Centralized exchange in Ireland
Order-book exchange that takes custody of user assets and matches trades between users.
CEX 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 Central Bank of Ireland (CBI) — 6–12 month rigorous process with Individual Accountability Framework for senior management
- Customer Due Diligence (CDD/KYC) per Part 4 of the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010–2021
- Suspicious Transaction Reporting (STR) to CBI/FIU with enhanced mechanisms under WCTR
- Record-keeping obligations for transactions, CDD, and monitoring
- Travel Rule compliance under EU recast FTR — EUR 0 threshold (no de minimis); full originator/beneficiary data required on all transfers
- EU 5AMLD transposed into Irish law — KYC, registration, and suspicious activity reporting for fiat-to-crypto and custodian wallet providers
- Ongoing supervision by CBI for AML/CFT compliance
Key Restrictions
- Must obtain MiCA CASP authorization from CBI — custody, exchange, and order-matching are separate licensed activities under MiCAR
- Local entity incorporation required — CBI regulates CASPs with a presence in Ireland
- Detailed outsourcing and operational resilience documentation required by CBI
- Senior management subject to Individual Accountability Framework
- EU Travel Rule applies with zero threshold — all withdrawals/transfers must carry originator/beneficiary information
- Must comply with EU and Irish financial sanctions regimes (CBI International Financial Sanctions)
Key Risks
- CBI is known for rigorous authorisation process — 6–12 month timeline and high compliance bar may delay market entry
- Regulatory ambiguity around how MiCA interacts with existing Irish AML legislation (pre-MiCA VASP regime is being phased out but transitional arrangements may apply)
- Third-party reports list 22 VASPs as of Q4 2024, but official register data may differ — competition and CBI scrutiny may increase
- Sanctions compliance complexity (EU sanctions + OFAC FAQs for virtual currency — extraterritorial risk for USD-linked activity)
- Rapidly evolving regulatory landscape (MiCA full applicability from Dec 2024) creates transitional compliance risk
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.
CUSTODY: CASP authorization — custody is a licensed MiCA activity
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.
Travel Rule adopted — threshold: EUR 0 (no threshold under TFR recast)
Adoption and Effective Date: Adopted via the EU recast FTR, effective December 2024. Ireland, as an EU member, implements this uniformly, with the Central Bank of Ireland overseeing supervision.
Threshold Amounts: Follows the FATF-recommended €1,000 (or USD 1,000 equivalent) de minimis threshold for virtual asset transfers, above which full Travel Rule data must be shared; requirements may vary below this per EU rules.
VASPs Covered: All VASPs, including those handling crypto transactions, must comply for both originating and beneficiary roles in transfers.
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- high
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Conditional — a centralized exchange can operate in Ireland only after obtaining MiCA CASP authorization from the Central Bank of Ireland (6–12 month rigorous process), incorporating locally, and complying with full AML/KYC obligations, zero-threshold Travel Rule, and CBI operational resilience requirements.
Questions this verdict aims to answer
- What exchange / VASP license applies?
- What custody segregation rules apply to user assets?
- What market-conduct and listing rules apply?
- What travel-rule obligations apply on withdrawals?