Regulatory Developments In 2011 - Activity At The FSO And Central Bank Enforcement Unit

Central Bank of Ireland (the "Central Bank")

In accordance with the its Enforcement Strategy 2011 – 2012, robust enforcement measures were taken by the Central Bank throughout 2011 against regulated entities and persons involved in the management of those regulated entities that failed to comply with regulatory requirements. The Central Bank reported a 20% increase in administrative sanctions proceedings in comparison to 2010.

In December 2011 the Central Bank imposed its largest fine to date. It fined Combined Insurance Company of Europe Limited €3,350,000.00 arising from 'grave and persistent' breaches of the Consumer Protection Code. The Director of Enforcement of the Central Bank, Peter Oakes, commented that this fine "reflects the seriousness with which we view fundamental regulatory failures including inadequate systems and controls which cause large scale non-compliance with our regulatory requirements".