Ms Seána Cunningham:

Yes. We are not losing entirely the concept of a firm committing a breach and somebody, through his or her seniority, being part of that breach in terms of holding him or her accountable. There are directly enforceable obligations against individuals envisaged that are not dependent on establishing a contravention by a firm.

Having said that, again it will be when you are looking at a particular issue that you would look to decide how best to come at this in the context of what this tells us. Is it that a firm has failed across systems and controls in a particular area? Is it that I am then looking at this senior person or am I actually looking at a failure by a senior person to act with integrity and honesty? The more high-level common conduct standards may come into play as of themselves.