The objective of the framework is to drive a permanent uplift in governance standards. In our view, this is where firms taking real ownership of the framework will make a major difference. If firms embed the framework properly, it should ideally result in fewer serious issues in the sector over time - and, correspondingly, less need for enforcement actions.

Our approach to enforcement - both in relation to the IAF and more generally - is based on the key concepts of proportionality and targeted deployment with an outcomes focus.

Proportionality means that we seek to bring enforcement action only for those cases where such significant action is merited, considering all of the circumstances, including the seriousness of the suspected breach and the harm or potential harm involved.

Targeted deployment of enforcement tools means that, given the material costs and significant resources involved in bringing formal enforcement proceedings, we take a proportionate and risk-based approach in doing so and once we have considered whether our regulatory objectives could be achieved in other ways.

An outcomes focus means that it is never our aim to bring enforcement action as a matter of course. We are always focused on the overall outcomes of our enforcement decisions and actions as part of our overall regulatory strategy.

With regard to the IAF, it is essential, as we have discussed above, that the new framework does not have a chilling effect on the recruitment of good quality individuals into the Irish financial system. Accordingly, an understanding of our approach to the enforcement of the new framework is important.

Our approach to enforcement of the new framework is consistent with the approach adopted in other jurisdictions, where similar frameworks have brought significant benefits in terms of improved governance within firms without material increases in enforcement activity.