Central Bank of Ireland publishes 47th Edition of the AIFMD Q&A

On 4 April 2023, the Central Bank of Ireland published the 47^th Edition of the AIFMD Q&A.

This edition of the Q&A revises ID1145, which considers if a RIAIF or a QIAIF can invest either directly or indirectly in crypto-assets. The revised Q&A does not change the Central Bank’s position in relation to RIAIFs. The Central Bank is increasing limits for indirect exposure to digital assets, depending on the liquidity provided by the QIAIF: where a QIAIF is open-ended it can gain exposure to digital assets of up to 20% of NAV. Where a QIAIF is closed-ended or has limited liquidity it can it can gain exposure to digital assets of up to 50% of NAV. Requirements to avail of this are set out in the revised QA.

In light of the above, the Central Bank has updated the pre-submission process for Qualifying Investor AIFs proposing to invest indirectly in digital assets in excess of what is outlined in the AIFMD Q&A  ID1145 or any direct investment in digital assets. Details of what is required as part of the pre-submission is set out here.