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Compact of Free Association

The Compacts of Free Association (COFA) are bilateral treaties between the United States and the sovereign Pacific island nations of the Federated States of Micronesia (FSM), the Republic of the Marshall Islands (RMI), and the Republic of Palau, establishing a relationship of free association whereby these nations retain full internal self-governance while receiving substantial U.S. economic assistance, complete defense responsibilities assumed by the U.S., and certain privileges for their citizens in the United States, in exchange for U.S. strategic denial rights over their territories to prevent military basing by adversarial powers.^[1]^[2]^[3] Originating from the post-World War II administration of the Trust Territory of the Pacific Islands under U.S. trusteeship from the United Nations, the compacts emerged as the preferred path for FSM, RMI, and Palau following negotiations in the 1970s and 1980s, allowing independence from trusteeship while securing U.S. support amid Cold War strategic concerns in the Pacific.^[2]^[1] Initial agreements were signed between 1982 and 1986, entering into force by 1994 for Palau, with provisions for periodic financial grants totaling billions of dollars over decades to fund infrastructure, health, and education in these resource-scarce economies.^[2]^[1] Key provisions include U.S. authority for mutual security, encompassing active defense against armed attack and exclusive U.S. operational control over defense matters, alongside the associated states' commitment not to grant similar basing rights to other nations, which has maintained U.S. strategic preeminence in critical maritime regions.^[3]^[4] Citizens of the associated states enjoy visa-free entry to the U.S. for residence and employment, with access to federal services like education and disaster relief, though recent amendments have adjusted eligibility for certain welfare programs amid fiscal debates in Congress.^[5]^[6] The compacts have been renewed multiple times, with FSM and RMI agreements extended for 20 years in 2023-2024 providing over $7 billion in combined funding, and Palau's similarly updated, underscoring their enduring role in U.S. Indo-Pacific strategy against emerging competitors like China, despite criticisms over aid dependency and uneven development outcomes in the associated states.^[4]^[7]^[1]

Historical Background

Post-World War II Origins

Following Japan's defeat in World War II, the United States seized control of the Micronesian islands in the Caroline, Marshall, and Mariana archipelagos (excluding Guam, which remained a U.S. territory) during intense Pacific campaigns from 1944 onward.^[8] These islands had been under Japanese administration as Class C mandates from the League of Nations since 1919. To legitimize its post-war administration amid decolonization pressures, the U.S. pursued a United Nations trusteeship rather than outright annexation.^[9] On April 2, 1947, the UN Security Council approved Trusteeship Agreement No. 21, designating the area as a strategic trusteeship administered solely by the United States, effective July 18, 1947.^[10] This established the Trust Territory of the Pacific Islands (TTPI), encompassing over 2,000 islands across approximately 3 million square miles of ocean, with a population of around 100,000 in 1947.^[11] The U.S. Navy provided initial military governance starting in late 1944, transitioning to a civilian High Commissioner in 1951 under the Department of the Interior.^[11] The trusteeship's stated goals, per Article 76 of the UN Charter, included fostering self-government, economic advancement, and human rights protection, though implementation prioritized U.S. security objectives.^[9] U.S. strategic imperatives, heightened by emerging Cold War rivalries with the Soviet Union, underscored the TTPI's role in denying adversaries access to key Pacific locales for military basing and surveillance.^[12] This included establishing installations like those on Kwajalein Atoll in the Marshall Islands for missile testing, initiated in 1946.^[8] The administration's dual focus on development aid—such as infrastructure and education—and military utility created tensions with local aspirations for autonomy, setting the stage for later negotiations toward free association agreements that balanced U.S. defense needs with Micronesian sovereignty.^[12] By the 1960s, Micronesian political bodies like the Congress of Micronesia began advocating for revised status options, evolving the trusteeship framework into the Compacts of Free Association.^[13]

Negotiations and Path to Independence

Following the establishment of the Trust Territory of the Pacific Islands (TTPI) in 1947 under United Nations trusteeship administered by the United States, Micronesian leaders increasingly sought greater autonomy and self-determination by the late 1960s.^[13] The Congress of Micronesia, formed in 1965 as the legislative body for the TTPI, passed resolutions in 1969 calling for negotiations on future political status, emphasizing options such as independence, free association, or integration with the U.S.^[14] In response, the U.S. initiated formal status talks in 1970, establishing joint committees to explore pathways to self-government while addressing U.S. strategic interests in the region, including defense and denial of influence to adversarial powers during the Cold War.^[15] By 1975, the Northern Mariana Islands opted for a separate commonwealth status through the Covenant to Establish a Commonwealth, approved via plebiscite and entering into force in 1978, diverging from the rest of the TTPI.^[16] The remaining districts—Yap, Truk, Ponape, and Kosrae (later Federated States of Micronesia or FSM), the Marshall Islands, and Palau—pursued constitutions and separate negotiations.^[12] In 1979, the FSM adopted its constitution, followed by the Marshall Islands and Palau in the same year, establishing their governments and enabling bilateral talks with the U.S. on Compacts of Free Association (COFA).^[16] These negotiations, spanning over a decade of intermittent discussions, focused on balancing Micronesian sovereignty with U.S. provisions for economic aid, military access, and exclusive defense authority.^[17] Draft compacts were finalized and signed in 1982 after extensive bargaining, with the FSM and Marshall Islands versions approved by local plebiscites in 1983.^[1] U.S. Congress enacted them via Public Law 99-239 in 1986, terminating the TTPI trusteeship for those entities and granting independence in free association, effective November 1986 for the Marshall Islands and FSM.^[2] Palau's compact faced repeated delays due to failed referendums—eight between 1983 and 1993—primarily over concerns regarding U.S. military presence and financial terms, requiring amendments before approval in 1993 and U.S. ratification via Public Law 99-658, with entry into force on October 1, 1994.^[1] This process marked the end of U.S. trusteeship administration over the former TTPI districts, transitioning them to sovereign status under the COFA framework while preserving U.S. strategic oversight.^[8]

Freely Associated States

Federated States of Micronesia

The Compact of Free Association (COFA) between the United States and the Federated States of Micronesia (FSM) was initialed in 1980, signed on October 1, 1982, and approved by the U.S. Congress via Public Law 99-239 before entering into force on November 3, 1986.^[18] This agreement granted FSM sovereignty while establishing a framework for U.S. defense responsibilities, economic assistance, and special migration privileges for FSM citizens.^[1] The COFA succeeded the U.S.-administered Trust Territory of the Pacific Islands, transitioning FSM from trusteeship to free association status.^[19] Under the original COFA, the U.S. provided economic grant assistance totaling approximately $1.6 billion from fiscal year 1987 through 2003, supplemented by contributions to a trust fund amounting to $517 million.^[2] In exchange, FSM granted the U.S. exclusive military access and committed to strategic denial of its territory to adversaries, with the U.S. retaining authority over foreign affairs related to defense.^[3] FSM citizens gained the right to reside and work indefinitely in the U.S. without visas, though access to certain federal benefits was limited until later amendments. The 2003 amendments, enacted as Public Law 108-188 and effective from June 30, 2004, extended assistance through 2023, emphasizing infrastructure, health, and education sectors while establishing trust funds for long-term sustainability.^[1] These amendments maintained core defense provisions, including U.S. operational rights for military activities in FSM waters and airspace.^[20] In May 2023, the U.S. and FSM signed agreements amending the COFA for an additional 20 years, approved by U.S. Congress in March 2024 via the Compact of Free Association Amendments Act.^[21] The renewal commits $3.3 billion in direct economic assistance to FSM, averaging about $140 million annually in grants, plus trust fund contributions and sector-specific programs in education, health, and infrastructure.^[22] It also restores eligibility for certain federal benefits for COFA migrants and enhances U.S. strategic positioning amid regional security concerns.^[23] As of fiscal year 2024, annual U.S. contributions include $250 million to FSM's trust fund.^[24]

Republic of the Marshall Islands

The Republic of the Marshall Islands (RMI) formalized its Compact of Free Association (COFA) with the United States through an agreement signed in 1982 and entered into force on October 21, 1986, marking the end of the U.S.-administered Trust Territory of the Pacific Islands for the RMI.^[6] This arrangement recognizes RMI sovereignty while designating the United States as responsible for its external defense and security, including the authority to operate military facilities and deny comparable access to other nations.^[2] The Compact was amended in 2003, effective May 1, 2004, and renewed for another 20 years via an agreement signed on October 16, 2023, and entered into force on May 1, 2024.^[25] Core provisions encompass economic support, with the 2023-2043 renewal allocating approximately $2.3 billion in total assistance, including annual grants rising from $28 million to $50 million (adjusted for inflation) for budgetary, health, education, infrastructure, and environmental needs, alongside a $700 million trust fund.^[21] This funding constitutes the bulk of U.S. aid to Pacific Islands, supporting RMI's economy where Compact grants historically represent a significant portion of government revenue.^[2] RMI citizens benefit from unrestricted rights to reside, work, and access select U.S. federal services in the United States without visas, fostering migration and remittances that bolster the islands' economy.^[7] A distinctive aspect involves compensation for U.S. nuclear weapons testing from 1946 to 1958, which affected multiple atolls; the original Compact provided $150 million for impacted communities, supplemented by subsequent U.S. appropriations totaling over $250 million prior to 1986.^[26] The U.S. government maintains it has fulfilled legal obligations under the Compact's Section 177, including health and environmental programs, though RMI officials and affected populations assert inadequate remediation for ongoing radiation-related health issues and site cleanup, leading to international advocacy and stalled negotiations at times.^[27] The 2023 renewal's trust fund partially addresses these legacy concerns, but disputes persist over full accountability.^[2]

Republic of Palau

The Republic of Palau, formerly part of the Trust Territory of the Pacific Islands administered by the United States, achieved independence through the Compact of Free Association (COFA) that entered into force on October 1, 1994.^[28]^[29] This agreement established Palau as a sovereign nation while granting the United States primary responsibility for its defense and providing economic assistance in exchange for strategic access and denial rights.^[28] Palau's COFA ratification followed a protracted process, distinguishing it from the earlier agreements with the Federated States of Micronesia and the Republic of the Marshall Islands.^[2] Negotiations for Palau's post-trusteeship status began in the late 1970s, culminating in the signing of the COFA on August 7, 1982, after Palau adopted its constitution in 1981.^[30] The U.S. Congress approved the compact via Public Law 99-658 in 1986 and Public Law 101-219 in 1989, but implementation stalled due to domestic opposition in Palau over provisions potentially conflicting with its nuclear-free constitution, which prohibited nuclear-armed or powered vessels and weapons.^[2] This led to eight failed referendums between 1983 and 1993, requiring a constitutional amendment in July 1993 to lower the approval threshold for compacts from 75% to a simple majority, enabling ratification on November 7, 1993.^[30]^[1] Under the COFA, the United States assumes exclusive authority for Palau's defense, including the right to establish and operate military facilities, conduct operations, and deny access to adversarial powers—a "strategic denial" clause critical to U.S. interests in the western Pacific.^[29] In return, Palau receives federal economic assistance, federal programs and services comparable to U.S. territories (such as postal and weather services), and infrastructure support.^[28] Palauan citizens enjoy visa-free entry to the United States for residency, employment, and education, though without voting rights or welfare benefits equivalent to U.S. citizens; conversely, the U.S. retains veto power over Palau's security-related foreign affairs.^[31] The compact lacks a fixed termination date but mandates joint reviews at the 15-, 30-, and 40-year marks.^[28] Economic provisions have been amended periodically; a 2010 agreement extended assistance through fiscal year 2024, providing approximately $140 million in direct aid plus trust fund contributions.^[1] In May 2023, Palau and the United States signed a 20-year renewal, approved by Congress in March 2024 via the Compact of Free Association Amendments Act, allocating $889 million in economic support from 2024 to 2044, including annual grants, trust fund deposits, and federal services.^[32]^[33] This renewal underscores Palau's geopolitical role amid regional tensions, with U.S. defense commitments ensuring no foreign military basing by competitors like China.^[31] As of 2025, the agreement remains in effect, supporting Palau's economy—where U.S. transfers constitute about 20% of GDP—while preserving its sovereignty in non-security matters.^[34]

Core Provisions

Economic and Financial Assistance

The economic and financial assistance provisions under the Compacts of Free Association (COFA) form the core of U.S. support to the Freely Associated States (FAS)—the Federated States of Micronesia (FSM), Republic of the Marshall Islands (RMI), and Republic of Palau—primarily through Title II of each compact, which authorizes direct grants for priority sectors including education, health care, infrastructure, environmental protection, and public sector capacity building.^[1]^[27] These grants, administered by the U.S. Department of the Interior's Office of Insular Affairs via mechanisms such as joint economic management and resettlement committees, transitioned from unrestricted block grants in the original compacts to more accountable sector-specific allocations following 2003 amendments, aiming to enhance fiscal transparency and development outcomes.^[1]^[35] Assistance also includes U.S. contributions to investment trust funds, established to provide perpetual income streams after direct grant periods expire, with earnings supporting ongoing budgetary needs.^[27]^[36] For the FSM and RMI, the original COFA agreements, effective November 1986, provided annual block grants totaling approximately $1.1 billion over initial periods, but the 2003 amendments, enacted as Public Law 108-188 and effective from fiscal year (FY) 2004, restructured support into $3.5 billion over 20 years—$2.1 billion in direct grants tapering from $82 million annually in early years to $30 million by FY2023, plus $1.4 billion in trust fund deposits projected to yield $16 million yearly in perpetuity thereafter.^[35]^[36] Palau's compact, effective October 1994, similarly offered sector grants under Title II, with initial funding of about $700 million through FY2009, followed by extended support including $20 million annually through FY2024.^[1]^[2] Across the FAS, this aid has historically comprised 40-60% of national government revenues, underscoring structural economic dependence despite self-governance.^[27] The 2023-2024 twenty-year renewals, approved by Congress in early 2024, allocate $3.3 billion to the FSM, $2.3 billion to the RMI (including a new trust fund agreement), and $889 million to Palau, with disbursements emphasizing climate resilience, health, and education while maintaining sector grant frameworks and trust fund growth targets.^[21]^[2] In FY2023, prior to full renewal implementation, compact grants totaled $232 million, representing roughly 80% of U.S. assistance to Pacific Island nations and highlighting the program's scale relative to other regional aid.^[2] U.S. oversight includes annual fiscal reports and audits to mitigate risks of mismanagement, though Government Accountability Office reviews have noted persistent challenges in achieving self-sustaining growth.^[37]^[36]

Military Defense and Security Arrangements

The United States holds exclusive authority and bears full responsibility for the external security and defense of the Freely Associated States (FAS)—the Federated States of Micronesia (FSM), Republic of the Marshall Islands (RMI), and Republic of Palau—as stipulated in Title Three of each Compact of Free Association (COFA).^[29]^[38] This includes the prerogative to operate military forces and conduct operations within FAS territories to safeguard against armed attack or other threats, with the FAS governments obligated to facilitate such activities upon request.^[3] The FAS retain primary responsibility for their internal security and law enforcement, though the United States may provide advisory or other assistance as mutually agreed.^[29] In exchange for U.S. defense commitments, the FAS grant the United States continuing rights to military access, including use of ports, airfields, and designated land areas for operations, training, and infrastructure, subject to prior consultation on specific sites.^[3] These rights are implemented through subsidiary agreements, such as the Agreement Regarding the Military Use and Operating Rights in the FSM, which outlines procedures for U.S. forces' entry, operations, and environmental safeguards at agreed locations.^[39] Comparable agreements exist for the RMI and Palau, ensuring operational flexibility while respecting FAS sovereignty over non-military matters.^[39] The COFA arrangements incorporate strategic denial clauses, requiring the FAS to refrain from actions that could prejudice U.S. security interests, including prohibiting third-country military basing, alliances, or transit rights that the United States might deny in its own territory, without prior U.S. consultation.^[40] This mutual framework, effective since the original compacts entered into force between 1986 and 1994, was preserved unchanged in the 2023-2024 twenty-year renewals, which focused primarily on economic and climate-related updates.^[2]

Migration and Residency Rights

Citizens of the Federated States of Micronesia (FSM), Republic of the Marshall Islands (RMI), and Republic of Palau hold the right under the Compacts of Free Association (COFA) to enter the United States and its territories without visas, and to reside, work, and study there indefinitely as nonimmigrants.^[6]^[41]^[42] This status permits employment without additional authorization and establishes residence qualifying toward naturalization under the Immigration and Nationality Act, though applicants must meet standard eligibility criteria.^[3]^[43] COFA migrants do not automatically receive lawful permanent resident status, remaining subject to U.S. immigration enforcement for deportability in cases of aggravated felonies or certain other crimes, without the protections afforded to green card holders.^[44]^[6] Travel to the U.S. requires a valid passport from the respective Freely Associated State, and entry is documented via Form I-94.^[41] The provisions apply uniformly across the three states, with the 2023-2024 COFA renewals maintaining these migration terms without alteration.^[2] Access to federal public benefits for COFA citizens has varied; the 1996 Personal Responsibility and Work Opportunity Reconciliation Act initially barred them from most means-tested programs, but the 2003 COFA amendments restored eligibility for Medicaid (in states opting to cover them), Medicare Part A for certain hospital services, and Supplemental Security Income for aged, blind, or disabled individuals meeting residency requirements.^[43]^[45] Further expansions in 2020 classified them as "qualified aliens" for additional programs like the Children's Health Insurance Program, though eligibility remains state-dependent and excludes programs such as SNAP and TANF unless states provide coverage using non-federal funds.^[45]^[46] These arrangements balance unrestricted mobility with U.S. retention of sovereignty over immigration adjudication and benefit distribution.

Sovereignty and Strategic Denial Clauses

The Compacts of Free Association affirm the sovereignty of the Federated States of Micronesia (FSM), Republic of the Marshall Islands (RMI), and Republic of Palau as independent nations, while delegating to the United States exclusive responsibility for their defense and security.^[1] Under these agreements, the freely associated states (FAS) exercise full internal and external sovereignty in non-defense matters, including foreign affairs, economic policy, and domestic governance, without U.S. veto power over such decisions.^[2] This arrangement, formalized in the original compacts signed between 1982 and 1990 and effective from 1986 to 1994, replaced the U.N. Trust Territory status administered by the U.S. post-World War II, granting the FAS internationally recognized independence while preserving U.S. strategic interests.^[3] Central to the defense provisions are the strategic denial clauses, which prohibit the FAS from granting military basing, transit, or operational access to third-party nations without U.S. approval, effectively reserving territorial control for U.S. security objectives.^[47] These clauses, embedded in Article IV of the compacts (e.g., Sections 451–455 for the FSM and RMI), stipulate that the U.S. maintains "complete responsibility" for external defense, including the authority to foreclose adversarial use of FAS land, waters, or airspace that could undermine U.S. interests.^[48] For instance, Section 355 of the related federal legislation (48 U.S.C. § 1931 note) reinforces that the FAS shall not recognize or permit third-country military activities conflicting with U.S. defense arrangements.^[47] This mechanism originated from U.S. negotiations to secure Pacific outposts against Soviet influence during the Cold War and was renewed in 2003 and 2023–2024 to counter emerging threats from the People's Republic of China (PRC).^[49] The clauses provide the U.S. with veto power over FAS agreements that could allow foreign military presence, such as port visits or infrastructure projects with dual-use potential, ensuring "strategic denial" of key maritime chokepoints and missile range sites like Kwajalein Atoll in the RMI.^[4] In practice, this has manifested in U.S. consultations blocking PRC-flagged vessel access or port developments in the FAS, as evidenced by diplomatic interventions reported in congressional oversight.^[47] While the FAS retain nominal sovereignty to conduct non-military foreign relations, the denial provisions bind them to U.S. security priorities, with non-compliance risking suspension of compact benefits; however, FAS leaders have occasionally tested these limits through economic outreach to China, prompting U.S. funding increases in the latest renewals to reinforce adherence.^[1] Critics, including some Pacific analysts, argue this creates de facto dependency, though U.S. sources emphasize mutual benefits in deterring aggression without full territorial annexation.^[49]

Implementation and Renewals

Initial Entry into Force

The Compacts of Free Association for the Federated States of Micronesia (FSM) and the Republic of the Marshall Islands (RMI) entered into force in late 1986, following the termination of the United Nations Trust Territory of the Pacific Islands (TTPI), which the United States had administered since 1947.^[1] Negotiations for the compacts began in the early 1980s after the FSM and RMI adopted their constitutions in 1979 and 1978, respectively, signaling readiness for self-governance beyond the trusteeship framework.^[50] The U.S. Congress approved the compacts through Public Law 99-239, signed by President Ronald Reagan on January 14, 1986, which authorized financial assistance and defense provisions while granting the islands sovereignty.^[2] Local approval processes, including referendums, preceded U.S. presidential proclamations to activate the agreements. For the RMI, the compact took effect on October 21, 1986, via Proclamation 5564, which confirmed the end of the trusteeship and the establishment of free association status.^[51] This followed the RMI's constitutional government formation in 1979 and compact ratification by its Nitijela legislature.^[38] Similarly, the FSM's compact entered into force on November 3, 1986, after its Congress of the Federated States approved the agreement and the U.S. issued the necessary executive actions under Section 177 of the compact.^[3] These activations aligned with Executive Order 12569, which delegated implementation responsibilities to federal agencies, ensuring coordinated transition from TTPI oversight to bilateral relations.^[52] The Republic of Palau's compact faced prolonged delays due to internal political debates and repeated referendum failures on sovereignty terms, despite U.S. congressional approval via Public Law 99-658 in November 1986.^[29] Palau held six referendums between 1984 and 1993, with the final approval occurring on November 9, 1993, after constitutional amendments addressed fiscal concerns.^[2] The agreement entered into force on October 1, 1994, through Proclamation 6726 by President Bill Clinton, marking Palau's independence and the onset of economic aid scheduled through fiscal year 2009.^[53] This staggered implementation reflected Palau's unique challenges in balancing domestic consensus with U.S. strategic requirements, including military access rights.^[54] Overall, the initial entries into force shifted the islands from trusteeship dependency to sovereign entities with U.S. security guarantees, totaling over $1.5 billion in initial U.S. commitments across the three states for infrastructure and economic development.^[1]

2003 Amendments

The 2003 Amendments to the Compacts of Free Association, approved by the U.S. Congress as Public Law 108-188 on December 17, 2003, extended economic and financial assistance to the Federated States of Micronesia (FSM) and the Republic of the Marshall Islands (RMI) for an additional 20 years, from fiscal year 2004 through 2023.^[55]^[2] These amendments followed the expiration of the original compacts' economic provisions and addressed concerns over fiscal accountability, with the U.S. providing approximately $3.5 billion in total assistance, including annual grants, sector-specific funding for health, education, and infrastructure, and contributions to trust funds designed to generate post-2023 income.^[56] For the FSM, annual grant assistance began at $76.2 million in FY2004, adjusted for inflation, while the RMI received $41.5 million initially, with additional allocations for Kwajalein Atoll impacts and nuclear-affected areas.^[55] Trust funds required matching contributions from the FSM ($30 million by September 30, 2004) and RMI (initial $25 million plus annual additions), emphasizing self-sustainability after the grant period.^[55] Immigration provisions under the amendments preserved nonimmigrant entry, residence, and employment rights for FSM and RMI citizens in the United States without visas, but restricted eligibility for most means-tested federal benefits to reduce fiscal burdens on U.S. states and territories like Hawaii and Guam, where "compact impact" from migration had strained local resources.^[6]^[55] Up to $250,000 was allocated to each nation for passport security enhancements by September 30, 2004, and naturalized citizens acquiring status primarily for U.S. immigration benefits faced exclusion.^[55] The amendments also authorized $30 million annually to affected U.S. jurisdictions for compact-related costs.^[55] Defense arrangements remained central, with the United States retaining exclusive responsibility for external security and the right to operate military facilities, including an extension of access to Kwajalein Atoll in the RMI through 2066, with a U.S. option to extend to 2086.^[2]^[55] Prohibitions on nuclear, chemical, or biological weapon storage applied except in emergencies, and the U.S. could suspend obligations if the associated states permitted incompatible third-party military activities.^[55] The amendments entered into force on May 1, 2004, for the RMI and June 30, 2004, for the FSM, following mutual agreements signed in April and May 2003, with joint review mechanisms at the 5th, 10th, and 15th anniversaries to assess implementation.^[6]^[55] Palau's compact was not amended in 2003, as its economic provisions extended separately until 2009.^[1]

2023-2024 Twenty-Year Renewals

Negotiations for renewing the Compacts of Free Association with the Republic of the Marshall Islands (RMI) and the Federated States of Micronesia (FSM) began in 2021, following the expiration of their prior 20-year economic assistance terms at the end of 2023, while the Republic of Palau's compact faced renewal in 2024.^[1] These talks addressed extended U.S. economic aid, defense responsibilities, and access to federal programs amid heightened geopolitical tensions in the Pacific, including concerns over Chinese influence.^[2] The U.S. Department of the Interior led the process, emphasizing strategic denial of the regions to adversaries in exchange for continued U.S. military access and operational control.^[21] The U.S. signed the amended compact with the RMI on October 16, 2023, in Honolulu, which entered into force on May 1, 2024, after congressional ratification.^[25] Similar agreements followed for the FSM and Palau, with all three renewals formalized under the Compact of Free Association Amendments Act of 2023, enacted as Division G of the Consolidated Appropriations Act, 2024, and signed by President Biden on March 9, 2024.^[57] ^[21] These 20-year extensions commit $7.1 billion in total U.S. economic assistance: $3.3 billion to the FSM, $2.3 billion to the RMI, and $889 million to Palau, allocated through annual grants, trust fund contributions, and infrastructure support, surpassing prior funding levels to account for inflation and development needs.^[21] ^[2] Key provisions retain U.S. exclusive defense authority, including the right to foreclose third-party security pacts, while granting citizens of the associated states continued compact migration privileges to the U.S. without visas and eligibility for select federal services like Medicaid and postal subsidies, though with new caps on certain benefits to address fiscal strains.^[2] The amendments introduce enhanced oversight mechanisms, such as interagency coordination for aid delivery and annual reporting to Congress on compliance and strategic objectives.^[24] Delays in congressional approval, resolved only after prolonged budget negotiations, highlighted tensions over funding scale and migration costs, estimated at hundreds of millions annually for U.S. welfare systems.^[58] Despite these, the renewals affirm the U.S. commitment to Pacific security, with implementation phased through fiscal year 2024 appropriations.^[59]

Geopolitical and Strategic Value

U.S. Security Interests in the Pacific

The Compacts of Free Association (COFAs) secure U.S. defense responsibilities for the Freely Associated States (FAS)—the Republic of the Marshall Islands (RMI), Federated States of Micronesia (FSM), and Republic of Palau—granting the United States exclusive access to their land, waters, and airspace for military purposes.^[4] This arrangement spans approximately 4.3 million square kilometers of exclusive economic zones, an area exceeding the size of the contiguous United States, enabling maritime surveillance, submarine operations, and potential basing to maintain freedom of navigation in key Pacific sea lanes.^[4] The U.S. retains unilateral authority to operate military facilities without FAS consultation on external threats, while prohibiting the FAS from establishing defense pacts with other nations.^[16] Central to these interests is the strategic denial of adversarial powers, particularly the People's Republic of China (PRC), from gaining footholds in the central Pacific; the COFAs explicitly bar foreign military basing or transit rights that could threaten U.S. assets or allies.^[49] The RMI's Kwajalein Atoll hosts the U.S. Army's Ronald Reagan Ballistic Missile Defense Test Site, operational since 1944 and renewed under COFA provisions, supporting hypersonic and missile defense testing critical to countering PRC and other ballistic threats.^[27] Palau's position near the Philippines enhances U.S. forward posture for rapid response in the western Pacific, while the FSM's archipelago facilitates undersea cable protection and anti-submarine warfare amid rising PRC naval activity.^[60] The 2023-2024 COFA renewals, signed into U.S. law on March 8, 2024, allocate over $7.1 billion in total funding through 2043, including $2.3 billion for regional security enhancements like coast guard vessels and maritime domain awareness systems shared via the Pacific Islands Forum.^[57] FAS citizens' eligibility to enlist in the U.S. armed forces bolsters recruitment, with more than 1,000 serving as of 2024, contributing to U.S. force projection without maintaining separate FAS militaries.^[2] These provisions align with U.S. Indo-Pacific Strategy objectives, prioritizing deterrence against PRC coercion while leveraging the FAS's geographic centrality for missile warning, space domain awareness, and logistics in contested environments.^[4]

Countering Adversarial Influence

The Compacts of Free Association grant the United States exclusive authority over the defense of the Freely Associated States (FAS)—the Federated States of Micronesia (FSM), Republic of the Marshall Islands (RMI), and Republic of Palau—while incorporating a right of strategic denial that empowers the U.S. to veto any third-country military access, basing, or strategic utilization of FAS territories without U.S. consent.^[61]^[62] This provision directly counters adversarial influence, particularly from China, by denying potential footholds for naval operations, missile deployments, or intelligence facilities that could threaten U.S. access to critical sea lanes spanning over 2 million square miles of the western Pacific.^[61] Under these arrangements, the U.S. maintains operational control for military exercises, personnel rotations, and infrastructure development, including the Ronald Reagan Ballistic Missile Defense Test Site on Kwajalein Atoll in the RMI (extended through 2066) and a planned long-range discrimination radar in Palau.^[61] China's expanding activities in the Pacific, including debt-financed infrastructure via the Belt and Road Initiative and attempts to secure security pacts, have targeted the FAS to erode U.S. predominance, as evidenced by the RMI's 2018 brief consideration of diplomatic recognition of Taiwan's rival and the FSM's rejection of a proposed China security agreement in 2022.^[62]^[63] The COFA's denial clauses mitigate such encroachments by legally binding the FAS to prioritize U.S. security interests, fostering alignment in international forums where the FAS consistently support U.S. positions against Chinese initiatives, such as opposing expansive security frameworks at the United Nations.^[61] Additionally, FAS citizens' eligibility for U.S. military service—numbering over 1,000 active personnel as of 2023—bolsters U.S. force projection while embedding mutual defense ties.^[61] The 2023-2024 COFA renewals, extending economic assistance for 20 years through fiscal year 2043 at a total commitment of $7.1 billion across the FAS, reinforce these denial mechanisms amid Chinese economic inducements, with specific allocations including $2.3 billion for the RMI to offset rival offers and sustain loyalty.^[61]^[62] These funds, comprising roughly 80% of total U.S. aid to the Pacific Islands region ($232 million in FY2023 alone), prioritize infrastructure, climate resilience, and governance to diminish vulnerabilities exploited by adversaries, thereby preserving U.S. strategic depth without ceding ground to powers seeking to alter regional power dynamics.^[2] This approach has proven effective, as the FAS have rebuffed Chinese diplomatic and basing overtures post-renewal, maintaining the U.S.-centric security architecture established since the original compacts entered force in 1986, 1986, and 1994 respectively.^[61]

Socioeconomic Outcomes

Development Achievements in the Associated States

The Compacts of Free Association have facilitated substantial U.S. economic assistance to the Federated States of Micronesia (FSM), Republic of the Marshall Islands (RMI), and Republic of Palau, supporting infrastructure development and public sector capacity. From fiscal years 2004 to 2023, the FSM received approximately $2.1 billion in compact grant assistance and trust fund contributions, while the RMI obtained $722 million, enabling sustained government operations and targeted investments in essential services.^[2]^[27] The 2023 amendments extend this support with $3.3 billion for the FSM and $2.3 billion for the RMI over 20 years, including allocations for trust funds designed to generate perpetual revenue streams after direct grants conclude.^[64] In Palau, compact funding has directly funded key infrastructure projects, including the Compact Road—a comprehensive highway system enhancing connectivity across Babeldaob Island—and rehabilitation of the Airai International Airport, improving transportation and economic access.^[65] Additional grants have supported telecommunications resiliency with $7 million for a second fiber optic cable in 2023, alongside Angaur dock upgrades and broader infrastructure maintenance through an established fund accruing interest for ongoing repairs.^[66]^[67]^[68] These initiatives, totaling $889 million in renewed assistance through 2044, prioritize public safety, justice, and climate adaptation alongside physical developments.^[69] Sector-specific grants under the compacts have bolstered education and health programs across the associated states. Annual U.S. funding allocates roughly $50 million to education and $35 million to health in the FSM and RMI combined, sustaining operations like Head Start preschool programs, special education services, and vocational training, which were reinstated following compact renewals.^[50]^[70] In Palau, $66 million in 2024 grants advanced health infrastructure and emergency preparedness, contributing to high vaccination rates that enabled border reopening in late 2021.^[71]^[72] These efforts have maintained access to U.S. federal postal, weather, and aviation services, indirectly supporting developmental stability.^[73]

Persistent Challenges and Dependency Concerns

The Freely Associated States (FAS)—the Federated States of Micronesia (FSM), Republic of the Marshall Islands (RMI), and Republic of Palau—face ongoing economic vulnerabilities rooted in structural limitations and excessive dependence on U.S. Compact grants, which comprised 28% of FSM government expenditures, 21% of RMI expenditures, and 13% of Palau expenditures in fiscal year 2019.^[61] U.S. assistance overall accounts for up to one-third of these nations' annual budgets, funding essential public services but crowding out incentives for fiscal discipline and private-sector growth.^[37] Geographic isolation, minuscule land areas (RMI: 70 square miles; FSM: 270 square miles; Palau: 177 square miles), scarce natural resources, deficient infrastructure, and acute susceptibility to climate impacts compound these issues, stifling diversification into sustainable industries like tourism or fisheries beyond subsistence levels.^[61] Efforts to attain self-sufficiency have faltered despite decades of aid, with per capita GDPs lagging at approximately $3,800 in the FSM, $6,800 in the RMI, and $15,800 in Palau as of recent estimates, indicative of stagnant productive capacity.^[61] The 2003 amendments established trust funds intended to yield perpetual income post-grant expiration, yet projections reveal their inadequacy: for the FSM and RMI, grants ending in fiscal year 2023 leave a high risk of insufficient disbursements, including a 36% probability of zero payouts from the FSM fund before fiscal year 2034 and 12% for the RMI.^[37] Palau's fund, extended to fiscal year 2024, fares better but still demands reforms absent clear U.S. advisory timelines, perpetuating a reliance that analysts attribute to aid's distortion of local incentives rather than catalytic investment in human capital or entrepreneurship.^[37] This dependency manifests in elevated emigration—over 94,000 FAS citizens reside in the U.S., driven by domestic opportunity deficits—and raises doubts about the Compacts' long-term efficacy in building resilient economies, as renewed $7.1 billion in assistance through 2043 risks entrenching the status quo without corresponding governance or revenue reforms.^[61] Congressional Research Service assessments underscore that self-sufficiency goals, embedded in Compact language since 1986, remain unfulfilled, particularly in the FSM and RMI, where aid sustains operations but fails to reverse brain drain or poverty concentrations, such as roughly 30% of urban Marshallese below basic-needs thresholds.^[61]^[74] Such outcomes highlight causal links between unconditional transfers and diminished self-reliance, echoing critiques in development economics that external rents often impede institutional maturation in small island contexts.^[75]

Key Controversies

Legacy of U.S. Nuclear Testing

The United States conducted 67 nuclear weapons tests in the Marshall Islands between 1946 and 1958, with 23 detonations at Bikini Atoll and 44 at Enewetak Atoll, equivalent to 1.6 Hiroshima bombs daily for 12 years.^[76]^[77] These tests, part of Operation Crossroads, Operation Greenhouse, Operation Ivy, Operation Castle, and Operation Hardtack I, involved yields up to 15 megatons, such as the Castle Bravo shot on March 1, 1954, which produced unexpected fallout contaminating Rongelap and Utirik atolls and exposing over 250 Marshallese to acute radiation doses exceeding 100 rads in some cases.^[78]^[79] Environmental contamination persists, rendering Bikini Atoll largely uninhabitable due to cesium-137 and strontium-90 in soil, lagoon sediments, and coconuts, with half-lives of 30 years necessitating evacuation of over 160 Bikini residents in 1946 and failed resettlement attempts in 1969 and 1978.^[80] At Enewetak, post-test cleanup from 1978 to 1980 buried 110,000 cubic yards of radioactive waste under the Runit Dome on Enewetak Island, but rising sea levels and structural degradation have caused leaks, dispersing plutonium and americium into groundwater and ocean, as documented in Department of Energy monitoring.^[81] Fallout from 20 tests affected additional atolls like Rongelap, with global dispersion detected as far as India, though localized hotspots remain highest in the Marshall Islands.^[79]^[82] Health studies link radiation exposure to elevated risks of thyroid cancer, leukemia, breast cancer, and hematologic malignancies, particularly among children exposed via radioiodine uptake, with Marshallese cohorts showing incidence rates 10-20 times higher than unexposed Pacific Islanders per National Cancer Institute analyses.^[83]^[84] Birth defects, including "jellyfish babies" (congenital anomalies), and chronic conditions like hypothyroidism and cardiovascular disease correlate with doses from fallout ingestion and inhalation, though small population sizes (fewer than 70,000) complicate statistical attribution amid confounding factors like tobacco use and diet.^[85]^[86] The U.S. Congress's 1990 appropriation enabled the Rongelap Atoll Local Government to relocate residents in 1985 after surveys confirmed unsafe radiation levels.^[77] Under Section 177 of the 1986 Compact of Free Association, the U.S. accepted responsibility for nuclear testing effects, establishing the Marshall Islands Nuclear Claims Tribunal, which awarded $2.3 billion for personal injuries, property damage, and health programs but received only about $151 million in U.S. funding, leading to underpayment of claims and tribunal dissolution in 2009.^[2]^[77] Total U.S. payments exceed $600 million, including $250 million pre-Compact for health and resettlement, plus environmental remediation, though Marshallese officials argue these fall short of full remediation costs estimated at billions, citing unaddressed intergenerational harms and disputed causation in some cases.^[26]^[87] A 2023 agreement added $5.3 million for health care and $700,000 annually for environmental monitoring, but ongoing disputes highlight gaps between tribunal judgments and U.S. disbursements, with the Republic of the Marshall Islands seeking fuller accountability amid renewed Compact negotiations.^[88]^[89]

Compact Migrant Impacts on U.S. Welfare Systems

Citizens of the Freely Associated States (FAS)—the Federated States of Micronesia, Republic of the Marshall Islands, and Republic of Palau—may reside and work indefinitely in the United States under the Compacts of Free Association without visas or employment authorization, but their access to federal welfare benefits has been restricted since the 1996 Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA), which classified them as ineligible for most means-tested programs such as Supplemental Nutrition Assistance Program (SNAP), Temporary Assistance for Needy Families (TANF), and Supplemental Security Income (SSI), except for emergency Medicaid and certain school programs.^[90] The 2009 Children's Health Insurance Program Reauthorization Act (CHIPRA) partially restored Medicaid and CHIP eligibility for FAS migrant children, pregnant women, and, in some states, certain low-income adults, leading to increased enrollment; for instance, in Hawaii, COFA migrant enrollment in state-funded premium assistance programs dropped from about 9,100 in 2015 to 3,225 in 2017 after federal changes, but emergency care usage remained high.^[91] These restrictions aimed to curb perceived welfare migration incentives, though empirical data shows FAS migrants often migrate for economic opportunities and family ties rather than benefits alone, with health needs exacerbated by factors like nuclear testing legacies and poor baseline conditions in home islands.^[92] In host jurisdictions, FAS migrants' welfare usage has imposed notable fiscal strains, particularly on Medicaid and local social services, due to high rates of chronic conditions such as diabetes and obesity—prevalent among Marshallese at over 40% for diabetes—and large household sizes averaging 5-7 members.^[92] Hawaii, home to an estimated 13,000-18,000 COFA migrants as of 2018, reported over $90 million in annual uncompensated costs for healthcare, education, and social services attributed to them, with emergency department visits by uninsured COFA patients rising 21% after partial Medicaid cuts.^[93] ^[94] Guam, with around 15,000-18,000 FAS residents, expended $147 million in fiscal year 2017 on education and social services for them, including $38.5 million for health and welfare, often exceeding local tax revenues from migrants who earn median incomes below $20,000 annually.^[95] In Arkansas, a growing Marshallese community of about 10,000-12,000 faced 70% uninsured rates pre-2021 restorations, relying heavily on charity care and emergency Medicaid, contributing to local hospital burdens amid poverty rates exceeding 30%.^[96] ^[97] To mitigate these impacts, the U.S. Department of the Interior provides annual compact impact grants—$30 million since the 2003 amendments—reimbursing affected areas like Hawaii, Guam, and the Commonwealth of the Northern Mariana Islands for excess costs, though recipients have reported shortfalls, with Guam claiming billions in unreimbursed expenses over decades.^[98] The 2024 Compact Impact Fairness Act, enacted as part of renewed COFA funding, restores full federal SNAP and non-emergency Medicaid eligibility for adult FAS migrants, effective in states like Arkansas from October 2024, potentially shifting more costs to federal budgets but reducing state-level strains; however, pre-restoration data indicated net fiscal drains, as migrants' tax contributions (e.g., payroll and sales taxes) typically offset only 20-40% of service expenditures in high-impact areas.^[99] ^[23] Government Accountability Office analyses confirm population growth—doubling in some areas since 2003—correlates with these pressures, though migrants also fill labor shortages in sectors like fishing and poultry processing.^[94]

Governance, Corruption, and Fulfillment Disputes

The Freely Associated States—Federated States of Micronesia (FSM), Republic of the Marshall Islands (RMI), and Republic of Palau—maintain sovereign constitutional governments with elected executives and legislatures, structured as presidential republics or federations, while the United States provides defense and retains veto authority over security matters under the Compacts.^[1] U.S. financial assistance, which constitutes the majority of their budgets, is disbursed through joint oversight bodies such as the Joint Economic Management Committee (JEMCO) for FSM and the Joint Economic Management and Financial Accountability Committee (JEMFACC) for RMI, aimed at promoting fiscal responsibility and development projects.^[1] These mechanisms reflect U.S. efforts to mitigate governance weaknesses inherent in small, aid-dependent island nations, including limited administrative capacity and fragmented federal authority in FSM, where state-level disputes have delayed infrastructure grants.^[100] Corruption remains a persistent challenge, exacerbated by political patronage, small populations enabling personal networks, and external influences seeking leverage. In the RMI, 59% of surveyed residents in 2022 identified government corruption as a major problem, with 54% attributing it primarily to members of parliament and 52% reporting experiences of election-related bribery.^[101] Palau exhibits somewhat lower perceptions, with 42% viewing government corruption as significant, though 29% link it to high-level officials; the nation maintains a Code of Ethics Act and Bureau of Anti-Corruption to prosecute offenses, yet enforcement gaps persist in business dealings.^[101]^[34] FSM faces similar issues, including allegations of bribery involving senior officials and high rankings in regional corruption indices for political and business practices.^[102] Notable cases include a 2023 U.S. conviction of Chinese nationals for bribing RMI legislators to influence elections and secure contracts, highlighting foreign interference risks.^[27]^[103] Instances of fund diversion, such as withheld U.S. nutrition grants in FSM's Chuuk state due to misuse, underscore weak internal controls.^[100] Disputes over Compact fulfillment often center on U.S. aid effectiveness rather than outright non-payment, with FAS governments critiquing funding levels for health, education, and infrastructure amid rising costs, while U.S. assessments emphasize local mismanagement limiting outcomes. From 1987 to 2003, the U.S. provided $2.1 billion in compact grants to FSM and RMI, followed by $3.6 billion committed through 2023, yet GAO evaluations found stagnant private sector growth, persistent dependency, and inadequate progress on tax, land, and investment reforms essential for self-sufficiency.^[100]^[100] Political delays and capacity shortfalls have impeded joint committee approvals, prompting U.S. concerns over waste in past ventures.^[100] In the 2023-2024 twenty-year renewals, the U.S. imposed fiscal reform trials—requiring demonstrations of policy advancements before annual grant releases—to address these deficiencies and enhance accountability, a condition FSM and RMI accepted in bilateral agreements signed in May 2023.^[104]^[100] These measures, totaling approximately $140 million annually for FSM and $80 million for RMI, prioritize anti-corruption and economic diversification to counter aid dependency's disincentives for governance improvement.^[104]

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The program is the US response to the legacy of nuclear testing that occurred in the Republic of the Marshall Islands from 1946 to 1958.
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U.S., Marshall Islands Grapple With Nuclear Legacy
Nov 1, 2022 · The 67 U.S. atmospheric nuclear weapons tests between 1946 and 1958—23 at Bikini Atoll and 44 at Enewetak Atoll—spewed radiation over the ...
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Legacy of US nuclear weapons tests in the Marshall Islands created ...
May 27, 2025 · Nuclear testing in the Marshall Islands created radiation exposures globally, with “hotspots” detected as far west of the Marshall Islands as ...
[83]
Aftermath of Nuclear Testing in the Pacific Islands - ASCO Publications
Nov 27, 2024 · Radiation exposure led to increased incidences of various cancers among PIs, notably thyroid, breast, and hematologic malignancies. Children ...
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Marshall Islands Nuclear Testing: The Aftermath | National Cancer ...
Oct 27, 2023 · According to the National Cancer Benefits Center, thyroid cancer and leukemia are particularly prevalent due to radiation exposure. Birth ...
[85]
The Relationship of Thyroid Cancer with Radiation Exposure ... - NIH
The potentially widespread radiation exposure from radio-iodines of fallout has raised concerns about the risk of thyroid cancer in the Marshallese population.
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Long-Term Health Effects of Marshall Island Nuclear Testing - Stanford
Feb 26, 2024 · Chronic health complications result from radionuclide absorption into organs; particularly red bone marrow, thyroid gland, stomach wall, and colon.
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US Policy on Marshall Islands Nuclear Test Compensation Must ...
Oct 5, 2023 · The United States risks losing ground to China in the Marshall Islands because of Washington's refusal to pay full compensation for Cold War-era nuclear tests.
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U.S., Marshall Islands Sign Deal on Nuclear Testing Impacts
Mar 1, 2023 · Pursuant to past Marshall Islands compacts, the United States provided grant assistance worth approximately $661 million and $309 million on ...
[89]
Marshall Islands calls for US to pay more compensation over ...
Jul 13, 2023 · The foreign minister of the Marshall Islands has called for more US compensation over the legacy of massive US nuclear testing.
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Noncitizen Eligibility for Medicaid and CHIP - Congress.gov
Mar 10, 2025 · Noncitizens' eligibility for Medicaid and CHIP largely depends on (1) applicants' immigration status; (2) whether they arrived in the United States.
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The Impact of the Medicaid Expiration on COFA Migrants and ...
Jul 27, 2020 · In 2017, 3225 COFA migrants received premium assistance whereas this number in 2015 was approximately 9100. This suggests that at least 6000 ...Missing: Guam | Show results with:Guam
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Marshallese COFA Migrants in Arkansas - PMC - NIH
May 5, 2017 · Marshallese COFA migrants in Arkansas face disproportionate chronic diseases, high rates of diabetes, and many are uninsured, with limited ...
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The “Compact Impact” in Hawai'i: Focus on Health Care - PMC - NIH
It is estimated that Hawai'i spends over $90 million annually in uncompensated social, education, heathcare, and legal costs attributed to COFA migrants.
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Compacts of Free Association: Populations in U.S. Areas Have ...
Jun 15, 2020 · This report describes (1) estimated compact migrant populations and recent trends in compact migration; (2) reported costs related to compact ...Missing: dependency | Show results with:dependency
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Compact Impact | The Bureau of Statistics and Plans Guam
The Government of Guam expended $147 million in FY 2017 for providing educational and social services to migrants from the Freely Associated States to Guam.Missing: systems | Show results with:systems
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Interpretive policy analysis: Marshallese COFA migrants and the ...
Jun 11, 2016 · While only 50 % of participants were uninsured, local studies estimate that the uninsured rate among COFA migrants in Arkansas is closer to 70 % ...
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At long last, Medicaid coverage for Marshallese Arkansans
Feb 23, 2021 · Adults born in the Marshall Islands can now get Medicaid in Arkansas, due to a new federal law and state rule change, with coverage retroactive ...<|control11|><|separator|>
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Compact Impact | U.S. Department of the Interior
The goal of this $30 million in annual grants support is to help these affected jurisdictions defray costs incurred as a result of increased demands.Missing: welfare FAS
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Arkansas' Marshallese community again eligible for SNAP benefits
Oct 1, 2024 · Eligible Marshallese migrants in Arkansas can begin applying for the Supplemental Nutrition Assistance Program (SNAP) Tuesday after access to the federal ...
[100]
GAO-06-590, Compacts of Free Association: Development ...
... Marshall Islands (RMI) through a Compact of Free Association. In 2004 ... Compact's establishment of key defense rights for all three countries. The ...
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[PDF] PERCEPTIONS OF CORRUPTION IN SEVEN SMALL PACIFIC ...
As Figure 3 shows, the Pacific GCB found that respondents were most concerned about politicians. (20 per cent said MPs were likely to be involved in corruption) ...
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Allegations of Bribery Against Micronesia's President - Facebook
Mar 14, 2025 · Good to know and be aware of the on going corruption in our FSM Government. Hopefully, these officials who were involved in this allegations ...
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Scammers Behind Marshall Islands Bribery Scheme Stuck ... - OCCRP
Mar 5, 2025 · Two Chinese scammers convicted behind a high-profile Pacific Islands bribery scheme, Cary Yan and Gina Zhou, have been stranded at Manila's international ...
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U.S. Strengthens Compact Partnerships with FSM and RMI at ...
Sep 4, 2025 · The FSM receives about $140 million annually and the RMI about $80 million. Discussions focused on completing overdue audits, implementing ...<|separator|>