A review of recent requirements for Virtual Asset Service
Providers
As of 23 April 2021, firms involved in the provision of
crypto-asset services will note the commencement of certain
sections of the Criminal Justice (Money Laundering and Terrorist
Financing) (Amendment) Act 2021 (the "2021
Act") which transposed into Irish law the European
Union's Fifth Anti-Money Laundering Directive.
The introduction of the 2021 Act has had the effect of bringing
virtual asset service providers
("VASPs") within its scope and such
VASPs will now be required to register with the Central Bank of
Ireland (the "Central Bank") along with
having to fulfil its other AML/CFT obligations. Importantly,
firms not established in Ireland and/or not carrying on business as
a VASP prior to the 2021 Act coming into force are obligated to
register with the Central Bank before carrying out any business
relating to virtual assets from Ireland. VASPs already
established in Ireland and carrying
