On 23 April 2021, crypto-asset services became subject to
regulation in Ireland for the first time. On that date, the
relevant sections of the Criminal Justice (Money Laundering and
Terrorist Financing) (Amendment) Act 2021, which gives effect to
provisions of the EU's Fifth Money Laundering Directive
(Directive 2018/843/EU), came into force.
Although focused on anti-money laundering compliance, the new
supervisory regime will have wider implications for firms providing
crypto-asset services, their managers and their owners.
What services are in scope?
The new legislation introduces the concept of a "virtual
asset service provider" (VASP). A VASP is
defined as a person or firm who by way of business carries out one
or more of the following activities on behalf of another: