Irish legal and regulatory update - 1 October 2019 to 31 December 2019

The Investment Limited Partnership (Amendment) Bill 2019 passed to the second stage of the review process in late 2019 and is currently before Seanad Éireann (the Irish upper house). It is expected that the CBI will publicly consult on the proposals relating to the Senior Executive Accountability Regime (SEAR) in early 2020. The new Administrative Sanctions Procedure (ASP) Sanctions Guidance dated November 2019 is intended to provide greater clarity on the CBI’s approach to enforcement sanctioning factors. On 30 October 2019, the Data Protection Act 2018 (section 60(6)) (Central Bank of Ireland) Regulations 2019 came into operation. The European Commission has published the results of its third annual review of the functioning of the EU-US Privacy Shield.