Mr. Tony O'Brien:

At the individual level, with regard to whoever was responsible at the time for the governance of each agency, where there is no evidence of any reasonable quality that the necessary approvals existed, it is reasonable to conclude that the necessary approvals did not exist and that therefore someone made the decision to proceed in the knowledge that they did not have the necessary approvals. The reality is that they have the effective freedom - not the real freedom, but at a practical level they have had the freedom - to do this because they have their own payroll system. They simply have the capacity to do it. We are moving, as we discussed elsewhere, to a different type of financial control environment, in terms of the facilities we have, to have a view of transactions of payroll through a shared services environment. When we get there, it simply will not be possible for entities to make and implement such decisions, unless they do the absolutely fraudulent thing of running their own payroll off somewhere; then we would be able to see the money leaving.

There has been a structure, an architecture, that has enabled this to happen, but clearly there was a culture - we are going back to the 1990s in some instances - in which it was considered acceptable and appropriate to do it. Not least because of the economic and fiscal circumstances the country has been through, with the FEMPI legislation and so on, we are at this point coming to a position at which it is understood that this is not acceptable, and we are going to bring about an environment in which it cannot be done.