[Update: The CompliReg page has been updated to include the Central Bank's Supervisory expectations for CASPs and issuers of ARTs and EMTs. You now download from one spot the so-called 'Holy Trinity' of Central Bank of Ireland's cryptoasset documentation as follows:

1) Application Form for Markets in Crypto Asset Regulation
2) The Key Facts Document
3) MiCAR Authorisation and Supervision Expectations

https://complireg.com/casp-micar.html]

Great to finally see that Ireland's National Competent Authority for #MiCAR (Markets in CryptoAssets Regulation) has published:

1) An Application Form (35 pages) to complement the MiCAR Key Facts Document (32 pages)
2) A statement confirming that "to ensure successful implementation of the new MiCAR regime in Ireland, cognisant of business demands and the 12-month transition period, we have put in place a well-resourced and expert team to deal with the CASP authorisation process. This team will continue to engage extensively and constructively with the sector and applicants."

CompliReg has helpfully placed a copy of both the MiCAR Application Form and the previously published Key Facts Document on its website here https://complireg.com/casp-micar.html. Get in touch with them if you are on the journey to become MiCAR authorised in Europe. Ireland is but just one country where the team works on MiCAR and Emoney/Payment authorisations.

We understand that Crypto Assets Ireland is holding its second #DigitalAssets meeting later this month. Since its arrival on the scene in mid January, Crypto Assets Ireland founded by Joe McCann has run informative in-person and online events and has published a lot of useful stuff. Explains why there are more than 600 followers of its linkedin page which went live just over two months ago. Click its name above to follow it (to learn about its next event) and also kindly follow Fintech Ireland which is supporting the Crypto Assets Ireland initiative with content and information.


What is the new MiCAR Application Form?
1. General information
2. Programme of Operations
3. Prudential requirements
4. Governance arrangements and internal control mechanisms.
5. Business Continuity
6. Detection and prevention of money laundering and terrorist financing
7. Management Body
8. Shareholders or members with qualifying holding
9. ICT systems and related security arrangements
10. Segregation of clients’ crypto-assets and funds
11. Complaints-handling
12. Custody and administration policy
13. Operating rules of the trading platform and market abuse detection
14. Exchange of crypto-assets for funds or other crypto-assets
15. Execution Policy
16. Provision of advice or portfolio management on Crypto-assets
17. Transfer Services
18. Cross-border provision of crypto-asset services
19. Other comments
​
​Source - Peter Oakes

It is a busy Q4 2024 in the Irish crypto asset sector with 6 Virtual Asset Services Providers obtain registration with the Central Bank of Ireland.  And all six are very welcome to the Fintech Ireland and MiCA Ready Fintech Maps.  Special thanks to the CompliReg for sponsoring and supporting this edition (version 9) of the the Virtual Asset Service Providers Map.    

Joining the Irish Fintech Ecosystem are:

1. CoinJar Europe Limited - registered to provide services: #i, ii, iii & iv *
2. Figure Markets Ireland Ltd - registered to provide services: #iii
3. Legend Financial Ireland Limited - registered to provide services: #i & ii
4. HashKey Europe Limited - registered to provide services #i, ii, iii & iv
5. Fidelity Digital Assets Ireland Ltd - registered to provide services #i, iii & iv
6. StoneX Digital International Ltd - registered to provide services ##i, ii, iii & iv

​
* Service Provided as appearing on Central Bank Register as at 4 December 2024:

(i) Provision of exchange services between virtual assets and fiat currencies
(ii) Exchange between one or more forms of virtual assets;
(iii) Transfer (to conduct a transaction on behalf of another natural or legal person that
moves a virtual asset from one virtual asset address or account to another) of virtual assets
(iv) Custodian wallet providers


The above six VASPs bring the total number of Registered VASPs in Ireland to 21, joining these other 15 VASPs.

• Gemini Intergalactic Europe Limited
• Zodia Custody (Ireland) Limited 
• Coinbase Europe Limited 
• Coinbase Custody International Limited 
• Paysafe Payment Solutions Limited
• Payward Europe Solutions Limited (Kraken)
• NoFrixion Limited
• Pionew Ireland Limited
• Moonpay Technology Services Limited                
• Zodia Markets (Ireland) Limited 
• Ripple Markets Ireland Limited
• Fortuna Digital Custody Ltd
• Ramp Swaps (Ireland) Limited
• Foris DAX Global Limited (Crypto.com)
• Sors Digital Assets Limited

The increase in the number of Registered VASPs brings the total number of Authorised and Registered Fintechs to at least 82 players.  This definition of fintech covers VASPs, Emoney Firms, Payment Institutions, AISPs and PISPs authorised or registered in Ireland. There are other firms, such as MiFID firms that are likely fintech and will include those we identify on a Map at a later date.

​Find these 82 Authorised and Registered fintechs on the Map below.

Ireland is now home to at least 75 regulated fintechs with the registrations of both Foris DAX Global Limited (aka Crypto.com) and Sors Digital Assets Limited.  The two companies were registered by the Central Bank of Ireland under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 as virtual asset service providers.  To remind, VASPs are not authorised but registered to provide their services.

Linkedin Post here: https://www.linkedin.com/posts/peteroakes_cryptoasset-virtualasset-micar-activity-7219828976863641601-fNxw

Fintech Ireland is delighted to welcome both firms to the ever-growing Regulated Fintech Map (Version 11) and the VASP Map (version 8).  Thanks to CompliReg and MiCA Ready which support firms in the  in the #cryptoasset / #virtualasset industry.

By the way, did you know that today (19 July 2024) is the second anniversary of the very first registration of a VASP?  That honour belongs to Gemini Intergalactic Europe Limited which was registered on 19 July two years ago.  Happy anniversary!

This registration of Crypto.com on 7 June 2024 and Sors Digital Assets on 16 July 2024 increases the pool of regulated fintech in Ireland to at least 75, comprised of:

* 27 authorised electronic money institutions
* 22 payments institutions,
* 6 standalone open banking firms,
* 15 VASP, and
* 5 crowdfunding services providers.

Those who read the recent Authorisation and Gatekeeping Report issued by the Central bank of Ireland might recall:

• that as at 31 December 2023 there were 14 applicants for a VASP registration in the pipeline as at that date.  Obviously deduct 2, and that means if there have been no withdrawals and no new applications, we might see a further 12 firms become registered before year’s end.  If that is the case the Central Bank will have its work cut out for itself dealing with potentially 27 MiCAR applications. Of course, it would be wise to assume that further companies have applied for registration since the start of this year.
• the average number of days taken to register a VASP is 530 calendar days and is largely driven by time taken by the applicants to respond to queries raised during the assessment. A significant number of firms have withdrawn from the registration process. 

According to Companies Registration Office Records, Sors Digital Assets is a shareholder (32.67%) in Fortuna Digital Custody Ltd which was registered as a VASP by the Central Bank of Ireland earlier this year on 9 May 2024.  Sors Digital Assets is owned by Brian Elders (55%) and Stephen Browne (45%).  Brian Elders is a director of both Sors Digital Assets and Fortuna Custody Ltd.  Sors Digital Assets had net assets of €769K as at 31 December 2023.  Stephen Browne is another director of Sors Digital Assets.

​Foris DAX Global Limited is wholly owned by  Foris Dax Holdings Ltd.  Its directors are Mariana Dinkova Gospodinova, Rafael De Marco E Melo and Antonio Alvarez Lorenzo.  Within the Crypto.com group, Mariana serves as EVP Operations & GM Europe; Rafael is co-founder and CFO; and Antonio is Group Chief Compliance Officer.  Crypto.com's VASP registered operations made a small overall profit (comprehensive income) of €71.4K in the year to 31 December 2022 well down on the €3.120M profit for the previous year.  The company's net assets as at 31 December 2022 were €3.2M.   

We wish both Crypto.com and Sors Digital Assets the very best success for their future endeavours.
​​

Fintech Ireland Newsletter: If you wish to receive the regular Fintech Ireland Newsletter for a round-up of fintech news and our events, sign-up here.  We use MailChimp, so you can sign-up and unsubscribe with ease. ​

Since mid August 2023, it has been very quiet at the Virtual Asset Services Provider end of town when the then last VASP, MoonPay, was registered in Ireland on 15 August.

Fintech Ireland and MiCAReady.com have published version 4 of the Map (with assistance from Susan O’Neill of SuLu Solutions and Peter Oakes of Fintech Ireland), updated to include Zodia Markets (Ireland) Limited.  Zodia Markets today (26 October 2023) joins Zodia Custody (Ireland) Limited, the latter which was registered back in July 2022, on version 4 of the Fintech Ireland Registered VASP Map.

The VASPs are registered by the Central Bank of Ireland for Anti Money Laundering/Countering the Financing of Terrorism purposes under Section 106A of the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010 to 2021.  They are not, as such, 'authorised' firms.

Welcome Zodia Markets (Ireland) Limited to the Map.

Zodia Markets was registered by the Central Bank of Ireland on 26 October 2023.  Specifically, it is registered for service numbers: (i) exchange between virtual assets & fiat currencies; and (ii) the exchange between one or more forms of virtual assets.  Zodia Custody is registered in Ireland for service numbers: (iii) transfer of virtual assets -  conduct a transaction on behalf of another; and (iv) custodian wallet provider.  Zodia Custody was the second of 10 VASP registered in Ireland when it became registered back on 29 June 2022.

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

Zodia Market's local board of directors (according to Companies Registration Office records) are Nicholas Philpott and Michael Walsh.  The VASP was incorporated on 16 June 2021.

In a statement released on Linkedin by Zodia Markets its Chief Executive Officer, Michael Walsh, commented: “The registration will act as a launchpad for the business to enter the EU, a market where we see significant opportunity and demand for our offering”.   In the statement, Zodia Markets said "That this exciting development will enable it to provide services to clients throughout the European Union ahead of the implementation of the Markets of Cryptoassets Regulation. 

BTW, Fintech Ireland and Peter Oakes are supporting both (1) MiCA Ready which tracks materially important EU news on MiCA and (2) Digital Assets Africa.   If you need assistance with getting your VASP registered in Ireland or elsewhere in Europe reach out to Peter.

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
• Version 3, August 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. 
 

​