Fintech News from Ireland and around the World

Updated Regulated Fintech Map (Emoney and Payments v11.0)

2/8/2023

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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 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.

Our Peter Oakes spoke with Charlie Taylor of the Business Post on Sunday 3 July 2022 about the registration of Experian Ireland as an AISP:

"The news was also welcomed by Peter Oakes, a former Central Bank enforcement director and founder of Fintech Ireland, an industry group."Irish customers will be able to share transactional information from their bank account with other banks and third parties. Customers will be able to better monitor, control and improve the way their banking data is used, including managing their so-called ‘credit score’ when looking for financing.
“We are yet to see the fruits of open banking in Ireland to the same degree as elsewhere. Together with other fintechs providing open banking, Irish consumers and small businesses will enjoy more choice in an increasingly competitive landscape," Oakes said.

Further Reading: See also Charlie Taylor's article on the authorisation of emoney and payment services firms and the issues firms are facing getting authorised in Ireland in his article of 10 April 2022 titled D efensive attitude of Central Bank putting off fintech investors. And see our News posts of:

25 April 2022 on the announcement of Bookings Holding becoming an authorised emoney firm; and
10 April 2022 titled Defensive attitude of Central Bank putting off fintech investors.

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Virtual Asset Service Providers Landscape in Ireland - Map 2.0

17/7/2023

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Welcome NoFrixion and Pionew Ireland to Fintech Ireland's Registered Virtual Asset Service Providers Map v 2.0

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. [See April 2023 Blog here]

We have now updated the Map to Version 2 as at Monday 17 July 2023.

Welcome NoFrixon Limited and Pionew Ireland Limited to the Map.

No Frixon was registered on 31 May 2023 and Pionew Ireland followed on 11 July 2023. Both firms are registered to

(i) provision of exchange services between virtual assets and fiat currencies
(ii) exchange between one or more forms of virtual assets; and
(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.

Pionew Ireland is also registered be a (iv) Custodian wallet provider.

They join Coinbase Europe Limited, Coinbase Custody International Limited, Gemini Intergalactic Europe Limited and Zodia Custody Ireland Limited and Paysafe Payment Solutions Limited.

According to records at the Companies Registration Office,

NoFrixion Ireland has 6 Irish resident directors (Aaron Clauson, Kathryn Hotten, Maurice Roche, Patrick Pinschmidt, Kieran Francis Mcloughlin and Feargal Brady); and
Pionew Ireland has two USA resident directors (Robert Francis Morris and Tang Guojing) and one Irish resident director (Anne Rothwell).

BTW, Fintech Ireland and Peter Oakes are supporting MiCA Ready which tracks materially important EU news on MiCA and Digital Assets Africa

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More collaboration between Irish Banks and Fintechs to fight Financial Crime

5/7/2023

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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?

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

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.

there is more responsibility that these high-growth institutions should adopt in protecting the integrity of the financial services system

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.

END

* 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)

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PSD3: The European Commission to revise rules to improve consumer protection and competition in electronic payments

28/6/2023

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These amendments, in the view of the European Commission, represent an evolution not a revolution of the EU payments framework. The amendments are aimed at improving the functioning of EU payment markets by:

strengthening measures to combat payment fraud;
allowing non-bank payment service providers (PSPs) access to all EU payment systems, with appropriate safeguards, and giving them a right to have a bank account;
improving the functioning of open banking, especially as regards the performance of data interfaces, removing obstacles to open banking services and consumer control over their data access permissions;
reinforcing the enforcement powers of national competent authorities and facilitating implementation of the rules clarifying various elements;
further improving consumer information and rights;
improving the availability of cash; and
merging the legal frameworks applicable to electronic money and to payment services.

Central Bank of Ireland Safeguarding Notice, 25 May 2023

31/5/2023

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Safeguarding Notice 25 May 2023
The purpose of this communication is to further clarify the nature of the specific audit of compliance with the safeguarding requirements under the Payment Services Regulations (PSR)/ Electronic Money Regulations (EMR), as communicated in the Central Bank’s letter dated 20 January 2023, addressed to all payment and electronic money institutions authorised in Ireland.

Following discussions with Chartered Accountants Ireland (CAI), an acceptable format for these engagements has been agreed, as detailed below. CAI will issue guidance to their members on performing these engagements in due course.

Click here for the (1) 25 May 2023 Safeguarding Notice; and (2) 20 January 2023 CBI Dear CEO Letter.

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Updated Regulated Fintech Map (Emoney and Payments v11.0)

Virtual Asset Service Providers Landscape in Ireland - Map 2.0

Welcome NoFrixion and Pionew Ireland to Fintech Ireland's Registered Virtual Asset Service Providers Map v 2.0

More collaboration between Irish Banks and Fintechs to fight Financial Crime

PSD3: The European Commission to revise rules to improve consumer protection and competition in electronic payments

Central Bank of Ireland Safeguarding Notice, 25 May 2023

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