Authorisation Process for Money Transmission Businesses  

The purpose of this section is to provide information to firms considering applying for authorisation as a money transmission business. The Central Bank of Ireland (Central Bank) is the competent authority in Ireland for the authorisation and supervision of money transmission businesses under Part V of the Central Bank Act 1997 (as amended) (the Act). 

Each applicant seeking authorisation must satisfy the Central Bank that it can meet the Authorisation Requirements and Standards for Money Transmission Businesses (AR&S). 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 compliance with the AR&S are authorised. 

The Central Bank seeks to process each application as expeditiously as possible while meeting its obligation to operate a rigorous and effective gatekeeper function. It aims to ensure that the application process is facilitative and accessible from the perspective of applicants and, importantly, that applicants have clarity with regard to the process, its requirements and timelines. 

Before Applying for Authorisation

In advance of submitting an application for authorisation, the firm should satisfy itself that: 

Firms are advised to seek legal advice if they are unsure as to whether their proposed activities require authorisation pursuant to the Act or if they are unsure as to how they should comply with the AR&S. If, after having received and considered such advice, firms have any doubt about their status, they are advised to submit an application for authorisation.

Summary of the Key Stages in the Application Process

  • The applicant submits a completed Application Form with supporting documentation; 
  • The Central Bank acknowledges receipt of the application submission; 
  • The Central Bank assesses whether the application submission contains the key information and documentation required to progress to the assessment phase; 
  • Where all key information and documentation has been provided, the Central Bank completes an assessment of the application submission and may issue detailed comments and/or seek additional information; 
  • The applicant is provided with the opportunity to address the comments and requests issued by the Central Bank in a revised application submission(s); 
  • The Central Bank will assess these subsequent application submission(s) and notify the applicant of its assessment and next steps. The applicant is provided with a further opportunity to address any concerns arising at this stage in the process (if any); and 
  • The Central Bank will notify the applicant of its decision in respect of the application submission. 

In the sections set out below, the firm will be able to learn about the different stages of the application process in more detail. 

The Documentation Required to Make an Application for Authorisation

Applicants should submit the following documentation which should be fully completed:

  1. An Application for Authorisation as a Money Transmission Business Form (including the specific information/documentation requirements set out therein); 
  2. A Business Plan; and 
  3. A Programme of Operations. 

Once an application is submitted the applicant will also need to ensure that all relevant individuals proposed to hold a Pre-Approval Controlled Function ("PCF") role (typically board members, senior management, key function holders) and any qualifying shareholders complete Fitness and Probity Individual Questionnaires. Individual Questionnaires must be submitted electronically via the Central Bank’s Online Reporting System by all relevant individuals, but qualifying shareholders (that are not proposed PCF role holders) are required to submit a paper version. Please note that access to the online Individual Questionnaire only becomes available after an application has been deemed to contain all the key information needed to progress to the assessment phase of the application process. 

The completed Application Form, along with all relevant accompanying material, should be submitted in both paper and electronic format to the Central Bank. The paper copy should be sent to MTB Authorisations Team, Consumer Protection:  Policy & Authorisations, Central Bank of Ireland, PO Box 559, New Wapping Street, North Wall Quay,Dublin 1 and the electronic version can be included with the paper copy or sent by email to MTauthorisations@centralbank.ie. The completed paper IQ(s), where relevant, should also be submitted to the above address. 

The Key Stages in the Application Process

The key stages of the application process are as follows: 

Stage 1 - Acknowledgement

The Central Bank will acknowledge receipt of an Application for Authorisation submitted by the firm within 3 working days of receipt. 

Stage 2 - Key Information Check

The Central Bank will then check that the application material submitted contains all the key information and documentation required to proceed to the assessment phase. Within 10 working days of receipt of the application, the Central Bank will either:

I) Advise the applicant that the application contains sufficient material 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); or 

II) Advise the applicant that the application does not contain sufficient material to proceed to the assessment phase and so is not being progressed to that phase. A statement of the omitted information is also provided to assist the applicant should it wish to submit another application in the future. Any subsequent application will be considered a new application and the application process commences again at Stage 1.

Stage 3 - Assessment Phase

Where sufficient information has been received, as outlined in Stage 2(1) above, the Central Bank will then proceed to the assessment phase of the application process. The application material submitted will be reviewed against the relevant AR&S to determine whether sufficient information has been provided to enable the Central Bank to issue a 'Notification of Assessment' letter as referred to in Stage 4 below. The Central Bank will issue initial comments to the applicant based on its review of the application material submitted and any subsequent comments based on its review of responses submitted by the applicant. The Central Bank has published service standards (see below) in respect of the processing of applications for authorisation and in the context of meeting those standards the service standard timeframe to which the Central Bank has committed for the assessment phase of the application process is 90 working days. However, it should be noted that in the event of further and/or subsequent information being sought, this 90 day ‘clock’ is paused until such information is received by the Central Bank from the applicant.

In the event of the applicant failing to respond to a request from the Central Bank for further and/or subsequent information, after 60 working days the application may not be considered further by the Central Bank (see Guidance Note).

Stage 4 – Notification of Assessment

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

a) Where the assessment is favourable, the Central Bank will notify the applicant by letter that it proposes to authorise the applicant on the basis of the information provided in its application submission, provided any specified final steps are taken and/or any specified final items of information and evidence are received. This letter will also specify any conditions the Central Bank proposes to impose on the authorisation itself once granted. This letter will explain the reasons for these proposed conditions and the applicant will be afforded the opportunity to make representation in respect of the proposed conditions before the Central Bank makes any decision on the application.

b) In the event that the Central Bank is not satisfied on foot of the Assessment Phase such that it can issue a 'Notification of Assessment' letter under (a) above, the Central Bank will advise the applicant of this by letter. The letter will set out the areas to be addressed and afford the opportunity to do so and make any submissions it wishes to the Central Bank in respect of these matters.

Stage 5 Notification of Decision in respect of the Application

Once the Central Bank has assessed any further information/evidence/representations submitted by the applicant following on from Stage 4 above, the Central Bank will notify the applicant, via letter, of its decision on the application as follows:

a) Authorisation with Specific Conditions - The Central Bank has decided to grant an authorization with specific conditions attached to the authorisation. The specific conditions to be attached to the authorisation will be outlined in the letter.

b) Proposed Refusal of Authorisation - The Central Bank is minded to refuse the application for authorisation. In accordance with the applicable legislation, the Central Bank will notify the applicant of the grounds for the proposed refusal of the authorisation. The applicant will then have an opportunity to make submissions in response to the proposed refusal. These submissions will then be considered by the Central Bank following which a decision will be taken by the Central Bank to grant of refuse the authorisation applied for, as appropriate. Details of the Central Bank's processed for the refusal of an application for authorisation are available here.

If the firm has any queries in respect of the application process it can contact the Central Bank at MTauthorisations@centralbank.ie.

Optional Pre-Application Meeting

The Central Bank offers the facility of an optional pre-application meeting to firms to answer specific questions about any aspect of the application process and completing the Application Form. Please note that the Central Bank recommends that firms who wish to avail of this facility have reviewed the application material in full before requesting such a meeting and have their specific questions prepared in advance in order to make the meeting as productive as possible. Such meetings will typically be no longer than one hour. 

Service Standards Performance Reports

Please find a link to the Service Standards Performance Reports page here.

The reports set out the Bank's performance against Service Standards that it has committed to in respect of (i) Authorisation of Funds, (ii) Authorisation of Financial Service Providers and (iii) Processing of Fitness and Probity applications, on a half-yearly basis.

Section 149A of the Consumer Credit Act, 1995 (as amended) ('the CCA') 

Bureaux de Change and Money Transmission Businesses providing relevant services must comply with Section 149A of the CCA which provides that you shall not impose a new charge or increase an existing charge for a service provided to a customer or a group of customers, without the prior approval of the Central Bank of Ireland (the 'Central Bank').

The Central Bank may impose sanctions on a firm pursuant to Part IIIC of the Central Bank Act, 1942 ('the Act') if, having concluded an inquiry, it determines that the firm has committed a contravention as defined by section 33AN of that Act.

Please see attached note on Section 149A of the CCA.