In addition to cases where mortgage files were frozen, transaction agreements with banks covered a number of areas, including reporting breaches, breaches of the credit institutions` code of conduct, breaches of the Consumer Protection Code, breaches of the Code of Conduct for loans to neighbouring parties, and violations of anti-money laundering requirements. One of the comparisons last year was with a former director of Quinn Insurance Limited (under administration) (“QIL”). The CBI referred the person`s case to the investigation, but confirmed in the report that the transaction was closing the investigation against him. It is unusual that no further details about this comparison were disclosed by the CBI or published on its website. If we look back at the enforcement actions taken over the last five years, we can get an idea of the sectors in the financial services sector where the central bank`s enforcement activities have been more concentrated. 27% of the transaction agreements concluded during this period were for banks. Second, transaction agreements with investment firms were 17%, with insurance/reinsurance companies accounting for 15% and insurance intermediaries/intermediaries 15%. According to the Central Bank, it has concluded 139 transaction agreements since 2006 as part of its administrative sanction procedure, bringing the total amount of fines imposed by the Central Bank to more than 123 million euros. At a time when companies are jealously trying to protect their reputations, the publication of the finer details of the transaction agreements is intended to ensure the maximum level of publicity of the colony, much to the chagrin of the sanctioned company. It is also a clear reminder to other companies that the Central Bank has teeth and does not hesitate to use them. A notable feature of the CBI`s transaction procedure is the CBI`s insistence on the company (or the person, as may be the case), to admit infringements and to accept the publication of a detailed publication statement. The publication statement is published on the CBI`s website a few days after the count. Both admission and advertising can have a significant impact on a business, especially reputation.
At the end of the investigation, the CBI may impose sanctions either by entering into a transaction agreement with the relevant agency or after a negative finding has been made upon request (the latter is a formal mechanism by which an investigation member or members appointed by the CBI decide whether a “prescribed offence” has occurred – usually when a case is not resolved).