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Government in charge.
FCB executes.

Every applicant clears a three-tier statutory gate. FCB operates under a structured Operating Agreement with defined performance obligations. Montserrat retains sovereign authority — at every tier, at every moment.

Three-Tier Approval Gate

Every applicant. Every renewal.
No exceptions.

Tier 1
DRO Review
Digital Residency Office · § 11
Tier 2
FIU Screening
Financial Intelligence Unit · § 13
Tier 3
Minister Approval
Final Statutory Authority · § 12

No permit issues without all three. DRO recommends · FIU clears · Minister signs.

Layered Controls

Compliance stack · Sovereign levers.

Two complementary systems. The compliance stack filters bad actors out; the sovereign-lever stack keeps Montserrat in full control of the programme itself.

Compliance Stack

Layered AML/CFT architecture

  • KYC
    Biometric and document verification at intake by FCB — liveness, sanctions, PEP, adverse media.
  • FIU
    Independent screening on every application — government authority outside FCB's control.
  • Min
    Minister's final approval — no permit issued without sign-off (§ 12).
  • Mon
    Re-verification at each renewal (3-year initial + 5-year terms for MID); ongoing monitoring throughout.
  • § 17
    Permanent blacklist for rejected or revoked applicants, shared across regulators.
  • Audit
    Independent compliance audit at Year 1 and annually thereafter.
Sovereign Levers

Government retains full oversight authority

  • § 14
    Operating Agreement defines scope, obligations, and accountability for both parties.
  • § 17
    Bill, Regulations, Blacklist are instruments only Government controls.
  • § 8
    No right of entry, abode, employment, or voting — BOT-compatible.
  • Aud
    Published revenue reports — financial transparency as a default.
  • Susp
    Minister can suspend issuance programme-wide at any time.
  • Revk
    DRO can revoke individual permits with confirmation by Minister.
Organisational Structure

Who does what, under what authority.

Cabinet
Policy authority. Endorses integrated programme scope. Authorises Operating Agreement negotiation. Reviews the Year-2 stablecoin extension as a separate decision. Signs Commencement Order (§ 21).
Minister
Programme-level authority. Final approval on every permit (§ 12). Issues Regulations (§ 20). May suspend issuance programme-wide. Terminates or amends Operating Agreement.
DRO
Administrative authority. Digital Residency Office under § 11 — reviews applications, manages renewal, coordinates with FIU / FSC, initiates revocation. Headed by a DRO Director reporting to the Minister.
FIU
Compliance authority. Financial Intelligence Unit — independent statutory screening on every application (§ 13). Outcomes binding on issuing authority.
FSC
Regulatory coordination. Financial Services Commission — receives information under AML/CFT Code 2024. Coordinates on adjacent services if Cabinet activates § 5(1)(b).
Operator · FCB
Delivery authority. Operates platform, onboarding, and compliance infrastructure under § 14 Operating Agreement and § 15 Operator Standards. No discretion over permit issuance. Accountable under defined performance obligations.
The Sovereign Constant

Four zeros, by statute.

Sovereignty-additive by design — no change to population, no immigration consequence, no grant of citizenship, no shift in tax residency.

0
Population Impact
0
Immigration Effect
0
Citizenship Grant
0
Tax Residency Shift
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