Crypto & Digital Assets in Ireland

Key dates

17 June 2026

- CBI issues and publishes the warning notice that Lambestone Holding Limited (CLONE) is an unauthorised investment / investment business firm / crypto‑asset service provider and that its name is listed under section 53 of the Central Bank (Supervision and Enforcement) Act 2013

Suggested considerations

• Update internal sanctions, fraud, and high‑risk entity screening lists immediately to include Lambestone Holding Limited (CLONE), its known websites, email addresses and telephone numbers, and ensure these are used in client onboarding, periodic KYC reviews and transaction monitoring.
• Instruct client‑facing and dealing staff not to refer clients to, or accept instructions from, Lambestone Holding Limited (CLONE) or any individual using the listed domains, emails or phone numbers, and document this in internal guidance.
• Review and enhance client‑due‑diligence procedures to include explicit checks for clone‑firm indicators, including mismatches between a firm’s claimed regulatory status and the CBI online registers, as well as verification against CRO records.
• Implement a formal process to monitor and log Central Bank of Ireland warning notices (and similar notices from ESMA, other EU national competent authorities, FCA, etc.) and to propagate relevant alerts across first‑ and second‑line control functions.
• Conduct targeted staff awareness and training sessions for front‑office, call‑centre, and complaints‑handling teams on clone‑firm typologies, with Lambestone Holding Limited (CLONE) used as a current example of CRO‑identity cloning.

What changed

• - The CBI has formally designated Lambestone Holding Limited (CLONE) as an unauthorised investment firm, investment business firm and crypto‑asset service provider for Ireland, and has published its...
• The warning confirms that Lambestone Holding Limited (CLONE) is not authorised to operate as an investment firm or to provide crypto‑asset services in Ireland, and therefore may not lawfully provide...
• The CBI explicitly identifies Lambestone Holding Limited (CLONE) as a “clone firm” that has copied the name, address and CRO number of a legitimate company in the Companies Registration Office (CRO)...
• The CBI clarifies that there is no connection whatsoever between the legitimate CRO‑registered company and the scam entity, thereby protecting the reputation of the genuine firm and reducing...
• The warning includes a non‑exhaustive list of websites, email domains and telephone numbers used by the clone (multiple .com domains, support and individual email accounts, and international phone...

Key dates

03 June 2026

- CBI issues the Warning Notice on AMOVA Asset Management Ireland Limited (Clone), formally confirming it is unauthorised to operate as an investment firm, investment business firm or to provide crypto‑asset services in Ireland, and publishing its details under section 53 of the Central Bank (Supervision and Enforcement) Act 2013

Suggested considerations

• Configure name‑screening tools, CRM systems and vendor/onboarding databases to flag “AMOVA Asset Management Ireland Limited”, “AMOVA Asset Management Ireland Limited (Clone)”, the website domain “amova‑assets.com” and the email “admin@amova‑asset.com” as high‑risk indicators requiring escalation.
• Implement controls to distinguish between the legitimate CBI‑authorised AMOVA firm and the clone, for example by storing verified legal entity identifiers (LEIs), company registration numbers, CBI authorisation numbers and official domains for the legitimate firm.
• Train relationship managers, advisers, client‑facing staff and call‑centre teams to recognise characteristics of clone‑firm scams, including cloned names, look‑alike websites and unsolicited approaches, using this warning and recent similar CBI notices as case studies.
• Review and, where necessary, strengthen client‑communication and investor‑education materials to explain the risk of clone firms, directing clients to the CBI’s public registers and warning notices to independently verify firm authorisation.
• Enhance fraud‑risk and financial crime risk assessments to explicitly include clone‑firm risks in the investment, wealth‑management, and crypto‑asset channels, and document how these risks are mitigated (e.g. screening, call‑back controls, domain verification).

What changed

• - The CBI has formally designated “AMOVA Asset Management Ireland Limited (Clone)” as an unauthorised investment firm, investment business firm and crypto‑asset service provider for the purposes of...
• The Warning Notice confirms that the clone entity is not authorised to operate in Ireland and must not be treated as a regulated counterparty or service provider.
• The CBI explicitly clarifies there is no connection whatsoever between the Central Bank‑authorised firm of the same name and the scam entity, reinforcing expectations for firms to distinguish between...
• The publication reiterates that the entity is using website and email details (including the domain amova‑assets.com and the email admin@amova‑asset.com) to approach consumers, which should be...
• By publishing the firm name under section 53 of the Central Bank (Supervision and Enforcement) Act 2013, the CBI reinforces its ongoing supervisory focus on clone‑firm frauds and the expectation that...

Key dates

05 March 2026

- 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

26 May 2026

- 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

05 June 2026

- 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

TBD (post‑June 2026)

- 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

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.

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.

Key dates

5 June 2026 Deadline

- Deadline for stakeholder submissions responding to the 16 questions in DP12

Post

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/ )

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).

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.

Key dates

23 April 2021

19 March 2025; Period of breaches, including 12-month window of unmonitored €176 billion transactions

5 November 2025

Settlement reached between CBI and Coinbase Europe

6 November 2025

CBI public announcement and Settlement Notice published

12 January 2026

High Court confirmed sanctions, making them final and effective

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.

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.