Virtual Asset Service Provider - Application for Registration Information

The purpose of this section is to provide information to persons seeking to apply for registration as a Virtual Asset Service Provider (‘VASP’). The Central Bank of Ireland (‘Central Bank’) is the competent authority in Ireland with responsibility for the AML/CFT registration and supervision of VASPs under the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010 to 2021, as amended (‘CJA 2010 to 2021’). It is important to note that a registration as a VASP is a registration for AML/CFT purposes only.

VASPs are “designated persons” for the purposes of the CJA 2010 to 2021 and are required to comply with the AML/CFT obligations contained under Part 4 of the CJA 2010 to 2021.

Applicant Firms applying for AML/CFT registration will have to submit an application to the Central Bank. In order for the Central Bank to approve an application for registration, the Central Bank must be satisfied that an Applicant Firm’s AML/CFT policies and procedures are effective in combatting the money laundering and terrorist financing (‘ML/TF’) risks associated with its business model, and an Applicant Firm’s management and beneficial owners are fit and proper.

Each applicant seeking registration must satisfy the Central Bank that it can meet its obligations under the CJA 2010 to 2021. In fulfilling its statutory role in this regard, the Central Bank adopts a robust, structured and risk-based process that seeks to ensure that only those applicants that demonstrate that they are in a position to comply are registered.

The Central Bank will process each application for registration as expeditiously as possible, while meeting its obligation to operate a rigorous and effective gatekeeper function.

Application Process

Before Applying for Registration

In advance of submitting a VASP AML/CFT registration form, the Applicant Firms should satisfy itself that:

  • the services it is proposing to offer constitute VASP services as set out in the CJA 2010 to 2021;
  • it is in a position to comply with its AML/CFT obligations under the CJA 2010 to 2021; and
  • it has read the VASP Instruction Manual and Guidance Note, and has taken the information provided therein into consideration when completing the VASP AML/CFT Registration Form.

The onus is on the Applicant Firm to ensure that it is satisfied that it is conducting a VASP activity. Independent legal advice should be sought if an Applicant Firm is in any doubt as to whether registration is required.

Pre-Registration Meeting

The Central Bank offers the facility of an optional pre-application meeting to applicants, in order to answer specific questions about any aspect of the registration process and the completion of the VASP AML/CFT Registration Form. It is recommended that applicants avail of this meeting prior to the submission of the VASP AML/CFT Registration Form. Please note that applicants who wish to avail of this meeting should have prepared their registration material to an advanced state before requesting such a meeting, and should have their specific questions prepared in advance, so that the meeting can be as productive as possible. However, it is not within the remit of the Central Bank to provide advice at these meetings. If an applicant wishes to avail of a pre-application meeting, the applicant should send an email to [email protected].

Summary of the Key Stages in the Registration Process

  1. Applicant submits a VASP Pre-Registration Form to the Central Bank. Please email the completed form to [email protected].
  2. The Central Bank issues an email to the applicant containing an Institution Number, a Reporting Date and details on how to access and submit a VASP AML/CFT Registration Form via the Central Bank’s Online Reporting (’ONR’) system.
  3. The applicant submits a VASP AML/CFT Registration Form and all supporting documentation through the ONR system.
  4. The Central Bank acknowledges receipt of the VASP registration submission by email to the Applicant Firm.
  5. The Central Bank assesses whether the VASP registration submission contains all required information and documentation to progress to the assessment phase, and notifies the Applicant Firm by email.
  6. Where all the required information and documentation has been provided, the Central Bank conducts an assessment of the registration application. Where necessary, the Central Bank will request further information and/or clarification from the applicant.
  7. The applicant is provided with the opportunity to respond to the Central Bank’s request for further information and/or clarification.
  8. The Central Bank will assess the additional information provided by the applicant and notify the applicant of its assessment and next steps. The applicant may be provided with a further opportunity to address concerns arising at this stage in the process (if any).
  9. The Central Bank will notify the applicant of its decision to either grant or refuse the registration. 

Documentation that is required to accompany the Application for Registration

Applicants should submit the following fully completed registration forms:

  1. VASP AML/CFT Registration Form (including the specific information and documentation requested therein)
  2. Beneficial Owners Application Forms, as appropriate:
    1. Application for each Legal Person or Other Entity Type who is a beneficial owner in an Applicant VASP
    2. Application for each Natural Person who is a beneficial owner in an Applicant VASP
  3. The applicant will also need to ensure that all relevant individuals proposed to hold Pre-Approval Controlled Function roles complete Fitness and Probity Individual Questionnaires. Individual Questionnaires must be submitted electronically via the Central Bank’s ONR system by all relevant individuals. Applicants should review the Central Bank’s Guidance on Fitness and Probity Standards 2018 before submitting an Individual Questionnaire.

The completed VASP AML/CFT Registration Form, along with all relevant supporting documentation, must be submitted via the Central Bank’s ONR system.

Instructions and Guidance to Submit VASP Registration Forms on the Online Reporting System | pdf 1638 KB

Key Stages in the Application for Registration Process

Stage 1 – Acknowledgement

The Central Bank will acknowledge receipt of an application for registration submitted on the ONR system by the applicant.

Stage 2 – Information Check

The Central Bank will check that the application for registration information and documentation submitted on the ONR system is complete (i.e. contains all the required information and documentation).  The Central Bank will email the applicant to advise either of the following:

  1. That the application for registration contains the required information and documentation to proceed to the assessment phase (further information is likely to be required as part of the assessment phase and may be required thereafter, before a decision will be made in respect of the application for registration); or
  2. That the application does not contain all the required information or documentation to proceed to the assessment phase and as a result, the application cannot proceed to the assessment phase. Details of any information omitted from the registration application will be provided to the applicant. The application for registration will not be assessed by the Central Bank until the completed application is received.

Stage 3 – Assessment Phase

Where all the required information and documentation has been received, the Central Bank will proceed to the assessment phase of the application process. The application (including all accompanying documentation) will be assessed against the registration requirements as set out in the CJA 2010 to 2021, to determine whether sufficient information has been provided to enable the Central Bank to make a determination as to whether the applicant can be registered.

During the assessment phase, the Central Bank will issue comments and/or questions to the applicant based on its assessment and review of the application for registration. The Central Bank may also request further documentation to be provided by the applicant. It will be the responsibility of the applicant to provide clear detailed responses to the comments and/or questions. The Central Bank will assess the applicant’s responses and may issue further comments and/or questions based on its review of the responses submitted by the applicant.

Stage 4 – Notification of Assessment

The Central Bank will notify the applicant of the outcome of the Assessment Phase of the application process as follows:

  1. Where the assessment is favorable, the Central Bank will notify the applicant in writing that it is minded to register the applicant on the basis of the information provided in the Applicant Firms application. This letter will also specify any specific conditions the Central Bank proposes to impose on the registration, once granted. Further, it will explain the reasons for the proposed conditions (if any). The applicant will be afforded 21 calendar days to make representations in respect of the proposed conditions before the Central Bank makes a final decision on the application.
  2. In the event that the Central Bank is not satisfied with the applicant’s application following the Assessment Phase, the Central Bank will notify the applicant in writing of the grounds on which the Central Bank is minded to refuse the registration of the applicant. The applicant will have 21 days to make written representations to the Central Bank detailing why the Central Bank should grant the application. 

Stage 5 – Notification of Decision

The Central Bank will assess any representations submitted by the applicant following Stage 4 above.

The Central Bank will then notify the applicant in writing, of its final decision, as follows:

  1. Registration

    The Central Bank has decided to grant registration.

  2. Registration with Specific Conditions

    The Central Bank has decided to grant registration with specific conditions attached to the registration. The specific conditions will be set out in the letter.

  3. Proposed Refusal of Registration
    Where the Central Bank is still minded to refuse registration following an applicant’s written representations, the Central Bank will notify the applicant, in writing, of the Central Bank’s decision and the grounds for the proposed refusal of the registration.

    As per section 106H (6) of the CJA 2010 to 2021, as amended, a decision of the Central Bank to refuse an application under section 106G is an appealable decision for the purposes of Part VIIA of the Central Bank Act,1942.