Virtual Asset Service Provider

Central Bank of Ireland
Application for Registration Information

Virtual Asset Service Provider
Application for Registration Information

For those seeking to apply for registration as a Virtual Asset Service Provider (‘VASP’), the The Central Bank of Ireland (‘Central Bank’) is the competent authority in Ireland with responsibility for the AML/CFT registration and supervision of VASPs under the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010 to 2021, as amended (‘CJA 2010 to 2021’). It is important to note that a registration as a VASP is a registration for AML/CFT purposes only.

VASPs are “designated persons” for the purposes of the CJA 2010 to 2021 and are required to comply with the AML/CFT obligations contained under Part 4 of the CJA 2010 to 2021.

Applicant Firms applying for AML/CFT registration will have to submit an application to the Central Bank. In order for the Central Bank to approve an application for registration, the Central Bank must be satisfied that an Applicant Firm’s AML/CFT policies and procedures are effective in combatting the money laundering and terrorist financing (‘ML/TF’) risks associated with its business model, and an Applicant Firm’s management and beneficial owners are fit and proper.

Each applicant seeking registration must satisfy the Central Bank that it can meet its obligations under the CJA 2010 to 2021. In fulfilling its statutory role in this regard, the Central Bank adopts a robust, structured and risk-based process that seeks to ensure that only those applicants that demonstrate that they are in a position to comply are registered.

The Central Bank will process each application for registration as expeditiously as possible, while meeting its obligation to operate a rigorous and effective gatekeeper function.

Application Process

Before Applying for Registration

In advance of submitting a VASP AML/CFT registration form, the Applicant Firms should satisfy itself that:

- the services it is proposing to offer constitute VASP services as set out in the CJA 2010 to 2021;
- it is in a position to comply with its AML/CFT obligations under the CJA 2010 to 2021; and

The onus is on the Applicant Firm to ensure that it is satisfied that it is conducting a VASP activity. Independent legal advice should be sought if an Applicant Firm is in any doubt as to whether registration is required.

Summary of the Key Stages in the Registration Process

1. Applicant submits a VASP Pre-Registration Form to the Central Bank.
2. The Central Bank issues an email to the applicant containing an Institution Number, a Reporting Date and details on how to access and submit a VASP AML/CFT Registration Form via the Central Bank’s Online Reporting (’ONR’) system.
3. The applicant submits a VASP AML/CFT Registration Form and all supporting documentation through the ONR system.
4. The Central Bank acknowledges receipt of the VASP registration submission by email to the Applicant Firm.
5. The Central Bank assesses whether the VASP registration submission contains all required information and documentation to progress to the assessment phase and notifies the Applicant Firm by email.
6. Where all the required information and documentation has been provided, the Central Bank conducts an assessment of the registration application. Where necessary, the Central Bank will request further information and/or clarification from the applicant.
7. The applicant is provided with the opportunity to respond to the Central Bank’s request for further information and/or clarification.
8. The Central Bank will assess the additional information provided by the applicant and notify the applicant of its assessment and next steps. The applicant may be provided with a further opportunity to address concerns arising at this stage in the process (if any).
9. The Central Bank will notify the applicant of its decision to either grant or refuse the registration.

Documentation that is required to accompany the
Application for Registration

Applicants should submit the following fully completed registration forms:

1. VASP AML/CFT Registration Form (including the specific information and documentation requested therein)
2. Beneficial Owners Application Forms, as appropriate:
1. Application for each Legal Person or Other Entity Type who is a beneficial owner in an Applicant VASP
2. Application for each Natural Person who is a beneficial owner in an Applicant VASP
3. The applicant will also need to ensure that all relevant individuals proposed to hold Pre-Approval Controlled Function roles complete
Fitness and Probity Individual Questionnaires. Individual Questionnaires must be submitted electronically via the Central Bank’s ONR
system by all relevant individuals. Applicants should review the Central Bank’s Guidance on Fitness and Probity Standards 2018 before
submitting an Individual Questionnaire.

How We Can Help You
Setting up your VASP entity in Ireland!

We assist in the full registration process with Central Bank of Ireland.

If you are looking to obtain a Crypto Asset Services Provider (VASP) license in Ireland, Atrium Legal Lab can offer you its legal, technical and business expertise and consulting support.

Our dedicated Financial Services Regulatory Team works closely with clients who are subject to AML / CFT requirements across a number of sectors. We have also advised a number of clients engaged in providing crypto services in Ireland.
We have vast experience in dealing with AML / CFT issues across the spectrum from establishing an AML / CFT framework and preparing policies and procedures; providing annual training; advising on suspicious transaction report filings; advising on governance and outsourcing arrangements related to AML / CFT and guiding clients through themed inspections and supervisory / enforcement engagement on AML / CFT.

Further Information

Virtual Asset Service Providers ('VASPs')
Regulation of providers of services relating to virtual assets
Click Here!

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