Central Bank appoints external reviewer for independent review of its enforcement activities

What Changed

• - The CBI has formally commissioned an independent review of its enforcement activities, covering both how enforcement is structured and how it operates in practice, rather than a narrow thematic or procedural tweak.
• The review mandate expressly covers the performance of enforcement activities and the role of enforcement within the wider supervisory framework, indicating that enforcement may be repositioned relative to ongoing supervision and prudential or conduc
• The review will examine enforcement structures and processes, including decision‑making governance, which may result in new approval routes, escalation paths, or committee structures for opening, progressing and settling enforcement cases.
• The review will look at case‑selection criteria and processes, suggesting potential future changes to how and why firms or individuals are selected for enforcement action, and possibly the introduction of more codified, risk‑based or transparent sele
• Timeliness of enforcement actions is in scope, which may lead to explicit timelines or service standards for case progression, investigation milestones, and resolution, with potential knock‑on effects on firms’ internal response expectations.
• The review will assess transparency for the public, firms and individuals impacted, which could result in revised disclosure practices, more detailed public statements, or earlier communication of case status and outcomes.

Suggested Considerations

• Review and document your enforcement‑facing governance, including Board and senior management oversight of investigations, decision‑making on settlement, and escalation paths, to ensure these are robust and can withstand a more structured or time‑bound enforcement approach.
• Assess whether your record‑keeping, data, and management information relating to regulatory breaches, incidents, and CBI interactions are sufficiently complete and organised to support faster and more transparent enforcement processes.
• Conduct a gap analysis of investigation procedures and response playbooks (e.g. dawn raid readiness, information requests, interviews, internal investigations) to ensure they can meet potentially tighter CBI timeliness and information‑quality expectations.
• Update Board and senior management on the launch of the enforcement review and agree a watching brief, including designation of a responsible function (e.g. Compliance or Legal) to monitor the review, its terms of reference, stakeholder engagements and eventual recommendations.
• Engage external counsel or industry associations, as appropriate, to prepare for possible consultation or stakeholder engagement opportunities during the review, including developing key messages on proportionality, timeliness, transparency and coordination with supervision.
• Stress‑test your firm’s disciplinary and remediation frameworks, ensuring that identified breaches are promptly investigated, remediated, and documented in a manner that would stand up to more stringent enforcement scrutiny and possible public disclosure.

Key Dates

Who is Affected