update for any triggering change. The BOIR is the document that defines the entity’s KYC perimeter: token holders below the 25% threshold are not identified.
Restricted Countries and Jurisdictions Matrix
Per FATF, OFAC, EU, UK lists. For DAO LLCs operating front-ends, the matrix governs geographic access controls. EU geo-blocking is critical for preserving the reverse-solicitation defence under MiCA Article 61.
Transaction Monitoring Framework
On-chain and off-chain monitoring procedures. For protocols using the DAO LLC as a treasury wrapper, monitoring covers protocol-level flows; for custodial-adjacent structures, monitoring covers user-facing flows. The framework must be designed against the dormant VASP definition.
Travel Rule Implementation
FATF Recommendation 16 procedures, applicable where the entity self-identifies as VASP. Since the RMI VASP licensing regime is dormant, the practical question is whether the DAO LLC is structured to fall inside or outside the VASP definition. Travel Rule implementation is required where inside; structural redesign is required where outside is the intended position.
SAR/STR Procedures
Reporting to the Domestic Financial Intelligence Unit. The DFIU has been an Egmont Group member since June 2002. SAR/STR procedures must specify trigger thresholds, internal escalation, and reporting timelines under the Proceeds of Crime Act.
Compliance Monitoring Programme
Annual cycle of policy review, transaction sampling, training, and reporting. The 2024 DAO Regulations require maintenance of compliance records and make non-compliance a basis for revocation of the certificate of formation under Section 15.
Data Protection and Wallet Management Procedures
Key custody, multi-sig, hardware-security-module protocols where applicable. For DAO LLCs with on-chain treasuries, the wallet-management procedures are part of the substantive AML/CFT framework, not a separate technology document: the procedures govern who can move treasury assets and under what governance authority.
Business Plan and Financial Projections
Three-year revenue model where the entity generates revenue (relevant for for-profit DAO LLCs under the 3% GRT calculation). Where the DAO LLC is a non-profit treasury or governance wrapper with no commercial revenue, a treasury management plan and budget substitute for a conventional business plan.
Technology and Operational Documentation
Smart-contract architecture summary, governance flow diagrams, on-chain treasury controls, key-management procedures (multi-sig or HSM where applicable), and incident-response plan. For AI agent DAO LLCs, additional documentation covers autonomous-decision-making constraints and the governance-override pathway.
Costs and Pricing
The Marshall Islands DAO LLC is the most cost-efficient sovereign DAO legal wrapper available in 2026. MIDAO’s published standard package is USD 9,500 for formation and first-year registered agent, with annual renewal at USD 2,000 to 5,000. The total Year 1 cost including legal, compliance documentation, and banking facilitation is typically USD 11,500 to 25,000.[1]
Government and Registered Agent Fees
| Item | Cost (USD, May 2026) | Notes |
|---|---|---|
| MIDAO DAO LLC formation (standard package) | 9,500 | Includes certificate of formation, FIBL, first-year registered agent, BOIR initial filing.[1] |
| MIDAO TurboDAO 24-hour express | 10,000 | 24-hour onboarding plus 1-year virtual office and telephone.[1] |
| MIDAO annual renewal | 2,000–5,000 | Registered agent, statutory filings, BOIR refresh.[1] |
| Series DAO LLC add-on | Confirm at quote | Per-series fee on top of parent DAO LLC.[1] |
| Standard LLC formation via IRI | Several hundred to low four figures | Non-DAO LLC formations; administered by International Registries Inc.[5] |
| IBC formation via IRI | Several hundred to low four figures | Business Corporations Act 1990 entity.[5] |
| Apostille and document certification | 200–500 per document | Bank account opening typically requires apostilled corporate documents. |
Total Cost Summary
| Component | Year 1 (USD) | Annual ongoing (USD) | Notes |
|---|---|---|---|
| Government and registered agent fees | 9,500 | 2,000–5,000 | MIDAO standard package; renewal varies with services elected.[1] |
| Legal advisory (jurisdiction-specific structuring) | 2,000–5,000 | 1,000–3,000 | Operating agreement, US tax memo where applicable, BOIR drafting. |
| Compliance documentation (AML/CFT policy suite, risk assessment, sanctions framework, BOIR, transaction monitoring framework) | 3,000–7,000 | 1,500–3,000 | Bespoke Marshall Islands-specific drafting; not template-derived. |
| Banking facilitation | 1,000–3,000 | 500–1,500 | Multi-application support; institutional onboarding typically takes 6 to 12 weeks. |
| Total Year 1 | 11,500–25,000 | All-in including formation, compliance documentation, and banking facilitation. | |
| Annual ongoing | 5,000–12,500 | From Year 2 onward, exclusive of for-profit GRT. |
For for-profit DAO LLCs only, add 3% Gross Revenue Tax on earned revenue and interest (excluding capital gains and dividends) from Year 1.[4][20]
Timeline
The Marshall Islands DAO LLC formation timeline is short by design. Standard formation completes in 3 to 5 working days through MIDAO once the BOIR and KYC pack are clear. TurboDAO compresses the registry filing to 24 hours. Banking, not formation, is the rate-limiting step for end-to-end operational readiness.[1]
| Stage | Duration | Cumulative |
|---|---|---|
| KYC pack collection and BOIR draft | 1–2 weeks | 1–2 weeks |
| Operating agreement drafting | 1–3 weeks (parallel) | 2–4 weeks |
| MIDAO intake and AML risk assessment | 3–7 working days | 2–5 weeks |
| Certificate of formation and registry filing | 3–5 working days (24 hours TurboDAO) | 3–5 weeks |
| Compliance documentation drafting | 4–8 weeks (parallel with formation) | 4–8 weeks |
| Banking application and approval | 6–12 weeks (sequential) | 10–20 weeks |
| Total to operational | 10–20 weeks |
MIDAO’s published Pricing page lists 3 to 5 working days as the standard formation timeline and 24 hours as the TurboDAO express option.[1] The reason formation moves quickly is that the Marshall Islands has no substantive licensing assessment to clear; the registry filing is administrative once MIDAO has cleared its DNFBP-level intake. The reason end-to-end operational readiness takes 10 to 20 weeks is banking: institutional approval for an RMI DAO LLC typically takes 6 to 12 weeks for the first account, and run-rate operations require banking before the entity can transact in the off-chain world.
Taxation
The Marshall Islands is a zero-tax jurisdiction for non-profit DAO LLCs and for standard LLCs and IBCs on foreign-source income. For-profit DAO LLCs face a 3% Gross Revenue Tax on earned revenue and interest. The structure delivers RMI-level tax neutrality but does not displace home-country attribution rules for beneficial owners.[4][20]
| Tax | Rate (May 2026) | Crypto application |
|---|---|---|
| Corporate income tax (non-profit DAO LLC) | 0% | Applies to all income.[4] |
| Gross Revenue Tax (for-profit DAO LLC) | 3% | On earned revenue and interest; excludes capital gains and dividends. Annual flat USD 80 on the first USD 10,000 of gross revenue, then 3%.[4] |
| Corporate income tax (IBC / standard LLC) | 0% on foreign-source income | Foreign-source income is the operative category for non-resident-domestic entities.[20] |
| Capital gains tax | 0% | No capital gains tax at the RMI level. |
| Withholding tax | 0% | No withholding on dividends, interest, or royalties paid by RMI entities. |
| Stamp duty | 0% | No stamp duty on share or membership-interest transfers. |
| VAT or sales tax | None at federal level | Limited local turnover tax exists but does not capture non-resident-domestic activity. |
| Payroll tax | Applies only where local employees are engaged | Most DAO LLCs have no local employees and no payroll tax exposure. |
US Tax Overlay (mandatory for any US-person involvement)
The Compact of Free Association makes the Marshall Islands a heavily US-touched jurisdiction. Most RMI entities will be CFCs (controlled foreign corporations) or PFICs (passive foreign investment companies) for US-person members, and the RMI-level 0% or 3% tax does not displace US Subpart F, GILTI, or PFIC attribution rules.[10] The real constraint is not Marshall Islands tax. It is the home-country attribution rule of whichever jurisdiction the beneficial owners actually live in. The RMI is a FATCA-reporting jurisdiction and participates in the OECD Common Reporting Standard, which means the entity’s existence is visible to home-country tax authorities through automatic information exchange.
CRS and CARF Reporting
The Marshall Islands participates in the OECD Common Reporting Standard (CRS) and is committed to implementing the Crypto-Asset Reporting Framework (CARF) on the OECD timeline. The first CARF reporting cycle is expected in 2027 covering 2026 reportable accounts. Where a DAO LLC operates a custodial wallet or exchange function (rare under current structuring), CARF reporting will attach to the entity’s reportable users.
EU Tax-List Status and DAC6
The Marshall Islands was on the EU list of non-cooperative jurisdictions for tax purposes from to , and has remained off the EU blacklist since.[9] Where cross-border payments involve EU-resident counterparties, the DAC6 hallmark C1b(ii) reporting may still trigger because the RMI does not impose corporate income tax at the standard EU comparison rate; advisers in the EU member-state side of the transaction handle the reporting.
Ongoing Compliance & Post-Registration
The Marshall Islands compliance regime for DAO LLCs is concentrated in three obligations: the annual report filed between 1 January and 31 March; the Beneficial Owner Information Report refresh on the same annual cycle, with 30-day update for triggering changes; and the continuous AML/CFT obligations administered through MIDAO under its DNFBP designation. Non-compliance can trigger revocation of the certificate of formation.[2][4]
Annual Reporting Obligations
DAO LLCs file an annual report with MIDAO between 1 January and 31 March each year. The report covers: updated beneficial ownership (BOIR refresh), current governance leadership or smart-contract address (where the operating agreement references contracts that may upgrade), community engagement and operational activities during the year, and financial activities at a summary level.[2] The report is the substantive compliance check on the entity’s continued eligibility for the DAO LLC form.
Renewal Fees and Supervision
MIDAO’s annual renewal runs USD 2,000 to 5,000 depending on services elected (registered office, virtual telephone, additional BOIR services).[1] The standard LLC and IBC annual fee is administered by IRI and is materially lower. There is no separate supervision fee, because there is no substantive regulator supervising DAO LLC operational activity beyond MIDAO’s DNFBP-level AML/CFT oversight.
Regulatory Inspections
MIDAO is the operational gateway for any RMI Banking Commission inquiry into a DAO LLC. The September 2023 AML/CFT Guidelines for Banks and Financial Service Providers establish the Commission’s expectations.[6] As of , the Commission has not announced a thematic inspection programme focused on DAO LLCs, but the APG 3rd Round MER findings make a 2026–2027 review cycle a reasonable planning assumption.[7]
Enforcement
Section 15 of the DAO Regulations 2024 grants the Registrar power to revoke a DAO LLC’s certificate of formation for non-compliance with the Regulations, including BOIR failures, non-payment of fees, or failure to maintain a registered agent.[2] The Banking Commission has parallel enforcement powers under the Banking Act 1987 for AML/CFT breaches.[6] The Proceeds of Crime Act criminalises laundering predicates, and the United Nations Sanctions (Implementation) Act 2020 carries criminal penalties for sanctions breaches that flow through RMI entities.
Banking
Banking is the operational reality the Marshall Islands DAO LLC structure does not solve. The RMI itself has only two banks and a fragile US correspondent banking relationship. RMI DAO LLCs therefore bank offshore, typically through US-licensed neobanks, European EMIs, Asian crypto-friendly banks, or specialist crypto institutions. Expect 6 to 12 weeks for the first account.[8]
The Bank of Marshall Islands’ US correspondent banking relationship has been precarious since at least the 2018 IMF Article IV consultation, which flagged the fragility of dollar correspondent access as a national-level systemic concern.[8] The typical banking architecture therefore places the operational account with a US-licensed neobank, a European EMI, an Asian crypto-specialist bank, or a multi-currency fintech platform that has the risk appetite for non-resident-domestic entities with DAO-style governance.
Documentation that institutional providers expect: apostilled corporate documents, beneficial ownership confirmation matching the BOIR, an AML/CFT policy and procedures pack tailored to the entity’s intended activities, a sanctions screening framework, and a clear answer to the question “how does this entity generate fiat throughput?” The last question is the one most DAO LLCs answer poorly, because protocol-level DAOs often have no fiat throughput, which makes them poor banking candidates regardless of structure quality.
Jagelski & Partners’ banking partner network covers 90 or more institutions across Europe, the Americas, the Middle East, and Asia, including providers with documented appetite for Marshall Islands DAO LLCs. Jagelski & Partners is paid by the institution, not by the client. We do not charge an onboarding fee. A licence without banking access is a certificate on the wall: learn about our Banking service →
US-licensed neobanks, European EMIs, Asian digital-asset specialists, and multi-currency platforms matched to DAO LLC governance and fiat-throughput profiles. The partner network maintains live account-opening routes in every jurisdiction Jagelski & Partners services, and banking feasibility is confirmed at the scoping stage, before any licence application is filed.
Explore Banking SolutionsFATF Status & International Standing
The Marshall Islands is not on the FATF grey list as of . The Asia/Pacific Group on Money Laundering adopted the country’s 3rd Round Mutual Evaluation Report in September 2024 and published it in November 2024; the report identifies the DAO sector and the non-resident-domestic-entity sector as priority risk areas.[7]
The Marshall Islands is a member of the APG, the FATF-style regional body for the Asia/Pacific region. The 3rd Round MER, adopted September 2024 and published November 2024, is the operative international assessment of the RMI’s AML/CFT framework as of .[7] Key MER findings: the RMI has “introduced generally comprehensive risk-based AML/CFT preventive measures for FIs and DNFBP”, but the DAO sector is a priority risk area not yet well understood by all relevant authorities, and MIDAO was only formally subject to AML/CFT requirements as a DNFBP at the end of the on-site visit in December 2023.[7]
The Marshall Islands was on the EU list of non-cooperative jurisdictions for tax purposes from to , and has remained off the EU blacklist since.[9] As of , the most prudent planning assumption is that the APG MER findings on DAO-sector and offshore-sector risk will produce another round of regulatory tightening in 2026 to 2027, not relaxation. The 2024 DAO Regulations are the first response; further regulations on BOIR scope, DNFBP supervision intensity, and possibly VASP licensing activation are reasonable forward expectations.
EU Market Access
A Marshall Islands DAO LLC does not confer EU passporting rights. MiCA contains no third-country equivalence regime; there is no mechanism for the European Commission to recognise a Marshall Islands DAO LLC as equivalent to an EU CASP. MiCA Article 61 permits third-country firms to serve EU clients only when the client initiates contact entirely on their own initiative.[13] ESMA’s Guidelines on Reverse Solicitation under MiCA (Ref: ESMA35-1872330276-2030, dated and applicable from ) interpret this restrictively: any form of EU-targeted marketing, EU-language website content, geo-targeted advertising, app store availability in EU member states, or use of EU-based influencers constitutes solicitation that voids the exemption. The exemption is designed for isolated contacts, not systematic EU market access. For a detailed analysis of what constitutes solicitation and the documentation requirements, see Reverse Solicitation Under MiCA →.
Advantages and Limitations
The Marshall Islands DAO LLC delivers the strongest sovereign legal wrapper for protocol governance and AI agent structures available in 2026. The structure is unsuitable for centralised exchanges, MiCA-passportable CASPs, or operators that need institutional banking on the entity’s own name from day one. The trade-offs are clean and well-defined.
- First-in-the-world DAO LLC statute. Sovereign recognition of the DAO as a legal person with limited liability for token-holder members.[4]
- Zero or 3% tax with no withholding. Non-profit DAO LLCs pay 0% corporate tax; for-profit DAO LLCs pay 3% GRT on earned revenue only.[4]
- KYC only above 25% governance threshold. Token holders below the threshold are not identified, materially more permissive than Wyoming DAO LLC under the Corporate Transparency Act.[4]
- Fast formation. Three to five working days for standard formation; 24 hours for TurboDAO express.[1]
- US dollar settlement without US legal nexus. Compact of Free Association uses USD as legal tender; entity itself is not under US federal jurisdiction.[10]
- No active VASP licensing regime. The dormant VASP definition in §102(ii) of the Banking Act makes VASP activity not legally operable from the RMI. Mitigation: Structure the DAO LLC to fall outside the VASP definition (no custody, exchange, or transfer for third parties). For operators requiring a VASP licence, redirect to BVI, another offshore VASP centre, or an EU MiCA jurisdiction.[2]
- No EU passporting. A Marshall Islands DAO LLC cannot serve EU clients on a systematic basis. Mitigation: Operators targeting EU clients can obtain a separate CASP authorisation in an EU member state (full market access via passporting) or, for isolated genuinely unsolicited contacts only, may fall within the narrow reverse solicitation exemption under MiCA Article 61.
- Banking is hard. Domestic banking is functionally unavailable; offshore banking takes 6 to 12 weeks for the first account. Mitigation: Begin banking applications in parallel with formation, target multiple institutions, and accept that an EMI account will likely precede a full bank account.[8]
- APG MER flagged DAO sector as priority risk area. The November 2024 MER signals likely future regulatory tightening. Mitigation: Treat the 2024 DAO Regulations as a baseline and plan for incremental BOIR scope and DNFBP supervision expansion in 2026 to 2027.[7]
- OFAC reach via COFA. RMI-incorporated entities have repeatedly been designated by OFAC; counterparties screen RMI entities accordingly. Mitigation: Build OFAC sanctions screening into the AML/CFT framework from day one; do not treat it as an optional layer.[11]
How Marshall Islands Compares
Three offshore peers are the closest comparators for the Marshall Islands. Vanuatu offers a VASP licensing regime under the Financial Dealers Licensing Act but no DAO statute. Comoros (Anjouan) is the lowest-cost VASP licensing pathway. Saint Kitts and Nevis is a Caribbean alternative with a developed corporate-services sector. Labuan sits one tier up as a regulated APAC alternative.
| Factor | Marshall Islands | Vanuatu | Comoros (Anjouan) | Saint Kitts and Nevis |
|---|---|---|---|---|
| Licence Type | DAO LLC, IBC, LLC. No active VASP licence. | VASP licence under FDLA | VASP licence under Anjouan Offshore Finance Authority | VASP registration under the Virtual Asset Act |
| Regulator | Registrar of Corporations; RMI Banking Commission | Vanuatu Financial Services Commission | Anjouan Offshore Finance Authority | FSRC Saint Kitts and Nevis |
| Timeline | 3–5 working days (DAO LLC) | 3–6 months | 1–2 months | 4–9 months |
| Min. Capital | No fixed minimum | USD 50,000–500,000 by class | None published | No fixed floor; case-by-case FSRC assessment |
| Total Year 1 Cost | USD 11,500–25,000 | USD 30,000–60,000 | USD 15,000–30,000 | USD 89,000–126,000 |
| Corporate Tax | 0% non-profit DAO LLC / 3% GRT for-profit | 0% on foreign-source income | 0% on foreign-source income | 0% on foreign-source income |
| Local Presence | Registered agent only | Registered office and resident director | Registered agent | Registered agent |
| EU Passporting | No | No | No | No |
| FATF Status | Not greylisted; APG MER Nov 2024 | Not greylisted as of May 2026 | Not greylisted | Not greylisted |
| Best For | Protocol governance, AI agent legal persons, non-profit DAO treasuries | VASP-licensed crypto activity at moderate cost | Lowest-cost VASP licensing | Caribbean entity with corporate-services infrastructure |
Compare every crypto jurisdiction side by side →
The Marshall Islands is alone among offshore peers in offering a statutory DAO LLC structure with limited liability for token-holder members. Vanuatu and Comoros are licensing jurisdictions; the Marshall Islands is a structuring jurisdiction. Operators who want a licence choose Vanuatu (more credibility) or Comoros (lower cost). Operators who want a sovereign legal person for a DAO or AI agent choose the Marshall Islands. The choice is not interchangeable.
Cross-tier reference: Labuan (Malaysia) sits at the next tier up, offering a Securities Commission-regulated digital asset framework with substantive supervision. Operators choosing between the Marshall Islands and Labuan are typically deciding between a permissive structuring regime and a regulated APAC base. The choice depends on whether the operational model needs supervisory credibility (Labuan) or governance flexibility (Marshall Islands).
When the Marshall Islands Is the Right Choice
Choose Marshall Islands if:
- The project is a DeFi protocol that needs a legal wrapper delivering limited liability without identifying every token holder.
- The governance is, or is becoming, on-chain and algorithmic, and the operating agreement can reference smart contracts directly.
- The structure is a non-profit treasury wrapper for protocol governance or grant distribution.
- The project needs US dollar settlement without bringing the entity under US federal jurisdiction.
- The project is an AI agent or autonomous-system operator seeking a sovereign legal person to hold property, contract, and operate accounts.
Consider alternatives if:
- The project is a centralised exchange or custodial wallet provider needing a recognised VASP or CASP licence: redirect to BVI, another offshore VASP centre, Vanuatu, or an EU MiCA jurisdiction.
- The project needs EU market access by passport: redirect to Estonia, Lithuania, Cyprus, or Malta.
- The project’s beneficial owners are predominantly US persons whose CFC, PFIC, or GILTI exposure would dominate any RMI tax benefit: focus instead on Delaware or Wyoming for a domestic US structure.
- The project needs institutional banking on the entity’s own name within 30 days of formation: no offshore jurisdiction will deliver that timeline; consider an EU MiCA jurisdiction with pre-existing banking relationships.
Not sure which column is you? Ask Emma. She compares these jurisdictions in seconds, in your language.
Common Mistakes in Marshall Islands Applications
The most common Marshall Islands DAO LLC failures stem from misreading the dormant VASP definition, treating MIDAO as administrative rather than as a substantive AML/CFT gate, or underestimating the US tax overlay on US-person beneficial owners. The 2024 DAO Regulations and the November 2024 APG MER reset several baselines that pre-2024 templates do not address.
- Designing the structure as a VASP without realising the licence is dormant. Operators sometimes structure a centralised exchange or custodial wallet provider as a Marshall Islands DAO LLC, assuming the §102(ii) VASP definition is supported by a live licensing regime. What MIDAO’s documentation does not address is how to design around the definition, so the entity must be structured to fall outside VASP activity or redirected to a licensing jurisdiction.[2]
- Treating MIDAO as discretionary or administrative. MIDAO is the sole statutory registered agent for DAO LLCs under the DAO Act 2022 and a designated non-financial business and profession under the 2024 DAO Regulations and the September 2023 AML/CFT Guidelines.[2][6] Operators sometimes attempt to apply through a different agent or assume the intake is a back-office check. The MIDAO intake is the primary AML/CFT gate.
- Porting a Wyoming DAO LLC operating agreement to the Marshall Islands. Wyoming and Marshall Islands DAO LLCs are statutory cousins, not twins. The Marshall Islands KYC threshold is 25% of governance rights; Wyoming is subject to the US Corporate Transparency Act. The Marshall Islands BOIR has different content and update cadence than Wyoming filings. Templates require Marshall Islands-specific redrafting, not search-and-replace.
- Ignoring the US tax overlay for US-person beneficial owners. The 0% non-profit or 3% for-profit GRT looks attractive on the RMI side, but US-person members face CFC, PFIC, GILTI, and Subpart F attribution. Operators sometimes proceed without a US tax memo and discover after Year 1 that the effective US tax rate equals or exceeds the projected RMI savings, making the structure governance-driven only.[10]
- Assuming reverse solicitation is a viable EU market strategy. ESMA’s February 2025 guidelines under MiCA Article 61 interpret reverse solicitation restrictively.[13] Marshall Islands DAO LLCs with EU-language websites, EU-targeted marketing, geo-untargeted app store presence, or EU-based influencer relationships do not preserve the exemption. Experienced applicants treat reverse solicitation as a defensive shield for isolated contacts, not as a market-access strategy.
- Underbudgeting compliance documentation and banking. The MIDAO formation fee is USD 9,500. The all-in Year 1 cost including compliance documentation and banking facilitation is USD 11,500 to 25,000, and banking adds 6 to 12 weeks of timeline on top of the 3 to 5 day formation. Operators budgeting against the MIDAO sticker price alone discover the gap during Stage 5 of the process and lose 4 to 8 weeks reworking compliance documentation that should have been drafted in parallel.
Frequently Asked Questions
No, not under current law. Section 102(ii) of the Banking Act 1987 defines a VASP and conditions VASP activity on a licence from the Banking Commissioner, but no VASP licences are being issued as of . MIDAO’s published documentation is explicit that operating a VASP, defined to include custody, exchange, and transfer of virtual assets for or on behalf of others, is not legally available from the Marshall Islands under current law. Operators who need to run a centralised exchange should redirect to BVI, Vanuatu, or an EU MiCA jurisdiction. The Marshall Islands DAO LLC is a structuring jurisdiction, not a licensing jurisdiction.
Any natural or legal person can be a member. Membership is typically held by token holders, with the smart contract serving as the operating agreement for algorithmically managed DAO LLCs. For non-profit DAO LLCs, membership confers governance rights but not economic ownership. For for-profit DAO LLCs, membership confers governance and economic rights. KYC is required only for beneficial owners controlling 25% or more of governance rights, voting rights, or distribution rights; token holders below the 25% threshold are not identified. This is materially more permissive than the Wyoming DAO LLC, which is subject to the US Corporate Transparency Act.
As a wrapper, not a market. The DAO Act provides a legal wrapper and defines a class of digital securities, and the jurisdiction is used as a holding wrapper for tokenised vehicles, but there is no domestic issuance or trading market; a token that is a security still answers to securities law. Where the vehicle is a fund, route via fund licensing.
Standard formation through MIDAO takes 3 to 5 working days once the BOIR and KYC pack are complete. TurboDAO compresses the registry filing to 24 hours at a higher fee. The upstream work, KYC collection, operating agreement drafting, and the MIDAO AML risk assessment, typically takes 2 to 5 weeks. End-to-end operational readiness, including banking, takes 10 to 20 weeks because institutional banking for an RMI DAO LLC takes 6 to 12 weeks for the first account approval. Banking, not formation, is the rate-limiting step.
For each beneficial owner controlling 25% or more of governance rights: certified passport copy (non-expired), residential address proof within 3 months (utility bill or bank statement), and source-of-wealth documentation where the AML risk profile warrants it. For the entity: the proposed operating agreement (or governance smart-contract addresses for algorithmically managed DAO LLCs), the FIBL application, and a description of intended activities calibrated against the dormant VASP definition. MIDAO’s intake covers all of these documents in the initial onboarding call.
MIDAO’s standard formation package is USD 9,500 and includes the certificate of formation, FIBL, first-year registered agent, and initial BOIR filing. The all-in Year 1 cost, including legal advisory, compliance documentation drafting, and banking facilitation, is USD 11,500 to 25,000. Annual ongoing cost from Year 2 is USD 5,000 to 12,500, exclusive of the 3% Gross Revenue Tax for for-profit DAO LLCs. TurboDAO 24-hour express is USD 10,000 and includes a virtual office and telephone for the first year. There is no minimum capital requirement.
No. The Marshall Islands does not impose a minimum capital requirement for DAO LLCs, standard LLCs, or IBCs. This is materially different from licensing jurisdictions like Vanuatu (USD 50,000 to 500,000 depending on VASP class) or EU MiCA jurisdictions (EUR 50,000 to 150,000 by CASP service type). The absence of minimum capital is one reason the Marshall Islands is well-suited to early-stage protocol structures with no treasury at formation; the DAO LLC can be incorporated before any token launch and grow into its treasury organically.
No, not as of . The Marshall Islands is a member of the Asia/Pacific Group on Money Laundering, and the APG’s 3rd Round Mutual Evaluation Report was adopted in September 2024 and published in November 2024. The report identifies the DAO sector and the non-resident-domestic-entity sector as priority risk areas not yet well understood by all relevant authorities, but it does not place the country on FATF or APG enhanced monitoring. The 2024 DAO Regulations and the September 2023 AML/CFT Guidelines respond directly to the MER findings.
A Marshall Islands DAO LLC does not grant EU market access or passporting rights. MiCA Article 61 permits third-country firms to serve EU clients only when the client initiates contact entirely on their own initiative, but ESMA’s guidelines (dated , applicable from ) interpret this exemption very narrowly. Any form of EU-targeted marketing, EU-language website content, geo-targeted advertising, or use of EU-based influencers voids the exemption. Operators seeking systematic EU market access should obtain a separate CASP authorisation in an EU member state.
Not in the Marshall Islands. The RMI has only two domestic banks and a fragile US correspondent banking relationship, flagged in the 2018 IMF Article IV consultation as a systemic concern. RMI DAO LLCs typically bank through US-licensed neobanks, European EMIs licensed in jurisdictions such as Lithuania or Latvia, Asian crypto-friendly banks in Singapore or Hong Kong, and specialist crypto institutions. First account approval takes 6 to 12 weeks. Jagelski & Partners’ banking partner network includes 90 or more institutions with documented appetite for Marshall Islands DAO LLCs.
Three core obligations. First, an annual report filed with MIDAO between 1 January and 31 March covering beneficial ownership refresh, governance leadership or smart-contract address, operational activities, and financial activities. Second, a continuous BOIR maintenance obligation with 30-day updates for triggering changes (under the 2024 DAO Regulations). Third, ongoing AML/CFT compliance administered through MIDAO under its DNFBP designation, including sanctions screening, transaction monitoring where applicable, and incident reporting to the Domestic Financial Intelligence Unit. Section 15 of the DAO Regulations 2024 grants the Registrar power to revoke the certificate of formation for non-compliance.
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References
Show all references
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- Asia/Pacific Group on Money Laundering, Anti-Money Laundering and Counter-Terrorist Financing Measures: Republic of the Marshall Islands, 3rd Round Mutual Evaluation Report (November 2024), fatf-gafi.org, accessed .
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- International Registries Inc., Marshall Islands Economic Substance Regulations 2018 (as amended through August 2019), register-iri.com, accessed .
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- CoinDesk, Marshall Islands Further Strengthens Law That Made DAOs Legal Entities, coindesk.com, accessed .