Ireland -- Sanctions Compliance Regulatory Overview

Ireland's cryptocurrency sanctions framework operates under multiple overlapping regimes: the EU's MiCAR (Markets in Crypto Assets Regulation), the VASP (Virtual Asset Service Providers) framework established in April 2021, and international sanctions obligations from OFAC and other bodies.

EU and Domestic Framework

MiCAR Compliance: As of December 30, 2024, crypto asset service providers in Ireland must comply with MiCAR rather than the legacy VASP regime.[2] VASPs registered before that date received a 12-month transitional period (until December 30, 2025) to either obtain CASP authorization from the Central Bank of Ireland or cease operations.[2] The shift from VASP registration to CASP authorization represents Ireland's alignment with EU-wide crypto regulation.

VASP Requirements: Under the earlier regime, firms providing virtual asset services must be registered with the Central Bank of Ireland prior to commencing operations.[2] As of July 2024, fifteen entities were registered as VASPs in Ireland.[4]

International Sanctions Obligations

OFAC Compliance: U.S. persons and businesses subject to OFAC jurisdiction—including those operating in Ireland that facilitate transactions with U.S. involvement—must comply with OFAC sanctions regardless of whether transactions use digital or fiat currency.[5][6] This includes:

• Blocking access to sanctioned cryptocurrency addresses on OFAC's Specially Designated Nationals (SDN) List[1][5]
• Prohibiting transactions with blocked persons or entities[5]
• Implementing continuous screening beyond simple wallet-address matching, as OFAC warns that listed addresses are unlikely to be exhaustive[1]
• Reporting blocked assets to OFAC immediately[6]

EU Sanctions: The EU adopted sweeping sanctions packages in 2025, including measures explicitly targeting Russian crypto providers and related infrastructure.[3] Irish firms must operationalize the Travel Rule framework for crypto transfers under EU requirements.[1]

Sanctioned Entity Screening Obligations

VASPs must implement risk-based compliance programs that include sanctions list screening.[1][7] Obligations include:

• Screening against OFAC's SDN List and EU sanctions lists
• Building jurisdiction-specific logic into compliance programs rather than relying on generic global standards[1]
• Detecting exposure to sanctioned actors through continuous monitoring beyond simple address matching[6]
• Understanding that sanctions obligations apply to digital currency addresses, which can appear on the SDN List[1]

Firms cannot assume wallet-address matching alone solves compliance requirements.[1]

Penalties and Enforcement

The search results do not provide specific penalty amounts for violations. However, OFAC enforces sanctions with strict liability, meaning violations carry significant compliance risks.[6] OFAC has issued subpoenas to virtual currency businesses regarding customers and transactions.[7]

Country-Specific Sanctions Lists

The search results reference OFAC's SDN List and EU sanctions lists but do not provide direct URLs to Ireland-specific cryptocurrency sanctions lists. Ireland, as an EU member state, applies EU sanctions regimes. U.S. persons and non-U.S. entities with U.S. connections must also comply with OFAC sanctions, which have extraterritorial reach involving U.S. individuals, dollars, or the U.S. financial system.[6]

The Central Bank of Ireland and the Irish Financial Services Regulatory Authority would be the primary sources for jurisdiction-specific guidance, though the search results do not provide direct links to their crypto sanctions documentation.