Ms Seana Cunningham:

As a reflection on our experience, we were also very supportive of the work of the Law Reform Commission in the context of looking at regulatory powers and corporate offences, and indeed at the broader framework. We set out these high-level proposals initially and then put them forward as part of the culture report on the banking sector. This is about the enhancement of a framework. Legislative change has already enhanced the powers of the Central Bank, including the Central Bank Reform Act 2010 and the Central Bank (Supervision and Enforcement) Act 2013. These have been very helpful in advancing the framework; this is a very important proposal to further enhance things. This concerns looking directly at the conduct of individuals through the prism of a legal framework. Currently, under our framework, the administrative sanctions procedure, we must first look at whether a firm has breached a legal requirement and then whether an individual has participated. We believe that this proposal allows us to look at this in a very different way.