Professor Philip Lane:

We have an enforcement directorate in the bank which is quite big. We have many very good lawyers in the bank and what they are essentially tasked with doing is investigating. An investigation phase is taking place which involves trying to work out how this happened. They have various information-gathering powers. They can carry out interviews, go into these banks and look at documentation. I do not think it is a good idea for me to speculate on where this will go in terms of individual accountability but in the absence of being able to speculate about that in respect of trackers, let me point out that one thing we have been saying in recent weeks and months involves the Law Reform Commission. We wrote to the commission to say that a changed approach to individual accountability might be something for the Oireachtas to think about for the future. The UK introduced this recently. In the UK, essentially, the senior management of financial institutions must take responsibility. It would not be a defence under that system for someone to say they did not directly write any letter or email authorising some inappropriate behaviour. The head of or someone in senior management in one of these organisations must take responsibility for the conduct of the organisation. It might be helpful if Ms Rowland weighs in on this issue.