Welcome Decta Limited to the regulated fintech ecosytem in Ireland!  Its authorisation brings the pool of regulated fintech in Ireland to 68, comprised of:

• 27 authorised electronic money institutions
• 21 payments institutions,
• 4 standalone open banking firms
• 11 virtual asset services providers and
• 5 crowdfunding services providers. 

Decta Limited's authorisation is the 2nd emoney institution to be authorised so far this year. The most recent payments company authorised was Etsy Ireland Limited and previous to that it was emoney firm Navro Payments Europe Limited.

As we said back on 20 February 2024, we are pretty sure that these numbers will continue to grow in 2024.

In what must have felt as extended St Patrick Day's long weekend for the Irish Decta Team, the company was authorised by the Central Bank of Ireland on Tuesday 19 March 2024 as an emoney institution. 

Decta Limited has been authorised to provide emoney services and payment services #3 (Execution of credit transfers, including standing orders) and #5 (Issuing of payment instruments and/or acquiring of payment transactions). 

Some observations:

• ​Why did Decta seek an authorisation in Ireland when another Decta Limited became authorised in Cyprus for emoney services on 10 August 2023?
• The Irish company was incorporated back on 1 October 2021.  That seems a long time from its incorporation date to today for an entity to become authorised - nearly 30 months. While a firm may not start an application immediately after it is incorporated, most firms - where they are the subsidiaries of foreign firms - start the journey no later than three to six months following incorporation.  If one was conservative and went with the six month timeline, it may have taken Decta Limited 24 months to become authorised.    
• It appointed its first set of Irish resident NEDs on 1 June 2022, with one of them leaving just after Christmas Day 2023 following the appointment of another NED just before that Christmas period.
• In addition to the NEDs, the company's local CEO sits on its board together with two group executives including its Cypriot authorised company's CEO and its Deputy CEO. 
• The Irish comapny's shareholders are RRE Tradecenters Holding Limited based in Cyprus and SIA "Suharenko Family Investments" based in Latvia, holding 67% and 33% of the Irish company respectively.   
• SIA "Suharenko Family Investments" is a shareholder in the Latvia Bank, AS “Rietumu Banka”.  
• Irish billionaire Dermot Desmond owns a one-third stake in Rietumu Banka.  Its group profits fell 37pc to €11.4m in the first nine months of 2023.
• Decta's operations in the UK, Decta Limited (UK), are authorised by the Financial Conduct Authority for emoney and payment services. 
• Decta was cited by Transparency International UK in a report focused upon financial crime risk.  The very informative report titled 'Together in Electric Schemes, Analysing Money Laundering Risk in E-Payments' was issued in December 2021.  The Bank was hit by two regulatory sanctions.  The largest sanction was a fine of €80mn later reduced by a French appeals court to €20mn.  According to The Baltics Times on 24 April 2023 "The Supreme Court in Paris concluded that the money laundering would not have been possible without Rietumu Banka. The case materials showed evidence of at least EUR 200 million laundered through the bank."  

• According to CRO records for Decta Limited as at year end December 2022 the company incurred a loss of €114.1K, had Net Current Assets of €46.9K and Net Liabilities of €110.6K.

​The Decta brand was called out by Transparency International UK in a report focused upon financial crime risk.  The very informative report titled 'Together in Electric Schemes, Analysing Money Laundering Risk in E-Payments' and issued in December 2021 carried a case study in which it noted that:

"[s]ome Latvian banks now own UK EMIs. Decta Limited, a UK EMI, lists its PSC as Rietumu Holding, the firm behind Rietumu Bank in Latvia.  In 2017, Rietumu was fined €80 million by French authorities after it was found to be involved in major tax and money laundering schemes. In response to an investigation by independent global media organisation, openDemocracy, Decta Limited stated it “acts in strict accordance with the requirements of FCA”, adding “we regularly pass anti-money-laundering (AML), Anti-Fraud, Know Your Customer and Combating the Financing of Terrorism audits held by Visa, Mastercard and big-four auditors, proving Decta to be complying with all latest AML standards.” 

In June 2021, Rietumu was fined again for money laundering failings in Latvia, this time in relation to its association with payment service providers, including those based outside of the country. A page on the website of Latvia’s central bank (Latvijas Banka), shows Rietumu has correspondent banking relationships with at least six UK EMIs.

It is becoming increasingly clear that British EMIs using Baltic banks for clearing services raises money laundering risk for both the UK and Baltic states. UK EMIs with unsuitable owners or weak AML controls are unlikely to carry out sufficient checks on their clients, while Baltic banks may believe firms regulated by the FCA have higher AML standards than they do in reality. This situation would lead to international payments being made from British EMI accounts using Baltic correspondent banks without sufficient checks being carried out on who was making them. This is similar to the scenario that occurred in the “Laundromats” exposed by the OCCRP, which resulted in billions of pounds in suspicious transactions being sent around the world." (see page 15 of this document).

Read more media here:

19/04/2022 - Last year also saw an appeals court in Paris reduce to €20 million a previous €80 million fine levied by a French court in 2017 against the bank for allegedly enabling clients of a company called France Offshore to evade taxes and launder money through companies in tax havens.

24/04/2023 - Verdict of French court on fine on Rietumu Banka for money laundering takes force

• decision on EUR 20 million fine for money laundering has come into force

17/06/2021 - Latvian bank Rietumu fined 5.85 mln for money laundering failures 

​

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• Need assistance with an emoney or payments authorisation or an account information service provider or virtual asset services provider registration application, check out Fintech Ireland and CompliReg's handy authorisation guides at https://fintechireland.com/fintech-authorisations.html.  

2024 is off to a slow start for those expecting a slew of authorisations and registrations by the Central Bank of Ireland of electronic money institutions, payments institutions and virtual asset services providers.

2023 saw just 5 electronic money firms become authorised in Ireland and just 1 payments institution became authorised.  Given that one of the emoney firms authorised was an upgrade from a payments institution authorisation, Ireland only welcomed 4 new companies to its emoney / payments sector. There was better news for the local crypto industry with 7 virtual asset service providers becoming registered in 2023 out of a pool of 11 such firms. These virtual asset firms and others that may get registered in 2024 can look forward to a deeper and more intense authorisation process should they choose Ireland to be their European home under the Markets in Crypto Asset Regulation. Fingers crossed.  And note MiCAReady.com is here to help those firms and other plan for their pan-European Union journey.

​Thus far in 2024 just one of these types of companies has received the Central Bank's imprimatur, that being Navro Payments Europe Limited, formerly known as Paytrix Ireland Limited.  According to publicly available Central Bank records, Navro Payments Europe was authorised as an electronic money institution on Friday 2 February 2024 (and only appearing on the Central Bank's register run of 6 February). In addition to emoney services, Navro Payments Europe was also authorised to provide payment service #3c (i.e.  Execution of credit transfers, including standing orders.)

Last August it was announced that fintech industry pioneer Joe Redmond had joined the Paytrix team as the new CEO for Ireland to drive its compliance and expansion plans across Europe. Other heavy hitters involved with Navro Payments Europe includes Peter Rowan, who joined the board of directors on 28 September 2022 and is listed on his linkedin profile as General Manager in addition to his director role. Other board directors of the newly authorised Irish company are Paytrix founders Edward Harrison and Aran Brown.  

Navro Payments is 100% owned by Paytrix Holding Limited.  The company was rebranded Navro Payments according to Companies Registration Office records pursuant to section 32 of the Companies Act 2014.

​Ireland is now home to 26 authorised electronic money institutions, 21 payments institutions, 4 standalone open banking firms, 11 virtual asset services providers and 5 crowdfunding services providers.  Rumour has it that a few more firms will hit these registers in the coming days.  We'll wait and see. 

Looking back over the Period H1 2020 to H1 2023 - to co-ordinate with the Central Bank of Ireland’s own Regulatory Service Standards Performance Reports - there are some interesting observations. During that period, as shown in the image below, the regulator:

• received 171 applications
• completed 235 key information checks
• authorised 10 electronic money firms (one being an upgrade from payment institution authorisation [InterPay Limited] and another which subsequently withdrew its authorisation in 2022).
• authorised /registered just 7 payments firms, including a large portion being standalone open banking firms (i.e. AISP and PISP)

The data in the first two bullet points comes the section within the reports headed Payment Firms (Payment Institutions, Electronic Money Institutions, Small Electronic Money Institutions & Money Transmission Businesses) & Bureaux de Change Authorisations.  Unfortunately the regulator's statistics for Bureaux de Change do not show the date a firm was authorised/registered.  Further, in the absence of more detailed data, it is possible (if not probable) that there is some double counting here.  

The data in the last two bullet points comes from the regulator's registers. 

Based on the numbers of firms authorised/registered versus applications received, one might have a few questions about the throughput of applications at the Central Bank.  However, there is no point speculating or over analysing the limited information available in the public domain.  What we need to do so is publication of substantial, independent and detailed information about the authorisation process and deeper and richer metrics. 

What is fair to say is that since since 2017, when Ireland had just two electronic money firms, that number has swelled 12 fold to the start of February 2024. Over the same period, the number of payments firms (authorised and registered) has jumped from 10 to 25 in total (21 authorised and 4 registered). More impressive is the rapid but seemingly controlled growth of quality digital asset firms totaling 11 from July 2022 to the end of last year.

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. 

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

​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.