CBI's New Enhanced Flexibility For QIAIF Digital Asset Exposure

On 4 April 2023, the Central Bank of Ireland ("Central Bank") published a new AIFMD Q&A ("New Guidance") that increases the limits for a Qualifying Investor AIF ("QIAIF") seeking indirect exposure to digital assets and removes the need for a Central Bank pre-submission under the limits depending on the QIAIF's liquidity.

Background

The QIAIF regime has long been the most popular category of regulated Irish AIF in Ireland. The speed to market of the QIAIF has been a key feature supporting the success of the regime as a result of the Central Bank's 24-hour fast-track authorisation process. No prior regulatory review of authorisation applications is required, except for a number of limited exceptions. Instead, the Central Bank relies on a certification of compliance with the relevant requirements from the investment fund's legal advisers and the AIFM.