SEE UPDATED NEWS BLOG OF 1 JULY 2020 AND NEW MAP HERE 

Above you will find the map of regulated emoney firms and payment services firms as displayed in the registers at the Central Bank of Ireland on 8 April 2020. 

One question we are often asked is how does a company get authorised as either an emoney or a payment services firm in Ireland.  To answer that recurring question, we wrote two guides in partnership with CompliReg, founded by a leading regulatory and central banking expert.  You can find the authorisation guides on our website here. And please feel free to contact us or CompliReg if you have questions.

A number of non-indigenous Irish #fintech firms have asked how can Fintech Ireland make noise about their presence in Ireland. The easiest way for us to do so is where the fintech has received an authorisation/registration from the Central Bank of Ireland (CBI).

The map immediately above (powered by CompliReg) shows those firms appearing on the CBI's public records displayed on 8 April 2020 as either authorised/registered #payments service firms or authorised #emoney firms. The group includes both indigenous Irish fintech and international fintech authorised in one of those two categories.

They are:
Payments Firms:
AIB Merchant Services, Western Union, Fexco, CurrencyFair.com, TransferMate Global Payments, #Fire, CUSOP (Payments) Ltd, #PrimaFinance, Avantcard, Barclaycard, #Chasepaymentech, Google Pay, #smallworld, AFEX, BUREAU BUTTERCRANE LTD, Remitly, J.P. Morgan, Circit.io, Xpress Money, CRIF & Finclude (fka. Verge.Capital)
​
Emoney Firms:
EML, Facebook, Soldo, Optal, Paysafe Group, paysafecard.com, Prepaid Financial Services Limited (PFS), #foreigncurrencydirect, Stripe, Coinbase. One4all Group & Payoneer.

Those firms in the above map which are indigenous to Ireland also appear on our bigger Fintech Ireland Map version 3.0 which you can find here. 

If you use this graphic and other material on this website, please give a shout out to Fintech ireland and direct your colleagues and business contacts to the website.

Today we posted an article on Linked with the above Fintech Ireland graphic which shows the fintech companies which have Payment Services Directive (PSD 2) and Emoney Directive authorisations from the Central Bank of Ireland (CBI) and those registered as Account Information Service Providers (AISP) with the CBI under the PSD 2.  

Percentage wise there was a noticeable increase in 2019 in both PSD & Emoney firms. Figures are based on CBI data as of today. All firms were authorised by the end of 2019. 

The two firms appearing at the bottom right in the PSD section Circit.io & CRIF are registered as AISPs only.  However Stripe, Fexco, fire.com & Paysafe Group are all permitted to provide payment initiation services & account information services.

Particular mention is made of the regulated fintech pioneers in Ireland such payments firms - TransferMate, CurrencyFair, AIB Merchant Services, Western Union, Fexco and Fire; as well as Emoney firms Perfect Card and Facebook. 

In summary, the Irish Central Bank has authorised/registered:

* 12 EMoney Firms
* 18 Payment Services Firms 
* 2 AISPs

Although it is great news that Ireland is continuing to attract fintech companies to our shores, there is certainly a lot of competition out there.  In a recent Financial Times article, it was reported that "[t]he Lietuvos bankas / Bank of Lithuania had, by the end of 2019, issued e-money licences to 64 fintechs with about 40 more applications under examination. That ranks well behind the UK, which has more than 150 regulated fintechs, but ahead of all other EU countries, none of whom has more than 20."

Other firms in the Fintech Ireland graphic not already mentioned above include:

Prepaid Financial Services, Optal, Soldo, Foreign Currency Direct plc, Coinbase, One4all Group,  #PrimaFinance, Barclaycard, Chase, J.P. Morgan, CUSOP (Payments) Ltd, Small World Financial Services, #GooglePay and Associated Foreign Exchange 

4th July 2019 - FCA issues Dear CEO Letter to E-Money and Payment Services firms on 'Safeguarding arrangements of non-bank payment service providers'.

If you believe that you may have trouble providing the attestations required to be given to the FCA contact Peter Oakes (linkedin profile) who is working with both UK and Irish professional services firms which are helping fintech firms with their regulatory obligations.

Here's a short summary of the FCA's findings (with links providing further detail):

1) Problems with segregation
There were significant shortcomings identified in firms’ safeguarding arrangements including:
• poor understanding of which funds are relevant and should be segregated;
• delays in segregating funds following receipt; and
• failing to check that the correct amounts are being segregated frequently enough (i.e. through reconciliation processes)

2) Weak risk management and oversight
Sample of firms showed insufficient oversight of arrangements for managing the risks to customer funds. Examples of this included:
lack of detail and rationale in policy documentation
lack of effective and regular monitoring and review of safeguarding.
Several firms with rapidly evolving business and operating models could evidence adequate consideration of the impact of their operational changes on safeguarding arrangements.

3) Priority areas for improvement and some points firms should consider to help ensure that customer funds are protected in an insolvency event. Click here to read more

4) Examples of how firms have operationalised the requirements in line with the rules and guidance, and other examples of non-compliant processes. Click here to read more

The FCA now expects all relevant firms to review their current safeguarding arrangements, including the rationale for the decisions made, to make sure they fully meet the requirements.

The FCA expects firms should, if not already done, map each of its products or services to determine when the funds they hold are relevant funds and whether they require additional safeguarding arrangements.

Where a firm has identified inadequacies, the FCA expects the firms to take prompt remedial action. This includes notifying the FCA in writing without delay if in any material respect the firm has not complied with or is unable to comply with the requirements in regulation 20 of the EMRs or regulation 23 of the PSRs. 

• PSD Firms must complete and return the Safeguarding Attestation - Authorised Payments Institutions
• E-Money Firms must complete and return the Safe Guarding Attestation - Electronic Money Institutions 

Note: Each and every Electonic Money Firm and Authorised Payments Institution must respond by confirming one of the following statements to the FCA:

A) I confirm that my firm has carried out a review of its safeguarding procedures taking into account the guidance in the FCA’s Approach Document and the letter of 4 July 2019 date.  I confirm that I am satisfied that my firm complies with the safeguarding requirements set out in regulation 23 of The Payment Services Regulations 2017. OR

B) My firm has ceased to carry out payment services and is taking appropriate steps to cancel its authorisation.

The FCA says that it is requiring this attestation to gain a personal commitment from each relevant firm that specific action has been taken. The FCA's aim is to ensure that there is clear accountability and senior management focus on those specific issues where the FCA would like to see change within firms. 

Fintech Ireland is continuing its international tour of hot fintech hubs. Following a very successful launch of Fintech Cyprus (www.fintechcyprus.com) at the start of April, here are our other upcoming trips to showcase fintech in Ireland and support Irish fintech abroad:

Lisbon, Portugal: 25th & 26th April - Foreign Direct Investment Trade & International Collaboration Mission
Abu Dhabi, United Arab Emirates: 30th April to 2nd May - Foreign Direct Investment Trade & International Collaboration Mission.  See Events Page. 
Valletta, Malta: 8th to 10th May - QUBE Events, NexGen Payments Forum (see Events Page and www.fintechmalta.com)
London, United Kingdom: 20 & 21 May 2019 - City Week 2019 (Further Details Here)
New York, USA: 28th May to 31st May - Foreign Direct Investment Trade & International Collaboration Mission (Details to Follow)

To learn more, contact us via email [email protected] and/or via Linkedin (include a message with any connection request!)
  

Coinciding with the QUBE Events 7th NextGen Payments Forum, Peter Oakes of Fintech Ireland has helped launch www.fintechmalta.com.  Join us at QUBE Events 7th NextGen Payments Forum in Valletta, Malta on 9th and 10th May 2019 to learn more about Fintech Malta.  Book using the unique Fintech Malta 20% discount code at https://fintechmalta.com/events.html

We look forward to seeing you in Malta on May.