Settlement Notice - Coinbase Europe Limited (Coinbase Europe)

• Date: 06 November 2025

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The Central Bank of Ireland

Administrative Sanctions Procedure (ASP)

Settlement Notice

To: Coinbase Europe Limited (Coinbase Europe)

Date: 5 November 2025

Part 1. Action

1. For the reasons set out in this Settlement Notice, t he Central Bank of Ireland is

publishing a statement pursuant to Section 33BC(2) of the Central Bank Act 1942 as

amended ( the 1942 Act), concerning C oinbase Europe, for cont raventions of the

Criminal Justice (Money Laundering and Terrorist F inancing) Act 2010 (the CJA 2010);

between 23 April 2021 and 19 March 2025.

2. Coinbase Europe has agreed to the facts in Part 2 (the Undisputed F acts) and admitted

the prescribed contraventions in Part 3 of this Settlement Notice, su ch that further

investigation is unnecessary.1 On this basis, the Central Bank has decided that it is

appropriate to impose the following sanctions:

 A reprimand; and

 A monetary penalty in the amount of €30,66 3,906 reduced to €21,464,734 after

application of the settlement scheme discount.

1 Section 33AR(1)(a)(ii) of the 1942 Act: “where there are un disputed facts that in the reasonable opinion of the

Bank render an investigation unnecessary, suspects on reasona ble grounds that a person is committing or has

committed a prescribed contravention…”

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3. Coinbase Europe has agreed to these sanctions,2 however, they will not take effect

unless they are confirmed by the High Court.3

4. Further details on the prescribed contraventions and sanctions are set out in Parts 3 and

4 of this Settlement Notice.

5. A chronology of events is set out in the Appendix below.

Summary of Reasons for the Central Bank’s Action

6. Coinbase Europe is a wholly owned subsidiary of Coinba se Global, Inc., a United States

corporation, and is part of the global Coinbase Group 4 which operates a significant

global trading platform for crypto assets.

7. Coinbase Europe was established in 2020 to provide crypto asset and wallet services to

customers in Europe and other international jurisdictions and is an entry point for those

customers to use the Coinbase Group trading platform.

8. Cryptocurrency firms are exposed to significant money laundering an d terrorist

financing (ML/TF) risks due to their technological features, cross-border operations, and

anonymity-enhancing ca pabilities. Virtual asset service providers (VASPs), along with

banks and credit unions are currently the three largest reporting sect ors for suspicious

transaction (STRs) in Ireland.

9. In April 2021 Coinbase Europe became a ‘designated person’ for the purposes of the CJA

2010 and was registered as a VASP by the Central Bank in December 2022. The CJA

2010 requires designated persons to properly monitor transactions for ML/TF and to

2 In this case, Coinbase has also agreed to dispense with an inquiry.

3 Pursuant to Section 33 AWA of the 1942 Act.

4 As at the date of this Settlement Notice, Coinbase Inc. is, in glob al terms, the 3rd largest cryptocurrency

exchange by volume and the largest in the United States. I t operates in more than 100 countries. In 2024,

the total volume of trading on the platform by Coinbas e Group’s global customer base was equivalent to

$1.2 trillion, an increase of 148% from 2023. In 2024, the ave rage number of transacting users on the

platform per month was 8.4 million. In 2025, Coinbase Global, Inc . joined the S&P 500, the first crypto

industry firm to do so. The S&P 500 is a stock market index of 5 00 of the largest publicly traded companies

in the United States.

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have in place the necessary systems to do so. These requirements ensure that suspicious

transactions are detected and reported to the relevant authorities without delay giving

these authorities the best opportunity to act upon these reports.

10. The prescribed contraventions which are the subject of this Settlement Notice concern

Coinbase Europe’s failure to comply w ith its transact ion monitoring obligations

between 23 April 2021 and 19 March 2025.

11. Coinbase Europe outsourced significant aspects of its transaction monitoring to a sister

entity, Coinbase Inc, which is based in the United States. Specifically, Coinbase Inc.

operated the tran saction monitoring system (TMS) which monitored transactions and

flagged any that required further review. While Coinbase Europe was permitted to do

this, it was obliged to oversee this transaction monitoring and remained responsible for

compliance with the CJA 2010.

12. As a result of data configuration issues, 5 out of 2 1 high risk TMS scenarios did not

operate fully as intended, which meant that the TMS failed to fully and properly monitor

30,442,437 transactions (the Non-Monitor ed Transactions) for Coinbase Europe for

certain high-risk scenarios from 23 April 2021 until 29 April 2022 (the Non-Monitoring

Issue). When these issues were detected by Coinbase Inc. they were rectified promptly

so that the TMS operated properly from 29 April 2022.

13. As a consequenc e of the Non-Monitoring Issue, it was then necessary to rescreen the

Non-Monitored Transactions (the Transaction Rescreening). There were three steps

to this process:

1. Coinbase Inc. had to rescreen the Non-Monitored Transactions for the high-risk

scenarios originally not captured by the TMS. This step was completed by August

2022 and 184,790 transactions were identified as requiring further review;

2. Then Coinbase Inc. had to investigate the alerts, w hich under its own internal

procedures should have been completed in a timely fashion. However, the process

of reviewing these alerts did not commence until May 2023. This was completed