Not long after we released version 12 of Fintech Ireland's regulated fintech map comprising of authorised  electronic money and payments institutions and registered account information services providers (and as predicted) the Central Bank of Ireland authorised another emoney institution.  Thus we have released version 13.0 of the Map.

Kraken, a trading name of Payward Ireland Limited, was authorised as an electronic money institution on 25th September 2023 and may also provide payments services number 3c.  Many will know Kraken as a digital asset / crypto asset firm.  Kraken is also registered in Ireland under local law transposing the 5th AML Directive and it appears on Fintech Ireland's Map of Registered Virtual Asset Service Providers along with (as of today) another eight VASPs. 

Kraken is also one of one of five VASPs which also holds an electronic money authorisation - the other four being Coinbase, Gemini, Paysafe and NoFrixion.  Kraken's regulated Irish operations are owned by Payward Europe Limited, which in turn is own by Payward Inc.  

According to latest set of account available from the Companies Registration Office (CRO) for the year ending December 2021,  Payward Ireland Limited had a turnover of just €26,634 which was fully consumed by administrative expenses.  Given that it was not registered as a VASP until 11 April 2023, followed by its emoney authorisation on 25 September 2023, we will not get a clearer picture of the potential for its success in Ireland until say Quarter 4 2024 when its accounts for 2023 will be published on the CRO's website.

So what can Kraken do with its emoney authorisation?  Obviously it can issue and redeem electronic money and separately provide payment service 3c which is "Execution of payment transactions, including transfers of funds on a payment account with the user’s payment service provider or with another payment service provider with respect to execution of credit transfers, including standing orders.  

To date since the start of 2023, Ireland's Central Bank has authorised just four firms as either an electronic money institution (EMI) or a payments institutions (API) i.e. Kraken (Payward Ireland) (EMI), Freemarketfx Ireland (API), TransferMate (Interpay Limited) (EMI) and NoFrixion Limited (EMI). TransferMate was previously authorised as a payments institution from 2011-2023 before becoming an EMI in April 2023.  Thus effectively, Kraken, NoFrixion and Freemarketfx Ireland are the only new entities to become authorised in 2023 (3 authorisations in 9 months).    

Kraken was authorised more than 2.5 years after it was incorporated in Ireland on 23 February 2021. 

Our Peter Oakes last spoke with Charlie Taylor of the Business Post on the topic of regulatory authorisations on Sunday 20 August 2023.

• Peter Oakes, a former Central Bank enforcement director and founder of Fintech Ireland, said a firm setting up in Ireland needs to be aware that the upfront and post-authorisation costs in the first year will set them back about €1.5 million.
• “A considerable part of this outlay is required ahead of approval with no guarantee it will be given,” Oakes said.
• “No one wants to say this because everyone will say that by doing this you are not flying the green flag. Some consultants hide behind that because they might not be engaged [by clients] and risk losing other client work both pre and post authorisation in areas such as tax, IP, employment, commercial and corporate work. No-one should be surprised by this,” he added.

Ireland is now home to 48 legal entities which provide emoney services, payment services and standalone account information services.  There are 26 payments services firms in Ireland which includes 4 account information services providers and 23 emoney firms.  The records of four firms state that their authorisations were withdrawn.  The three that are no longer authorised to provide services in Ireland are Xpress Money Services Limited,  SWFS Ireland Limited and Modulr FS Europe Limited.  The 4th entity, noted above, Interpay Limited (TransferMate) switched from payments services only to an electronic money (plus payment services 3b, 3c, 5, 6) in April 2023.

Further Reading: See our post on the release of version 12 of this Map for more information. 

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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 5 September 2023 we have produced an updated Fintech Ireland Map of authorised electronic money institutions, authorised payment institutions and registered account information services providers.

New to version 12 of the Map is Freemarketfx Ireland Limited, which was authorised on Monday 4 September 2022 to payment services 3c and 5.  These services allow Freemarkefx Ireland to provide:

• #3)  Execution of payment transactions, including transfers of funds on a payment account with the user’s payment service provider or with another payment service provider: (c) Execution of credit transfers, including standing orders; and
• #5) Issuing of payment instruments and/or acquiring of payment transactions. 

To date since the start of 2023, Ireland's Central Bank has authorised just three firms as either an electronic money institution (EMI) or a payments institutions (API) i.e. Freemarketfx Ireland (API), TransferMate (Interpay Limited) (EMI) and NoFrixion Limited (EMI). TransferMate was previously authorised as a payments institution from 2011-2023 before becoming an EMI in April 2023.  Thus effectively, NoFrixion and Freemarketfx Ireland are the only new entities to become authorised in 2023 (2 authorisations in 8 months).    

Freemarketfx Ireland Limited was authorised more than 2.5 years after it was incorporated in Ireland on 23 March 2021. According to Irish companies registration records, Freemarketfx Ireland is 100% owned by FreemarketFX Limited in the UK, which as per the UK FCA records, has been an Authorised Payment Institution since 16 May 2018.

Our Peter Oakes last spoke with Charlie Taylor of the Business Post on the topic of regulatory authorisations on Sunday 20 August 2023.

• Peter Oakes, a former Central Bank enforcement director and founder of Fintech Ireland, said a firm setting up in Ireland needs to be aware that the upfront and post-authorisation costs in the first year will set them back about €1.5 million.
• “A considerable part of this outlay is required ahead of approval with no guarantee it will be given,” Oakes said.
• “No one wants to say this because everyone will say that by doing this you are not flying the green flag. Some consultants hide behind that because they might not be engaged [by clients] and risk losing other client work both pre and post authorisation in areas such as tax, IP, employment, commercial and corporate work. No-one should be surprised by this,” he added.

Ireland is now home to 47 legal entities which provide either payment services or emoney services.  There are 26 payments services firms in Ireland which includes 4 account information services providers and 22 emoney firms.  The records of four firms state that their authorisations were withdrawn.  The three that are no longer authorised to provide services in Ireland are Xpress Money Services Limited,  SWFS Ireland Limited and Modulr FS Europe Limited.  The 4th entity, noted above, Interpay Limited (TransferMate) switched from payments services only to an electronic money (plus payment services 3b, 3c, 5, 6).


Further Reading: See our post on the release of version 11 of this Map for more information.