Regulatory Decisions Unit 

The Regulatory Decisions Unit (RDU) is a unit of Central Bank of Ireland. One of the roles of the RDU is to facilitate the appointment of decision makers in four regulatory regimes operated by the Central Bank and to provide administrative and/or legal support to appointed decision makers. The RDU’s role covers the following types of decision-making processes:

  • Administrative Sanctions Procedure Inquiries (ASP Inquiries)
  • Certain decisions under the Fitness and Probity regime
    • Decisions to issue or confirm a suspension notice or to impose a prohibition under Part 3 of the Central Bank Reform Act 2010 (as amended)
    • Decisions to approve or refuse an application for approval as a PCF (pre-approval controlled function) under Section 23 of the Central Bank Reform Act 2010 (as amended)
  • Decisions pursuant to an assessor regime incorporated in certain financial services legislation [1] and
  • Proposed refusals or revocations of authorisations.

The role of the RDU in relation to ASP Inquiries is set out in the Inquiry Guidelines prescribed by the Central Bank pursuant to Section 33BD of the Central Bank Act 1942, as amended, (the Act). 

Regulatory Decisions Panel

The Regulatory Decisions Panel (“RDP”) is a panel established by the Minister for Finance for the purposes of section 33BI of the Central Bank Act 1942, being a panel designated as such by the Minister for Finance under section 97 of the Central Bank (Individual Accountability Framework) Act 2023 (the “IAF Act”). The RDP comprises both externally recruited experts and Central Bank staff. If a Central Bank investigation has not been resolved, for example by way of settlement, a member of the RDP will be appointed to act as impartial decision maker in the case.

Read more about the Central Bank’s enforcement regime.

The RDP comprises internal (i.e. Central Bank) panel members and externally recruited panel members. External members are made up of legal practitioners and industry experts, who may be authorised to exercise certain powers on behalf of the Central Bank. Appointment to the RDP does not guarantee selection for appointment as a decision maker to a case.  Appointment as decision maker is determined on a case-by-case basis based on certain factors such as experience and expertise, availability, training and conflict of interests.

Internal (i.e. Central Bank) panel members

Internal RDP members comprise of those Central Bank staff designated by the Minister for Finance in accordance with the IAF Act, who hold a qualifying role, being the role of Director or Head of Division in all Directorates with the exception of the Enforcement and Anti-Money Laundering Directorate and the Strategy and Governance Directorate. The Governor, Deputy Governors, Chief Operations Officer and Chief Transformation Officer are not members of the RDP.

Externally recruited panel members

Externally recruited appointed RDP members are individuals designated by the Minister for Finance in accordance with the IAF Act, with a mix of expertise across a variety of relevant areas including, legal, accounting, consumer protection and financial services. They were appointed following a public competition undertaken in 2019 and 2020.

Members of the RDP may be appointed to act as decision makers in the following three regulatory regimes:

  • Administrative Sanctions Procedure inquiry held pursuant to Part IIIC of the 1942 Act;
  • Decisions to issue or confirm a suspension notice or to impose a prohibition under Part 3 of the Central Bank Reform Act 2010 (as amended); and
  • Assessments under financial services legislation.

In respect of proposed refusals or revocations of authorisations and decisions to approve or refuse an application for approval as a PCF, those decisions are made by Central Bank staff holding a qualifying role, being the role of Director or Head of Division in all Directorates with the exception of the Enforcement and Anti-Money Laundering Directorate and the Strategy and Governance Directorate.

All externally recruited panel members are appointed for an initial four-year term. This appointment may be terminated in certain circumstances. The panel may be supplemented from time to time as appropriate.

Central Bank staff members remain members of the RDP for so long as they hold a qualifying role. An internal (i.e. Central Bank) RDP member who leaves the employment of the Central Bank or ceases to hold a qualifying role can remain in their position as an appointed decision maker until the conclusion of the case.

The current externally recruited RDP members are:

Mr. Justice Mahon studied law in University College Dublin and Kings Inns, qualifying as a Barrister in 1976. He was appointed as Senior Counsel in 1988. He served as a Judge of the Circuit Court from 2002 to 2013, was appointed as Chairperson of the Planning Tribunal in 2003 and served as a Judge of the Court of Appeal from 2014 to 2018. He is an experienced barrister and mediator, receiving his Certificate in Mediation in 2016 with the Mediators Institute of Ireland. He was appointed Ombudsman for the Defence Forces in 2018.
Mr. Justice Iarfhlaith O’Neill completed his Bachelor of Arts in History and Economics at University College Dublin and is a qualified barrister. He served as a Judge of the High Court from 1999 to 2014. He is an experienced barrister, mediator and senior counsel, who is currently a member of the Mediators Institute of Ireland. At present, he is the Chairman of the Mental Health [Criminal Law] Review Board.  He previously served as the Chairperson for the Central Bank of Ireland in the Inquiry concerning certain persons concerned in the management of Quinn Insurance Limited and is currently serving as the Chairperson for the Central Bank of Ireland in the Inquiry concerning a person formerly concerned in the management of a Regulated Financial Service Provider.  

 

Mr. Justice Aindrias Ó Caoimh completed his Bachelor of Civil Law at National University of Ireland in 1971 and was conferred with the degree of Barrister at Law by the Kings Inns in 1972. He practiced at the Bar of Ireland as a barrister and later as a Senior Counsel from 1972 to 1999. He served as a Judge of the High Court from 1999 to 2004 and served as a Judge of the European Court of Justice from 2004 to 2015. He has been the lead investigator in three disciplinary investigations conducted by the External Action Service of the European Union 2015 to 2018 under its Code of Conduct and Discipline and was subsequently the presiding member of the Independent Assessment Panel in the CervicalCheck Non-Disclosure ex gratia Scheme.

Ms. Justice Margaret Heneghan is a barrister, senior counsel and an accredited mediator, with in depth knowledge and skills in negotiation, dispute resolution, regulation and governance. She served as a Judge of the Circuit Court from 2010 to 2014, and as a Judge of the High Court and ex officio Court of Appeal from 2014 to 2017. She holds a Diploma in Company Direction and sits as a non-executive director of a number of corporate boards both in commercial and pro bono roles.

Peter Hinchliffe is a barrister with significant experience of making independent decisions in a legal or regulatory environment. He sits as a tribunal judge in the General Regulatory Chamber and in other jurisdictions in England, and N. Ireland. In the UK, he is a member of the Enforcement Decisions Panel of the Office of Gas and Electricity Markets (OFGEM) and a Panel Chair for the Access Disputes Committee. He has previously held independent decision-making roles in the financial services sector as Deputy Chair of the Regulatory Decisions Committee of the Financial Conduct Authority and in similar roles with the Pensions Regulator and the UK Treasury and as Lead Ombudsman for insurance at the Financial Ombudsman Service. He is currently serving as the sole member of the Central Bank Inquiry into suspected prescribed contraventions on the part of permanent tsb p.l.c. (PTSB) and a person concerned in its management.

Ms. Marian Shanley completed her Bachelor of Law degree at University College Dublin and is a qualified solicitor. She was a member of the Law Reform Commission for 12 years. She has previously served as the Registrar and Solicitor on the Ferns Report; the Commission of Inquiry into Child Abuse where she was one of the Commissioners and, more recently the Fennelly Commission into Garda phone-tapping and other matters. At present, she is the Chairperson of the Central Bank Inquiry into suspected prescribed contraventions on the part of Irish Nationwide Building Society (INBS) and certain persons concerned in its management.

Ms. Bríd Munnelly completed her Bachelor of Law at Trinity College Dublin and is a qualified solicitor and accredited mediator. She pursued a legal career at McCann FitzGerald and Matheson, where she was a partner for fifteen years before becoming a consultant. She is currently an independent member of the Governing Council of the Chartered Accountants of Ireland. Her broader experience includes committee and board experience with a particular focus on administrative/regulatory and financial services law and complex litigation.

Dame Elizabeth Neville completed her Master of Arts in Philosophy and Psychology at Oxford University and her Doctorate in Occupational Psychology at University College London. She pursued a career in the police service, and became the Chief Constable of Wiltshire Police. More recently, she was a Member of the Regulatory Decisions Committee at the Financial Conduct Authority and a Member of the Determinations Panel of the Pensions Regulator in the UK. At present she is a Member of the Code Adjudication Panel of the Phone-paid Services Authority and a Companies House Independent Adjudicator. She is currently serving as a Member of an Inquiry Panel for the Central Bank of Ireland in the Inquiry concerning a person formerly concerned in the management of a Regulated Financial Service Provider.

Ms. Lillian Boyle completed her Bachelors of Law at Glasgow University and pursued a career in finance with a particular focus on insurance and previously held the role of President of the UK Chartered Insurance Institute (of which she is a Fellow). She is a Chartered Fellow of the UK Chartered Institute for Securities & Investment. She has extensive board level experience in the public and private sector with a particular focus on regulatory and professional standards and currently she is Chairman of the Isle of Man Financial Services Authority.

Mr. David O’Donohoe completed his Bachelor of Laws at University College Dublin and has pursued a legal career at Hussey & O’Higgins, Brendan McArdle & Co., O’Connell Rooney and Arthur Cox, where he was a partner since 1992. He was Head of the firms Dispute Resolution practice from 2004 to 2012 and a member of the Management group from 2008 to 2012. He was, until 2020, a member of the firm’s conflicts committee and the partner in charge of firm risk management. In 2021, he set up his own practice. He is an experienced solicitor, arbitrator and mediator, who ranked as band one practitioner in Dispute Resolution and Insurance in Chambers Europe for 15 years and as band one leading individual in Dispute Resolution and Insurance in Legal 500 for 15 consecutive years.

Mr. Patrick Brady completed his Bachelor of Public Administration at the Institute of Public Administration and his Masters in Executive Leadership at the University of Ulster and Boston College. He was previously the Director of Policy and Risk at the Central Bank of Ireland and more recently, the Group Head for International and EU Public Policy and Regulatory Affairs at KBC Group NV. At present, he is an independent adviser to banks and insurers on regulatory policy, risk, regulatory engagement, supervision, prudential issues and governance.

Paul Gorecki completed his Bachelor of Science in Economics at the University of London, his Master’s in Economics at Queen’s University, Canada, and his Doctorate in Economics at London School of Economics and Political Science. He pursued a career in economics at the Economic Council of Canada, the Northern Ireland Economic Council, the Economic and Social Research Institute and as a regulator at the Competition Authority. Paul was also a member of the Council of the Pharmaceutical Society of Ireland. He has published extensively on regulation and competition law and policy.

Mr. Brian Kennedy is a graduate of Trinity College Dublin (LL.B.), the College of Europe, Bruges, Belgium (LL.M.) and the King’s Inn. He has pursued a legal career as a barrister, arbitrator and mediator since 1997 and was called to the Inner Bar (Senior Counsel) in 2012. He is an experienced barrister in general civil law practice with an emphasis on commercial and public law, including European Union law. In 2019, he was called to the Bars of England and Wales and Northern Ireland.

Mr. John Cashin completed his Master’s in International Legal Studies at New York University and his Juris Doctor at Fordham University School of Law. He has pursued a career in insurance and reinsurance where he was Deputy Superintendent at the New York State Insurance Department and has held various senior positions at Zurich Insurance Group including Head of Compliance & Government Affairs and General Counsel of General Insurance. He is a certified arbitrator and is currently the principal of the Law Office of John R. Cashin which specialises in insurance and reinsurance dispute arbitration. He is a dual national with Irish citizenship. He previously served as an Inquiry Panel Member for the Central Bank of Ireland in the Inquiry concerning certain persons concerned in the management of Quinn Insurance Limited.

Mr. George Maloney completed his Bachelor of Science in Business Studies and Management at Trinity College Dublin, is a Fellow of the Chartered Association of Certified Accountants and a licenced Insolvency Practitioner. He has pursued a career in professional practice with extensive experience over thirty-five years in corporate consulting, investigations and insolvency. He is included on current insolvency and enforcement panels for the National Asset Management Agency (NAMA) and is a member of the Revenue Commissioners panel for expert witness and complex insolvency assignments. At present, he is a consultant in the firm RSM Ireland which is an independent member of the RSM International network.

Ms. Ciara McGoldrick completed her Bachelor of Law at Trinity College Dublin and is a qualified barrister. She is a fellow of the Institute of Chartered Accountants. She pursued a legal career with a particular focus on professional regulation and medical negligence. At present, she is Junior Council at the Law Library and also is an adjunct professor in the Sutherland School of Law, University College Dublin. She is currently serving as a Member of an Inquiry Panel for the Central Bank of Ireland in the Inquiry into suspected prescribed contraventions on the part of Irish Nationwide Building Society and certain persons concerned in its management.

Dr. Irene Lynch Fannon completed her Bachelor of Law at University College Dublin, her postgraduate Bachelor of Law at Oxford University and her Doctorate at University of Virginia, USA. She is a qualified solicitor and has pursued a legal career practising as an academic lawyer at University College Cork (UCC) where she has held the roles of Dean of the Faculty of Law and Head of the College of Business and Law.  As a Professor at UCC, her research areas are European and national Corporate Insolvency and Rescue (Restructuring) Law, Corporate Law and Stakeholder Theory and she has published widely in these areas.  Having taken a leave of absence for a year from UCC, she is currently Head of Knowledge Management at Matheson. At present, she is a member of the Company Law Review Group since 2018 and is also an independent reviewer of cases for the Chartered Accountants Regulatory Board.

Mr. Mike Sullivan completed his Bachelor of Accounting and Finance at Dublin City University and pursued a career in accountancy and risk management. He was a partner in and Head of PwC Ireland Risk Management practice with a focus on internal audit, IT risks and controls, risk management, corporate governance, regulatory compliance and internal control until 2020 when he retired.

Mr. Geoffrey McEnery completed his Bachelor of Commerce at University College Dublin and is a qualified Chartered Accountant. He has forty years executive and non-executive banking experience including eighteen years international experience at CEO level in the Middle East and Asia. He was the CEO of the Asian banking business of Lloyds TSB Bank based in Hong Kong (previously Hill Samuel Bank) and a Main Board Director of Hill Samuel Bank and Hill Samuel Investment Services Group in London. He is currently serving as a Member of an Inquiry Panel for the Central Bank of Ireland in the Inquiry into suspected prescribed contraventions on the part of Irish Nationwide Building Society and certain persons concerned in its management.

Mr. Graham O’Brien, a Chartered Accountant, completed his Bachelor of Commerce and his postgraduate Diploma in Professional Accounting at University College Dublin and has pursued a career in finance at Deloitte, NCB and Investec Securities Holdings Ireland Limited (formerly NCB Group) where he was Finance Director. He is currently the Chairman of Quilter Cheviot Europe Limited and Independent Non-Executive Director of a number of other companies in the financial services sector. He also chairs the Investment Committee of the Harcourt Venture Fund. He is currently serving as a Member of an Inquiry Panel for the Central Bank of Ireland in the Inquiry concerning a person formerly concerned in the management of a Regulated Financial Service Provider.

Mr. Conor Molloy completed his Bachelor of Commerce (Accounting and Finance) degree at University College Dublin and has pursued a career in financial services risk management, governance and regulatory consulting with over twenty years’ experience in the international financial markets. He is an expert in banking, asset management, insurance, reinsurance and private equity with direct experience internationally (Europe, the UK and the US). Mr. Molloy has deep regulatory compliance, governance, risk management, audit, financial reporting, credit risk, enterprise risk management, market risk, treasury, liquidity and capital management expertise. At present, he serves as a regulated Board Chair and as a Senior Advisor with Guidehouse Europe Limited, London (formerly Navigant Consulting) and Guidehouse Inc. Conor previously served as a Senior Advisor with Alvarez & Marsal and as European Director of Promontory Financial Group. Mr. Molloy is a Chartered Banker, Chartered Director and a Fellow of the Institute of Risk Management, London.  

Ms. Deirdre-Ann Barr completed her Bachelor of Law at University College Cork and her postgraduate Masters of Law in European Union Law at University College Dublin and has pursued a legal career at Matheson, where she was a partner until 2019. She was previously a member of the Company Law Review Group, a statutory expert advisory body on company law. At present, she is an independent non-executive director, an independent reviewer with Chartered Accountants Ireland and chairs a three person panel appointed by an Irish bank to review and adjudicate on appeals by customers.

Mr. Iraj Amiri completed his Bachelor of Science in Mathematics at Manchester University and his Master of Science in Statistics at University of Manchester. He is a Chartered Accountant and a fellow member of the Institute of Chartered Accountants in England and Wales. He pursued a career in finance at Deloitte, where he was a senior partner until 2010. He has over 25 years of experience of audit and assurance activities and has recently completed his second term as a member of the UK Financial Conduct Authority Regulatory Decisions Committee. At present, he is a Non-Executive Director and Chairman of the Audit and Risk Committee for the Development Bank of Wales, he is the Chair of the Audit Committee and a member of the Risk Committee for the Coventry Building Society and he is also the Non-executive Director and Chair of the Audit Committee at AON UK Plc.

 RDU Notices

The Legal Notices page contains notices published by the RDU from time to time and certain decisions made by appointed decision makers.  This page includes details of:

  • ASP Inquiry Hearings taking place as well as certain determinations or decisions issued by Inquiry members

[1] The financial services legislation into which the assessor regime is incorporated includes the following regulations:

  1. European Union (Market Abuse) Regulations 2016 (S.I. No. 349 of 2016);
  2. European Union (Prospectus) Regulations 2019 (S.I. No. 380 of 2019);
  3. Transparency (Directive 2004/109/EC) Regulations, 2007 (S.I. No. 277 of 2007); 
  4.  European Union (European Markets Infrastructure) Regulations 2014 (S.I. No. 443 of 2014);
  5. European Union (Markets in Financial Instruments) Regulations 2017 (MiFID II) (S.I. No. 375 of 2017);
  6. European Union Securities Financing Transactions Regulations 2017 (S.I. No. 631 of 2017);
  7. European Union (Indices Used in Benchmarks in Financial instruments and financial contracts or to measure the performance of investment funds) Regulations 2017 (S.I. No. 644 of 2017);
  8. European Union (General Framework for Securitisation and Specific Framework for Simple, Transparent and Standardised Securitisation) Regulations 2018.