Mr. Jeremy Godfrey:

I cannot remember the highest penalty we have had under the current regime. Mr. Blaney can correct me if I am wrong, but I understand people have paid us under settlement agreements. One of the highest payments was about €3 million. When we take criminal prosecutions, typically they are in the District Court and the maximum fine is €5,000 per count.

It is not just a question of the level of the fine; it is also the process by which the fine is arrived at and administered. It is important that ComReg imposes an administrative fine and financial sanction. Under the current regime we have to go to the lower courts for criminal prosecutions, which involves low numbers, or go to the High Court and ask it to impose a financial section. We have found it extremely important to have administrative financial sanctions. That is something which is available to some of the other regulators in Ireland. It is available to most of our peers across Europe. It is in line with the Law Reform Commission.