Glossary

A · B · C · D · E · F · H · I · M · N · O · P · Q · R · S · T · V · W

A

Anti-Money Laundering Authority (AMLA)

The EU's new anti-money-laundering supervisor, based in Frankfurt. From 10 July 2027 a single AML Regulation replaces each member state's own version of the rules, and AMLA sits above the national supervisors. Binder §7.7 makes the MLRO bring revised procedures to the Board before that date. Binder §7.7 · Chapter 7

Anti-money-laundering (AML) rules

The law against moving criminal money through financial firms. It makes obliged entities check who their clients are, watch transactions, report suspicion and appoint an MLRO. Today it comes from an EU Directive, so each member state has its own version, until one regulation applies from 10 July 2027. Binder §7 · Binder §7.7 · Chapter 7

Asset-referenced token (ART)

A token that claims a stable value by referencing something other than one currency, such as several currencies or a commodity. Its issuer must be authorised before it offers the token, and must hold a reserve of assets so that holders can be paid out. Definition: ART · Chapter 2

Authorisation

The regulator's written permission to provide named crypto-asset services, which people in the office call the licence. Before granting it, the regulator examines the whole business: capital, people, custody, technology and the plan for closing. The Central Bank authorised Halcyon on 12 November 2025 for five services. Binder §1.1 · Appendix A · Chapter 1 · Chapter 3

B

Breach log

The MLRO's record of every breach of the Binder: what happened, its scale, the root cause, the fix, and whether it is also an ICT incident. An entry is made on the day the breach is found, and the log goes to the Board each quarter. Binder §7.6 · Chapter 7

Business day and working day

Two ways of counting days, used by different clocks. In the Binder a business day is a day banks in Dublin are open, and complaints and the daily count run on it. The regulator's application deadlines run in working days, which leave out weekends and public holidays. Binder, what this binder is §3 · Chapter 3 · Chapter 4

C

CASP

A crypto-asset service provider: a company whose business is providing crypto-asset services to clients professionally (Article 3(1)(15)). In plain words, a firm that holds, trades or moves crypto-assets for other people. It needs authorisation, and Halcyon has been one since 12 November 2025. Definition: CASP · Binder §1.1 · Chapter 1 · Chapter 2

Change control

Halcyon's rule that no live system changes without a change record approved first: what, why, risk, tests, rollback and approver. Compliance signs off any change to custody, transfers, reconciliation or surveillance. A vendor's update made without one caused the Travel Rule failure of February 2026. Binder §9.2 · Chapter 7 · Chapter 10

Class 1, Class 2 and Class 3

MiCA's three classes of crypto firm, each with a minimum for own funds. Class 1 covers services such as executing orders, transfers and advice, and needs €50,000. Class 2 adds custody or exchange and needs €125,000, and Class 3 adds a trading platform and needs €150,000. Binder §3.1 · Appendix B.1 · Chapter 3 · Chapter 10

Client funds

A client's euro in Halcyon's hands, which still belongs to the client. It must reach a bank by the end of the next business day, in an account held for clients and apart from Halcyon's own money. Halcyon may never use it for itself. Binder §4.3 · Chapter 5

Complaint

Any expression of dissatisfaction by a client about a Halcyon service, even without the word. Compliance acknowledges it within 5 business days and decides within 15, or within 35 if it writes first with reasons. A client still unhappy may go to the Financial Services and Pensions Ombudsman. Binder §6.1 · Binder §6.3 · Binder §6.5 · Chapter 4

Compliance Binder

The written policies Halcyon keeps because MiCA, DORA and the anti-money-laundering rules require them, with extracts of the client terms. The Head of Compliance owns it, and a policy changes only by Board resolution. It is the evidence that Halcyon keeps the conditions of its licence. Binder, what this binder is §1 · Chapter 1 · Chapter 4 · Chapter 10

Conflict of interest

Any place where Halcyon's own interest, or one client's, pulls against another client's, such as selling a client a coin from Halcyon's own stock. Halcyon must find each conflict, prevent or manage it, and describe its conflicts on its website. Compliance keeps the register of conflicts. Binder §5.1 · Binder §5.4 · Chapter 4

Credit institution

The law's word for a bank. Clients' euro must be placed at one by the end of the next business day. Only a credit institution or an electronic money institution may issue an electronic money token. Binder §4.3 · Chapter 1 · Chapter 5

Crypto-asset

A digital representation of a value or a right that can be transferred and stored electronically using distributed ledger technology or similar technology (Article 3(1)(5)). In plain words, a token on a shared ledger. Whoever holds its private key controls it. Definition: Crypto-asset · Chapter 1

Crypto-asset service

Any of the ten services MiCA lists, from custody and exchange to advice and transfers. A firm that provides any of them to clients needs authorisation for that service. Halcyon holds five of the ten, and Appendix B of the Binder is its register. Definition: Crypto-asset service · Appendix B · Chapter 2

Custody and administration

Holding clients' crypto-assets, or the keys to them: the first of Halcyon's five services. The custodian keeps clients' assets in separate wallets and a register of positions for each client. It is liable for a loss attributable to it, up to the asset's market value at the time. Binder §4.1 · Binder §4.6 · Chapter 1 · Chapter 5

Customer due diligence (CDD)

Checking who a client is before doing anything for them: identity, address, sanctions and politically-exposed-person screening, and a risk rating. A high-risk client gets enhanced due diligence. No client trades, deposits or withdraws until the checks are complete. Binder §7.2 · Chapter 7

D

Distributed ledger

A shared record kept by many computers at once, which no one owns. A new entry counts only when enough of those computers agree, and after that nobody can quietly change it. A blockchain is the best-known kind. Definition: Crypto-asset · Chapter 1

DORA

The Digital Operational Resilience Act: the EU law on keeping financial firms' technology running and their data safe, applying since January 2025. It covers crypto firms as well as banks. It asks for a framework, incident reports, testing and control of outside providers. Binder §9 · Chapter 9

E

Electronic money institution (EMI)

A licensed payment firm that is not a bank and issues e-money, a stored euro balance. With a bank, it is the only firm that may issue an electronic money token. Halcyon is not one, so the euro clients keep in its app is e-money from Brightwater Payments Limited. Binder §1.3 · Chapter 2 · Chapter 5

Electronic money token (EMT)

A token that claims a stable value by referencing one official currency, such as the euro: what the market calls a stablecoin. Only a bank or an electronic money institution may issue one. The holder may redeem it at par at any time and receives no interest. Definition: EMT · Chapter 1 · Chapter 2 · Chapter 5

Exchange, and execution of orders

Two of Halcyon's five services, which look alike on a screen. In exchange, Halcyon is the other side of the trade, dealing at its own price. In execution of orders, Halcyon gets the client's trade done wherever the result is best, without being the other side. Appendix B · Chapter 2

F

Fitness and probity

Ireland's name for MiCA's rule that the people who run a crypto firm be honest and competent. Fitness means competence and probity means honesty. The Head of Legal keeps a file on each director, and a new director takes no board decision until the Central Bank clears them. Binder §2.2 · Appendix A.4 · Chapter 3 · Chapter 4

H

Home authority and host authority

The home authority is the regulator that authorised a crypto firm and supervises it, and for Halcyon that is the Central Bank. A host authority regulates another member state where the firm serves clients under the passport. It is told about the firm, not asked to approve it. Binder §1.4 · Chapter 6

I

ICT-related incident

Any event that harms a firm's systems, networks or data, such as a failed update, an attack or a provider's outage. ICT means information and communication technology. Every incident is logged with the time it was detected, and only a major one is reported. Binder §9.3 · Chapter 9

ICT risk management framework

The written rules, systems and controls that keep a firm's technology running and its data safe, as DORA requires. Halcyon's CTO runs it day to day. The Board approves it, reviews it each year and after every major incident, and answers for it. Binder §9.1 · Chapter 9

ICT third-party provider

Any outside company that supplies technology to Halcyon. Every contract with one goes in the register of information and must carry DORA's contract terms. For a critical provider, one whose failure would stop a service, the CTO also keeps an exit plan. Binder §9.6 · Binder §9.7 · Binder §4.5 · Chapter 9

Inside information

Precise information about a crypto-asset or its issuer that has not been made public and would be likely to move its price significantly. Dealing on it is insider dealing, and passing it on needlessly is unlawful disclosure. A listing decision is inside information until it is announced. Definition: Inside information · Binder §8.2 · Chapter 8

M

Major ICT-related incident

An ICT-related incident that crosses DORA's thresholds, such as how many clients were affected, how long it lasted or whether a critical service was hit. Only a major one is reported to the Central Bank, in three reports on fixed deadlines. Nobody has to lose anything. Definition: Major ICT-related incident · Binder §9.4 · Appendix C · Chapter 9

Market manipulation

Any trade, order or statement that gives a false or misleading signal about the supply, demand or price of a crypto-asset. A false signal is enough, and nobody has to be tricked into a trade. Surveillance watches for wash trading, spoofing, layering and pump-and-dump. Binder §8.3 · Chapter 8

MiCA

Regulation (EU) 2023/1114: the EU's single rulebook for crypto-assets and the firms that deal in them. Its rules for EMTs and ARTs applied from 30 June 2024, and the rest, including the rules for crypto firms, from 30 December 2024. An article number with no law named is MiCA's. Binder, what this binder is §1 · Binder, what this binder is §3 · Chapter 1 · Chapter 2

Money Laundering Reporting Officer (MLRO)

The one officer the anti-money-laundering rules make responsible for deciding whether a suspicion is reported. At Halcyon it is Elena Stavrou, the Head of Compliance. She alone decides whether to file a suspicious transaction report, and only a Board resolution may remove her. Binder §7.1 · Binder §2.4 · Chapter 7

N

National competent authority (NCA)

The regulator each member state names to supervise MiCA. Halcyon's is the Central Bank of Ireland, called “the Central Bank” throughout. It authorised Halcyon, and it receives Halcyon's reports of suspected market abuse and of major ICT incidents. Definition: NCA · Chapter 8

O

Obliged entity

A business the anti-money-laundering law requires to check who its clients are, watch their transactions, report suspicion and appoint an MLRO. Crypto firms became obliged entities before MiCA existed. Halcyon has been one since it registered in 2022. Definition: Obliged entity · Binder §7.1 · Chapter 1 · Chapter 7

Operation of a trading platform

Running an order book that matches one client's order to buy against another client's order to sell. Halcyon is not authorised for it, and its Board has resolved to apply. The service moves a firm to Class 3 and bars it from trading its own money against clients there. Binder §1.3 · Appendix B · Chapter 2 · Chapter 10

Originator and beneficiary

The two ends of a crypto transfer under the Travel Rule. The originator is the client who sends it, and the beneficiary is the person who receives it. The originator's firm sends both people's details to the beneficiary's firm, which checks them before crediting its client. Binder §7.4 · Chapter 7

Outsourcing

Paying another firm to do part of the work the licence covers. MiCA allows it, but the firm stays fully responsible to its clients for the outsourced work. Halcyon outsources the hardware that holds its clients' keys to Keystone Vault. Appendix A.13 · Binder §4.5 · Chapter 4

Own funds

The firm's own capital, which stays in the business to absorb losses, and clients' money never counts. MiCA sets it at the higher of the class floor and a quarter of last year's fixed overheads, the costs paid whether or not anyone trades. Halcyon must hold €1,600,000 and held €2,100,000. Definition: Own funds · Binder §3.1 · Chapter 1 · Chapter 3

P

Passport

A crypto firm's right to provide its authorised services in any other member state after notifying its home regulator. It needs no new authorisation, office or capital, and may start at the latest 15 calendar days after notifying. The passport stops at the EU's border. Definition: Passport · Binder §1.4 · Chapter 2 · Chapter 6

Private key and wallet

A private key is a secret number that controls an address on the ledger: whoever knows it can move the tokens there. A wallet is the software or device that keeps a key and signs with it. Halcyon's clients hold no keys, because Halcyon holds them through Keystone Vault. Binder §4.5 · Chapter 1 · Chapter 5

Q

Qualifying holding

A stake in a crypto firm large enough to influence it. Each holder of one must show, in the application file, who it is and where its money came from. A later change in who holds one must be notified to the regulator and assessed. Appendix A.5 · Chapter 3 · Chapter 10

R

Reconciliation

Comparing two records that should agree and explaining every difference. Every business day, the operations team checks the register of positions against the client wallets on the ledger, and the client funds ledger against the bank statement. A difference unexplained after one business day enters the breach log. Binder §4.7 · Chapter 5 · Chapter 7

Register of information

DORA's list of every contract with an outside technology provider: what it supports and whether it is critical. The CTO keeps Halcyon's. It did not exist when Halcyon applied for its licence, and building it held the application up for months. Definition: Register of information · Binder §9.6 · Appendix A.7 · Chapter 3 · Chapter 9

Register of positions

The record a custodian keeps in each client's name, showing the crypto-assets held, their quantity, the wallet address and every movement in or out. A balance in the app is a line in this register, not a token on the ledger. It proves what each client owns. Binder §4.4 · Chapter 1 · Chapter 5

Reverse solicitation

MiCA's narrow exemption for a client who approaches a firm entirely on the client's own initiative, and only for the service asked for. An advertisement, an app-store listing aimed at the country or a referral scheme ends it. It is never a way into a market. Definition: Reverse solicitation · Binder §1.5 · Chapter 6

S

Safeguarding and segregation

Safeguarding is the whole arrangement that keeps clients' crypto-assets and euro apart from the firm's own and out of its creditors' reach. Segregation is its first half: clients' crypto-assets sit in wallets separate from the firm's own. The second half is a ban on using clients' assets. Definition: Safeguarding · Binder §4.1 · Binder §4.2 · Chapter 5

Self-hosted address

A wallet a person controls with their own keys, with no crypto firm behind it. For a transfer above €1,000 to or from one, Halcyon checks that its own client owns or controls it, for example by a message signed with the wallet's key. Definition: Self-hosted address · Binder §7.5 · Appendix D.2 · Chapter 7

Stablecoin

The market's word for a token that claims a stable value. MiCA does not use it. A token pegged to one currency is an electronic money token, and one referencing anything else is an asset-referenced token. Definition: EMT · Definition: ART · Chapter 2 · Chapter 5

STOR

A suspicious transaction and order report: the notice a firm sends its regulator, here the Central Bank, when it suspects market abuse. At Halcyon the Head of Compliance alone decides, and files it without delay. The client is never told, and it is not an STR. Definition: STOR · Binder §8.5 · Chapter 8

Surveillance

Software that reads every order and trade in the app and raises an alert when a pattern looks wrong. Compliance reviews each alert within 2 business days and records whether it is explained, needs enquiry or is suspicious. Binder §8.4 · Chapter 8

Suspicious transaction report (STR)

The anti-money-laundering report of suspected money laundering. The MLRO alone decides whether to file it, with the national financial intelligence unit, not the Central Bank. Telling the client is tipping off, which the law forbids. Binder §7.3 · Chapter 7 · Chapter 8

T

Threat-led penetration testing

A controlled attack on a firm's live systems by an independent tester, the way a real attacker would try. Halcyon must run one at least every three years only if the Central Bank designates it. Ordinary scans and scenario tests run anyway. Binder §9.5 · Chapter 9

Transfer of Funds Regulation (the Travel Rule)

The EU law, nicknamed the Travel Rule, that makes the sender's and receiver's details travel with every crypto transfer, from 30 December 2024. Between two crypto firms there is no minimum amount. A transfer above €1,000 with a self-hosted address needs proof that the client controls it. Definition: Travel Rule · Binder §7.4 · Chapter 7

Transfer services

Moving a client's crypto-assets to another address on the client's instruction: the fifth of Halcyon's services. A transfer on the ledger cannot be reversed. The Travel Rule makes both people's details travel with it, and a transfer above €1,000 to the client's own wallet needs proof of ownership. Appendix D.2 · Chapter 2 · Chapter 7

Transitional period

The extra time MiCA gave firms already serving clients under national rules to get authorised. MiCA allowed up to 18 months, and each member state could shorten it. Ireland's ended on 30 December 2025, and a firm not authorised by then had to stop serving clients. Definition: Transitional period · Chapter 2 · Chapter 3

V

Virtual asset service provider (VASP)

The name for a crypto firm registered under the anti-money-laundering rules before MiCA. Registration was a narrow check of the firm's customer checks and the honesty of its owners and managers, with no look at capital, custody or technology. Halcyon was registered in 2022. Binder §1.1 · Chapter 1 · Chapter 3

W

White paper

The disclosure document that describes a token, the project behind it and its risks. Someone must publish it and notify it to the national regulator before the token is offered to the public or admitted to trading. Halcyon's listing committee admits no token without one. Definition: White paper · Binder §10.2 · Chapter 2

Wind-down plan

A firm's plan for closing in good order, so that every client gets back what is theirs. Halcyon's starts on any of three triggers, is funded for twelve months and stops custody last. Every client's assets are returned within 90 days. Binder §3.3 · Appendix A.14 · Chapter 3 · Chapter 4