Crypto ATM / kiosk operator in Ireland
Physical kiosks that exchange cash for crypto (and sometimes vice versa). High-cash AML risk profile.
Crypto ATM is conditionally permitted in Ireland with a local entity, subject to AML obligations and high licensing burden.
Verdict Details
- Permitted
- conditional
- Local entity required
- Yes
- Licensing burden
- High
- Last updated
- 2026-07-13
AML Obligations
- CASP authorization under MiCA via the Central Bank of Ireland (CBI) is required — 6–12 month rigorous application process with detailed outsourcing and operational resilience documentation
- CDD/KYC obligations under Part 4 of the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010–2021: identify customers, verify identities, understand transaction purpose, assess risk profile
- Suspicious Transaction Reporting (STR): VASPs must monitor for ML/TF suspicious activity and report to authorities; enhanced mechanisms under WCTR empower FIUs to suspend suspicious crypto transfers
- Record-keeping obligations: maintain records of all transactions, CDD, and monitoring to demonstrate AML/CFT compliance
- 5AMLD transposition: fiat-to-crypto operators (including crypto ATM/kiosks) must register with CBI, apply KYC/due diligence, and report suspicious activities
- Individual Accountability Framework applies to senior management — personal accountability for AML/CFT compliance failures
Key Restrictions
- CASP authorization is mandatory — operating an unregistered crypto ATM/kiosk would be illegal under MiCA and Irish AML law
- Must be a CBI-authorized CASP to offer fiat-to-crypto exchange services via kiosks — no standalone kiosk-specific license exists; it falls under the CASP/VASP regime
- Physical kiosk operations involving cash-in/cash-out are high-risk under AML classifications, likely requiring enhanced ongoing monitoring and CDD for each transaction
- No specified cash-transaction reporting threshold identified in provided facts — this is a gap (likely subject to EU Travel Rule and CBI guidance on cash transactions)
- Sanctions screening obligations apply via CBI International Financial Sanctions regime and OFAC/global sanctions guidance
Key Risks
- High-cash AML risk profile makes crypto ATM/kiosks a likely target for CBI enforcement; no public precedent of CBI-authorized crypto ATM operators as of the data
- Regulatory ambiguity around specific cash-transaction reporting thresholds for crypto kiosks — no explicit EUR threshold stated in provided facts
- CBI's rigorous authorization process (6–12 months) and Individual Accountability Framework create significant senior-management liability exposure
- No dedicated crypto ATM/kiosk licensing pathway — operator must map all activities to existing CASP categories, creating classification risk
- Travel Rule compliance (WCTR) for crypto transfers out of kiosks adds operational complexity for cash-in/cash-out flows
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
CBI — CASP authorization, VASP registration, AML supervision. Coinbase and Gemini chose Ireland as EU base.
MiCA Regulation (EU) (2023) — CASP authorization, comprehensive crypto regulation
Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (amended) (2021) — Pre-MiCA VASP AML registration
VASP: CASP authorization under MiCA via Central Bank of Ireland. 6-12 months (CBI rigorous). Individual Accountability Framework applies to senior management.
EXCHANGE: CASP authorization with EU-wide passporting — CBI requires detailed outsourcing and operational resilience documentation
Customer Due Diligence (CDD/KYC): VASPs must conduct CDD, including identifying customers, verifying identities, understanding transaction purposes, and assessing risks, as outlined in Part 4 of the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010 to 2021. This involves stricter KYC obligations like user identity verification and real-time monitoring, with no anonymous crypto transactions allowed.
Suspicious Transaction Reporting: VASPs must monitor transactions for suspicious activity related to money laundering or terrorist financing and report to the relevant authorities, with enhanced mechanisms under WCTR empowering financial intelligence units to suspend suspicious crypto transfers.
Record-Keeping Obligations: VASPs must maintain records of transactions, CDD, and monitoring to demonstrate compliance with AML/CFT rules.
Central Bank of Ireland (CBI): Designated National Competent Authority (NCA) under MiCAR for authorizing/supervising Crypto-Asset Service Providers (CASPs), enforcing AML/CFT for VASPs, and issuing consumer warnings.
EU Fifth Anti-Money Laundering Directive (5AMLD): Transposed via Irish law requiring VASPs (fiat-to-crypto exchanges, custodian wallets) to register with CBI, apply KYC/due diligence, and report suspicious activities. Registration ongoing; 15 VASPs listed as of July 2024.
Markets in Crypto-Assets Regulation (MiCAR): EU Regulation published 9 June 2023; applicable to ARTs/EMTs from 30 June 2024 and CASPs from 30 December 2024. Irish implementation: S.I. No. 607/2024 - European Union (Markets in Crypto-Assets) Regulations 2024 (published 12 November 2024), designating CBI as NCA for issuance, custody, trading platforms/exchanges.
Central Bank of Ireland International Financial Sanctions: https://www.centralbank.ie/regulation/how-we-regulate/international-financial-sanctions
Ireland Global Sanctions Guide: https://ezine.eversheds-sutherland.com/global-sanctions-guide/ireland
OFAC Virtual Currency FAQs: https://ofac.treasury.gov/faqs/topic/1626
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- medium
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Conditional — a crypto ATM/kiosk operator may serve Irish residents only after obtaining CBI CASP authorization under MiCA (high burden, 6–12 months), with full CDD/KYC, STR, record-keeping, and sanctions screening obligations, but no specific cash-transaction reporting threshold or dedicated kiosk-licensing pathway is identified in the provided facts.
Questions this verdict aims to answer
- What money-transmitter / kiosk-specific license is required?
- What cash-transaction reporting thresholds apply?
- What enhanced-KYC obligations attach to cash-in / cash-out?