1 We are at the early stages of a potential technological rewiring of finance. Fast-forward ten or twenty years, and it seems likely that the use of shared, programmable ledgers – and the tokenisation of financial assets – will have become embedded across the financial system. Today, we stand at a juncture. The question is less whether the technology will transform finance. Rather, it is how we collectively shape this ongoing transition, so that the potential of tokenised finance is realised,...
AI Analysis
The Deputy Governor’s speech sets out the Central Bank of Ireland’s (CBI) emerging regulatory stance on tokenised finance and distributed ledger technology (DLT), framing it as a structural transition rather than a niche innovation. While it does not introduce new binding rules, it clearly signals supervisory expectations, impending policy development (including follow‑up to the March 2026 Discussion Paper on tokenisation and DLT), and the need for regulated firms to integrate tokenisation risks, governance and operational resilience into existing regulatory frameworks.
What Changed
- The CBI formally recognises tokenisation and shared, programmable ledgers as a likely core infrastructure of the future financial system and signals that regulation will evolve to treat tokenised...
The speech confirms that CBI’s regulatory approach will be “technology‑neutral but not technology‑blind”, indicating that existing EU and Irish rules (e.g.
The CBI emphasises the need to keep central bank money at the core of tokenised finance, aligning its stance with Eurosystem work on wholesale and retail central bank digital currency (CBDC) and...
The speech reinforces that tokenised instruments representing traditional financial assets (securities, deposits, fund units) will generally be treated as regulated financial instruments, triggering...
The CBI highlights operational resilience, cyber risk, interoperability and smart‑contract governance as critical supervisory focus areas for tokenised finance infrastructure and platforms.
Suggested Considerations
Map all current and planned tokenisation and DLT initiatives (including pilots and proofs of concept) across the group and identify which EU and Irish regulatory regimes they fall under (MiFID II, UCITS, AIFMD, CRR/CRD, PSD2/PSR, Solvency II, MiCA, DORA, etc.).
Perform a regulatory gap analysis to confirm that tokenised products and services are fully captured within existing licensing permissions and assess whether any variation of permission, new authorisation, or recognition as a market infrastructure is required.
Review and update governance arrangements so that boards and senior management explicitly oversee tokenisation strategies, risk appetite, and the use of DLT, including ensuring clear allocation of responsibilities under the firm’s senior manager or fitness and probity framework.
Integrate tokenisation‑specific risks into the firm’s risk management framework, covering legal enforceability of tokens, smart‑contract risk, cyber and operational resilience, data integrity, interoperability, concentration risk in technology providers, and settlement and counterparty risk.
Review outsourcing and third‑party risk management frameworks to ensure that DLT platform providers, smart‑contract developers, node operators and custodians are treated as critical or important outsourced service providers where appropriate, with robust contractual, oversight and exit provisions.
Key Dates
05 March 2026
- CBI publishes its Discussion Paper on tokenisation and distributed ledger technology in financial services, initiating a structured consultation on tokenised markets, funds, money and payments
26 May 2026
- Deputy Governor speech sets out the CBI’s strategic approach to tokenised finance, confirming that consultation feedback will inform subsequent policy, supervisory expectations and potential rule changes
05 June 2026
- Closing date for submissions to the CBI Discussion Paper on tokenisation and DLT, after which CBI will prepare a feedback statement and refine its policy stance
TBD (post‑June 2026)
- CBI feedback statement on the tokenisation Discussion Paper expected, likely followed by more granular guidance and potential adjustments to supervisory and authorisation processes for tokenised activities
Compliance Impact
Non‑compliance will not immediately trigger new standalone tokenisation fines, but CBI is likely to use existing conduct, prudential, governance and operational resilience powers to challenge poorly controlled tokenised activities and may restrict or prohibit projects that do not meet its expectations. Firms that treat tokenised finance as “outside the regulatory perimeter” or fail to integrate it into existing compliance frameworks risk supervisory intervention, authorisation issues, enforcement action and reputational damage.
Introduction Good morning – I am delighted to be here, and many thanks to Brian and the BPFI for hosting us. 1 I very much look forward to the discussion, and to hearing from you all today, but before I do I would like to set out some reflections on a number of topics which are currently high on the regulatory agenda. While the discussion is multifaceted, and tied up with a regulatory cycle which has turned, an economic one which has become more challenging, not to mention a renewed focus by ...
Safeguarding Financial Integrity – Central Bank of Ireland’s Approach to Financial Crime Prevention Thank you for the invitation to speak at today’s event. This is an important opportunity for us to engage and share our experiences and approaches to deal with the global challenges and issues we are facing in financial crime. Change, instability, flux, unpredictability - all words that I guarantee you will hear on multiple occasions throughout the day’s events. I will not be any different. We ...
More than one in three Irish adults (35%) have experienced fraud or scams. 38% of fraud victims never reported their experience to their financial service provider or any authority. Research identified risky online behaviours as the single strongest predictor of fraud experience—more influential than age, income, or education level. Fraud victims are far more likely to recover monies when the fraud is reported. Fraud literacy reduces predicted fraud exposure Central Bank of Ireland of Ireland...
Today, the High Court published its written judgment in the matter of the Central Bank’s application under the Fitness & Probity Regime to confirm the one-year prohibition issued to a senior executive on 02 February 2022 concerning his role in a regulated firm in the investment fund and asset management sector. The decision of the High Court was to refuse the application. The Central Bank acknowledges the importance of the Court’s findings and the clarity that the judgment provides in this ca...
AI Analysis
The Central Bank of Ireland (CBI) issued a statement on 17 April 2026 acknowledging a High Court judgment refusing to confirm a one-year prohibition on a senior executive in the investment fund and asset management sector due to inadequate fair procedures during the CBI's Fitness & Probity (F&P) investigation. This matters for compliance professionals as it underscores the critical need for robust fair procedures in F&P processes and highlights recent legislative and guidance enhancements under the Individual Accountability Framework (IAF) Act 2023 to address such shortcomings. Firms must prioritize these updates to mitigate enforcement risks.
What Changed
- Legislative enhancements via IAF Act 2023: Introduced changes to strengthen CBI's investigation and prohibition powers under the F&P Regime, including additional safeguards for fair procedures in...
Updated Regulations and Guidance (April 2023): CBI published revisions reflecting IAF Act changes, focusing on improved investigation and decision-making processes...
CP-150 Consultation (2025): Led to updated Guidance on consolidated Fitness and Probity Standards, separate from F&P investigations...
CP-166 Consultation on Supplemental Guidance: Public consultation on prohibitions closed 25 March 2026; final guidance expected summer 2026...
Suggested Considerations
Review and implement April 2023 updated F&P Regulations and Guidance to ensure investigations and prohibitions incorporate IAF Act fair procedure safeguards (https://www.centralbank.ie/news/article/press-release-central-bank-statement-on-high-court-judgment-17-april-2026).
Conduct internal audits of F&P processes, focusing on fair procedures (e.g., notice, representation rights) for senior executives in CF/PCF roles.
Monitor and prepare for summer 2026 final guidance from CP-166 on prohibitions; submit any late feedback if applicable.
Train compliance and HR teams on heightened procedural standards, referencing High Court emphasis on fair procedures.
For firms in investment funds/asset management: Assess PCF suitability assessments against consolidated F&P Standards from CP-150.
Compliance Impact
Urgency: High – The High Court ruling directly critiques CBI's past F&P procedures, signaling elevated scrutiny on fair process compliance; failure risks court refusals of prohibitions, reputational damage, and escalated enforcement. With final CP-166 guidance imminent (summer 2026), firms face immediate pressure to align processes, especially post-IAF Act, to avoid similar outcomes in ongoing or future investigations.
Warning: Unauthorised Investment Firm / Unauthorised Investment Business Firm / Unauthorised Irish Collective Asset-Management Vehicle (ICAV) Unauthorised Firm Name Clarus IV ICAV (CLONE) Website https://www.clarusiv.com/ Email addresses used enquiries@clarusiv.com accounts@clarusiv.com michael.granger@clarusiv.com Phone number used +353 1525 9660 Authorisation in Ireland Clarus IV ICAV (Clone) is not authorised to provide investment services in Ireland. Additional Information This firm clone...
AI Analysis
The Central Bank of Ireland (CBI) has issued a warning notice under section 53 of the Central Bank (Supervision and Enforcement) Act 2013 regarding **Clarus IV ICAV (CLONE)**, an unauthorised entity cloning a legitimate authorised ICAV to perpetrate investment scams. This matters for compliance professionals as it underscores rising clone firm risks in Ireland's investment sector, requiring vigilance to protect clients and avoid facilitation of scams.
What Changed
This is not a regulatory change but a specific enforcement action publishing details of an unauthorised clone firm. It highlights no new requirements but reinforces existing obligations under Irish law to verify firm authorisation before engaging in investment services, with the CBI actively using public warnings to combat scams.
Suggested Considerations
Client communications: Issue alerts on clone risks and direct to CBI scam protection resources (www.centralbank.ie/financialscams).
Internal screening: Update compliance systems to flag clone indicators (e.g., similar names, cloned authorisation details); report suspicions to CBI at (01) 224 5800.
Legitimate firms: Publicly disavow any connection if cloned, as emphasised by CBI.
Key Dates
17 April 2026
- CBI publishes warning notice on Clarus IV ICAV (CLONE)
Compliance Impact
Urgency: Medium - Immediate for client-facing activities due to active scam using Irish phone numbers and domains, but not a new rule change; matters to prevent regulatory scrutiny for inadequate due diligence or client harm under conduct and authorisation rules. Recent pattern of ICAV clones (e.g., Parus ICAV on 08 April 2026, Red Arc on 10 April 2026) signals heightened scam activity, elevating ongoing monitoring needs.
Warning: Unauthorised Investment Firm / Investment Business Firm Unauthorised Firm Name Pimco Global Wealth / Pimco (Ireland) (Clone) Websites www.pimcoglobalwealth.com www.pimcoprivatewealth.com www.pimcoprivateclients.com www.pimcoglobaladvisors.com Email address used admin@pimcoglobalwealth.com Phone numbers used +353 1 912 8604 +353 1 531 4593 Authorisation in Ireland This firm is not authorised to provide investment services in Ireland. Additional information Pimco Global Wealth / Pimco ...
AI Analysis
The Central Bank of Ireland (CBI) issued a warning notice on 17 April 2026 under section 53 of the Central Bank (Supervision and Enforcement) Act 2013, identifying "Pimco Global Wealth / Pimco (Ireland) (Clone)" as an unauthorised investment firm impersonating the legitimate authorised entity Pimco Global Advisors (Ireland) Limited by cloning its name, CRO number, and address. This matters for compliance professionals as it underscores rising cloning scams targeting Irish consumers, requiring firms to enhance client vigilance, scam monitoring, and public communications to mitigate reputational and conduct risks.
What Changed
This is not a regulatory change or new requirement but a specific enforcement warning publicising an unauthorised clone firm operating via listed websites (www.pimcoglobalwealth.com, www.pimcoprivatewealth.com, www.pimcoprivateclients.com, www.pimcoglobaladvisors.com), email (admin@pimcoglobalwealth.com), and Irish phone numbers (+353 1 912 8604, +353 1 531 4593). It reinforces CBI's ongoing use of section 53 powers to name and shame unauthorised entities engaged in deceptive practices, with no new rules but heightened emphasis on consumer deception via firm cloning.
Suggested Considerations
Verify authorisation: Firms and clients must check CBI's register (www.centralbank.ie) before engaging with any entity claiming to offer investment services.
Issue internal alerts: Authorised firms should disseminate this warning to staff, clients, and intermediaries via emails, client portals, and websites, emphasising no connection to clones.
Monitor and report: Screen for the listed websites, emails, and phone numbers in client communications; report suspicious activity to CBI at (01) 224 5800 or via unauthorised firm reporting portal.
Enhance controls: Implement or update scam detection protocols, including client onboarding checks for impersonation red flags and training on cloning tactics.
Public disclaimers: Legitimate firms like PIMCO should post fraud warnings, as seen on their site, advising against sharing personal/bank details with unknowns.
Key Dates
17 April 2026
- CBI publishes warning notice on Pimco Global Wealth (Clone)
Compliance Impact
Urgency: Medium - Immediate for Pimco-impacted firms due to active deception using Irish contact details, but medium overall as CBI warnings are routine (e.g., multiple Pimco clones in 2024-2026). Matters for conduct risk, client protection, and reputation; failure to act could breach CBI fitness & probity or consumer duty expectations, especially amid rising scams (e.g., Clarus IV ICAV clone on same date).
Warning: Unauthorised Retail Credit Firm Unauthorised Firm Name Finance Advice Help Website Financeadvicehelp.com Email address used contact@financeadvicehelp.com Authorisation in Ireland Finance Advice Help is not authorised to provide retail credit services in Ireland. Notes: Any person wishing to contact the Central Bank with information regarding such firms / persons may telephone (01) 224 5800 or report an unauthorised firm directly to the Central Bank . For more information on how to pr...
AI Analysis
The Central Bank of Ireland (CBI) has issued a warning notice under section 53 of the Central Bank (Supervision and Enforcement) Act 2013, identifying "Finance Advice Help" (website: financeadvicehelp.com; email: contact@financeadvicehelp.com) as an unauthorised firm providing retail credit services in Ireland. This matters for compliance professionals as it underscores CBI's proactive enforcement against unauthorised entities, heightening risks of consumer scams and potential liability for authorised firms if clients inadvertently engage with clones or similar frauds.[Source URL: https://www.centralbank.ie/news/article/finance-advice-help--central-bank-of-ireland-issues-warning-on-unauthorised-firm]
What Changed
This is not a regulatory change but an enforcement action via a public warning notice. It reinforces existing requirements under the Central Bank (Supervision and Enforcement) Act 2013 (section 53), which empowers CBI to publish names of unauthorised firms offering regulated services like retail credit. No new rules are introduced; it signals ongoing vigilance against unauthorised retail credit providers.[Source URL: https://www.centralbank.ie/news/article/finance-advice-help--central-bank-of-ireland-issues-warning-on-unauthorised-firm]
Suggested Considerations
Verify firm status: Use CBI's unauthorised firms search tool before engaging with any retail credit provider (https://www.centralbank.ie/regulation/how-we-regulate/authorisation/unauthorised-firms/search-unauthorised-firms).
Report suspicions: Contact CBI at (01) 224 5800 or via direct reporting portal for any dealings with Finance Advice Help or similar entities.[Source URL: https://www.centralbank.ie/news/article/finance-advice-help--central-bank-of-ireland-issues-warning-on-unauthorised-firm]
Educate clients/staff: Disseminate scam protection guidance from www.centralbank.ie/financialscams; implement "SAFE test" for verification.[Source URL: https://www.centralbank.ie/news/article/finance-advice-help--central-bank-of-ireland-issues-warning-on-unauthorised-firm]
Monitor clones: Screen for impersonation risks, as seen in related warnings (e.g., Shamrock Lend clone).
Key Dates
14 April 2026
Publication date of warning notice; Immediate public alert on unauthorised status of Finance Advice Help.[Source URL: https://www.centralbank.ie/news/article/finance-advice-help--central-bank-of-ireland-issues-warning-on-unauthorised-firm]
Compliance Impact
Urgency: Medium – This is a routine CBI warning (one of many in 2025-2026), not targeting authorised firms directly, but it elevates consumer protection and conduct risks. Firms must act promptly to update internal alerts and client advisories to mitigate reputational harm, regulatory scrutiny, or indirect liability from scam exposures; failure could trigger CBI inquiries under conduct rules.
The Prohibition Notice (PDF) issued after Mr Buckley signed a Statement of Undisputed Facts, in which he accepted that between 1 February 2021 and 12 December 2023, while he was employed at two different retail intermediaries, he issued invoices to clients directing payment to his personal bank account in place of his employers’ bank details. Mr Buckley also accepted that he misrepresented his financial qualifications to clients during the course of his employment. The Prohibition Notice issu...
AI Analysis
The Central Bank of Ireland (CBI) has issued an indefinite prohibition to Nicholas (Nick) Buckley from all controlled functions, effective 25 February 2026, following his admission of diverting client payments to his personal account and misrepresenting financial qualifications while at two retail intermediaries from 1 February 2021 to 12 December 2023. This enforcement action underscores the CBI's commitment to the Fitness and Probity Regime, emphasizing integrity in customer-facing roles to maintain public trust. Compliance professionals should note it as a precedent for severe sanctions on dishonesty, potentially influencing vetting and monitoring practices.
What Changed
This is not a new regulation but an enforcement outcome under the existing Fitness and Probity Regime, established by the Central Bank Reform Act 2010, which mandates high standards of competence, integrity, and honesty for individuals in controlled functions. No regulatory changes are introduced; instead, it reinforces enforcement mechanisms, including investigations and prohibitions for breaches, particularly in customer-facing roles where honesty is paramount.
Suggested Considerations
Firms employing similar roles: Immediately review invoicing processes to ensure payments direct only to firm accounts, with segregation of duties and dual approvals for client billing.
Fitness and Probity assessments: Conduct enhanced due diligence on customer-facing staff, verifying qualifications via independent sources and monitoring for personal financial gain conflicts.
Incident reporting: Escalate any suspected integrity breaches (e.g., qualification misrepresentation or fund diversion) to CBI under fitness and probity notification obligations.
Training programs: Update mandatory training on Fitness and Probity Standards (available at https://www.centralbank.ie/regulation/fitness-and-probity), focusing on honesty in client interactions.
Prohibition checks: Screen all controlled function holders against CBI's public prohibitions list before approvals or role changes.
Key Dates
1 February 2021
12 December 2023; Period of Buckley's admitted misconduct (diverting payments and misrepresenting qualifications)
25 February 2026
Effective date of the indefinite prohibition on Buckley performing any controlled functions
01 April 2026
Publication date of the CBI press release announcing the Prohibition Notice
Compliance Impact
Urgency: Medium – This is a specific enforcement precedent rather than a new rule, but it signals heightened CBI scrutiny on integrity breaches in retail intermediation, with indefinite bans as a tool to protect consumers. It matters because customer-facing misconduct erodes trust, prompting firms to strengthen controls proactively to avoid similar investigations, especially given CBI Director of Enforcement's warning on accountability. Non-compliance risks firm-level sanctions, reputational damage, and operational disruptions.
Good morning everyone. It is a pleasure to join you today at the Abbey Theatre. We are here, of course, to launch a commemorative coin to honour Seán O’Casey, one of Ireland’s most important literary figures, and one whose voice continues to resonate profoundly, both in Ireland and internationally. I am delighted to welcome Shivaun O’Casey, Seán O’Casey’s daughter. It is particularly fitting to mark this occasion in her presence. Thank you to the Abbey Theatre for hosting us here today, a pla...
Good afternoon and welcome to this Central Bank of Ireland workshop on the Consumer Protection Code. Today I will focus on the outlook for consumers and investors. But first let me pause to talk a little about the broader context in which we find ourselves. We are living through a period marked by extraordinary change, geopolitical instability, rapid technological transformation and shifting economic conditions. Governor Makhlouf summarised this well when he said how 2026 has already seen ext...
AI Analysis
Deputy Governor Colm Kincaid's speech on 24 March 2026 emphasizes consumer protection as central to the Central Bank of Ireland's (CBI) mission amid geopolitical, technological, and economic changes, highlighting the revised **Consumer Protection Code 2025** (CPC 2025) as a key modernization effort. This matters for compliance professionals because the CPC 2025 introduces enhanced, digitally-focused protections effective **24 March 2026**, replacing the 2012 Code after a 12-month implementation period, with firms required to proactively secure customer interests.
What Changed
The CPC 2025 comprises Standards for Business Regulations (governance, resources, risk management, conduct standards) and Consumer Protection Regulations (cross-sectoral and sector-specific rules for...
Core obligation: Firms must "secure customers’ interests," shifting to a proactive, customer-focused mindset.
Cross-sectoral requirements: Knowing the consumer/suitability; conflicts of interest/remuneration; vulnerable consumers (updated definition); digitalisation (customer-focused design); effective...
Specific enhancements: Fraud/scam protections; mortgage switching disclosures; greenwashing prevention via clear sustainability claims; expanded consumer definition (e.g., SMEs up to €5m turnover...
Supporting materials: Guidance on securing interests/vulnerable consumers, mapping tool for legacy codes, redline amendments.
Suggested Considerations
Gap analysis: Map current policies/processes against CPC 2025 using CBI's mapping tool; update for new obligations like digital service design, vulnerability screening, fraud measures.
Urgency: High – With effectiveness today (24 March 2026), firms face immediate non-compliance risk as the 12-month window closes; CBI supervision will intensify on digital/fraud/vulnerability protections amid heightened risks (e.g., cyber, scams). Non-adherence risks enforcement under CBI's powers, reputational damage, and fines, especially as this "gold-plates" EU rules in a volatile environment.
Good morning everyone, I am delighted to be here for what looks set to be an interesting conference on a topic which is both very close to my heart and central to what we do at Central Bank of Ireland (“the Central Bank”) – as we work to deliver on our mission, and in particular ensuring the financial system is operating in the best interests of consumers and the wider economy. 1 I am particularly delighted to be back in UCD – where I had the pleasure to study economics as an undergraduate, w...
AI Analysis
This speech by Deputy Governor Mary Elizabeth McMunn outlines the Central Bank of Ireland's (CBI) shift toward **outcomes-focused regulation and supervision**, emphasizing five key priorities from the 2026 Regulatory and Supervisory Outlook (RSO) to address geopolitical risks, consumer protection, technology, and resilience in a volatile environment. It matters for compliance professionals as it signals intensified CBI scrutiny on firm behaviors and outcomes rather than mere rule compliance, with direct implications for supervisory engagements, thematic reviews, and enforcement across banking, funds, insurance, and payments sectors.
What Changed
No new legislative changes are introduced in the speech itself, which serves as a practitioner's perspective on implementing the RSO 2026 priorities.
Resilience to geopolitical/macro risks (operational resilience, cyber security, financial resilience).
Technology transformations (AI, digital money, tokenisation).
These build on prior developments like the revised Consumer Protection Code (CPC), DORA implementation, and enhanced AML/CFT frameworks,...
Suggested Considerations
Conduct gap analyses for revised CPC compliance, focusing on thresholds, customer experience, and fraud support (immediate if in-scope).
Strengthen financial crime controls: Improve fraud detection, victim support, scam awareness; update AML/CFT via enhanced questionnaires and transaction monitoring.
Review technology/AI governance: Assess AI models, digital innovations (e.g., tokenisation); engage CBI supervisors pre-implementation; ensure data quality/reliability.
Embed ESG/climate risks: Integrate into governance/business models; prepare for desktop/onsite reviews and greenwashing checks.
Key Dates
24 March 2026DEADLINE
- Revised Consumer Protection Code (CPC) takes effect (12-month lead-in complete; firms must be compliant)
H1–H2 2026
- DORA implementation including threat-led penetration testing (survey issued H1)
H1–H2 2026
- Enhanced AML/CFT Risk Evaluation Questionnaire
H1 2026–H2 2027
- Thematic inspection of transaction monitoring and STR reporting
H1–H2 2026
- UCITS Value at Risk (VaR) model review and depositary oversight
Compliance Impact
Urgency: High – The speech, delivered today (9 March 2026), underscores imminent RSO 2026 execution with CPC effective in 2 weeks (24 March 2026) and H1 2026 activities (e.g., DORA testing, AML questionnaires) starting soon. Non-compliance risks intensified supervision, thematic inspections, enforcement, and reputational damage in a high-geopolitical-risk environment; outcomes-focus demands proactive evidence of resilience and consumer safeguards over procedural box-ticking.
The Central Bank has today published its Regulatory & Supervisory Outlook 2026 , which sets out its latest assessment of the risk landscape facing the financial sector and the supervisory work it will undertake in response. This follows on from the Governor’s letter to the Tánaiste on the economic outlook and regulatory priorities in January . This is the third year of the report, which continues to be set against a backdrop of a changing, uncertain and increasingly complex external environme...
AI Analysis
The Central Bank of Ireland (CBI) has published its **Regulatory & Supervisory Outlook 2026**, outlining priorities shaped by geoeconomic fragmentation, technological acceleration, and elevated risks like operational resilience, cyber threats, data/AI, and consumer protection. This matters for compliance professionals as it signals intensified supervisory scrutiny, including desktop and onsite inspections, across Ireland's financial sector to ensure resilience and adaptability amid uncertainties.[https://www.centralbank.ie/news/article/press-release-central-bank-sets-out-its-regulatory-and-supervisory-priorities-26-february-2026][https://www.ogier.com/news-and-insights/insights/regulatory-outlook-2026-the-central-bank-of-ireland-s-priorities-explained/]
What Changed
No new binding regulatory requirements are introduced in this publication, which serves as a strategic outlook rather than enforceable rules. Key shifts in risk assessment include elevated operational risks (due to geopolitics, digitalisation, complex models), increased asset valuation/market risks, and rising data/models/AI risks, while inflation/interest rate risks have decreased.
Suggested Considerations
Implement revised CPC by 24 March 2026, assessing scope changes and business impacts.[https://www.ogier.com/news-and-insights/insights/regulatory-outlook-2026-the-central-bank-of-ireland-s-priorities-explained/]
Enhance financial crime controls, including fraud victim support, scam awareness, and market abuse detection; monitor AMLA developments.[https://www.ogier.com/news-and-insights/insights/regulatory-outlook-2026-the-central-bank-of-ireland-s-priorities-explained/]
Embed ESG/climate risks into governance, risk management, and business models, preparing for SFDR 2.0 and event response reviews.[https://www.ogier.com/news-and-insights/insights/regulatory-outlook-2026-the-central-bank-of-ireland-s-priorities-explained/]
Prepare for integrated supervision via gatekeeping enhancements and streamlined reporting.[https://maples.com/regulatory-round-up/central-bank-of-ireland-update-and-supervisory-approach-for-2026-fund-service-providers]
Key Dates
2026
2027; - Ongoing desktop/onsite reviews on operational resilience, ESG/climate, and supervisory priorities across sectors.[https://www.ogier.com/news-and-insights/insights/regulatory-outlook-2026-the-central-bank-of-ireland-s-priorities-explained/]
24 March 2026DEADLINE
- Revised Consumer Protection Code (CPC) takes effect, following 12-month lead-in; firms must ensure full implementation.[https://www.ogier.com/news-and-insights/insights/regulatory-outlook-2026-the-central-bank-of-ireland-s-priorities-explained/]
H1 2026
- CBI consultation on new Regulatory Impact Assessment (RIA) Framework.[https://maples.com/regulatory-round-up/central-bank-of-ireland-update-and-supervisory-approach-for-2026-fund-service-providers][https://www.centralbank.ie/docs/default-source/regulation/transforming-regulation-and-supervision/regulating-supervising-well-a-more-effective-and-efficient-framework.pdf]
Urgency: High – This outlook directly previews intensified 2026 supervision, with operational/cyber resilience and consumer protection as "key concerns" likely triggering unannounced inspections and enforcement. Firms risk findings on outdated resilience testing or CPC gaps, especially amid elevated risks; proactive alignment now prevents remediation costs and sanctions, given CBI's efficiency roadmap and international...
It is a pleasure to be here in Oxford 1 While I’m aware that this is a school of government and I’m a central banker, the two are inextricably linked. Societies and indeed economies are shaped by their institutions, specifically the legal, social, cultural, formal and informal norms that impact the way citizens interact with each other. Successful institutions are those that are trusted by the societies that created them and for which they ultimately serve. Today I am going to resist the oppo...
AI Analysis
Governor Gabriel Makhlouf's speech at the Blavatnik School of Government addresses central bank independence as a foundational institutional mechanism for delivering price stability and economic prosperity, rather than as a shield from accountability. The speech is not a regulatory enforcement action or new requirement, but rather a governance statement clarifying the Central Bank of Ireland's institutional philosophy on independence, credibility, and accountability—matters that directly affect how the CBI exercises supervisory discretion over regulated firms.
What Changed
This is not a regulatory change document but a governance clarification with compliance implications:
Reframing of independence: Central bank independence is characterized as an "anchor" enabling long-term decision-making rather than isolation from society.
Credibility framework: Credibility depends on competence, engagement, coherence, and public trust—not institutional distance alone.
Accountability emphasis: Independence requires continuous dialogue with society and other economic governance institutions; it "does not mean isolation."
Historical validation: The speech references the 1960s-1970s macroeconomic instability under political pressure versus post-pandemic effectiveness of credible central banks in controlling inflation.
Suggested Considerations
*Understand CBI decision-making philosophy: Recognize that CBI supervisory decisions are grounded in long-term economic stability objectives, not short-term political cycles.
*Align governance with credibility principles: The speech identifies four credibility pillars—competence, engagement, coherence, and public trust. Regulated firms should ensure their governance frameworks reflect these principles in their own operations.
*Monitor 2026 supervisory priorities: The speech references CBI's published 2026 Regulatory and Supervisory Priorities, which include maintaining resilience to geopolitical risks, securing consumer and investor interests, and delivering new responsibilities under Access to Cash legislation.
Key Dates
Second half 2026
- Ireland assumes EU Council Presidency; CBI will support government during this period
10 February 2026
- CBI published its 2026 Regulatory and Supervisory Priorities, which establish the operational framework within which this governance philosophy applies
18 February 2026
- This speech delivered, reinforcing institutional independence principles
I would like to welcome you all to the Central Bank of Ireland today 1 . We are delighted to host this gathering of EU Heads of Missions, representatives of our friends and partners from across the EU. A little over a year ago I had the pleasure to meet with you all. I spoke then of a geopolitical landscape facing significant strain and complexity; of the rise of economic nationalism and trade disputes; as well as the shift from cooperation to competition, and its impact on our ability to mee...
AI Analysis
This speech by Central Bank of Ireland (CBI) Governor Gabriel Makhlouf outlines priorities for building economic and financial resilience amid geopolitical risks, climate change, technological shifts, and geoeconomic fragmentation, emphasizing domestic policy focus areas like infrastructure, indigenous business growth, and fiscal buffers. It matters for compliance professionals as it previews CBI's forthcoming 2026 regulatory and supervisory priorities, signaling heightened scrutiny on operational and financial resilience, consumer protection, and alignment with a transforming regulatory framework. https://www.centralbank.ie/news/article/speech-governor-makhlouf-head-eu-missions-10-February-2026
What Changed
This is a forward-looking speech, not announcing immediate regulatory changes, but it references CBI's ongoing transformation agenda, including:
Four overarching supervisory priorities for 2026: (1) Maintaining/building resilience to geopolitical/macro-financial risks (operational and financial resilience); (2) Securing consumer/investor...
Upcoming publication of full 2026 Regulatory and Supervisory Priorities "in the next few weeks." https://www.centralbank.ie/news/article/speech-governor-makhlouf-head-eu-missions-10-February-2026
Broader roadmap initiatives: Integrated risk-based supervision; rulebook updates (e.g., AIF/UCITS, Fund Service Provider framework review post-AIFMD II, insurance compatibility with Solvency II,...
Suggested Considerations
Review and prepare for priorities: Monitor for 2026 priorities release (imminent); assess firm alignment with resilience themes (geopolitical/macro-financial risks, operational resilience, consumer protection).
Enhance resilience planning: Strengthen operational/financial resilience frameworks, including stress testing for geopolitical shocks, infrastructure dependencies, and climate risks; update outsourcing/governance per cross-sectoral guidance.
Engage on consultations: Participate in H1 2026 RIA Framework consultation and upcoming FSP review; review internal reporting/data processes for proportionality.
Sector-specific: Funds/asset managers—prepare for AIF/UCITS updates and FSP review; banks/insurers—align with CRD V/Solvency II compatibility reviews; all firms—ensure business models address narrow economic vulnerabilities.
Key Dates
2025
2026; - Ongoing implementation of banking/payments supervisory activities and multi-year roadmap (supervision, regulation, gatekeeping, reporting). https://www.matheson.com/insights/fig-top-5-at-5-06-03-2025/ https://www.centralbank.ie/news/article/press-release-central-bank-of-ireland-publishes-roadmap-to-deliver-a-more-effective-and-efficient-regulatory-framework-10-december-2025
Next few weeks from 11 February 2026
- Publication of CBI's full 2026 Regulatory and Supervisory Priorities. https://www.centralbank.ie/news/article/speech-governor-makhlouf-head-eu-missions-10-February-2026
H1 2026
- Consultation on new Regulatory Impact Assessment (RIA) Framework. https://maples.com/regulatory-round-up/central-bank-of-ireland-update-and-supervisory-approach-for-2026-fund-service-providers https://www.centralbank.ie/docs/default-source/regulation/transforming-regulation-and-supervision/regulating-supervising-well-a-more-effective-and-efficient-framework.pdf
Shortly (2026)
- Launch of comprehensive Fund Service Provider (FSP) Framework review. https://www.centralbank.ie/docs/default-source/regulation/transforming-regulation-and-supervision/regulating-supervising-well-a-more-effective-and-efficient-framework.pdf
Compliance Impact
Urgency: Medium—This speech signals strategic direction rather than enforceable rules, but imminent priorities publication and 2026 consultations demand proactive preparation to avoid intensified supervision/enforcement. It matters because CBI emphasizes resilience in a high-risk environment (geopolitics, AI, climate), with non-compliance risking closer scrutiny under new integrated approach; firms ignoring this could face heightened operational reviews amid efficiency drive without standards reduction. https://www.centralbank.ie/regulation/transforming-regulation-and-supervision
Introduction Good morning and thank you to Michael for inviting me to speak at the Compliance Institute’s Annual General Meeting. It is always a real pleasure to engage with compliance professionals. At the Central Bank, we recognise the essential role played by the compliance community in ensuring that financial firms are well-run and contributing to a financial system that is trusted and resilient. We also recognise the important role played by the compliance institute, equipping those work...
AI Analysis
This speech by Gerry Cross, Director of Capital Markets and Funds at the Central Bank of Ireland (CBI), outlines key supervisory priorities including securing customers' interests via the revised Consumer Protection Code, Individual Accountability Framework (IAF) implementation, regulatory simplification, resilience, technology leverage, and an evolving outcomes-focused supervision approach. It matters because it signals CBI's expectations for compliance professionals to drive these outcomes in firms, emphasizing proportionality and ongoing engagement amid regulatory evolution. Compliance teams must integrate these themes to align with CBI's shift toward less process-driven, more effective oversight.
What Changed
- Revised Consumer Protection Code: Introduces new Standards for Business, building on the Code reviewed with industry input; focuses on delivering good outcomes for consumers and the economy.
Individual Accountability Framework (IAF): Implemented 18 months prior (circa mid-2024); enhances clarity on responsibilities, supports governance, and aligns with outcomes-focused regulation rather...
Supervisory Approach Evolution: Shifting in 2025-2026 to risk-based, outcomes-focused, less process-driven supervision integrated across financial stability, consumer protection, safety/soundness,...
Regulatory Simplification: Openness to reviewing frameworks (e.g., fitness and probity) for simpler, outcomes-based alternatives without compromising effectiveness; supports broader simplification...
Resilience and Technology: Ongoing focus on financial resilience post-reforms, leveraging technology for supervision; no specific new rules but emphasis on embedding these in operations.
No new...
Suggested Considerations
Implement Revised Consumer Protection Code: Complete readiness by 24 March 2026; apply new Standards for Business in operations, leveraging CBI workshops for guidance.
Embed IAF: Maintain enhanced responsibility mapping, support decision-making, and engage with CBI on implementation feedback to mature governance.
Adopt Outcomes-Focused Practices: Shift from process-driven to outcomes-based compliance (e.g., customer interests, resilience); review internal frameworks for simplification opportunities.
Engage with CBI: Participate in ongoing consultations, workshops, and stakeholder feedback on supervision evolution, IAF, and Consumer Protection Code.
Leverage Technology: Integrate tech for resilience and compliance efficiency, aligning with CBI's supervisory priorities.
Key Dates
24 March 2026DEADLINE
- Revised Consumer Protection Code comes into force; firms must ensure full readiness and ongoing embedding of provisions, including new Standards for Business
Compliance Impact
Urgency: Medium. This speech reinforces imminent obligations like the 24 March 2026 Consumer Protection Code effective date (less than 2 months from speech/publication), requiring immediate readiness checks, but lacks new rules or critical enforcement threats. It matters for long-term alignment with CBI's outcomes-focused supervision, reducing future supervisory risks through proactive embedding of IAF and simplification; non-engagement could signal poor governance amid evolving oversight.
Mr Philip Smith, former Chief Executive Officer (CEO) and Executive Director of RSA Insurance Ireland DAC disqualified for 13 years by the Central Bank of Ireland for his admitted participation in a breach of financial services law by RSAII On 1 December 2025 the Central Bank of Ireland reprimanded Mr Smith and disqualified him for 13 years from being a person concerned in the management of a regulated financial service provider for his participation in a breach by RSA Insurance Ireland DAC (...
AI Analysis
The Central Bank of Ireland (CBI) reprimanded and disqualified former RSA Insurance Ireland DAC (RSAII) CEO Philip Smith for 13 years from management roles in regulated financial service providers due to his admitted role in under-reserving large loss claims, breaching Article 13(1)(a) of the European Communities (Non-Life Insurance) Framework Regulations 1994 (S.I. No. 359/1994). This enforcement action underscores CBI's commitment to individual accountability for senior executives who circumvent controls, risking policyholder protection and firm solvency, as evidenced by RSAII's subsequent need for a major capital injection. It matters for compliance professionals as it demonstrates CBI's use of prolonged disqualifications and inquiries under the Administrative Sanctions Procedure (ASP) to deter governance failures in insurance firms.
What Changed
This is not a regulatory change or new requirement but an enforcement precedent reinforcing existing obligations under the 1994 Regulations for insurers to maintain adequate technical reserves reflecting true liabilities. It highlights CBI's focus on senior executive accountability for deliberate policy circumvention, such as undocumented processes overriding claims handlers' estimates, which inflated reported profits and understated liabilities.
Suggested Considerations
Conduct internal audits of large loss claim reserving processes to verify compliance with Article 13(1)(a) of the 1994 Regulations, ensuring estimates are accurately recorded in databases without undocumented overrides.
Review senior management oversight of claims handling; document all approvals and prohibit informal (e.g., in-person or hard-copy only) processes that bypass controls.
Enhance governance training for executives on personal liability under ASP, including simulations of reserving decisions and policyholder risk scenarios.
Assess historical exposures for under-reserving; remediate if needed, and prepare for potential CBI inquiries (noting 10+ year investigation timelines).
Update conduct and culture frameworks to align with CBI expectations for CEOs to drive compliance, as per Deputy Governor Colm Kincaid's comments.
Key Dates
2014
- CBI enforcement investigation into Mr Smith and RSAII commences
December 2018
- CBI reprimands and fines RSAII €3.5m for related breaches, including reserve failures
November 2022
- CBI decides to hold an Inquiry into Mr Smith's participation under Part IIIC of the Central Bank Act 1942
1 December 2025
- Reprimand and 13-year disqualification imposed on Mr Smith, effective immediately under IAF Act transitional provisions (no High Court confirmation needed)
12 December 2025
- CBI publishes public statement on the enforcement action
Compliance Impact
Urgency: High – This action signals intensified CBI scrutiny on individual accountability in insurance reserving, with 13-year bans possible for deliberate breaches risking policyholders, even without actual losses. It matters now (post-1 Dec 2025 effective date) as firms face elevated enforcement risk amid CBI's "full extent of powers" approach, potentially leading to parallel firm/individual sanctions and long inquiries; proactive reviews prevent similar outcomes, especially with statutory fine limits not mitigating non-financial penalties.
New report outlines the Central Bank’s approach to more effective and efficient regulatory and supervisory framework, reducing complexity and improving clarity while maintaining resilience and important protections in the system. This work builds on the Central Bank’s strategy to transform regulation and supervision, including the introduction of our new integrated supervisory approach and the improvements made in our gatekeeping processes in recent years. The roadmap sets out a comprehensive...
AI Analysis
The Central Bank of Ireland published a comprehensive multi-year roadmap on December 10, 2025, aimed at streamlining its regulatory and supervisory framework across four pillars: supervision, regulation, gatekeeping, and reporting. This initiative represents a strategic shift toward more effective and efficient oversight while explicitly maintaining resilience standards and consumer protections, responding to EU calls for regulatory reform to enhance competitiveness.
What Changed
The roadmap encompasses four major reform areas:
Supervision: Implementation of a new integrated, risk-based supervisory approach introduced in January 2025, consolidating multidisciplinary teams...
Insurance: Major compatibility review to eliminate duplication with Solvency II reforms and review of 2021 Recovery Planning Regulations
Banking: Review of domestic banking rules predating CRD V/CRR to ensure consistency with updated EU standards
Credit Unions: Updates to the Credit Union Handbook following simplification of the Lending Framework
Funds: Changes to AIF rulebook and UCITS regulation with full review of the Fund Service Provider Framework
Suggested Considerations
*Immediate actions for compliance professionals:
*Monitor consultation releases: Track the Central Bank's website for the 2026 RIA Framework consultation and respond with firm-specific impact assessments
*Assess rulebook changes: Review how proposed updates to insurance regulations, banking rules, credit union handbook, and fund regulations affect your firm's compliance framework
*Evaluate supervisory engagement: Understand how the new integrated supervisory model affects your firm's supervisory relationship and reporting lines
*Prepare for gatekeeping changes: Anticipate enhanced consistency and transparency requirements in authorisation and Fitness & Probity processes
Key Dates
January 2025
- New integrated supervisory model became effective
2025
- Strategic review of Industry Funding Levy approach (consultation expected during 2025)
2026
- Public consultation on new Regulatory Impact Assessment Framework
2026 to first half of 2028
- Multi-year programme implementation period for all roadmap initiatives
The Central Bank of Ireland has fined Coinbase Europe Limited €21,464,734 for breaching its anti-money laundering and counter terrorist financing transaction monitoring obligations between 2021 and 2025. The Central Bank of Ireland (the Central Bank) has fined Coinbase Europe Limited (Coinbase Europe) €21,464,734 for breaching its anti-money laundering (AML) and combatting terrorist financing (CFT) obligations with respect to transaction monitoring as required by the Criminal Justice (Money L...
AI Analysis
The Central Bank of Ireland (CBI) fined Coinbase Europe Limited €21,464,734 for AML/CFT transaction monitoring failures under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (CJA 2010), involving over 30 million unmonitored transactions worth €176 billion from April 2021 to March 2025. This marks CBI's first enforcement against a crypto firm, highlighting regulators' focus on robust real-time monitoring and timely Suspicious Transaction Reporting (STR) for virtual asset service providers (VASPs). It matters as it sets a precedent for EU crypto compliance amid MiCA and AMLA implementation, signaling increased scrutiny and potential multimillion-euro penalties for similar lapses.
What Changed
This is an enforcement action, not new legislation, but it reinforces existing CJA 2010 requirements for VASPs: ongoing transaction monitoring, immediate STR filing to the Financial Intelligence Unit (FIU) and Revenue Commissioners upon suspicion of money laundering or terrorist financing, and adoption of internal policies/controls to prevent/detect financial crime.
Suggested Considerations
Conduct Gap Analysis: Review transaction monitoring systems for configuration errors, back-testing historical data, and ensuring 100% coverage of high-risk transactions.
Enhance Controls: Implement robust internal policies, automated alerts, and governance to detect/prevent ML/TF; test systems regularly for faults affecting >1% of volume.
Accelerate STR Processes: Ensure real-time suspicion flagging and filing; remediate delays via prioritized back-monitoring with FIU coordination.
Board/Compliance Reporting: Document remediation plans, as Coinbase did, and prepare for audits/enforcement; train staff on VASP-specific risks under MiCA/AMLA.
19 March 2025; Period of breaches, including 12-month window of unmonitored €176 billion transactions
5 November 2025
Settlement reached between CBI and Coinbase Europe
6 November 2025
CBI public announcement and Settlement Notice published
12 January 2026
High Court confirmed sanctions, making them final and effective
Compliance Impact
Urgency: High – This establishes a €21.5m benchmark for VASP monitoring failures in the EU, with risks amplified by MiCA (effective 2024) and AMLA (2025 onward), where national regulators like CBI will enforce harmonized rules. Firms risk similar fines (30% settlement discount possible), reputational damage, and operational restrictions if unmonitored volumes exceed 1-5%; immediate reviews are essential given CBI's precedent and cross-EU applicability.
Warning Unauthorised Investment Firm / Unauthorised Investment Business Firm Unauthorised Firm Name Monument Financial Group Website https://monumentfg.com/ Email addresses used admin@monumentfg.com [name].[surname]@monumentfg.com Phone number used +353 81 800 5284 Authorisation in Ireland This firm is not authorised to provide investment services in Ireland. Notes: Any person wishing to contact the Central Bank with information regarding such firms / persons may telephone (01) 224 5800 or re...
AI Analysis
The Central Bank of Ireland (CBI) has issued a warning notice under section 53 of the Central Bank (Supervision and Enforcement) Act 2013, identifying **Monument Financial Group** as an unauthorised firm providing investment services in Ireland without authorisation. This matters for compliance professionals because it underscores the CBI's proactive enforcement against unauthorised activity, heightens scam awareness, and signals risks of consumer harm, regulatory referrals to An Garda Síochána, and potential enforcement against facilitating parties.[https://www.centralbank.ie/news/article/monument-financial-group---central-bank-of-ireland-issues-warning-on-unauthorised-firm]
What Changed
This is not a regulatory change or new requirement but an enforcement action via a warning notice published on 25 August 2025. It publicly names the firm, its website (https://monumentfg.com/), emails (admin@monumentfg.com, [name].[surname]@monumentfg.com), and phone (+353 81 800 5284), confirming it lacks authorisation for investment services in Ireland.
Suggested Considerations
Immediate verification: Use CBI's authorisation registers and unauthorised firms search tool before any engagement with firms claiming investment services.[https://www.centralbank.ie/regulation/how-we-regulate/authorisation/unauthorised-firms/search-unauthorised-firms]
Client communications: Advise clients to apply the "SAFE test" (check authorisation, avoid unsolicited offers, etc.) and visit www.centralbank.ie/financialscams for scam protection guidance.
If engaged: Cease all activity, secure funds, and report to CBI/Gardaí; no compensation protections apply.
Key Dates
25 August 2025
- Warning notice published by CBI, adding Monument Financial Group to the unauthorised firms list.[https://www.centralbank.ie/news/article/monument-financial-group---central-bank-of-ireland-issues-warning-on-unauthorised-firm]
Compliance Impact
Urgency: Medium. This matters as part of a pattern of CBI warnings (e.g., Expert Limited on 19 June 2025, RCE Banque on 29 August 2025, DotBig on 01 December 2025), indicating rising unauthorised investment activity and scam risks in Ireland. Authorised firms face indirect liability for poor due diligence, reputational damage, or facilitation charges; consumers risk total fund loss without regulatory protections.
I’d like to thank Insurance Ireland and Milliman for inviting me here today for this Chief Risk Officer (CRO) Forum. I’d like to use this opportunity to briefly reflect on the recent turmoil we’ve seen in the banking sector, what this might mean for (re)insurers, and to highlight some of our supervisory priorities going forward. Much commentary has already been devoted to the fallout from SVB and Signature Bank in the US, and to the acquisition of Credit Suisse by UBS. Whilst the exposure of ...
Introduction Good morning everyone. Thank you for inviting me to speak here today. Before I begin, I’d like to acknowledge the important role played by Financial Services Ireland in advocating for its members, and in promoting the Irish financial services sector, both here and abroad. Whilst the respective missions we undertake are undoubtedly different, we have a shared interest in a strong and stable financial services sector. It is claimed that the phrase “may you live in interesting times...
It has come to the attention of the Central Bank that a scam entity by the name SEI Investment (United States, Ireland), formerly operating the fraudulent clone website www.seiinvestment.com, has been claiming to be an investment firm / investment business firm in the absence of appropriate authorisations. In this instance, the scam entity cloned details and website content of the legitimate firm, SEI Investments (www.seic.com), in order to deceive consumers. The legitimate firm was proactive...
AI Analysis
The Central Bank of Ireland (CBI) issued a warning on 26 September 2022 about a fraudulent entity named "SEI Investment (United States, Ireland)" that cloned the legitimate authorised firm SEI Investments (www.seic.com) via the fake website www.seiinvestment.com to deceive consumers into unauthorised investment services. This matters because it highlights the rising threat of clone firm scams, which impersonate authorised entities using stolen details like names, addresses, and authorisation numbers, exposing firms to reputational risk and consumers to financial loss without Investor Compensation Scheme protection. Authorised firms must remain vigilant in monitoring for clones and reporting them promptly, as demonstrated by SEI Investments' proactive response that led to the site's deactivation in February 2022.
What Changed
This is not a regulatory change or new requirement but a public enforcement warning under Section 53 of the Central Bank (Supervision and Enforcement) Act 2013, emphasising ongoing enforcement against unauthorised firms providing regulated financial services, which is a criminal offence. It reinforces consumer protection guidance without introducing new rules, but signals CBI's heightened focus on clone firm frauds, as seen in similar warnings (e.g., The Capital Holdings clone, Bank of Ireland clones).
Suggested Considerations
Monitor for clones: Regularly search for impersonations of your firm's name, website, authorisation numbers, LEI, CRO, or address; report suspicions to CBI at (01) 224 4000.
Client communications: Advise clients to always access CBI Register directly from www.centralbank.ie (not via email/website links), double-check URLs/phone numbers, verify products on legitimate sites, and apply the SAFE test for unsolicited contacts.
Internal processes: Update fraud awareness training, client onboarding checks, and surveillance for clone activity; emulate SEI Investments by proactively notifying authorities.
Public reporting: Encourage staff/clients to report unauthorised activity via CBI hotline or Search Unauthorised Firms page.
Key Dates
February 2022
- Fraudulent clone website www.seiinvestment.com deactivated following legitimate firm's report
26 September 2022
- CBI issues warning notice on SEI Investment clone
Compliance Impact
Urgency: Medium – Not critical as the specific clone site was deactivated in 2022, but medium due to persistent clone fraud trend evidenced by ongoing CBI warnings into 2026 (e.g., BW Financial Services clone in August 2025, Stalwart Investments clone in March 2026). Matters for authorised firms as it underscores reputational, operational resilience, and consumer protection obligations under CBI's supervisory framework; unaddressed clones can lead to client complaints, enforcement scrutiny, or compensation claims if mis-sold products are linked back erroneously.
Ban on price walking in motor and home insurance comes into effect on 1 July 2022. New customer discounts not affected. For automatic renewals, better information and reminders to be provided to encourage switching. The Central Bank of Ireland has today published the Central Bank (Supervision and Enforcement) Act 2013 (Section 48(1)) (Insurance Requirements) Regulations 2022 which will apply to insurance undertakings and insurance intermediaries from 1 July 2022. The Central Bank identified d...
AI Analysis
The Central Bank of Ireland (CBI) published the Central Bank (Supervision and Enforcement) Act 2013 (Section 48(1)) (Insurance Requirements) Regulations 2022 on 15 March 2022, banning price walking in motor and home insurance from 1 July 2022 to eliminate loyalty penalties for renewing customers while preserving new customer discounts and competition. This matters for compliance professionals as it imposes immediate prohibitions on differential pricing, mandatory annual reviews, enhanced renewal disclosures, and record-keeping, with CBI emphasizing ongoing oversight to ensure fair consumer outcomes.
What Changed
- Ban on Price Walking: Insurance undertakings and intermediaries cannot charge renewing customers (defined as "relevant renewing customers") a premium higher than that charged to an equivalent...
Annual Pricing Reviews: Firms must conduct an annual review of motor and home insurance pricing policies and processes within two months of each year-end to ensure compliance, including controls to...
Automatic Renewal Disclosures: Firms must provide specific information to consumers before automatic renewals, including renewal price, right to cancel, and options to switch providers, to promote...
Record-Keeping: Written records must be retained for annual reviews, material pricing decisions, and compliance assessments.
Scope Exclusions: Applies prospectively from 1 July 2022; no retrospective application or transitional period.
Suggested Considerations
Pricing Adjustments: Update systems/models to ensure renewal prices ≤ EQFRP; identify close-matched products for comparisons.
Conduct Reviews: Perform comprehensive annual review of pricing policies/processes, documenting compliance, controls, and rectifications; avoid "tick-box" approaches.
Enhance Communications: Revise renewal notices/documents to include mandated info (e.g., price, cancellation rights, switching options); handle pre-1 July notices pragmatically but comply in spirit.
Record Maintenance: Retain written records of reviews, pricing decisions, and compliance evidence for audit readiness.
Internal Governance: Assess/align with CPC General Principle 2.1; monitor for material changes requiring documented consistency checks.
Compliance Impact
Urgency: Medium (as of 2026). The regulations have been effective since 1 July 2022 with no transitional period, requiring immediate system/process overhauls at implementation; non-compliance risks enforcement under Section 48 of the 2013 Act. Ongoing annual reviews and CBI's commitment to monitoring pricing practices sustain medium-term priority, especially amid CBI's consumer protection focus, but established firms likely adapted by now—late compliance or audit gaps remain risks.
Recent increase in cross-border financial assets is largely due to migration of assets from UK banks to subsidiaries in Ireland, to continue to serve EU clients after Brexit. Paper examining the strength of the connectedness of Irish insurance sector and investment funds finds insurers primarily hold shares in equity, bond, and mixed funds. The Irish non-bank financial intermediation sector – as measured using a Financial Stability Board framework - is the fifth largest in the world. The Cent...
AI Analysis
The Central Bank of Ireland (CBI) published three "Behind the Data" papers on 20 January 2022 analyzing the international activities of Ireland's banking, insurance, investment funds, and non-bank financial intermediation (NBFI) sectors, highlighting post-Brexit asset migrations, insurer exposures via funds, and Ireland's fifth-largest global NBFI sector per FSB metrics. This matters for compliance professionals as it signals heightened CBI scrutiny on cross-border exposures, interconnectedness, and data granularity needs, potentially informing future supervisory expectations, macro-prudential policies, and reporting enhancements without imposing immediate rules.
What Changed
No direct regulatory changes, requirements, or new rules are introduced; these are analytical papers using existing locational banking, insurance, and fund data. Key insights include: (i) €180bn surge in cross-border bank assets (2018-Q3 2021) driven by UK-to-Ireland subsidiary migrations post-Brexit, concentrated in loans/deposits, derivatives, and three foreign-parent banks; (ii) Irish insurers' fund holdings primarily in equity (US-issued), bond (euro-area government/corporate), and mixed funds, with ~50% domiciled in Luxembourg but minimal local issuance; (iii) Recommendation for refined...
Suggested Considerations
Review and enhance internal reporting on cross-border assets, distinguishing Irish-parent vs. foreign-parent activities, in anticipation of potential narrower CBI statistics.
Map insurer fund exposures to underlying assets (e.g., equities, bonds) for geographic and asset-class transparency, addressing CBI-noted complexities in fund structures.
Assess NBFI activities against FSB economic functions for stability risks; prepare for possible granular data requests.
Monitor CBI's "Behind the Data" series for evolving trends, as it uses firm-submitted data and fulfills IMF recommendations (e.g., FSAP 2022 on fund exposures).
Key Dates
20 January 2022
Publication date of the three Behind the Data papers
Compliance Impact
Urgency: Low – This is informational analysis from 2022 with no binding rules, deadlines, or enforcement; it matters indirectly by flagging data gaps (e.g., parent distinction) that could shape future CBI supervision, macro-prudential tools, or reporting burdens, especially amid ongoing Brexit/NBFI focus. Firms with foreign parents or fund-heavy portfolios should note for risk monitoring, but no immediate compliance overhaul needed.
Remarks by Director General, Financial Conduct Derville Rowland at the Deloitte Global Insurance Webinar Good morning everybody and thank you to Deloitte for the invitation to speak at this webinar. Some people think of insurance as a relatively modern financial concept. But of course, as the insurance experts in this audience know, its origins can be traced all the way back to certain kinds of shipping loans in Babylon, through Ancient Rome and Greece, and into Medieval Europe. In the 17 th ...
Review finds that differential pricing practices can result in unfair outcomes for some consumers Proposal to ban the practice of ‘price walking’ to end the loyalty penalty for consumers who do not switch insurance provider regularly Proposals will ensure that new business discounts are still available to allow consumers to seek the best prices, while ensuring that those who remain with the same insurance provider are not penalized The Central Bank is proposing to ban the practice of price wa...
AI Analysis
The Central Bank of Ireland (CBI) proposes banning "price walking" in private car and home insurance to eliminate the loyalty penalty, where long-term customers pay significantly higher premiums (14% more for car, 32% more for home after 9 years) than new customers with similar risk profiles. This stems from a 2021 review finding differential pricing unfair to loyal or less mobile consumers, with regulations finalized and effective from 1 July 2022, confirmed effective in subsequent reviews. It matters as it enforces fair treatment under CBI's consumer protection mandate, requiring insurers to overhaul pricing models while preserving new customer discounts to maintain competition.
What Changed
- Ban on price walking: Insurers cannot charge second or subsequent renewal customers a higher premium than an equivalent year-one renewal customer with similar risk and service cost.
Disclosure of new business discounts: Firms must clearly disclose to new customers that lower prices include a new business discount.
Annual pricing policy reviews: Providers must review pricing policies yearly to ensure focus on customer impact, adherence to rules, and fair treatment.
Automatic renewals requirements: Introduce consumer consent for automatic renewals and enhanced information/reminders to support informed decisions and switching.
These were implemented via the...
Suggested Considerations
Pricing model adjustments: Revise systems to ensure renewal premiums ≤ year-one premiums for equivalent risks; test against historical data (e.g., 11 million policy records analyzed).
Disclosure updates: Amend new customer communications to explicitly state "new business discount" inclusion.
Governance and reviews: Implement annual pricing policy reviews with documented evidence of customer impact assessment and fair treatment compliance; integrate into board/CPC oversight.
Renewal processes: Obtain explicit consumer consent for auto-renewals; provide reminders and clear switching info pre-renewal.
Monitoring and reporting: Conduct internal audits; respond to CBI engagements; retain records for supervision.
Key Dates
22 October 2021
- Consultation period closes for proposals in the final report
Early 2022
- CBI intends to finalize measures post-consultation
15 March 2022
- Publication of final Insurance Requirements Regulations 2022
1 July 2022
- Regulations apply to insurance undertakings and intermediaries; ban on price walking effective
2023/2024
- CBI review confirms regulations working, no loyalty penalty observed, no further measures needed at that time
Compliance Impact
Urgency: low (as of 2026). Rules have been effective since July 2022, with CBI's 2023/2024 review confirming no loyalty penalties, no unintended consequences, and market stability—Ireland was first EU state with such a ban. Firms compliant since 2022 face ongoing low-risk monitoring; non-compliance risks enforcement under Section 48(1), but positive outcomes reduce immediate pressure. Matters for legacy audits or CPC reviews.
Introduction Good morning, and thank you for attending our Insurance Industry Event, the second of these which we’ve held virtually. Hopefully, as the vaccine rollout continues and restrictions are eased, there won’t have to be a third! The COVID 19 crisis has brought about a significant amount of change to all of our personal and professional lives, and with it has provided the opportunity to reflect on what is important, and where our priorities should lie. With this in mind, I would like t...
Speech delivered at Institute of Directors’ Briefing Webinar on 10 June 2021 Good morning everyone, I am delighted to speak to you on the importance of effective culture in firms, the contribution fitness and probity can make, and how we see the forthcoming Individual Accountability Framework further reinforcing effective culture. I’ll come to each of those topics in turn. But first let me say that the Central Bank and the Institute of Directors have overlapping visions. The Central Bank serv...
AI Analysis
This 2021 speech by Derville Rowland, Director General of Financial Conduct at the Central Bank of Ireland (CBI), emphasizes the critical role of the Fitness & Probity (F&P) regime and the forthcoming Individual Accountability Framework (IAF) in fostering effective culture, governance, and individual responsibility in regulated firms. It matters because it signals CBI's supervisory priorities on senior role holders' competence, integrity, and accountability, which have since evolved into concrete regulatory updates, directly impacting board and compliance functions to mitigate conduct risks and ensure consumer protection. https://www.centralbank.ie/news/article/speech-importance-of-fitness-probity-and-ensuring-responsibility-derville-rowland-10-june-2021
What Changed
The speech itself outlines no new statutory changes but highlights the F&P regime's role in ensuring "fit and proper" individuals in key roles and previews the IAF as a complementary framework to...
Consolidation of F&P Standards into the Fitness and Probity Standards 2025, applicable across all sectors, read alongside revised Guidance on the Fitness and Probity Standards (effective 20 November...
Amendments to Pre-Approval Controlled Functions (PCFs), adding roles like Designated Person for Investment Management (PCF-39D), Distribution (PCF-39E), and Regulatory Compliance (PCF-39F),...
Clarifications on due diligence (best-efforts basis for references, criminal checks, financial soundness via public records only—no bank statements required), time commitments (case-by-case), and...
Proportionality for fitness assessments but not probity; ongoing certification obligations for Controlled Functions (CFs) and PCFs.
These build on the speech's vision, addressing Enria Report...
Suggested Considerations
Conduct thorough F&P due diligence on PCF/CF holders pre-appointment and ongoing (best-efforts for references, criminal/financial checks via public records; assess time commitments case-by-case).
Certify annually that PCF/CF individuals meet standards; no dual certification needed if PCF covers CF-1/2.
Review and update succession planning, handover policies, and conduct breach procedures in light of new PCFs and IAF/SEAR (Statements of Effectiveness and Accountability of Responsibilities).
Assess residency and capacity for non-resident PCF holders case-by-case, considering firm complexity.
Embed F&P into culture and governance frameworks, aligning with IAF Conduct Standards once enacted.[Speech]
Key Dates
22 September 2021
- CBI notice of intention to amend PCFs under F&P regime (e.g., new Designated Persons roles)
20 November 2025
- Effective date for revised Guidance on Fitness and Probity Standards
24 November 2025
- CBI publishes Feedback Statement on CP160, Fitness and Probity Standards 2025, and revised Guidance
Post
amendment (TBD, after regulations effective); - 6-week window for in-situ PCF assessments and confirmations to CBI
Compliance Impact
Urgency: High – While the 2021 speech is foundational, 2025 Standards and Guidance are now effective, mandating immediate due diligence enhancements and certifications amid IAF rollout. Non-compliance risks CBI investigations, prohibitions, or sanctions, especially with expanded PCFs tying into broader accountability (e.g., SEAR). This elevates board exposure, demanding proactive governance reviews to align culture with consumer protection mandates.
Opening remarks at the 2020 Insurance Industry Briefing Good morning everyone. I would like to thank you for attending today’s industry briefing. In my remarks this morning, I will take this opportunity to touch on: the role that insurance can play in society; some of the reasons why the industry in Ireland is negatively perceived; and the areas of supervisory focus for the Central Bank moving forward. 2020 has been an unprecedented year in so many respects and the emergence of COVID-19 has a...
Good afternoon Chairman, Committee members, I am joined by Ed Sibley, Deputy Governor, Prudential Regulation and Derville Rowland, Director General, Financial Conduct. We welcome the opportunity to appear before you today. The effects of the COVID-19 pandemic have been deep and distressing for our community. The actions taken to contain the health emergency have affected the economy and all of our lives. The Central Bank’s job is to ensure the financial system operates in the best interests o...
I am joined today by Gráinne McEvoy, Director of Consumer Protection, and Domhnall Cullinan, Director of Insurance Supervision. Thank you for this opportunity to speak to you today about the Central Bank’s work in regulating and supervising the Irish insurance industry and specifically the practices of differential pricing and dual pricing. Insurance serves a critical role in the functioning of a modern society, through reducing uncertainty by protecting people and businesses against the risk...
The Central Bank of Ireland imposes a fine of €3,500,000 on RSA Insurance Ireland DAC for regulatory breaches relating to large loss claims and accounting irregularities On the 18 December 2018, the Central Bank of Ireland (the “ Central Bank ”) reprimanded and fined RSA Insurance Ireland DAC (“ RSAII ” or the “ Firm ”) €3,500,000 in respect of serious breaches relating to the following: Failure to establish and maintain Technical Reserves in respect of all underwriting liabilities assumed by...
AI Analysis
The Central Bank of Ireland (CBI) fined RSA Insurance Ireland DAC (RSAII) €3.5 million in December 2018 for serious breaches involving failure to maintain adequate technical reserves, inadequate internal controls and accounting procedures, and weak governance, stemming from deliberate under-reserving of large loss claims from 2009 to 2013, which understated reserves by €78.2 million as of 30 September 2013. This enforcement action underscores the CBI's zero-tolerance stance on reserving practices that risk policyholder protection and financial stability, highlighting how governance failures enabled manipulation and led to a significant capital injection for RSAII. It matters for compliance professionals as it demonstrates ongoing CBI scrutiny, with related actions against individuals like former CEO Philip Smith (13-year disqualification in 2025) and a former actuary (5-year prohibition).
What Changed
This is an enforcement action, not a new regulation, but it reinforces core pre-Solvency II requirements under the European Communities (Non-Life Insurance) Framework Regulations 1994, specifically Article 13(1)(a), mandating firms to establish and maintain technical reserves for all underwriting liabilities. It highlights breaches of the Corporate Governance Code for Credit Institutions and Insurance Undertakings 2010 (Section 6.3), requiring robust governance, internal reporting, and reliable information flows to decision-makers.
Suggested Considerations
Conduct reserving process reviews: Ensure claims handlers' recommended estimates are recorded without delay or manipulation; implement independent validation for large loss claims.
Strengthen internal controls: Develop sound administrative/accounting procedures and mechanisms to detect irregularities (e.g., unearned premium adjustments, claims expenses).
Enhance governance: Robustify internal reporting structures per Corporate Governance Code 2010 (Section 6.3); promote ethical culture to prevent individual overrides.
Senior accountability: Boards and executives must oversee compliance; remediate via capital injections if needed, as RSAII did.
Supervisory engagement: Cooperate fully with CBI probes; apply lessons to Solvency II reserving under Article 101 (post-2016).
Key Dates
2009
October 2013; Period of under-reserving breaches and manipulation of large loss claims
30 September 2013
Date of €78.2 million technical reserves understatement
October 2013
CBI identifies issues during scheduled supervisory engagement
2014
CBI investigation into RSAII and individuals (e.g., Philip Smith) begins
December 2018
RSAII admits four breaches; enforcement against firm concludes
Compliance Impact
Urgency: Medium – This 2018 action is historical but remains highly relevant due to 2025 individual enforcements, signaling CBI's long-term pursuit of accountability in insurance reserving and governance. It matters because under-reserving risks policyholder losses, financial instability, and capital adequacy (e.g., RSAII's injection), with CBI emphasizing deterrence via maximum fines and disqualifications; firms must self-assess controls to avoid similar scrutiny under Solvency II.
Settlement Agreement between the Central Bank of Ireland and Merrion Stockbrokers Limited Merrion Stockbrokers Limited fined €200,000 by the Central Bank of Ireland in respect of failings pursuant to the Fitness and Probity regime. On 12 December 2017, the Central Bank of Ireland (the ‘Central Bank’) fined Merrion Stockbrokers Limited (‘Merrion’) €200,000 and reprimanded it for a breach of section 21 of the Central Bank Reform Act 2010 (the ‘2010 Act’). Merrion has admitted this breach, which...
AI Analysis
The Central Bank of Ireland (CBI) fined Merrion Stockbrokers Limited €200,000 on 12 December 2017 for breaching section 21 of the Central Bank Reform Act 2010 by failing to implement adequate systems and controls under the Fitness and Probity (F&P) regime from 1 December 2011 to at least April 2015. This first-ever enforcement action against a firm for section 21 violations underscores firms' primary responsibility for ongoing due diligence on Controlled Functions (CFs) and Pre-Approval Controlled Functions (PCFs), signaling heightened CBI scrutiny on governance and accountability post-financial crisis.
What Changed
This 2017 enforcement does not introduce new regulatory changes but enforces existing requirements under the F&P regime, established via the Central Bank Reform Act 2010 and effective from 1 December...
Firms must maintain adequate systems and procedures for initial and ongoing due diligence to ensure CFs/PCFs meet F&P Standards (fitness: competence, integrity; probity: honesty).
Ongoing monitoring beyond initial checks, with written records and centralized documentation for each individual.
Accurate classification of roles as CFs/PCFs; failure here constituted a breach.
No subsequent statutory changes are noted in the publication, but it reinforces that firms bear ultimate...
Suggested Considerations
Develop/improve written policies and procedures for initial and ongoing due diligence on CFs/PCFs, including centralized records per individual.
Conduct thorough due diligence at appointment and continuously monitor compliance with F&P Standards; maintain demonstrable records.
Ensure accurate CF/PCF classification for all relevant roles (e.g., executive directors, finance heads, client advisors).
Implement monitoring systems to detect changes in fitness/probity and report to CBI if Standards are breached.
Board-level oversight: Review and remediate gaps, as post-2016 Merrion Board did.
Key Dates
1 December 2011
- Fitness and Probity regime effective; Merrion's breach period begins
Late 2014DEADLINE
- Management buy-out and new Board appointed; initial compliance improvements start
24 April 2015
- Merrion implements first written F&P policies and procedures
2016
- CBI inspection identifies breaches
12 December 2017
- CBI imposes €200,000 fine and reprimand via settlement agreement; investigation closed
Compliance Impact
Urgency: Medium - While from 2017, this foundational enforcement remains highly relevant for ongoing F&P obligations, with risks of fines/reprimands during CBI inspections (as in Merrion's 2016 review). It matters because firms hold primary accountability for a regime designed post-crisis to prevent unfit individuals in key roles; non-compliance exposes entities to significant reputational, financial (€200k precedent), and operational risks, especially amid evolving governance scrutiny.
Five Crises Ábhar mór bróid dom an léacht seo a thabhairt in onóir an Dochtúra T.K. Whitaker. Agus mar bharr ar sin, é bheith i láthair anocht. It is a great honour to be asked to deliver this lecture in honour of Dr. Ken Whitaker, all the more so in his presence. Go maire sé an céad! Or even better, as the Yiddish saying goes, ‘biz hundert un tsvantsik’. Economic crises often prompt us to look backwards and, perhaps, to seek solace in parallels and precedents in the past. Just as rising unem...
AI Analysis
This 2011 Whitaker Lecture by Professor Cormac O'Grada, hosted by the Central Bank of Ireland (CBI), is an academic speech analyzing five historical economic crises in Ireland, including the Economic War, WWII Emergency, 1950s downturn, and others, to contextualize the post-2008 financial crisis. It lacks any regulatory changes, enforcement actions, or compliance mandates, serving instead as reflective economic history rather than a binding publication. Compliance professionals need not action it directly, but it offers historical perspective on crisis resilience relevant to risk management and governance discussions.
What Changed
There are no regulatory changes, new requirements, or enforcement directives in this publication. The content is purely historical and analytical, discussing past Irish economic crises (e.g., net emigration peaks during 1934-38 Economic War and 1943 WWII Emergency) without proposing or announcing policy shifts.[User Provided Content]
Compliance Impact
Urgency: Low – This is a non-regulatory academic lecture with no immediate or ongoing compliance implications. It matters peripherally for firms emphasizing long-term economic history in prudential risk frameworks or governance training, but misclassification as "enforcement" (per query) overstates its relevance in 2026.