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.    

During the back half of May, Ireland was in the CFT/AML limelight with ACAMS Europe* and the European Anti-Financial Crime Summit both held in Dublin. This gave Ireland the opportunity to showcase the huge strides the nation is trying to make to combat financial crime. The key theme that I personally did not see come out as much as I’d like is the collaboration between Banks and FinTechs with Regulators and Enforcement agencies. 

There were great keynotes from the likes of Seana Cunningham, Central Bank of Ireland’s Director of Enforcement and Anti-Money Laundering, who clearly illustrated the critical value in recognising shared goals and valuing collective effort; raising awareness and being vigilant; and understanding the changing risks. Additionally, given the much-anticipated launch of the EU Anti-Money Laundering Authority, irrespective of where they land the HQ*, clearly shows the global movement to more collaboration across states to fight financial crime. 

So, why not act locally within Ireland and drive more collaboration within the State as well?

Globally we are seeing some states like Hong Kong, UAE and the UK all announcing banks, enforcement and regulators combining forces to have a more collaborative approach to the joint battle. Ireland only having three (3) banks would suggest that more collaboration across these banks is a logical approach. While we can appreciate the restrictions of ‘over sharing’ due to GDPR restrictions, there must be an argument for sharing intelligence of high-risk economic crime activity across our society’s first line of defence in protecting the integrity of our financial system.

​The benefits of this collaborative approach to protect the risk of suspicious activity surely outweighs the paranoia.
​
But what about the FinTechs in Ireland? 

​Ireland is well positioned as a breeding ground for FinTech’s and Payment Companies in Europe. In a recent piece written by IDA’s Chloe Wade, Ireland is continuing to scale and grow and there is a visible presence of sub-sectoral growth in Ireland in areas like digital payments, cross-border payments, payment gateways, digital banking, digital remittances, open banking, regtech, blockchain, and digital assets.

​International companies such as R3, Remitly, S&P Global, Revolut, MoneyCorp, and Boku have made Ireland the hub of their operations. These institutions are growingly coming under the watchful eyes of regulators due to the growth in bad actors using FinTechs and Payment Companies to channel illicit funds into the financial system. These companies should definitely have a more active role in the battle to combat financial crime activity. 

How can the Banking and Payments Federation (BPFI) do more?

While BPFI have been instrumental in driving more collaboration, there are limitations given not all Banks and FinTech’s are actively involved in this joint effort. But it doesn’t stop there. In a recent article posted by Pearse Doherty, Deputy Leader (Dáil), Spokesperson on Finance and Public Expenditure and Reform, Pearse calls for more accountability for telecommunications and internet service providers and even social media. Usually when fraudulent activity occurs through these channels, the customer is already exposed, and the damage is done. This clearly shows that there is a need in Ireland for the wider cross-checking of account information which has proved to be successful in the Netherlands and Britain.

Conclusion

Ireland has become a global hub for FinTechs and Payment Companies alike and while this is fantastic for FDI and overall economic growth of the nation, there is more responsibility that these high-growth institutions should adopt in protecting the integrity of the financial services system. The  banks in Ireland, coupled with the FinTechs and Payment Companies, Regulators and Enforcement, can and will position Ireland as one of the safest countries to conduct transactions. Thus, setting the stage for further growth in a socially responsible and compliant manner.

The contents of this article are those of the author, Amardeep (Deep) Hansra, Global FinTech and RegTech professional.  Deep is on the Fintech Ireland Advisory Council.
​
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​* Further Reading:

• Fintech Ireland’s Founder Peter Oakes was a member of a cryptoasset panel at ACAMS Europe and also joined the ACAMS Great Crypto Debate on: The Future of Finance or Unleashing Havoc.
• Fintech Ireland supports MoneyLaundering.ie which collates and publishes useful financial crime typologies  
• Minister McGrath announces intention for Ireland to seek to host EU Anti-Money Laundering Authority
• Previous guest blog – Ireland’s VASPs holding their own against the UK? The Virtual Asset Service Providers Landscape in Ireland (co-authored by Susan O’Neill of SuLu Solutions and Peter Oakes of Fintech Ireland)