Pearse Doherty (Donegal, Sinn Fein) | Oireachtas source

I appreciate that. I have two points. Financial institutions being able to pay the fine for the individual is problematic and maybe that is something the Central Bank could consider. It is difficult to have individual accountability in sanctioning somebody when it is the financial institution that is paying for it anyway. There are questions of probity and so on, but there is a difference in the sanction against an individual compared to an institution. The measurement would be different if applying a sanction against an individual and if we knew the institution was paying for that, it might be higher. That is one issue.

That is why I said this merits careful consideration with regard to incentives. The problem is that under the Central Bank's toolbox at the minute, immunity is provided - the Minister can correct me if I am wrong, and, therefore, there is an incentive where somebody brings an issue forward, although not for first movers, as far as I understand it.