Ms Seána Cunningham:

The duty of responsibility is partly centred on the idea that a person is responsible for a particular area and, therefore, part of the oversight requirement involves ensuring a firm is in compliance with its obligations. That is where that aspect remains relevant in the context of a senior person, the oversight of a particular area and ensuring the firm is compliant with the regulations in that particular area. I say that because, in the main, all the obligations are placed on firms.