Back on 12 April 2023, together with Susan O’Neill of SuLu Solutions and Peter Oakes of Fintech Ireland we issued the first Registered Virtual Asset Service Providers - Ireland Map.

Since then the Map has been updated twice to record the registration of addition virtual asset firms registered in Ireland.  We have now updated the Map to Version 3 as at Wednesday 30th August 2023.  That date is the most current run date on the Central Bank of Ireland's register for virtual asset firms.

Welcome MoonPayTechnology Services Limited to the Map.

MoonPay was registered on 15 August 2023 and is registered for service number (ii), the exchange between one or more forms of virtual assets.

MoonPay joins other registered virtual asset firms including Coinbase Europe Limited, Coinbase Custody International Limited, Gemini Intergalactic Europe Limited, Zodia Custody Ireland Limited, Paysafe Payment Solutions Limited, NoFrixion Ireland Limited and Pionex Ireland Limited.  Some of these crypto firms also hold an electronic money authorisation with the Central Bank of Ireland.

MoonPay's local board of directors (according to Companies Registration Office records) are Maximilian (Max)  Crown (Co-Founder & CFO) and Ivan Soto-Wright (Co-Founder CEO).  Max is also a director of other MoonPay entities in the UK, Malta and USA.

MoonPay, was launched in 2019 to allow people to buy and sell Non-Fungible Tokens. It is backed by celebrities such as Justin Bieber and Gwyneth Paltrow. In a statement to the Irish Independent, the company said it has now established a presence in Ireland. “MoonPay [now] has a team in Ireland. We also expect our headcount to grow in line with business demands and to ensure we remain in compliance with our regulatory obligations,” it said.

MoonPay builds payment infrastructure for crypto and has about 500 industry partners ranging from crypto wallets to layer-1 and layer-2 blockchains, Abhay Mavalankar, VP of corporate development and investments said. The company is valued at $3.4 billion, has more than 5 million customers and supports over 80 assets, according to its website.

At the end of August 2023, MoonPay launched MoonPay Ventures an investment arm that will focus on early-stage startups in web3, gaming and adjacent fintech categories (reported  by Jacquelyn Melinek in TechCrunch).  The investment arm, dubbed MoonPay Ventures, will mainly invest between $100,000 to $1 million, targeting seed and Series A rounds. It has already invested in more than 25 companies, including BCB Group, Ledger, BRUT, BeatClub, absolute labs, Create/OS, BridgeTower Capital and Mythical Games, according to MoonPa's Abhay Mavalankar.

There isn’t a specific fund amount that MoonPay is allocating, and the team will invest off its balance sheet with a “definite angle” toward commercial ROI.  “When it comes to web3 and backing exceptional founders, this is a logical extension of that,” Mavalankar said.

BTW, Fintech Ireland and Peter Oakes are supporting MiCA Ready which tracks materially important EU news on MiCA and Digital Assets Africa. 

Don't forget to check out our Fintech Ireland Crypto Page.

Previous editions of the Map.

• Version 1 April 2023 Blog here
• Version 2 July 2023 Blog here

09 August 2023: Ireland's Department of Finance has issued a Public Consultation Markets in Crypto Assets Regulation (EU 2023/1114).  CLICK HERE.

Minister for Finance Michael McGrath TD has today announced the launch of a public consultation on the exercise of national discretions contained within the Markets in Crypto Assets Regulation (MICAR) (EU) 2023/1114.

The Markets in Crypto-Assets Regulation is the first European-level legislation introducing a harmonised and comprehensive framework for crypto-assets, covering issues from the offering to the public of crypto-assets to preventing market abuse in crypto-asset markets. The consultation commences 9 August 2023 and ends 5p.m. on 15 September 2023.

The Department of Finance has issed a public consultation, commencing 9 August 2023 ending 15 September 2023 for purpose of obtainin submissions on the transposition of national discretions included within the Markets in Crypto-Assets Regulation (MiCAR) EU 2023/11141. MiCAR is the first European-level legislation introducing a harmonised and comprehensive framework for crypto-assets, covering issues from the offering to the public of crypto-assets to preventing market abuse in crypto-asset markets. The legislation provides a set of prescriptive rules that will shape the functioning of the European markets in crypto-assets, including transparency rules, authorisation requirements, customer protection rules and an anti-market abuse framework.

As a Regulation MiCAR has direct effect, however, there are a number of provisions in the Regulation to which full harmonisation does not apply and Member States are given discretion as to whether and how to apply these provisions.

The four national discretions this consultation seeks feedback on include:

• Article 88 (1): Public disclosure of inside information
• Article 111 (2): Administrative penalties and other administrative measures
• Article 143 (2): MiCAR transition period; and
• Article 143 (6): Simplified authorisation procedure.

Section 5 of this consultation document sets out detail of the national discretions contained within MiCAR and the Department invites comments on whether these discretions should be availed of, how they should be availed of and clear reasoning for such a position.

The Department of Finance invites people responding to the consultation to:

• Give their views on the specific questions set out below. You do not have to answer every question – you may choose to answer all of the questions or only those which are relevant to you.
•  Provide details of any issues or concerns you feel should be considered in dealing with the particular topic being addressed in your response.
• Where appropriate, provide some analysis or views on the regulatory and/or financial impact of the proposed approach.

The comments received will be taken into consideration when deciding how best to transpose the MiCAR into Irish law.

The consultation period will run from 9 August 2023 to 15 September 2023. 

The Department of Finance says that any submissions received after this date may not be considered.

If you wish to respond to this consultation paper you may do so either electronically or in writing by 15 September 2023.  Electronic submissions can be sent to https://consult.finance.gov.ie/.  Postal submissions to MiCAR Public Consultation, Financial, Advisory, Department of Finance, 1 Miesian, Plaza, D02 R583, Ireland. 
 

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Fintech Ireland Newsletter (August 2023 / 08.01)

Hi All -

Welcome to Fintech Ireland's Newsletter (August 2023), issued 8th August 2023. CLICK HERE TO READ ONLINE. If you wish to receive our newsletters direct to your inbox subscribe HERE)

Stay in touch. If this email was forwarded to you by a colleague, join the Fintech Ireland subscriber list for news, events and analysis at https://fintechireland.com/get-involved.html. The Fintech Ireland Network continues to go from strength to strength with: 2,800+ Email Subscribers; 5,043 LinkedIn Company Page Followers, 2,590 LinkedIn Group Members (with 240 requests to join yet to be vetted); 5,831 Twitter Followers; and 150,000 website visitors in the past 12 months - thank you.

AT A GLANCE - IN THIS EDITION:

CLICK HERE TO READ ONLINE

In this edition we cover:

• Upcoming Events and Material From Previous Events
• Fintech Leaders Series (NoFrixion), Q&A with Feargal Brady CEO & Co-Founder
• Fintech firms and organisations, including CluneTech, Vivid Money, Capitalflow, Bunq, Wise, Revolut, Tilia Payments, CreditLogic, Treasury Delta, TransferMate, Paysend, NoFrixion, Stripe, Synch, MyComplianceOffice, TaxBack, Sprintax, Tines, Raisin, Binarii Labs, Global Government Fintech, Blockchain Ireland, Wayflyer, Immedis and WireCard
• Announcing the first professionals to join the Fintech Ireland Advisory Council
• USA Today's coverage of Ireland’s tech industry
• Updated crypto and fintech Maps, showcasing 55 such firms achieving a regulated presence in Ireland
• Central Bank of Ireland's MiCAR Survey
• Why Ireland cannot attract neo banks and closure of fintech and crypto firms in Ireland
• Launch of the MiCA Ready website
• Need for greater collaboration between private and public sector on RegTech
• The EU’s plans for PSD3
• Fintech Ireland Fintech Maps Survey
• Re-shares of fintech news from, among others, Charlie Taylor, John Ihle, Jonathan Keane, Emmet Ryan, Gabrielle Monaghan, Sarah Collins, Tom Lyons, Francesca Comyn and Charlie Weston
• and much more.

CLICK HERE TO READ ONLINE

NoFrixion is a Money Movement platform combining the technology and regulatory authority to enable businesses to send, store, receive and reconcile funds programmatically. It is an Embedded Finance solution, focussed on embedded money movement.

​Founded in 2020 by Feargal Brady, Chief Executive Officer and Aaron Clauson, Chief technology Officer, NoFrixion raised €3.6m in seed funding in 2022. They were registered as Virtual Asset Service Provider (VASP) on the 31st of May 2023 by the Central Bank of Ireland (CBI), followed by authorisation as an Electronic Money Institution (EMI) on the 25th July 2023.  

​Fintech Ireland's Susan O'Neill caught up with Feargal Brady who talked us through NoFrixion’s plans for revolutionising money movement. 

Feargal Brady (FB): Myself and Aaron founded a business called BlueFace, an IP telephony company, back in 2004 just as the deregulation of Telecoms began. It was the early days of IP telephony, of Open Source software and the Cloud had yet to be invented. We built a full telephony platform in software, and provided IP telephony services to consumers, then businesses, and finally other telecoms companies. We were part of a global movement which designed and built the foundations of the embedded audio/video platforms which are so part of our lives now.

Throughout our careers, our experience with payments, banking and money movement in general has been really poor – both the business and the consumer experience. Any interaction required internet banking, while the functionality was always limited.

Aaron got involved with Bitcoin in 2015 and became one of the developers for Bitcoin Core. He introduced me to the Lightning Network, we thought it was an amazing way to pay online. We explored this, came across Open Banking, and decided that the business world needed better ways to transfer value.

The solution was to build a current account with IBAN in software, with connectivity to the international payments rails, including Bitcoin Lightning for futureproofing. The goals was to enable businesses to send, store, receive and reconcile using the API. By presenting a current account as a software API, money becomes programmable. The concept of separate accounting and current account platforms results in manual reconciliation and all sorts of delays and problems. Through our API, businesses have access to card acquiring, to SEPA and Faster Payments, access to the Lightning Network and most importantly to the core current account & IBAN which is built in software. 

​FB: We envision the emergence of the Lightning Network as a means of value transfer and we want to make sure we are ready for that – with both the technology and the regulatory authority. It’s hard to say when this will be, but there are a large number of use cases emerging. For example, it is an effective software solution for money transmission, it is ideally suited to micro-payments, and it can bypass currency exchange requirements. 

FB: Given the news over the last year in particular in the cryptocurrency world, it is great to see regulatory oversight to the level implemented by the CBI. It will be very interesting with MiCA being introduced, and we see it as something that is absolutely necessary. We found the applications process to be clear and transparent. The CBI are extremely professional, they clearly understand the area and they have got the expertise in-house to evaluate applications to the level necessary. It is a really difficult task, as there is so much happening and the area is moving so fast. The process itself was actually extremely useful as they look at things from a different perspective that you wouldn’t necessarily be aware of coming from a purely technical point of view. It is exactly this kind of expertise and insight which is required of a regulator, and will ensure a very high level of compliance for companies in the space.  

FB: Our primary focus right now is commercial development and building on the achievements of the past year. Embedded Finance has emerged as one of the biggest game changers in Fintech, and for us the money movement aspect of Embedded Finance. By bringing accounting and current accounts together it is possible to eliminate vast elements of manual processing around accounts receivable and payable. We have built out our core platform including integrations with the international payment rails to facilitate this.

There are two products - MoneyMoov for business is effectively an all in one accounting and current account, while MoneyMoov API enables core business applications to be integrated directly. Both result in the elimination of internet banking as a means of accessing the current account. We think that in the near future, Lightning Wallets will become more prevalent, and we will be ready to provide the service - so it is as much about future proofing as anything else. We also have a custody service / vault to enable secure Bitcoin storage and to exchange for fiat currency also.
​
We are obviously looking at MiCA now, and in the short term we are hoping to see Lightning adoption, to enable us to expand around Europe in tandem with MiCA.

FB: We have been running our own nodes on the Lightning network, contributing to some of the backend engineering – Aaron is involved in various Lightning projects which gives us really good visibility into what’s happening. We expect it to start to take off in the short term, and there’s some really interesting and innovative use cases as I mentioned. 

FB: There is use cases for all of the payment methods including SEPA, Open Banking, card payments etc, and there is definitely a demand for something like Lightning for micropayments as its extremely low cost, instant and decentralised. PoS is another good use case. Lightning will be another way of moving value, in particular on the internet. Some of the really interesting use cases are around currency exchange where it has the potential to eliminate exchange fees. The sheer volume of brain power going into the development of Lightning is extraordinary - some of the projects that are underway are incredible. It will be a very interesting few years. 

​If you need assistance with an emoney or payments authorisation or an account information service provider registration application, check out Fintech Ireland and CompliReg's handy authorisation guides at https://fintechireland.com/fintech-authorisations.html.

As of 3 August 2023 we have produced an updated Map of authorised electronic money institutions, authorised payment institutions and registered account information services providers.

New to this Map are:

• Paysend EU DAC - authorised on 20 December 2022 to provide electronic money and payment services 3a, 3b, 3c, 5, 6, 7, 8
• InterPay Limited t/a TransferMate - a change of authorisation on 25 April 2023 to electronic money institution (from a payments institution authorisation held since 2011) and payment services 3b, 3c, 5, 6 
• NoFrixion Limited - authorised on 25 July 2023 to provide electronic money and payment services 3a, 3b, 3c, 5, 7, 8.  NoFrixion was registered as a Virtual Asset Services Provider on 31 May 2023.

Thus far in the first seven months of 2023, only two firms have been authorised as either an electronic money institutions (EMI) or payments institutions (API) i.e. TransferMate and NoFrixion, and TransferMate was previously authorised as a payments institution from 2011-2023 before becoming an EMI in April 2023.  Thus effectively, NoFrixion is only new entity to become authorised in 2023.