Ms Derville Rowland:

The Deputy is correct that there is an issue about the pro rataapportionment of any breach to the timeframe within which the relevant rules apply. Post-2013 and pre-2013 would be bifurcated according to the sanctions in place in law at the time, but it also depends on the breaches being pursued in a particular case. We will look at the scenario in bank X and extract the relevant facts that match the breaches. The breaches are not all the same in each case. We will consider a suite of relevant breaches and then we will look at the facts and match those two together. The duration of the breaches will vary in each case. They might have broad similarity. An answer cannot be given without cutting the breaches according to the evidence in the case. The Deputy will appreciate that breaches may have stopped before 2013 or they may not. There will be a series of cut-offs for different breaches depending on the facts that we can evidence. I do not know, therefore, what sanctions will be capable of applying until I know what the breaches are and their duration, but if they predate 2013, the more limited set of sanctions will apply, and if they post-date it, then it is at large to the higher sanction levels, which is the €10 million or 10% of turnover, whichever is higher.