Focus on Cryptos

Author: Clerkin Lynch LLP

Date Published 12/04/2023

Update to VASP Register

The Central Bank of Ireland maintains a public register of firms registered as “Virtual Asset Service Providers” or “VASPs” pursuant to Section 106A of the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010 to 2021.

Virtual Asset Service Providers are registered and supervised by the Central Bank of Ireland for the purposes of anti-money laundering and countering the financing of terrorism . In this regard a “Virtual Asset Service Provider” means a person who by way of business carries out one or more of the following activities for, or on behalf of, another person: (a) exchange between virtual assets and fiat currencies; (b) exchange between one or more forms of virtual assets; (c) transfer of virtual assets, that is to say, conduct a transaction on behalf of another person that moves a virtual asset from one virtual asset address or account to another; (d) custodian wallet provider; (e) participation in, and provision of, financial services related to an issuer’s offer or sale of a virtual asset or both; but does not include a designated person that is not a financial or credit institution and that provides virtual asset services in an incidental manner and is subject to supervision by a national competent authority, other than the Central Bank of Ireland. A “Virtual asset” for such purposes means a digital representation of value that can be digitally traded, or transferred, and can be used for payment or investment purposes. Virtual assets do not include digital representations of fiat currencies, securities and other financial assets.

The register now shows a total of six entities being registered as VASPs in Ireland. Payward Europe Solutions Limited is the latest addition, having been registered in April 2023. Paysafe Payment Solutions Limited was also registered earlier this year. The remaining entities are Zodia Custody Ireland Limited , Gemini Intergalactic Europe Limited, Coinbase Custody International Limited and Coinbase Europe Limited. The scope of the registrations of these entities is in respect of a slightly different range of services under this regulatory regime so care should be taken to ensure the relevant entity has the appropriate registrations before engaging.