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ARTICLE · 18 APRIL 2023

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Central Bank Updates Its Q&A On Digital Assets For QIAIFs

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On 4 April 2023, in a welcome development the Central Bank of Ireland (the "Central Bank") updated its AIFMD Q&A (47th edition) to increase the investment limits for qualifying investor...

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On 4 April 2023, in a welcome development the Central Bank of Ireland (the "Central Bank") updated its AIFMD Q&A (47th edition) to increase the investment limits for qualifying investor alternative investment funds ("QIAIFs") seeking exposure to digital assets:

  • where a QIAIF is open-ended it can gain exposure to digital assets of up to 20% of net asset value ("NAV"); and
  • where a QIAIF is closed-ended or is open-ended with limited liquidity it can gain exposure to digital assets of up to 50% of NAV.

The requirements in order for QIAIFs to avail of these limits are set out in ID1145 of the revised Q&A as follows.

Where a QIAIF proposes to invest indirectly in digital assets the following requirements apply:

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