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 A significant number of firms have withdrawn from the registration process.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.
​​

Central Bank of Ireland has today, Wednesday 26 June 2024, issued the first edition of the Authorisations and Gatekeeping Report. 

We posted about this on Linkedin here.  You can watch the movie of extracts from the Report here.

In this blog you can download a copy of the Authorisations and Gatekeeping Report (in the next link below and at end of blog).  We have copied and pasted the forward by Sharon Donnery, Deputy Governor, Central Bank of Ireland immediately below.

Foreword

Sharon Donnery, Deputy Governor, Financial Regulation 

I am very pleased to introduce the Central Bank of Ireland’s (“The Central Bank”) inaugural “Authorisations and Gatekeeping Report". The Central Bank regulates and supervises over 12,000 firms providing products and services in Ireland, the European Union (“EU”) and around the world. Our mission is to serve the public interest by maintaining monetary and financial stability while ensuring that the financial system operates in the best interests of consumers and the wider economy. 

A strong regulatory and supervisory framework, ensuring we have a stable, resilient and trustworthy financial sector, enables us to deliver on our mission for the public. Our gatekeeping role is an integral part of that framework – helping to ensure firms and individuals are of a sufficiently high standard to meet regulatory requirements and to be trusted with the public’s money. Since 2018, the Central Bank has either authorised or approved close to 12,000 applications across a range of financial service providers, prospectuses and regulated financial products and has approved over 18,000 applications for senior positions in the financial sector in Ireland as part of our Fitness and Probity (“F&P”) regime. In 2023 alone, we received almost 3,300 applications for authorisation or approval and over 3,300 applications for senior positions.

In order to ensure the system and the public are protected and that trust is maintained, gatekeeping, and the phrase “regulated by the Central Bank of Ireland”, has to mean something in terms of standards and reassurance to the people of Ireland. As such, the process needs to be robust, and the standard needs to be appropriately high. 

However, given the volume of applicants and the benefits of new entrants for consumers and the wider economy, to ensure the gate is not an undue barrier to entry it is also important that the process is efficient and that it is transparent.

As such in recent years as part of our ongoing commitment to efficiency and in the face of feedback that we could improve our clarity and responsiveness to incoming applications, we have increased engagement and significantly improved our processes. We have done this while maintaining the high standard the public expects of regulated providers of financial services and of us.

As I have said before this is not about prioritising speed over rigour, as the authorisation process is just the beginning of the regulatory and supervisory relationship, and our experience is that going through the gate too swiftly often presents issues on the other side.

Recognising that better prepared firms find the authorisation process the most straightforward, in addition to increasing the efficiency and transparency of our own processes we have improved our communications and have set clearer expectations for firms. This aims to deliver better and more complete applications to the benefit of both the applicants and the Central Bank, increasing the efficiency of the gate, while maintaining its robustness. Through this new report, we are providing further transparency to all stakeholders. The report sets out how we discharge and continue to refine our authorisation mandate by:

• Providing information on our authorisation framework and risk appetite;
• Explaining our priorities and expectations of applicant firms;
• Providing insight into the operation of the F&P regime; and
• Outlining the key challenges that we see for firms seeking authorisation. 

We hope it is useful for all stakeholders, and complements our other engagements and publications. Looking ahead, enhancing how we regulate and supervise across all sectors is a strategic priority of the Central Bank. This includes continuing to enhance our authorisation processes, in terms of clarity, predictability and transparency for those seeking to be authorised.

​We will continue to improve our own process as well as our engagement and communication with the sector. We also want to learn from experience and welcome feedback from stakeholders on our processes. 

END

Download the inaugural “Authorisations and Gatekeeping Report"

​We will be covering the topics of Central Bank of Ireland Authorisations and its role as Gatekeeper to the regulated Irish financial services community at the Fintech Ireland Summit taking place on Thursday 28 November 2024.  Read more here.

​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. 

LinkedIN Post here - https://www.linkedin.com/feed/update/urn:li:activity:7201146292276711425/​


Ramp Swaps (Ireland) Limited joins the Fintech Ireland Maps following its registration as a Virtual Asset Services Provider on 17 May 2024.

This increases the pool of regulated fintech in Ireland to at least 73, comprised of:
​

• 27 authorised electronic money institutions,
• 22 payments institutions,
• 6 standalone open banking firms,
• 13 virtual asset services providers, and
• 5 crowdfunding services providers. 

Ramp Swaps was registered on 17 May 2024 a Virtual Asset Services Provider.  It is the second VASP to be registered thus far in 2024 by the Central Bank of Ireland. The previous registered VASP was Fortuna Digital Custody (see previous blog).

Ramp Swaps was incorporated in Ireland on 25 April 2023. The company is the 13th firm to become registered to provide crypto services in Ireland. 

According to records at the Companies Registration Office, the directors of the company are are Szymon Sypniewicz and Przemyslaw Kowalczyk who are co-funders of the Ramp Group. The group was established to make web3 accessible to all. According to Forbes "They prioritize safety and compliance in crypto and have experience in tech solutions and blockchain lending. Ramp focuses on user experience and partnerships and is registered with financial authorities.".

Ramp, which has been described as a 'PayPal for crypto' by Business Insider also registered as a Cryptoasset Services Provider by the UK FCA.  Poland's Ramp, which is building payment rails to allow more customers to invest in crypto, raised US$70mn in a Series B funding round announced on 11 November 2022. 

The Series B funding co-led by Mubadala Capital and Korelya Capital was a rare silver lining against a bleak crypto backdrop.  Ramp has now raised more than US$122mn in the last 12 months despite the current 'crypto winter'. The fintech will use the money to invest further in its product line, add local fiat currencies and payment methods, expand into new territories and hire fresh talent.

Coindesk reported on the registration on 23 May 2024.  In its reported it noted that:
​

• The Ramp Network is a financial technology company building payment rails connecting crypto to the global financial system. This registration will enable its users to exchange fiat currencies for more than 100 crypto assets.
• The company wants to make Ireland its European headquarters and has established a team and operation in Dublin. It intends to get authorized as a Crypto Asset Service Provider (CASP) under the Markets in Crypto Assets Regulation (MiCA).

Fortuna Digital Custody Limited and ACE Money Transfer Limited join the Fintech Ireland Maps following their respective registration as a Virtual Asset Services Provider and authorisation as a payments institution.

This increases the pool of regulated fintech in Ireland to 72, comprised of:
​

• 27 authorised electronic money institutions,
• 22 payments institutions,
• 6 standalone open banking firms,
• 12 virtual asset services providers, and
• 5 crowdfunding services providers. 

Fortuna Digital Custody Limited was registered on 9 May 2024 a Virtual Asset Services Provider.  It is the first VASP to be registered thus far in 2024 by the Central Bank of Ireland. The last VASP registered in Ireland before Fortuna was close to 5 months ago in December 2023.

Fortuna was incorporated in Ireland on 22 January 2021. The company is the 12th firm to become registered to provide crypto services in Ireland. 

According to records at the Companies Registration Office, the directors of the company are Neil Fleming, 
Juergen Hoebarth (Founder) and Brian Elders (Founder).  Connor Cantwell (Founder) is listed as company secretary.  The shareholders of the company are Cosimo Venture Partners (32.67%), Tokenization Limited (32.67%), Sors Digital Assets Limited (32.67%) and Neil Fleming (25). 

Ace Money Transfer Limited was authorised on 3 May 2024 as a payments institution by the Central Bank of Ireland for payment service #6 permission, which is money remittance.  

Ace Money Transfer was incorporated in Ireland on 3 September 2021.  Another example of a long journey between incorporation and regulation by the Central Bank of Ireland.  

Ace Money Transfer is 100% owned by another Irish company AFTAB Currency Exchange Limited.

We'll update this post with other information about the two companies at a later date.

 Eagle eyed might have notice that we had to re-jig CRIF RealTime Ireland Limited on the Map. Since first appearing as #8 (account information services) only services in early 2022, the Central Bank of Ireland registers subsequently showed the company as having both #7 (payment initiation services) and #8 around 14 July 2022.  Then in 2024, CRIF RealTime Ireland Limited reappeared on 22 April 2024 as reverting back to payment service 8 only.

The Minister for Finance, Michael McGrath TD, has today (19 April 2024) published a Mapping Report on the development of a National Financial Literacy Strategy in Ireland.

1. Financial literacy and education is an important part of financial consumer protection. Financial literacy covers people’s awareness, behaviour, knowledge, attitudes and skills in relation to money and is an important skill that everyone should have throughout their lives.
2. This report collates the extent of the current provision, across many organisations, of financial education in Ireland, and provides evidence, analysis and recommendations for the next stage of the design and development of a national strategy.
3. On the basis of extensive stakeholder engagement to date, including responses to a stakeholder survey issued in August 2023, this report describes the various bodies currently involved in delivering financial education in Ireland. It also sets out potential gaps and themes to be addressed in a financial literacy strategy and stakeholder expectations of that strategy.

Where and how is fintech referred to in the Mapping Report? 

Fintech referenced in the National Financial Literacy Strategy Mapping Report?

• "This is in addition to emerging risks with non-bank lending, Fintech, and climate change" (Hmm - Fintech is a risk?)

 

• "In recent years, the banking landscape in Ireland has changed significantly. According to the 2023 Consumer Banking Sentiment Survey15 , published by the Department of Finance in September 2023, while the two pillar banks continue to dominate the market in terms of market share of current accounts held, the survey results show that the use of ‘fintech’ (which includes a growing use of apps on smartphones and contactless payments by customers of traditional banks) has increased as has a rise in the market share of “digital only” banking providers, such as Revolut."

 

• "In terms of FinTech providers, the Survey results show that the top features of such providers for consumers are instant money transfer, free banking and a great/user-friendly mobile app. This is followed by splitting bills, spending information, foreign exchange and saving vault, while investment opportunities are the least important. Switching of banking products is very low in Ireland with many citing a general perception of it being difficult to switch, but general inertia being the most prominent reason."

 

• "The use of ‘fintech’, which includes a growing use of apps on smartphones and contactless payments by customers of traditional banks, has increased, as has a rise in the market share of “digital only” banking providers." 

 

• "One of the priority themes of the strategy is ‘Fintech & Digital Finance’. Under this theme, recent Ireland for Finance Action Plans included actions on financial literacy in order to support the public to adapt to the growth of fintech in retail activity. This involved the development of educational consumer resources by the CCPC in cooperation with the Department of Finance and the Central Bank"

See also https://www.gov.ie/en/press-release/23ccb-minister-mcgrath-publishes-mapping-report-on-the-development-of-a-financial-literacy-strategy-in-ireland/