The mechanism relies on the approval of bond prospectuses by a national financial regulator within an EU member state. For years, the Central Bank of Ireland handled this process under a 2017 EU mandate. However, the responsibility shifted to Luxembourg’s Commission de Surveillance du Secteur Financier in 2025. That institution ceased all such authorizations on August 31, citing the intense public outcry surrounding military operations in Gaza.
Since September 1, the legal obligation to oversee these filings reverted to the Central Bank of Ireland. The institution now faces a narrow set of choices: resuming the administrative burden itself, transferring the mandate to a more receptive jurisdiction like Germany at Israel's request, or simply declining to issue new approvals. Because of strict financial privacy regulations and the volatile political climate, the status of these discussions remains shielded from public view, leaving the €2.2 billion market in a state of indefinite suspension.
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