CBI commissions independent review of its enforcement activities

On 22 July 2026, the Central Bank of Ireland (CBI) announced that it has commissioned an independent review of the effectiveness and efficiency of its enforcement activities. The review will be led by Josephine Feehily, former Chair of the Revenue Commissioners and first Chair of the Policing Authority.

In announcing the review, Governor Makhlouf stated that it is timely to undertake an independent review in light of the evolving regulatory and legislative framework and changes to the CBI’s approach to regulation and supervision and to its enforcement framework and processes.

The review will have regard to:

• the overall efficiency and effectiveness of the CBI’s enforcement activities
• best practice by regulators performing similar functions domestically and internationally
• international standards and principles

According to the terms of reference, the review will:

• evaluate the effectiveness of the performance of enforcement activities by reference to the outcomes the CBI seeks to achieve and the role of enforcement in the supervisory framework. This should also include:
  • a consideration of the CBI’s structures and processes in terms of how enforcement activities are carried out and decisions made
  • the arrangements between enforcement and supervisors
  • the arrangements between the Legal Division, including the Regulatory Decisions Unit, and the Enforcement Directorate
  • the arrangements for engaging external legal advice
• evaluate the criteria and processes used to decide when a case should be selected for enforcement action and continued for such action
• evaluate the efficiency and timeliness of how enforcement activities are carried out having regard to legal processes, regulator-wide organisational priorities and available resources
• consider the transparency of enforcement activities both for the public and the firms involved and individuals who may be impacted
• make any suggestions that the reviewer considers would improve the effectiveness of the CBI’s enforcement activities

Ms Feehily’s report, including recommendations, will be provided to the Governor and will be published in due course.

The review comes less than three years after the introduction of reforms to the CBI’s Administrative Sanctions Procedure, the key framework for enforcement investigations in Ireland (see ALG’s summary of the enforcement framework here).

For further information on the CBI’s enforcement framework, including its Administrative Sanctions Regime, please contact Dario Dagostino, Partner, Mark Devane, Partner, Chloe Culleton, Partner, Sarah Lee, Senior Practice Development Lawyer or your usual ALG contact.

Date published: 29 July 2026