The ECB’s infringement procedure will be designed and operated by the ECB itself, and we believe that the ECB investigating unit will be the point of contact for institutions. The Central Bank will be only one of many voices in setting the direction of enforcement by the ECB, but our voice will be advocating an approach similar to that implemented here in Ireland.
That is, enforcement should be strong enough to be a deterrent against future failures, and be publicised so that it acts as such a deterrent. Supervision must be underpinned by a credible threat of enforcement. Coupled together, the ECB’s sanctioning role and the Central Bank’s existing role will cover the whole rulebook.