Pre controlled function roles for VASP applications

Cosgrove Gaynard Solicitors

If you are a VASP in Ireland, you will need to register with the Central Bank for AML/CFT purposes. If you are a firm that is not established in Ireland, or you are not conducting business as a VASP before the 2021 Act was brought in, then you must be registered with the Central Bank before any services commence. As part of the regulation of VASPs with the Central Bank of Ireland, individuals holding pre-approval controlled functions within a VASP must be approved under the latest fitness and probity regime of the Central Bank.

Pre controlled function roles for VASP applications

Virtual Asset Service Providers are, in essence, a type of financial firm that offer a range of services that are tied to virtual assets. A firm is classed as a VASP if they provide any of the following:

• Offer exchanges between assets that are virtual and fiat money.
• Offer exchanges between different types of virtual assets.
• Conduct transactions for individuals that move virtual assets around accounts.
• Acts as a custodian wallet provider.
• Provides or participates in financial services that are tied to issuers offer or sales of virtual assets.


Register with the Central Bank for AML and CFT

If you are a VASP in Ireland, you will need to register with the Central Bank for AML/CFT purposes. If you are a firm that is not established in Ireland, or you are not conducting business as a VASP before the 2021 Act was brought in, then you must be registered with the Central Bank before any services commence.

See our article here for further information on registering as a VASP.

Pre-controlled function roles in VASPs

The Central Bank’s fitness and probity regime applies to all persons in senior positions - these are known as Controlled Functions and Pre-Approval Controlled Functions. If an individual is performing a controlled function, then they must attain a standard of fitness and probity that is suitable for that specific function.

As part of the regulation of VASPs with the Central Bank of Ireland, individuals holding pre-approval controlled functions within a VASP must be approved under the latest fitness and probity regime of the Central Bank.


As mentioned the Central Bank’s Fitness and Probity Regime is required for all senior positions within a VASP. There is a vast list of Pre-Approval Controlled Functions and a list of these are set out further on the Central Banks website: ”https://www.centralbank.ie/regulation/how-we-regulate/fitness-probity/requirements-assessment-compliance/regulated-financial-service-providers/introduction


It is crucial that those designated to these positions meet the requisite criteria. Of note , they will also need to complete individual questionnaires as part of the registration process after we have lodged the registration forms with the initial application.

Should you have any queries, please do not hesitate to contact us further.

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