On-shore VASP in Ireland
Locally-incorporated VASP that operates under full local jurisdiction, holding all required licenses and registrations.
On-shore VASP 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 — 6-12 month rigorous application process
- Pre-MiCA VASP AML registration under Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (amended) — transitioning to MiCA regime
- Customer Due Diligence (CDD/KYC) per Part 4 of the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010-2021
- Suspicious Transaction Reporting to relevant authorities, with enhanced mechanisms under WCTR
- Record-keeping obligations for transactions, CDD, and monitoring
- Travel Rule compliance: EUR 0 threshold under TFR recast (effective December 2024); full data sharing for all VASP-to-VASP transfers
- EU 5AMLD obligations — registration with CBI, KYC/due diligence, suspicious activity reporting
- Compliance with EBA guidelines for AML risk management and ESMA technical standards
Key Restrictions
- Must be locally incorporated in Ireland or establish a legal presence
- Individual Accountability Framework applies to senior management
- CASP authorization required for custody, exchange, and other VASP activities
- Detailed outsourcing and operational resilience documentation required by CBI
- Must comply with MiCA regulation (applicable to CASPs from 30 December 2024)
- 33% capital gains tax on crypto disposals via Revenue Commissioners self-assessment
Key Risks
- CBI is known as a rigorous regulator — application timelines of 6-12 months are common and may extend
- Transition period from pre-MiCA VASP AML registration to full MiCA CASP authorization creates regulatory uncertainty
- All crypto disposals subject to 33% CGT — tax compliance burden on operator and users
- Sanctions compliance obligations under CBI oversight and OFAC/global sanctions regimes
- Competitive landscape with 22+ VASPs already registered as of Q4 2024
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.
Evidence fact ie.tax not found (may have been renamed).
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 — an on-shore VASP may operate in Ireland by obtaining MiCA CASP authorization through the Central Bank of Ireland (6-12 month process), incorporating locally, and complying with comprehensive AML/CFT, Travel Rule, and tax obligations under CBI supervision.
Questions this verdict aims to answer
- What license(s) are required to operate locally?
- What capital, governance, and reporting obligations apply?
- What is the application process and timeline?