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Evolving expectations of Fitness & Probity to support an Individual Accountability Framework

On Tuesday 28th August we hosted a Breakfast Briefing on the Evolving expectations of Fitness & Probity to support an Individual Accountability Framework.

The Central Bank of Ireland’s expectations for accountability and responsibility in Regulated Financial Services Providers (“RFSP’s”) is continually being reinforced through direct messaging, press releases and speeches in recent times.  In its recent Behaviour and Culture Report, the Central Bank has recommended the introduction of legislation to support an Individual Accountability Framework, setting conduct standards for staff and to ensure clearer lines of accountability within firms.

At our event we discussed these expectations in particular as they align to and evolve from the current Irish Fitness and Probity Regime.

The agenda focused on:

  • Overview of the Fitness and Probity Regime in Ireland and discussion of the evolution of these requirements in recent years;
  • Regulatory expectations in terms of individual accountability and responsibilities expected on the controlled function roles within RFSP’s;
  • Review of Enforcement actions taken following failures in respect of fitness and probity;
  • Review and reflection on the Senior Managers Regime in the UK, with specific focus on the recent changes undertaken;
  • Challenges for Board members, reflecting on the widening regulatory expectations both in Ireland, UK and across Europe; and
  • Discussion of outsourcing arrangements operating across Financial Services and reflecting on the expectation of Firms in terms of individual accountability and oversight.


Seána Cunningham (Director of Enforcement and Anti-Money Laundering at Central Bank of Ireland).

Pierre-Francois Rodriguez (Director, Deloitte UK)

Melissa Scully (Senior Manager – Corporate Governance, Deloitte Ireland)

Laura Wadding (Director – Regulatory Risk, Deloitte Ireland).



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