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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• Sign up to our Newsletter here.
• 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.  

We have added, with a very warm welcome, the following to the ‘Ireland’s Regulated Fintech Ecosystem (Payments & Crowdfunding)" Map Version 2:

1. Payoma Ireland Limited (authorised electronic money institution)
2. Bridge Peer Financial Limited trading as Property Bridges (authorised crowdfunding services provider)
3. Slua Ventures Ltd t/a Spark Crowdfunding (authorised crowdfunding services provider)

 
Payoma has also been added to our other regulated fintech map, Version 14, showcasing emoney and payments firms only.

Ireland is now home to 62 authorised or registered fintech across emoney, payments, open banking and crowdfunding.

​Payoma was authorised as an electronic money institution on 3 November 2023, and in addition to electronic money services is authorised to provide payment services 3a, 3b, 3c and 5. 

It is 100% owned by Payoma Limited in the UK which is authorised as an emoney firm by the Financial Conduct Authority. Payoma continues a trend of firms happy to go on the record about their positive experience of dealing with Ireland’s national competent authority, the Central Bank of Ireland saying in a statement “Our heartfelt gratitude extends to the entire team at the Central Bank of Ireland for their unwavering support and belief in the potential of our project. Their guidance has been invaluable, and it is with their assistance that we have realized this ambitious goal.”

Property Bridges and Spark Crowdfunding, both authorised by the cut-off date of 10 November 2023 join Seedrs Europe Limited as the only locally authorised crowdfunding service providers. 

Further Reading:

• Release of version 13 of the Regulated Fintech Emoney & Payments Map 

Sign-up to the Fintech Ireland Newsletter here to keep up to date with Irish fintech news, follows us on Twitter and follow the Fintech Ireland's Linkedin Page.  If you are first connections with Peter Oakes, you can also join the Fintech Ireland Group on Linkedin.

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. 

Sign-up to the Fintech Ireland Newsletter here to keep up to date with Irish fintech news, follows us on Twitter and follow the Fintech Ireland's Linkedin Page.  If you are first connections with Peter Oakes, you can also join the Fintech Ireland Group on Linkedin.

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

On 14 March 2022 (Central Bank of Ireland run date 15 March 2022), Ireland authorised Gemini Payments Limited.  This was the first such authorisation of an emoney firm since 27 October 2020.

Ireland is now home to 18 authorised electronic money institutions, 20 authorised payment institutions and 4 standalone account information service providers. We have updated our regulated fintech Map to version 6.0 where we showcase these firms.

Our Peter Oakes spoke with Charlie Taylor of the Irish Times on the authorisation of the Winklevoss twins Irish licence and wider digital asset issues facing Ireland.

In the article Peter Oakes said:

• an interesting play for Gemini in Ireland could be institutional wealth management and custody. Many large financial institutions, especially US banks operating in Ireland, have a strong interest in digital assets for both themselves and their clients. They generally segregate their trading and investment activities from the very specialised but fairly lucrative pricing and custodial responsibilities of digital assets.
• he expects to see Gemini to eye up a role in servicing Ireland’s €5.4 trillion assets under administration in the IFSC in the years to come.
• while there remains challenges about the perception of Ireland being an effective home for regulated digital assets, the arrival of Gemini as well as the existing Irish business of Coinbase help set the groundwork, and attraction, for other international and hopefully indigenous fintechs to follow bolstering employment in cutting edge technology and innovation.
• he expects Gemini will complement its new fintech licence with an Irish crypto asset registration to replicate its UK and international services.

Visit our Fintech Ireland Maps page for more information about the fintech and regtech companies we map.

Links:

1) Irish Times Article 20 March 2022: https://www.irishtimes.com/business/financial-services/winklesvoss-twins-secure-irish-e-money-licence-for-gemini-payments-1.4831606
2) Linkedin Post 20 March 2022: https://www.linkedin.com/posts/peteroakes_paymentservices-facebook-cryptoasset-activity-6911588283806277632-GaM0

Click here for Video

Cold day to be outside talking about the hot topic of #bitcoin and #cryptoassets / #digitalassets for Fintech Ireland with Will Goodbody of RTE, who also interviews Henrik Andersson, CFA (CIO Apollo Capital) and Lory Kehoe (Adjunct Assistant Professor, Trinity Business School) about their thoughts on #crypto as an asset class and regulation.

I am seeing:

1) a ramp up in scam investments, riding the epic wave of the #BTC price increase aimed at luring people into the FOMO (fear of missing out) opportunities; and

2) the loss of sight of the 'democratisation of financial services' and decentralised ethos' of #crypto in favour of speculative nature of 'assets' like bitcoin.

Don't read my comments as being negative on decentralisation and distributed ledger technology; they are leading to many interesting cost effective and time efficient applications.

Rather be wary of the bitcoin salespeople whose interests have noting to do with the " purely peer-to-peer version of electronic cash [that] would allow online payments to be sent directly from one party to another without going through a financial institution" heralded in the abstract of the Nakamoto paper.

Or put another way, 'don't lose sight of the forest for the trees'.

Linkedin Post here: https://www.linkedin.com/feed/update/urn:li:activity:6764935828859887616

And follow Fintech Ireland on LinkedIn here: https://www.linkedin.com/company/9349449