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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

On 4th October 2023, Fidelity Digital Assets released its Bitcoin First Revisited Report - Why investors need to consider bitcoin separately from other digital assets. DOWNLOAD HERE.

The copyright in the report [and this blog] belongs to by Chris Kuiper and Jack Neureuter and Fidelity Digital Assets.

STARTS:

Background
In January 2022, we outlined Bitcoin’s unique characteristics, why they make Bitcoin fundamentally different from other digital assets, and why this is important for investors to consider. Over a year and a half later, Bitcoin continues to gain adoption and market share in the digital asset space, while other digital assets have faced separate headwinds. While we encourage those seeking a detailed understanding of Bitcoin’s unique value propositions to read the earlier overview, we aim to reiterate many of Bitcoin’s fundamental advantages below while contextualizing Bitcoin’s progress and position within today’s current digital asset market. 

Executive Summary 
Once investors have decided to invest in digital assets, the next question becomes, “Which one?” Of course, bitcoin is the most recognized, first-ever digital asset, but there are hundreds—even thousands of other digital assets in the ecosystem. 
One of the first concerns investors have regarding bitcoin is, as the first digital asset, it may be vulnerable to innovative destruction from competitors (such as the story of MySpace and Facebook). Another common consideration surrounding bitcoin is whether it offers the same potential reward or upside as some of the newer and smaller digital assets that have emerged. 

In this paper, we propose: 

1. Bitcoin is best understood as a monetary good and one of the primary investment theses for bitcoin is as the store of value asset in an increasingly digital world. 
2. Bitcoin is fundamentally different from any other digital asset. No other digital asset is likely to improve upon bitcoin as a monetary good because bitcoin is the most (relative to other digital assets) secure, decentralized, sound digital money and any “improvement” will potentially face trade-offs. 
3. There is not necessarily mutual exclusivity between the success of the Bitcoin network and all other digital asset networks. Rather, the rest of the digital asset ecosystem can fulfill different needs or solve other problems that bitcoin simply does not. 
4. Other non-bitcoin projects should be evaluated from a different perspective than bitcoin. 
5. Bitcoin should be considered an entry point for traditional allocators looking to gain exposure to digital assets. 
6. Investors should hold two distinctly separate frameworks for considering investment in this digital asset ecosystem. The first framework examines the inclusion of bitcoin as an emerging monetary good, and the second considers the addition of other digital assets that exhibit venture capital-like properties. 

ENDS

DOWNLOAD HERE

The copyright in the report [and this blog] belongs to by Chris Kuiper and Jack Neureuter and Fidelity Digital Assets.

Source: ​https://www.fidelitydigitalassets.com/research-and-insights/bitcoin-first-revisited

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.

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