Crypto License in Ireland

Step 1: Register a Legal Entity in Ireland

Before applying for a crypto license, you must set up a company in Ireland. The most common business structure for crypto firms is a Private Limited Company (LTD).

Requirements for Company Formation:

• Company Name: Must be unique and compliant with Irish business regulations.
• Registered Office Address: A physical business address in Ireland is mandatory.
• Directors & Shareholders: At least one director (who can be a foreign national) and one shareholder are required.
• Company Secretary: If there is only one director, a separate company secretary is needed.
• Minimum Share Capital: No specific capital requirement, but you must demonstrate financial stability.
• Tax Registration: Register for corporate tax, VAT (if applicable), and employer payroll taxes.

Step 2: Appoint Key Personnel

To comply with CBI fitness and probity standards, the company must appoint qualified personnel for key compliance roles.

Mandatory Positions:

• Compliance Officer (MLRO – Money Laundering Reporting Officer): Responsible for AML policies, risk assessments, and reporting suspicious transactions.
• CEO or Managing Director: Oversees business operations and regulatory compliance.
• Risk & Finance Officer: Ensures the firm’s financial and operational stability.
• Local Representative in Ireland: At least one senior executive must be based in Ireland.

Step 3: Develop AML & CFT Compliance Policies

A core requirement for obtaining a VASP registration is proving strong Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) measures.

Key AML/CFT Requirements:

• Customer Due Diligence (CDD): Implement KYC (Know Your Customer) procedures to verify customer identities.
• Transaction Monitoring: Use automated monitoring systems to detect suspicious activities.
• Record Keeping: Maintain detailed records of customer transactions and compliance reports.
• Suspicious Transaction Reporting (STR): Submit reports to Ireland’s Financial Intelligence Unit (FIU).
• Employee Training: Regular AML/CFT training for staff handling crypto transactions.

Step 4: Prepare & Submit the VASP Registration Application

Once the company is registered and AML policies are in place, you must submit the VASP registration application to the Central Bank of Ireland (CBI).

Required Documents for VASP Registration:

• Business Plan: Outlines your company’s objectives, operations, and target market.
• AML/CFT Risk Assessment: Identifies potential money laundering and terrorist financing risks.
• Policies & Procedures Manual: Includes AML/CFT policies, customer verification processes, and security measures.
• Corporate Structure Chart: Shows the company’s ownership and management structure.
• Proof of Office Address: Required to demonstrate a physical presence in Ireland.
• Director & Shareholder Details: Includes passports, proof of address, and CVs.
• Source of Funds Declaration: Demonstrates that the business is financially sound.
• Fitness & Probity Questionnaires: Submitted electronically via the CBI’s Online Reporting System (ONR).

Step 5: Undergo Regulatory Review by the Central Bank

After submission, the Central Bank of Ireland (CBI) will conduct an in-depth review of your application.

Regulatory Review Process:

• Initial Assessment: The CBI checks for completeness and accuracy of the application.
• Risk-Based Review: Evaluates the company’s AML/CFT framework, business model, and financial health.
• Additional Information Requests: The CBI may ask for clarifications or supplementary documents.
• Compliance Interviews: Senior management (CEO, Compliance Officer) may be required to attend an interview with regulators.

Step 6: Approval & Registration as a VASP

Once the Central Bank is satisfied that your company meets all regulatory requirements, you will be granted VASP registration.

After Approval:

• Receive Registration Certificate: Official confirmation from the Central Bank of Ireland.
• Begin Operations: You can now legally offer crypto services in Ireland and across the EEA.
• Ongoing Compliance Monitoring: Regular audits, reporting, and potential onsite inspections.

📌 Note: Even after approval, your company remains subject to CBI supervision, and any non-compliance may result in penalties or revocation of the license.

Step 7: Maintain Compliance & Renew Registration Annually

Obtaining a crypto license in Ireland is just the beginning—ongoing compliance is crucial for maintaining registration.

Key Compliance Obligations:

• Annual AML/CFT Audit: Submit reports to the CBI and Financial Intelligence Unit (FIU).
• Transaction Reporting: Notify authorities of any suspicious activities.
• Director & Personnel Vetting: Inform the CBI of any changes in management or ownership.
• Regulatory Updates: Stay compliant with evolving EU and Irish crypto laws (e.g., MiCA Regulation).

📌 Renewal Requirement: Annual re-registration with the Central Bank.