1 We are at the early stages of a potential technological rewiring of finance. Fast-forward ten or twenty years, and it seems likely that the use of shared, programmable ledgers – and the tokenisation of financial assets – will have become embedded across the financial system. Today, we stand at a juncture. The question is less whether the technology will transform finance. Rather, it is how we collectively shape this ongoing transition, so that the potential of tokenised finance is realised,...
The Deputy Governor’s speech sets out the Central Bank of Ireland’s (CBI) emerging regulatory stance on tokenised finance and distributed ledger technology (DLT), framing it as a structural transition rather than a niche innovation. While it does not introduce new binding rules, it clearly signals supervisory expectations, impending policy development (including follow‑up to the March 2026 Discussion Paper on tokenisation and DLT), and the need for regulated firms to integrate tokenisation risks, governance and operational resilience into existing regulatory frameworks.
What Changed
- - The CBI formally recognises tokenisation and shared, programmable ledgers as a likely core infrastructure of the future financial system and signals that regulation will evolve to treat tokenised...
- The speech confirms that CBI’s regulatory approach will be “technology‑neutral but not technology‑blind”, indicating that existing EU and Irish rules (e.g.
- The CBI emphasises the need to keep central bank money at the core of tokenised finance, aligning its stance with Eurosystem work on wholesale and retail central bank digital currency (CBDC) and...
- The speech reinforces that tokenised instruments representing traditional financial assets (securities, deposits, fund units) will generally be treated as regulated financial instruments, triggering...
- The CBI highlights operational resilience, cyber risk, interoperability and smart‑contract governance as critical supervisory focus areas for tokenised finance infrastructure and platforms.
Suggested Considerations
- Map all current and planned tokenisation and DLT initiatives (including pilots and proofs of concept) across the group and identify which EU and Irish regulatory regimes they fall under (MiFID II, UCITS, AIFMD, CRR/CRD, PSD2/PSR, Solvency II, MiCA, DORA, etc.).
- Perform a regulatory gap analysis to confirm that tokenised products and services are fully captured within existing licensing permissions and assess whether any variation of permission, new authorisation, or recognition as a market infrastructure is required.
- Review and update governance arrangements so that boards and senior management explicitly oversee tokenisation strategies, risk appetite, and the use of DLT, including ensuring clear allocation of responsibilities under the firm’s senior manager or fitness and probity framework.
- Integrate tokenisation‑specific risks into the firm’s risk management framework, covering legal enforceability of tokens, smart‑contract risk, cyber and operational resilience, data integrity, interoperability, concentration risk in technology providers, and settlement and counterparty risk.
- Review outsourcing and third‑party risk management frameworks to ensure that DLT platform providers, smart‑contract developers, node operators and custodians are treated as critical or important outsourced service providers where appropriate, with robust contractual, oversight and exit provisions.
Key Dates
- CBI publishes its Discussion Paper on tokenisation and distributed ledger technology in financial services, initiating a structured consultation on tokenised markets, funds, money and payments
- Deputy Governor speech sets out the CBI’s strategic approach to tokenised finance, confirming that consultation feedback will inform subsequent policy, supervisory expectations and potential rule changes
- Closing date for submissions to the CBI Discussion Paper on tokenisation and DLT, after which CBI will prepare a feedback statement and refine its policy stance
- CBI feedback statement on the tokenisation Discussion Paper expected, likely followed by more granular guidance and potential adjustments to supervisory and authorisation processes for tokenised activities
Compliance Impact
Non‑compliance will not immediately trigger new standalone tokenisation fines, but CBI is likely to use existing conduct, prudential, governance and operational resilience powers to challenge poorly controlled tokenised activities and may restrict or prohibit projects that do not meet its expectations. Firms that treat tokenised finance as “outside the regulatory perimeter” or fail to integrate it into existing compliance frameworks risk supervisory intervention, authorisation issues, enforcement action and reputational damage.
AI-generated analysis. May contain errors or omissions — verify with the
original CBI source
before acting. Full disclaimer.
Introduction Good morning – I am delighted to be here, and many thanks to Brian and the BPFI for hosting us. 1 I very much look forward to the discussion, and to hearing from you all today, but before I do I would like to set out some reflections on a number of topics which are currently high on the regulatory agenda. While the discussion is multifaceted, and tied up with a regulatory cycle which has turned, an economic one which has become more challenging, not to mention a renewed focus by ...
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Safeguarding Financial Integrity – Central Bank of Ireland’s Approach to Financial Crime Prevention Thank you for the invitation to speak at today’s event. This is an important opportunity for us to engage and share our experiences and approaches to deal with the global challenges and issues we are facing in financial crime. Change, instability, flux, unpredictability - all words that I guarantee you will hear on multiple occasions throughout the day’s events. I will not be any different. We ...
Bank
In his latest blog, Governor Gabriel Makhlouf argues that central banks must modernise their digital infrastructure and regulatory frameworks to ensure that central bank money remains the stable foundation of Europe's financial system whilst enabling private sector innovation in a digitally transformed ecosystem.
BankFintechCrypto Exchange
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BankBroker DealerCrypto Exchange
Introduction Good morning. I am delighted to welcome you to Central Bank of Ireland today as part of our continued engagement with the crypto sector. This time last year we hosted an industry briefing focused on the path to success in the authorisation of Crypto-Asset Service Providers (CASPs). It has been a very active 12 months, and today I see many of you in the room from newly authorised CASPs who have come through the process successfully. This morning’s event is an excellent opportunity...
Crypto ExchangeFintech
Central Bank of Ireland today published a Discussion Paper examining the potential role of Distributed Ledger Technology (DLT) and tokenisation in the financial system . Deputy Governor Vasileios Madouros, commenting on the publication, said: “Distributed ledger technology and tokenisation have the potential to transform how financial services are delivered. We believe this technology, if enabled and deployed correctly, can change the financial system for the better, including by helping the ...
The Central Bank of Ireland (CBI) has launched Discussion Paper 12 (DP12) on Distributed Ledger Technology (DLT) and tokenisation in financial services to explore their transformative potential in areas like markets, funds, payments, and money, while assessing opportunities, risks, and enablers such as legal clarity and interoperability. This matters for compliance professionals as it signals CBI's proactive stance on integrating these technologies into a resilient financial system, aligning with EU ambitions like the Savings and Investment Union, and invites stakeholder input to shape future policy without proposing immediate rules. (Source: https://www.centralbank.ie/news/article/press-release-discussion-paper-tokenisation-and-distributed-ledger-technology-in-financial-services-5-march-26 [publication]; https://www.arthurcox.com/insights/central-bank-issues-discussion-paper-on-dlt-tokenisation-in-financial-services/ )
What Changed
This is a non-binding discussion paper, not a regulatory change or new requirement; it poses 16 questions on topics including legal recognition of tokenised instruments, governance, infrastructure, funds (e.g., tokenised MMFs and ETFs), payments, and risks like operational resilience and interoperability. It highlights needs for policy intervention to avoid fragmented "walled gardens," ensure central bank money's role, and address challenges in fractionalisation, transparency, and settlement finality, but no mandates are imposed yet.
Suggested Considerations
- Review DP12 (PDF available via CBI site) and prepare/ submit responses to the 16 questions by 5 June 2026, focusing on legal clarity, risks, funds tokenisation, and enablers like interoperability.
- Engage in CBI's structured stakeholder dialogues to influence future frameworks.
- Assess internal DLT/tokenisation pilots or plans against discussed risks (e.g., operational resilience, scalability) and opportunities (e.g., fractional ownership, 24/7 liquidity).
Key Dates
- Deadline for stakeholder submissions responding to the 16 questions in DP12
5 June 2026; - CBI to publish a feedback statement assessing responses and existing policy fit. (Source: https://www.centralbank.ie/news/article/press-release-discussion-paper-tokenisation-and-distributed-ledger-technology-in-financial-services-5-march-26 [publication]; https://www.arthurcox.com/insights/central-bank-issues-discussion-paper-on-dlt-tokenisation-in-financial-services/ )
Compliance Impact
Urgency: Medium – This consultative paper poses no immediate rules but represents a key opportunity to shape emerging DLT/tokenisation regulation amid CBI's 2026 priorities on tech-driven transformations and resilience; inaction risks missing input on critical enablers like legal finality for tokens, potentially leading to stricter future requirements misaligned with firm needs. It aligns with broader EU/BIS pushes (e.g., MiCA, tokenized reserves), amplifying relevance for firms in funds, payments, and crypto.
AI-generated analysis. May contain errors or omissions — verify with the
original CBI source
before acting. Full disclaimer.
In this blog, Governor Gabriel Makhlouf writes about the development of the Digital Euro and how central banks foster trust and safety in the financial system and in the implementation of projects like the Digital Euro.
BankFintechCrypto Exchange
The Central Bank of Ireland has fined Coinbase Europe Limited €21,464,734 for breaching its anti-money laundering and counter terrorist financing transaction monitoring obligations between 2021 and 2025. The Central Bank of Ireland (the Central Bank) has fined Coinbase Europe Limited (Coinbase Europe) €21,464,734 for breaching its anti-money laundering (AML) and combatting terrorist financing (CFT) obligations with respect to transaction monitoring as required by the Criminal Justice (Money L...
The Central Bank of Ireland (CBI) fined Coinbase Europe Limited €21,464,734 for AML/CFT transaction monitoring failures under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (CJA 2010), involving over 30 million unmonitored transactions worth €176 billion from April 2021 to March 2025. This marks CBI's first enforcement against a crypto firm, highlighting regulators' focus on robust real-time monitoring and timely Suspicious Transaction Reporting (STR) for virtual asset service providers (VASPs). It matters as it sets a precedent for EU crypto compliance amid MiCA and AMLA implementation, signaling increased scrutiny and potential multimillion-euro penalties for similar lapses.
What Changed
This is an enforcement action, not new legislation, but it reinforces existing CJA 2010 requirements for VASPs: ongoing transaction monitoring, immediate STR filing to the Financial Intelligence Unit (FIU) and Revenue Commissioners upon suspicion of money laundering or terrorist financing, and adoption of internal policies/controls to prevent/detect financial crime.
Suggested Considerations
- Conduct Gap Analysis: Review transaction monitoring systems for configuration errors, back-testing historical data, and ensuring 100% coverage of high-risk transactions.
- Enhance Controls: Implement robust internal policies, automated alerts, and governance to detect/prevent ML/TF; test systems regularly for faults affecting >1% of volume.
- Accelerate STR Processes: Ensure real-time suspicion flagging and filing; remediate delays via prioritized back-monitoring with FIU coordination.
- Board/Compliance Reporting: Document remediation plans, as Coinbase did, and prepare for audits/enforcement; train staff on VASP-specific risks under MiCA/AMLA.
- Third-Party Review: Engage independent auditors to validate fixes, mirroring Coinbase's post-error cooperation.
Key Dates
19 March 2025; Period of breaches, including 12-month window of unmonitored €176 billion transactions
Settlement reached between CBI and Coinbase Europe
CBI public announcement and Settlement Notice published
High Court confirmed sanctions, making them final and effective
Compliance Impact
Urgency: High – This establishes a €21.5m benchmark for VASP monitoring failures in the EU, with risks amplified by MiCA (effective 2024) and AMLA (2025 onward), where national regulators like CBI will enforce harmonized rules. Firms risk similar fines (30% settlement discount possible), reputational damage, and operational restrictions if unmonitored volumes exceed 1-5%; immediate reviews are essential given CBI's precedent and cross-EU applicability.
AI-generated analysis. May contain errors or omissions — verify with the
original CBI source
before acting. Full disclaimer.
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