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FSBA Conference 2022 – Navigating the Individual Accountability Framework

Audio clips from each session are available to listen to below.

Welcome, Introductory Remarks and Overview of Central Bank (Individual

Accountability Framework) Bill 2022 with John Breslin SC, The Hon. Ms Justice Nuala Butler

and David Sweetman BL.

Session 1: Investigation Phase – Walking the Investigation Tightrope discussed managing a regulatory breach scenario, the Central Bank’s “soft powers” of information gathering, tactical issues during the investigation phase, legal professional privilege under the new regime and potential self-incrimination issues.

Session 2: Life under Inquiry – Process and Consequences delved into the new inquiry model and breaking the “participation link”, the burden of proof, admissibility of evidence, legal representation, costs and Directors’ and Officers’ insurance, and public hearings.

Session 3: Contravention Risk – The New Compliance Dynamic examined the impact of conduct standards for directors and senior managers, the Staley case in the United Kingdom, the “reasonable steps” defence, Central Bank guidelines, self-reporting, conflicts of interest, learnings from the United Kingdom, legislating the “culture” of the industry.


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