IEIM401563 - Financial Accounts: Depository Account: Specified Electronic Money Products: Change of Status
Where a SEMP changes its status and ceases to be a SEMP during a calendar year, Financial Institutions should continue to treat the product as if it were a SEMP until the end of that calendar year.
Example 1
At the start of calendar year 2027, CoinTime is a SEMP. In June 2027 it changes its status and ceases to meet the definition of a SEMP, instead becoming a relevant cryptoasset under the CARF (see IEIM8000220). Financial Institutions should treat CoinTime as a SEMP for the whole of calendar year 2027, as it was a SEMP at the beginning of 2027 and changed status part way through the year. For the calendar year 2028, CoinTime is a relevant cryptoasset and falls under the CARF.
Example 2
At the start of calendar year 2027, HoodCoin is a SEMP. In March 2027 it changes its status and ceases to meet the definition of a SEMP, instead becoming a relevant cryptoasset under the CARF. In November 2027, HoodCoin ceases to be a relevant cryptoasset and reverts to being a SEMP.
Financial Institutions should treat HoodCoin as a SEMP for the whole of calendar year 2027, as it was a SEMP at the beginning of 2027 and changed status part way through the year. For the calendar year 2028, HoodCoin is again a SEMP and falls within the scope of the CRS. Because HoodCoin reverted back from being a relevant cryptoasset to a SEMP before the end of calendar year 2027, it will not be reportable under the CARF for either calendar year.