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what is the mandatory exchange

What Is the Mandatory Exchange in the Maldives: 28‑day Rule, Who Must Comply and Penalties

By Global Law Experts
– posted 1 hour ago

The mandatory exchange is a statutory obligation under the Foreign Currency Act (Law No. 32/2024) that requires certain businesses operating in the Maldives to convert a prescribed portion of their realised foreign-currency receipts into Maldivian Rufiyaa (MVR) within a fixed deadline. Tourism operators, licensed money-exchange businesses, and other entities receiving foreign-currency sales proceeds must complete the exchange by the 28th day of the third month following the month in which the revenue was realised. The requirement is implemented through MMA Foreign Currency Regulation 2024/R‑91, issued by the Maldives Monetary Authority (MMA), and carries administrative fines and licence sanctions for non-compliance.

This guide sets out who must comply, how the 28‑day timeline works in practice, and the penalties that apply when deadlines are missed.

What Is the Mandatory Exchange?, Definition and Quick-Action Checklist

At its core, the mandatory exchange answers a single compliance question: how quickly must a Maldives-based business convert its foreign-currency income into MVR, and through which channel? The Foreign Currency Act 32/2024 creates a framework for managing foreign currency transactions in the Maldives and regulating currency exchange practices. MMA Regulation 2024/R‑91 then supplies the operational rules, portal filing procedures, reporting templates, and the per-tourist baseline amounts that determine how much must be exchanged.

Before reading the detailed sections below, compliance officers should note three immediate action items:

  • Identify whether your entity falls within scope. Tourism businesses, licensed money-exchange operators, and entities receiving realised foreign-currency sales proceeds are the primary obliged parties.
  • Map your deadlines. Foreign currency must be exchanged by the 28th day of the third month following the month in which it was received.
  • Register on the MMA Foreign Exchange Portal. All filings and conversion reports are submitted through the MMA FX Portal; entities that have not yet registered should do so without delay.

Background, The Foreign Currency Act and MMA Regulation

Legislative History and Ratification

The Foreign Currency Bill was passed by Parliament on 12 December 2024 during the 60th sitting of the third session. The President ratified the bill on 14 December 2024, bringing the Foreign Currency Act (Law No. 32/2024) into force. According to the Presidency press release confirming ratification, the Act aims to establish clear guidelines for managing foreign currency transactions in the Maldives and to regulate currency exchange practices across all sectors.

The Maldives Monetary Authority, the country’s central regulatory authority for monetary policy and financial-sector supervision, subsequently issued MMA Foreign Currency Regulation 2024/R‑91 to provide detailed operational rules. These rules cover registration requirements, filing procedures through the MMA foreign exchange portal, licensing tiers for money-exchange operators, and the mandatory exchange timeline that every affected entity must follow.

Date Instrument Key Change
12 December 2024 Foreign Currency Bill, Parliament Bill passed in 60th sitting of the third parliamentary session
14 December 2024 Presidential ratification Foreign Currency Act (Law No. 32/2024) enters force
Late December 2024 MMA Foreign Currency Regulation 2024/R‑91 Implementing regulation with operational details, portal rules, and licence requirements published

Key Statutory Definitions

Two definitions are essential to understanding what is the mandatory exchange obligation:

  • Realised sales proceeds. Foreign currency actually received by a business from the sale of goods or services, not merely invoiced or accrued. The exchange clock starts from the month in which these proceeds are realised.
  • Designated foreign currency account. A dedicated account, maintained at a licensed commercial bank, into which a business must deposit its foreign-currency receipts before completing the mandatory exchange into MVR.

The Act reiterates a longstanding requirement that all domestic transactions in the Maldives must be conducted in MVR. While this principle existed under earlier Monetary Regulation, the Foreign Currency Act Maldives now formalises enforcement and adds a clear penalty regime.

Who Must Comply With the Mandatory Exchange, Sectors and Entity Types

The mandatory exchange obligation applies across several distinct sectors. Industry observers expect the MMA to continue refining sector-specific guidance as implementation matures, but the current framework identifies the following obliged parties:

  • Tourism operators. Resorts, guesthouses, safari vessels, tour operators, and dive centres that receive foreign-currency payments from tourists.
  • Licensed money-exchange operators. Entities holding an MMA money exchange licence that buy and sell foreign currency as a commercial activity.
  • Commercial banks. Banks accepting foreign-currency deposits and facilitating mandatory-exchange transactions on behalf of customers.
  • Tourist-facing retail and e-commerce sellers. Businesses that accept foreign-currency payments for goods or services delivered in the Maldives.
  • Remittance and payment-service providers. Licensed entities processing cross-border payments or remittances.

Exemptions and Thresholds

Individual tourists exchanging cash at bank branches or licensed exchange counters for personal use are not subject to the mandatory exchange reporting obligation, they are end-users of the system, not obliged entities. Small incidental cash receipts below any de minimis threshold specified in MMA guidance may also be excluded, though businesses should confirm the latest position directly with the Maldives Monetary Authority.

Entity Type Mandatory Exchange Obligation Deadline / Notes
Tourism operators (resorts, guesthouses) Exchange realised foreign-currency receipts to MVR or deposit to designated FX account and lodge via FX Portal By the 28th day of the third month following realisation; see calendar examples below
Licensed money-exchange operators Hold licence; convert or deposit surplus subject to regulation; submit monthly reports Licensing deposit (reported USD 50,000) and portal reporting; MMA registration required
Commercial banks Accept mandatory exchanges and provide FX portal/banking interface; report aggregated data to MMA Banks to reconcile customer receipts and provide reporting functions on an ongoing basis
Tourist-facing retail / e-commerce Transfer foreign-currency receipts to designated account and exchange within statutory deadline Same 28‑day/third-month rule applies
Remittance / payment-service providers Comply with foreign-currency reporting and mandatory exchange as directed by MMA licence conditions Licence-specific conditions apply; verify directly with MMA

Can Anyone Open a Currency Exchange?

No. Operating a money-exchange business in the Maldives requires a licence from the MMA. Applicants must meet capital, deposit, and KYC requirements before receiving approval. The licensing process is detailed in the section on money exchange licence Maldives requirements below.

The 28‑Day Rule Explained, Step-by-Step With Calendar Examples

The centrepiece of the mandatory exchange framework is the statutory deadline: the foreign currency required to be exchanged into MVR must be exchanged by the 28th day of the third month following the month in which it was received. Understanding how to calculate this deadline is critical for every compliance officer.

How to Calculate the Mandatory Exchange Deadline

  1. Identify the realisation month. Determine the calendar month in which the foreign-currency revenue was actually received (not invoiced).
  2. Count forward three months. Starting from the realisation month, count three full calendar months forward.
  3. Mark the 28th day. The mandatory exchange must be completed on or before the 28th day of that third month.
  4. If the 28th falls on a non-business day, best practice is to complete the exchange on the preceding business day to avoid any risk of a late filing.

Calendar Examples, Quick Reference

Revenue Realised Third Month Following Mandatory Exchange Deadline
January 2026 (any day) April 2026 28 April 2026
March 2026 (any day) June 2026 28 June 2026
October 2026 (any day) January 2027 28 January 2027
November 2026 (any day) February 2027 28 February 2027

Note that the deadline is always the 28th, not the last day of the month. This avoids ambiguity in months with 30 or 31 days, and provides a uniform compliance calendar across the year.

The Per-Tourist Baseline

Industry observers note that regulatory clarifications issued in the 2025–2026 period have introduced a per-tourist baseline of USD 500 as a reference amount for calculating mandatory exchange volumes in the tourism sector. The likely practical effect is that a resort hosting 200 tourists in a given month would need to exchange at least USD 100,000 into MVR by the 28th day of the third month following. Businesses should verify the current baseline directly with MMA guidance, as this figure may be updated.

How to Comply With the Mandatory Exchange Operationally

Meeting the 28‑day deadline requires a structured internal process. The following steps apply to most obliged entities:

  1. Aggregate monthly realised foreign-currency receipts. At month-end, compile all foreign-currency income received during the period. Separate receipts by currency (USD, EUR, GBP, etc.) where the regulation requires currency-specific reporting.
  2. Determine the amount subject to mandatory exchange. Apply any applicable thresholds or per-tourist baselines to calculate the net amount that must be converted. Retain supporting documentation (invoices, guest folios, payment confirmations).
  3. Lodge conversion via the MMA Foreign Exchange Portal or exchange at a licensed commercial bank. The MMA FX Portal is the primary filing and reporting channel. Alternatively, entities can convert currency directly through their commercial bank’s mandatory exchange service.
  4. Reconcile and retain records. Maintain exchange confirmations, portal submission receipts, and bank statements for a minimum retention period as specified in the regulation. Ensure records are available for MMA inspection.

MMA Foreign Exchange Portal, How to Register and File

The MMA foreign exchange portal is the centralised digital platform through which obliged entities submit their mandatory exchange filings. The registration and filing process follows these steps:

  • Registration. Apply for portal access through the MMA website. Submit entity registration documents (business registration certificate, MMA licence or registration confirmation, authorised signatory details).
  • KYC documentation. Upload know-your-customer documents for the entity and its beneficial owners, including identification documents and proof of address.
  • Monthly filing. For each reporting month, enter the total foreign-currency receipts, the amount exchanged, the exchange rate applied, and the bank through which conversion was completed.
  • Attachments. Upload supporting invoices, bank exchange confirmations, and any other documents required by the portal template.
  • Confirmation. Receive a portal submission receipt and retain it as proof of timely compliance.

Bank Interface, the BML Mandatory Exchange Feature

Bank of Maldives (BML) has introduced a dedicated Mandatory Exchange feature on its Internet Banking platform. This feature, currently available on the web browser version of Internet Banking, allows eligible businesses to exchange foreign currency online and provides a dedicated activity report to monitor mandatory exchange transactions. Other licensed commercial banks in the Maldives are expected to offer comparable functionality. This BML mandatory exchange module provides a practical alternative to direct portal filing for entities that prefer to complete the conversion through their primary banking relationship.

What Is the Process for Exchanging Foreign Currency in Cash at Branches?

Entities that receive foreign currency in physical cash, common for guesthouses and smaller tourism operators, may present the cash at a licensed commercial bank branch. The bank will process the conversion at the applicable exchange rate, issue a receipt, and report the transaction. Entities should ensure they retain the receipt and upload it to the MMA foreign exchange portal as part of their monthly filing.

Licensing and Registration, Money Exchange Licence Requirements in the Maldives

Any entity wishing to operate as a money-exchange business must obtain an MMA money exchange licence before commencing operations. The registration rules published under the Foreign Currency Act establish the framework of principles and procedures governing licensing.

Licence Tiers and Deposit Requirements

The regulation establishes a tiered licensing structure. While the precise tier definitions should be confirmed with MMA, the general framework distinguishes between larger-volume operators (often serving airports, resort areas, and urban centres) and smaller neighbourhood or island-level operators. Market sources report that entities engaged in money exchange must lodge a mandatory deposit of USD 50,000 with the MMA as part of their licence application. This deposit serves as a security against regulatory obligations and is held for the duration of the licence.

Licence Element Requirement Typical Timeline
Business registration Valid Maldives company registration Pre-requisite (before application)
Capital / deposit USD 50,000 mandatory deposit (reported) Lodged with MMA at application
KYC / due diligence Beneficial ownership disclosure, AML/CFT compliance documentation Submitted with application
Premises inspection Physical premises meeting MMA security and access standards MMA inspection after submission
MMA approval Licence issued upon satisfactory review Processing time varies; allow several weeks

How to Apply, Documents Checklist

  • Company registration certificate (current and valid)
  • Board resolution or authorisation confirming application for money-exchange licence
  • Beneficial ownership declaration for all shareholders holding 10% or more
  • AML/CFT policy and procedures manual
  • Proof of USD 50,000 deposit (bank confirmation or escrow receipt)
  • Premises details (address, floor plan, security arrangements)
  • Identification documents for directors, shareholders, and authorised signatories
  • Business plan including projected transaction volumes and target customer segments

Penalties, Enforcement and Remediation for the Mandatory Exchange

The Foreign Currency Act 32/2024 and MMA Regulation 2024/R‑91 establish a graduated enforcement framework. Penalties are calibrated to the nature and severity of the breach, with more serious sanctions reserved for wilful or repeated non-compliance.

Breach Likely Penalty Remediation / Defence
Late mandatory exchange (past 28th-day deadline) Administrative fine; amount determined by MMA based on value and delay period Complete exchange immediately; file late submission with explanation via FX Portal
Failure to register on MMA FX Portal Warning followed by fine; potential suspension of business activities Register without delay; provide evidence of prior compliance efforts
Operating money exchange without licence Licence revocation (if interim); criminal referral for wilful evasion; significant fines Cease operations; apply for proper licence; engage legal counsel
Incomplete or inaccurate portal filings Administrative fine; requirement to re-file and submit corrected documentation Voluntary correction and re-submission; implement internal review procedures
Repeated non-compliance Licence suspension or revocation; enhanced MMA monitoring; potential criminal prosecution Full compliance audit; appointment of compliance officer; voluntary disclosure to MMA

Entities that identify a compliance failure should consider voluntary disclosure to the MMA. Early indications suggest that the regulator views proactive remediation more favourably than failures discovered during inspection. Businesses facing enforcement action should seek specialist legal advice promptly.

Worked Examples and Compliance Checklist

Example 1, Tourism Resort

A resort on a private island receives USD 300,000 in guest payments during March 2026. Under the mandatory exchange rules, the resort must exchange this amount (or the applicable portion based on the per-tourist baseline) into MVR by 28 June 2026. The finance team aggregates March receipts by 5 April, lodges the conversion through their BML mandatory exchange Internet Banking module on 15 June, and uploads the bank confirmation to the MMA FX Portal by 20 June, well within the deadline.

Example 2, Money-Exchange Operator Missing Deadline

A licensed money-exchange operator in Malé fails to exchange its May 2026 surplus foreign currency by the 28 August 2026 deadline. The MMA identifies the breach during a routine portal audit in September. The operator receives an administrative fine and is required to complete the exchange immediately, file a late-submission report, and implement a documented compliance calendar to prevent recurrence.

Compliance Checklist, 10 Items Before the 28th-Day Deadline

  1. Confirm the entity is registered on the MMA Foreign Exchange Portal
  2. Aggregate all foreign-currency receipts for the relevant realisation month
  3. Apply the per-tourist baseline (if tourism sector) to calculate the mandatory exchange amount
  4. Verify the correct deadline date (28th day of the third month following realisation)
  5. Deposit foreign currency into the designated foreign currency account
  6. Initiate the exchange through the MMA FX Portal or commercial bank interface
  7. Obtain and save the bank exchange confirmation or portal submission receipt
  8. Upload all supporting documents (invoices, guest folios, KYC records) to the portal
  9. Reconcile exchange records against internal accounting entries
  10. File the monthly mandatory exchange report and retain records for the minimum retention period

Conclusion, Staying Ahead of Mandatory Exchange Requirements in the Maldives

The mandatory exchange framework under the Foreign Currency Act 32/2024 represents a significant regulatory shift for businesses operating in the Maldives. The 28‑day deadline, sector-specific obligations, and MMA portal filing requirements all demand structured internal processes and ongoing compliance monitoring. Entities that have not yet registered on the MMA foreign exchange portal or mapped their exchange deadlines should take immediate action. Given the pace of regulatory clarification, including evolving per-tourist baselines and licensing requirements, businesses benefit from engaging experienced banking and finance practitioners who can interpret MMA guidance and support licensing applications.

Last updated: 25 June 2026. Readers should verify all MMA portal URLs, deposit amounts, and regulatory thresholds directly with the Maldives Monetary Authority before acting on this guide.

Need Legal Advice?

This article was produced by Global Law Experts. For specialist advice on this topic, contact Premier Chambers at Premier Chambers, a member of the Global Law Experts network.

Sources

  1. Maldives Monetary Authority, Foreign Currency Act (English PDF)
  2. Presidency of the Maldives, The President Ratifies the Foreign Currency Bill
  3. Bank of Maldives, Mandatory Exchange
  4. Crowe Maldives, Introduction of the Foreign Currency Act in the Maldives
  5. QVL Advisory, New Foreign Currency Act in the Maldives: A Guide for Businesses
  6. CTL Strategies, Overview of the Foreign Currency Act
  7. CorporateMaldives, MMA Tightens Currency Exchange Rules
  8. Premier Chambers, Registration Rules under the Foreign Exchange Act

FAQs

What is the mandatory exchange in the Maldives?
The mandatory exchange is a statutory requirement under the Foreign Currency Act (Law No. 32/2024) and MMA Regulation 2024/R‑91. It requires certain businesses to convert their realised foreign-currency receipts into MVR within a prescribed deadline, specifically, by the 28th day of the third month following realisation.
Tourism businesses (resorts, guesthouses, tour operators), licensed money-exchange operators, commercial banks, tourist-facing retail and e-commerce sellers, and remittance or payment-service providers are the primary obliged entities.
The foreign currency must be exchanged by the 28th day of the third month following the month in which the revenue was realised. For example, revenue received in January must be exchanged by 28 April.
No. Operating a money-exchange business requires an MMA money exchange licence, which involves meeting capital requirements, lodging a mandatory deposit (reported at USD 50,000), and satisfying KYC and AML/CFT due diligence standards.
Register on the MMA FX Portal through the MMA website, upload KYC documentation, and submit monthly filings that detail total foreign-currency receipts, amounts exchanged, exchange rates, and supporting documents. A step-by-step walkthrough is provided in the operational compliance section above.
Penalties range from administrative fines for late exchange or incomplete filings, to licence suspension or revocation for repeated or wilful breaches. In serious cases, criminal prosecution may apply.
The USD 500 per-tourist figure has been reported as a baseline clarification in 2025–2026 regulatory guidance. Businesses should verify the current applicable amount directly with the Maldives Monetary Authority, as this figure may be subject to revision.
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What Is the Mandatory Exchange in the Maldives: 28‑day Rule, Who Must Comply and Penalties

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