The Central Bank of Ireland (CBI) fined Coinbase Europe Limited โฌ21,464,734 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 โฌ176 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. Key breaches included: misconfigured monitoring systems missing 30,442,437 transactions (31% of activity over 12 months); delayed r
What You Need To Do
- Conduct Gap Analysis
- Enhance Controls
- Accelerate STR Processes
- Board/Compliance Reporting
- Third-Party Review
Key Dates
23 April 2021 - 19 March 2025 Period of breaches, including 12-month window of unmonitored โฌ176 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.
CJA 2010 obligations remain perpetual.
Compliance Impact
Urgency: High โ This establishes a โฌ21.5m 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), reputationa