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 and
  • Proposed refusals or revocations of authorisations.

The role of the RDU in relation to ASP Inquiries is set out in the following guidelines:

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 (as ammended), being a panel designated as such by the Minister for Finance under section 97 of the Central Bank (Individual Accountability Framework) Act 2023 (IAF Act). The RDP comprises both externally recruited experts and the 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. the Central Bank) panel members and externally recruited panel members.

Internal members are made up of certain senior  staff of the Central Bank who hold the role of Director or Head of Division in all Directorates with the exception of the Enforcement Directorate. The Governor, Deputy Governors, Chief Operations Officer and Chief Transformation Officer are not members of the RDP.

External members are made up of legal practitioners and industry experts, with a mix of expertise across a variety of relevant areas including accounting, consumer protection and financial services

The RDP members are appointed by the Minister for Finance pursuant to section 33BI of the Central Bank Act 1942 (as amended), following a process conducted by the Central Bank after consulting the Minister.

Central Bank employees are eligible to be appointed as internal RDP members if they hold a qualifying position, being the role of Director or Head of Division in all Directorates with the exception of the Enforcement Directorate. External RDP members are recruited and appointed following a public competition.

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.

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 firm authorisations and decisions to approve or refuse PCF applications, those decisions are made by the Central Bank’s Gatekeeping Decisions Committee which comprises senior officials of the Central Bank at Deputy Governor, Director and Head of Division level. Certain members of the Gatekeeping Decisions Committee also serve as members of the RDP.

All externally recruited RDP members are appointed for an initial four-year term. The Central Bank has the discretion to extend the term of appointment for a further period of up to four years. This appointment may be terminated in certain circumstances. Where an external RDP member has been appointed as a decision maker to a case, the term of appointment will automatically be extended until the conclusion of that case and any associated court proceedings or appeals.

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

The RDP may be supplemented from time to time as appropriate.

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 2018 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. He was a member of the Mediators Institute of Ireland and was Chairman of the Criminal Law (Mental Health) 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. She is a member of the Parole Board and was appointed as Chair with effect from January 2025.

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 Northern Ireland. In the UK, he is a member of the Enforcement Decisions Panel of the Office of Gas and Electricity Markets (OFGEM). He has previously held independent decision-making roles in the financial services, legal and communications sectors, including Deputy Chair of the Regulatory Decisions Committee of the Financial Conduct Authority and similar roles with the Pensions Regulator and the UK Treasury. He was 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 the Fennelly Commission into Garda phone-tapping and other matters. She was the Chairperson of the Central Bank Inquiry into suspected prescribed contraventions on the part of Irish Nationwide Building Society and certain persons concerned in its management. That Inquiry has now concluded and the Written Decision of the Inquiry is subject to confirmation by the High Court.

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, a Member of the Determinations Panel of the Pensions Regulator in the UK and a Member of the Code Adjudication Panel of the Phone-paid Services Authority. At present she is 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 Chair 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 a member of the Council of the Pharmaceutical Society of Ireland and is currently an Adjudicator for the Commission for Communications Regulation. 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. He is the Chief Adjudication Officer of the Competition and Consumer Protection Commission.  He is the Chair of the Commercial Litigation Association of Ireland and a former Chair of the EU Bar Association of Ireland. He is a Fellow of the International Academy of Trial Lawyers and of the Chartered Institute of Arbitrators.

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 was 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. . That Inquiry has now concluded and the Written Decision of the Inquiry is subject to confirmation by the High Court.

Dr. Irene Lynch Fannon is a Professor Emerita at the School of Law, University College Cork (UCC).  She is a qualified solicitor and has pursued a legal career primarily practising as an academic lawyer.  In addition to conducting an active research and teaching career, she has held university management roles as Head of the School of Law (then the Department and Faculty of Law) and, at a later period, as 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 including Sustainability. She has published widely in these areas. She holds law degrees from University College Dublin, Oxford University (Somerville College) and the University of Virginia, USA. At present, she is a member of the Company Law Review Group (since 2018) and Chairs the Insolvency and Rescue Committee of that Group. She is a member of the European Commission of Experts on Insolvency and Rescue Law and is a member of the Education Committee of the Law Society of Ireland.

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 was 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. That Inquiry has now concluded and the Written Decision of the Inquiry is subject to confirmation by the High Court.

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 has extensive financial services experience having served in executive and board chair leadership roles in banking, digital finance / fintech, investment management, insurance, reinsurance, capital markets, private equity and payments in Ireland, the UK, throughout Europe and in the United States. He is a recognised expert in financial services regulatory advisory, corporate governance, stewardship, audit, financial reporting and capital management as well as chairing audit, risk and other board committees regulated by central banks and supervisory agencies internationally. Mr Molloy has served in senior advisory roles at Promontory Financial Group, IBM Financial Services, Guidehouse Europe (formerly Navigant) and Alvarez & Marsal Financial Industry Advisory Services. Mr Molloy completed his Bachelor of Commerce (Accounting & Finance) degree at University College Dublin followed by professional qualifications as a Chartered Director (Fellow), Chartered Accountant (FCA), Chartered Company Secretary (FCG), Chartered Banker, CAMS and the Institute of Risk Management, London (Fellow). Mr Molloy is also board director certified by the Institute of Directors, London and Dublin, in the United States (NACD) and in Luxembourg (ILA).  

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.