Financiere Mullin Fund Limited (Clone) – Central Bank of Ireland Issues Warning on Unauthorised Firm

Governor of the Central Bank of Ireland, Gabriel Makhlouf, and Governor of the South African Reserve Bank (SARB), Lesetja Kganyago, jointly signed a Memorandum of Understanding (MoU) in Washington DC, where they were both attending the meeting of G20 Finance Ministers and Central Bank Governors in October.The purpose of the MoU is to provide a framework to promote cooperation between the two institutions, and is established in the context of South Africa’s G20 Presidency, with Ireland as an invited member this year. The MoU will promote mutual understanding and action on key priorities of South Africa’s G20 Presidency, namely mitigating climate-related financial risks and advancing cross-border payments, addressing challenges related to cost, speed, access and transparency.The MoU reflects the critical role central banks play in safeguarding financial, economic and price stability against the effects of climate change, and their part in regulating, supervising, operating, overseeing and upgrading financial market infrastructures to enhance payments.Governor Makhlouf said: “It was a great pleasure to agree these key areas of cooperation with my South African colleague, and to discuss with Governor Kganyago our shared view of the importance of these issues.”Echoing this sentiment, Governor Kganyago said: “South Africa’s G20 Presidency has put these issues at the top of the global agenda. The SARB looks forward to ongoing collaboration with the Central Bank of Ireland and to further advancing these discussions.”

I am delighted to welcome you to the Central Bank of Ireland today.1  It is great to have such a broad range of stakeholders here from public service, civil society, charitable organisations and the financial services sector to discuss protecting consumers in vulnerable circumstances.  It is right to place a special focus on consumers in vulnerable circumstances, and that we reflect vulnerability in all its forms. If we are to have trust in financial services, we need to be confident our best interests will be secured when we are at our most vulnerable, when we are most likely to suffer financial detriment or harm. Periods of vulnerability in our lives (from bereavement to illness to financial and other shocks) often carry with them a requirement to make financial decisions we don’t regularly make, such as claiming on an insurance policy, encashing a financial product or deciding what to do with an inheritance. Major life events that make us vulnerable are also often accompanied by challenges to meet new expenses or other financial difficulties. We may also have to face the challenges presented by an ongoing vulnerability that affects how we need to receive services or advice if we are to be financial included like everyone else. We are all prone to vulnerability through gaps in our financial or digital literacy or lack of confidence in managing our money (or asserting our rights). The geopolitical context is also relevant. In his recent remarks following the Annual Meeting of the International Monetary Fund, Governor Makhlouf spoke to the vulnerabilities in the global financial system itself on which we will need to keep a very close eye and which, on the face of it, look uncomfortably familiar.2 Those of us here today know how rapidly and profoundly shocks to the global financial system can be felt in household finances, augmenting the impact of any vulnerability that household may already face. Or to frame this more constructively, we know how concrete steps to build the resilience of household finances can help our society as a whole to withstand such shocks and rebound from them. In all these circumstances, financial services needs to play its role to support consumers’ financial well-being, that is to say “a state in which individuals are able to smoothly manage their financial needs and obligations, can cope with negative shocks, can pursue aspirations, goals and capture opportunities, and feel satisfied and confident about their financial lives, keeping in mind country specific circumstances”.3That is a challenging task, and a complex one, but not one any of us here today faces alone, since we all have a role to play.Recognising the complexity of these issues, we have organised today’s workshop in order that we may learn from one another. We want to hear about different approaches and best practices, practical steps and measures you have put in place to ensure that culture, policies and processes take account of the needs of consumers in vulnerable circumstances.I also encourage the financial services sector to learn from other industries and public services who may have better approaches to consumers facing particular vulnerabilities. I would like it to be said in future that the financial services sector is amongst the best at supporting consumers in vulnerable circumstances. Would that be said today I wonder? In some respects it might, but in others I expect it would not.Our New Consumer Protection Code The backdrop to today’s event is the Central Bank of Ireland’s new Consumer Protection Code.4 It will come into force in March next year and contains modernised provisions on consumer vulnerability. The new Code builds on work done this past decade to strengthen the consumer protection framework in Ireland, both to align with global standards and in reaction to specific challenges and cases of misconduct we had to deal with.5The Consumer Protection Code is the cornerstone of our consumer protection framework for financial services, sitting within a wider framework of laws to protect consumers and investors. The recent review of the Code was a key strategic initiative of the Central Bank to ensure the Code remains fit for purpose and future-ready. We carried out the review in an open and engaged manner and I want to thank the more than 1,320 organisations and individuals who engaged with us through the process. In particular I thank those who responded to our public consultation. Our new Consumer Protection Code would not be what it is without your insights. As we move to implement the new Code, we want to continue to get the benefit of your insights, just as we did in the Code Review itself. Today’s event is an example of this approach, to take a modernised component of the new Code (vulnerability) and workshop with you what it should mean in practical terms. We will continue to arrange engagements such as this as we head towards the go-live date on 24 March 2026 and beyond. In doing so, we recognise the Code contains new provisions on which we need a shared understanding if we are to continue to improve financial services over time. At the Central Bank of Ireland, we are committed to continuing to engage with you on these topics. We are also committed to sharing and disseminating information as our understanding of the Code and its impact evolves. New protections for consumers facing vulnerable circumstancesOne of the new Code’s key enhancements is to broaden the concept of "vulnerability" to which specific protections apply. In doing so, we are aligning ourselves with the more sophisticated articulation of vulnerability in the revised G20/OECD High Level Principles on Financial Consumer Protection. The OECD’s recent review of our supervisory approach included specific recommendations to enhance our supervisory approach with respect to vulnerable consumers.6 We will factor what we hear today into our development of that approach under our new supervisory framework. Our implementation of the new Consumer Protection Code I know you will also be keen to understand how the Central Bank is approaching implementation of the new Code in general. There are four points I want to make: We expect regulated firms to now be well advanced in their implementation of the new Code underpinned by clear plans, resources and senior level accountability. Your care and attention to implementing the Code is something we will take into account in future supervisory actions. Here, I want to commend those industry bodies who have been so proactive in playing their role to support member firms through dedicated workstreams and groups. We recognise the Code introduces new requirements. We will work with firms and stakeholders across the system to build understanding of those requirements. We will be open and engaged on this, recognising the Central Bank does not always have the answer to what represents best practice in terms of operationalising a given provision of the Code. Today’s workshop is an example of this – you will understand better than us what a good approach to supporting a consumer facing a given vulnerability will be.We will weave the requirements of the Code throughout our supervisory work, consistent with our new integrated supervisory approach. As I outlined in recent remarks7, in the immediate period ahead this will involve a particular focus on: How firms operate and the consumer/investor experience: We expect firms to be well run, secure their customers’ interests and effectively manage any conflicts of interest by placing consumers and investors at the heart of decision making.Digitalisation: Digital innovation can support consumers and investors. However, it also comes with potential risks in terms of ensuring consumers are enabled to make the digital transition and given appropriate information and support when making transactions digitally.  There is also a need to ensure operational resilience, recognising the significant impact service disruption has on consumers.   Financial crime: This should be a priority for all firms and agencies involved with financial services. We all need to actively safeguard the integrity of the financial system and consumer interests by combatting financial crime.How firms have enhanced their supports for consumers facing vulnerable circumstances can be expected to feature in our supervisory engagements across each of these three themes.4.  We will assess the effectiveness of the Code through the substantive outcomes firms achieve. This will include enhancing how we gather and consider insights from consumers through our research, new capabilities we are equipping our supervisors with to monitor online activity and how we use conduct of business returns.8 Here I have a particular ask of regulated firms when it comes to implementing the Code: build a better understanding of your customers’ financial well-being, their needs and the challenges they face (including listening more closely to what their complaints are telling you about their experience of your firm).  I have seen good examples of this being done already and I believe, if done well, it can support good outcomes for both consumers and the businesses involved.Keeping track of progressWhen I say we need to assess the effectiveness of our regulatory frameworks through the substantive outcomes achieved for consumers, I generally see people nod in agreement. But I wonder do we know or agree what those outcomes should be?Perhaps today’s workshop will be an interesting insight into that. In recent remarks I spoke about the need to support a better social conversation on financial well-being. I am committed to this conversation because I want us to be able to keep track of how we are delivering better outcomes for consumers in real terms. How are we to assess these outcomes if we don’t have a shared concept of what ‘financial well-being’ means to begin with? The Central Bank supports Ireland’s Well-being Framework and we are working at OECD level to develop the conceptual framework for financial well-being specifically.  To support this work and our social conversation here in Ireland, I am keen that we build more structured data on this topic, hence my encouragement to regulated firms to place a focus on this. For its part, the Central Bank will continue to put information into the public domain to inform this conversation. In addition to our ongoing research and statistical publications, we are putting in place a new Consumer Insights Model, to understand the position of Irish consumers via a nationally representative survey of 4,000 consumers of financial services across a range of topics relevant to financial well-being. We will collect, measure and analyse data on these consumers’ behaviours and experience of different financial services. We will also measure their attitudes and sentiment across a range of consumer finance topics.  We will publish the outputs to inform policy as well as our own supervisory strategies. The Consumer Insights Model will enhance our understanding of the financial products consumers and investors buy, their experiences of financial service providers, their financial situation and their attitudes towards current issues affecting financial services.  It will also inform our risk analysis of sectors and markets and how we prioritise our work.  Events like today and our forthcoming Consumer Insights Model reflect the Central Bank’s demeanour towards how we will implement the Code. We realise the reforms of the Code will take work to implement and that we must support that work going in the right direction. We will also be monitoring closely the extent to which firms’ implementation of the Code is leading to demonstrably better outcomes for consumers. I suggest regulated firms put increasing focus on doing so too, so that together we keep track of how regulation is contributing to creating the right conditions for financial services to support financial well-being. Let me pause there and thank you for your attention and your participation in our workshop today.[1] Thanks Deirdre Mullally, Brendan Beere, Patrick Casey, Brenda Carron and James O’Sullivan for their help in preparing these remarks.[2] Governors Blog 2025 IMF Annual Meeting.[3] G20 Policy Note on Financial Well Being.[4] Central Bank of Ireland Consumer Protection Code.  [5] G20/OECD High-Level Principles on Financial Consumer Protection.  [6] OECD (2024), Financial Consumer Protection in Ireland: A Review of the Central Bank of Ireland's Supervisory Functions, OECD Publishing, Paris. [7] "Towards Our Future Financial Wellbeing" - Speech by Deputy Governor Colm Kincaid at Financial Services Ireland.  October 2025.[8] For example, see recently published research related to Buy Now Pay Later (BNPL).  Following this research, the Central Bank issued a Dear CEO letter to firms in the sector highlighting the importance of the research findings and the forthcoming consumer code requirements in this area. 

The Central Bank of Ireland today (31 October 2025) published the seventh annual Private Motor Insurance Report of the National Claims Information Database (NCID). The report looks at data from 2010 to 2024 and gives insights into the cost of premiums, claims and the overall aggregated financial performance of the private motor insurance sector. NCID compiles data from all insurers selling private motor insurance in Ireland with a view to improving the overall transparency of the private motor claims sector. The total gross written premium in 2024 for private motor insurance was €1.46bn. Other key findings published in today’s report include:Cost of InsuranceThe average written premium per policy increased by 9% to €623 between 2023 and 2024.The expected cost of claims per policy increased by 3% to €397 in 2024, the highest it has been since 2014. This is driven by damage claims:Damage claims cost per policy increased to €192, while injury claims cost per policy remains lower than pre-pandemic levels at €205. Injury claims cost remained stable between 2022 and 2024, compared to €257 for the pre-COVID 2015-2019 average. The average cost of smaller injury claims has reduced in recent years, but this has been offset by an increase in the average cost of larger injury claims.Expected claim costs as a percentage of premiums received was 68% in 2024.In 2024 93% of policies sold had comprehensive cover which is consistent with the 2023 findings.Income and Expenditure Operating profit was 4% of total income in 2024, down from 8% in 2023 and 12% in 2022.Overall, between 2010 and 2024 operating profit was 5%.Combined Operating Ratio (COR) was 95% gross and 99% net of reinsurance.Settled Claims in 2024The total cost of claims settled in 2024 was €792m. Damage claim costs accounted for 54% of total settled claim costs, an increase from the 29% average observed between 2015 and 2021. Damage claims increased by 6%, while the average cost of damage claims increased by 18% compared to 2023. For injury claims settled in 2024:48% settled directly with an insurer, with an average time taken to settle of 1.8 years.16% settled through the Injuries Resolution Board with an average time to settle of 2.7 years 36% settled through litigation with an average time taken to settle of 5 years. Personal Injuries GuidelinesFor injury claims settling directly or through the Injuries Resolution Board, virtually all claims settled under the Guidelines in 2024. For injury claims settled through litigation in H2 2024:57% settled under the Guidelines.43% settled with reference to the book of Quantum.The average cost of claims settled under the Guidelines in 2024 were (when compared to claims settled in the same channel under the Book of Quantum in 2020):33% lower for claims that settled directly before the Injuries Resolution Board.8% lower for claims settling through the Injuries Resolution Board.26% lower for claims settling directly after the Injuries Resolution Board. A reduction in compensation awards has also been observed for claims (under €100,000 compensation cost) settled in the litigated channel.  Robert Kelly, Director of Economics and Statistics at the Central Bank of Ireland, said: “We are pleased to publish the seventh annual Private Motor Insurance Report of the NCID today. It’s an important resource for policymakers, stakeholders and the wider financial services industry and improves the overall transparency of the claims environment and the insurance sector. “The average written premium has increased by 9% compared to 2023. The data also shows claims costs continue to rise, primarily due to an increase in damage claims. In 2024, damage claims accounted for 54% of settled claim costs, a significant increase from the 29% average observed between 2015 and 2021.“While there has been an upward trend in the number of claims settled and the associated costs since the COVID years, it is important to highlight the total cost of injury claims settled in 2024 was 16% lower than the average from 2015 to 2019, with the total number of injury claims settled being 23% lower. Operating profit was 4% of total income in 2024, down from 8% in 2023 and 12% in 2022. Overall, between 2010 and 2024, operating profit was 5%.”ENDS More InformationKelly Horn kelly.horn@centralbank.ie / media@centralbank.ie  

New phase will ensure technical readiness for first issuanceIf legislation in place in the course of 2026, a pilot exercise could start in 2027 and the Eurosystem should be ready for a potential first issuance of the digital euro during 2029Preparation phase begun in November 2023 has successfully concludedThe Governing Council of the European Central Bank (ECB) has decided to move to the next phase of the digital euro project. This decision follows the successful completion of the preparation phase, launched by the Eurosystem in November 2023, which laid the foundations for issuing a digital euro.The Governing Council’s decision aligns with European leaders’ request to accelerate progress on the digital euro, as recently stated at the October 2025 Euro Summit. A digital euro will preserve Europeans’ freedom of choice and privacy and protect Europe’s monetary sovereignty and economic security. It will foster innovation in payments and help make European payments competitive, resilient and inclusive. The Eurosystem will implement its preparations flexibly, in line with calls from euro area leaders for the Eurosystem to be ready for a potential digital euro issuance as soon as possible, while also recognising that the legislative process has not yet been completed. The ECB Governing Council‘s final decision on whether to issue a digital euro, and on what date, will only be taken once the legislation has been adopted. Under the assumption that European co-legislators will adopt the Regulation on the establishment of the digital euro in the course of 2026, a pilot exercise and initial transactions could take place as of mid-2027. The whole Eurosystem should then be ready for a potential first issuance of the digital euro during 2029.“The euro, our shared money, is a trusted sign of European unity,” said ECB President Christine Lagarde. “We are working to make its most tangible form – euro cash – fit for the future, redesigning and modernising our banknotes and preparing for the issuance of digital cash.”As payment habits evolve, and cash payments decline compared with digital transactions, the need for a public digital means of payment – complementary to cash – has become increasingly urgent. The digital euro will complement cash and bring its benefits – simplicity, privacy, reliability, availability across the whole euro area – to digital payments. Along with the Regulation on the establishment of the digital euro, the ECB is also supporting the European Commission’s proposal to reinforce the right to pay with cash.The Eurosystem will focus on three main areas:Technical readiness: developing the digital euro’s technical foundations, including initial system set-up and piloting;Market engagement: collaborating with payment providers, merchants and consumers to finalise the rulebook, conduct user research and test the system through pilot activities;Legislative process support: continue providing technical input to EU co-legislators and assist the legislative process as required.“This is not just a technical project but a collective effort to future-proof Europe’s monetary system,” said ECB Executive Board member Piero Cipollone, who chairs the High-Level Task Force on a digital euro. “A digital euro will ensure that people enjoy the benefits of cash also in the digital era. In doing so, it will enhance the resilience of Europe’s payment landscape, lower costs for merchants, and create a platform for private companies to innovate, scale up and compete.”Transparency and close cooperation with stakeholders have been – and will continue to be – fundamental to the project. The Eurosystem has benefited greatly from feedback from European decision-makers, market participants and potential users, and will continue to engage actively with a wide range of stakeholders.The Eurosystem’s continued preparation for a digital euro will be implemented flexibly, ensuring alignment with the legislative process. To this end, work will be structured in modules to enable gradual scaling and limit financial commitments. The final cost of a digital euro – for both its development and operation – will depend on its final design, including components and related services that need to be developed. As a result of the work done in the preparation phase, the total development costs, comprising both externally1 and internally developed components, are estimated at around €1.3 billion until the first issuance, which is currently expected during 2029. Subsequent annual operating costs are projected to be approximately €320 million per year from 2029. The Eurosystem would bear these costs, as it does for producing and issuing euro banknotes – which, like the digital euro, are a public good. As in the case of banknotes, these costs are expected to be compensated by the generated seigniorage – even if digital euro holdings were small compared with banknotes in circulation.The conclusion of the preparation phase marks an important transition in the digital euro project. Building on the insights gained during the investigation phase conducted from 2020 to 2023, we moved towards refining its practical design. Key achievements include (1) the development of the draft digital euro scheme rulebook, (2) the selection of providers for digital euro components and related services, (3) the successful running of an innovation platform for experimentation with market participants, as well as (4) the investigation by a technical workstream into the fit of the digital euro in the payment ecosystem. The latter, conducted by the ECB and market participants via the Euro Retail Payments Board, concluded that a digital euro could foster further competition in the European payments market. Besides directly benefiting from distributing the digital euro, banks and other payment service providers could leverage its open standards to expand their reach across the euro area without needing their own acceptance networks. They would also be able to co-badge the digital euro with existing payment solutions.The ECB provided technical input to co-legislators on request, thereby supporting the legislative process. This input demonstrated that the costs of the digital euro for banks will be contained – these costs will be close to the European Commission’s initial estimates and similar to those incurred for the implementation of the Payment Services Directive. It also showed that safeguards built into the design of the digital euro (such as holding limits) would ensure that it does not create financial stability risks.To ensure that the digital euro is designed to meet the needs of European citizens and merchants, the Eurosystem conducted extensive user research targeting vulnerable consumers and small merchants. The findings – available in a separate report published today – show the need for a simple, reliable and secure payment experience. These results reaffirm the ECB’s commitment to developing a digital euro that works for everyone and advances Europe’s financial evolution – designed to empower citizens, support innovation and strengthen the resilience of our monetary system. [1] External development costs until a first issuance are estimated at around €265 million.

Chair and Committee members, thank you for the invitation to join you today to discuss the issue of the Central Bank’s role in the Israeli Bond Programme. I am joined by Mary Elizabeth McMunn, Deputy Governor, Financial Regulation, and Gerry Cross, Director of Capital Markets and Funds. Since our first engagement with you on this issue over a year ago, we have endeavoured to support your examination of it to the fullest.The Central Bank’s role in this issue is governed by EU law. The EU Prospectus Regulation sets out harmonised EU laws with respect to securities which are the subject of that regulation. This is a part of the EU Capital Markets Union. Each Member State of the EU must appoint a competent authority in that jurisdiction. The Central Bank has been appointed as the competent authority in Ireland for the purposes of the EU Prospectus Regulation and must carry out its functions and duties as provided for under that Regulation.At all times, we have been obliged to carry out the statutory tasks and functions which have been assigned to us. We have to work within the law and we have carefully and comprehensively discharged our obligations under the EU Prospectus Regulation.As set out in my recent letter to the Committee, there are a number of important over-arching points that I would like to highlight, specifically the Central Bank’s role in the transfer of approval process, our professional secrecy obligations, and the framework of EU Regulations within which we operate.First, Article 20(8) of the EU Prospectus Regulation provides for the transfer of the approval of a prospectus on the request of an issuer to the competent authority of another Member State. Any such transfer is subject to prior notification to ESMA and the agreement of the competent authority to whom the approval function is to be transferred.In this process, the competent authority of the home Member State only approves the transfer to the competent authority of another Member State but does not approve the prospectus that is issued. The competent authority of the transferee Member State reviews and decides whether to approve the prospectus.In this framework, the Central Bank’s role was limited to transferring the role of approving the 2025 Prospectus to the Commission de Surveillance du Secteur Financier in Luxembourg (the CSSF). The Central Bank did not have any role in the review or approval of the 2025 Prospectus and did not receive any draft of that document. It was a matter for the CSSF to independently carry out the review and approval process.There are two distinct and separate steps in the transfer of approval process. The first is the transfer of approval of the prospectus to another competent authority. The second is the review and approval of the prospectus by that other authority. In carrying out its role of reviewing and approving the relevant prospectus, the CSSF is entirely independent of the Central Bank.Second, the Central Bank is subject to confidentiality obligations pursuant to the EU Prospectus Regulation and Section 33AK of the Central Bank Act 1942. Those obligations restrict us from disclosing confidential information obtained in the performance of our functions. The correspondence between the Central Bank and the State of Israel and between the Central Bank and the CSSF also falls within confidentiality restrictions. Within our legal obligations, we have sought, to put as much information as possible with regard to this matter into the public domain.Third, one of the functions that we are required to carry out under the Prospectus Regulation is to consider transfer of approval requests. When considering transfer of approval requests, we consider the connectivity of the prospectus with the jurisdiction from which and to which it is seeking a transfer.In the case of the State of Israel transfer of approval request, the issuer decided that it would cease from 1 September 2025 making offers to the public under its prospectus in Ireland. The bonds to be issued under the 2025 Prospectus may only be offered to the public in Austria, France, Germany, Luxembourg and the Netherlands.In circumstances where the State of Israel proposed to discontinue offers to the public under its prospectus in Ireland, the Central Bank approved the transfer of approval of the prospectus under the EU Prospectus Regulation.Finally, the Central Bank reviewed the recommendations in the report issued by this Committee in the context of its functions and with regard to the prospectus it approved for the State of Israel on 2 September 2024 which expired on 1 September 2025. However we had no role in the review and approval of the 2025 prospectus.We are happy to take your questions.

Last week I was in Washington at the latest Annual Meeting of the International Monetary Fund (IMF) as well as the latest (and final under the South African Presidency) meeting of G20 Finance Ministers and Central Bank Governors. These get-togethers (whether at the IMF or the G20) bring Finance Ministers and central banks to the same table and are an important opportunity for dialogue on key economic and financial issues. The backdrop to this year’s meetings was a global economy fragmenting along geopolitical lines, a trend that has accelerated this year, with implications for economies big and small. As a highly open and very well-connected economy with a significant financial system, these global developments matter to Ireland.The global economy and financial system Overall, the IMF’s message was of a resilient global economy but with underlying fragilities. Its latest projections for global growth have been revised upward relative to 6 months ago, but are lower than 12 months ago due to the intervening policy shifts. It will, though, take time to understand the full effects of the changing global trading framework. The US economy has started to show signs of a slowdown, although the (remarkable) investment in AI is masking some of the slowdown in other investments. Global imbalances (essentially the fact that some countries have persistent current account deficits, spending more on foreign goods and services than they earn – while others have surpluses) were a topic of discussion throughout the week (and will continue to be an area of focus for the Fund and the G20).From a financial stability perspective, the IMF highlighted the risks from stretched asset valuations, growing pressure in sovereign bond markets, and the increasing role of nonbank financial institutions (NBFIs) as market makers, liquidity providers and intermediaries in private credit, real estate, and crypto markets. I was struck by the potential for the vulnerabilities in the system to interact, in particular the combination of an AI boom (now with a growing role for debt financing), and the growth in private credit (with opaque lending standards), crypto markets and (increasing) sovereign debt.  We will need to keep a very close eye on these developments which, on the face of it, look uncomfortably familiar. Key themes Outside of the main meetings, three themes dominated my conversations: technology, NBFIs and institutional credibility.Not surprisingly, technology developments were a big theme, not least on payments.  Discussions with peers, with industry and with academia covered the rapidly evolving landscape (stablecoins, tokenised deposits, central bank digital currencies) and the implications for public policy outcomes, as well as the cross-border elements and the regulatory approaches by different jurisdictions.  This is an area which the Central Bank is focused on, reflecting the breadth of our mandate and the need to consider the issues from a consumer, investor, financial stability and macroeconomic perspective. Inevitably AI was also a big topic, with a focus on its potential to boost productivity and growth, but countries also need to be prepared and to have the right policies in place to protect consumers and prevent against divergence both within and across countries as well as managing the risks that increasing debt financing may pose. Invariably, there was continued focus on different dimensions of NBFIs where vulnerabilities are seen to be building up. The opacity of private credit markets was an issue of focus (not surprisingly in view of the collapse of First Brands at the start of the week) as was the growth of NBFIs investing in sovereign and corporate debt markets. There were calls across the meetings for implementing the agreed international standards to develop resilience in the sector, an area the Central Bank has been focused on for some time.Finally, institutional credibility and multilateralism. There was a greater focus than in previous years on the important role that institutions play in providing economic frameworks that support stability. Central bank independence was a topic of discussion, as was the IMF’s role to promote global and macroeconomic stability and provide independent policy advice for every single member. I have long appreciated the IMF’s commitment to being a trusted advisor and providing candid assessments across the globeSome reflectionsLast week’s meetings reinforced for me some clear priorities for Irish and European economic policy, which I reflected in my speech at the Atlantic Council. First and foremost, policy needs to focus on the fundamentals, managing the short term while planning for the medium term, ensuring our frameworks are fit-for-purpose and learning the lessons of the past while preparing for the future. Successful economies need stable and sustainable macroeconomic frameworks and sound fiscal and monetary policies, along with stable and well-regulated financial systems and well-functioning markets. For Ireland, against a backdrop of strong economic and population growth, continuing to attract investment will require a particular focus on closing infrastructure gaps in water, energy, transport, and housing as the Government set out in its recent Budget.  As part of the EU, Ireland is also part of the world’s largest single market and there is untapped potential in it integrating further in that market.  For Europe, it remains essential that we respond to the challenges that Mario Draghi and Enrico Letta highlighted in their reports last year.  As the world’s largest trade bloc – accounting for around 15.8 per cent of world trade – deepening the Single Market offers a hedge against broader global trade fragmentation, helping to reduce an over-reliance on external dependencies, fostering innovation, and promoting stable growth.  Perhaps most of all delivering the Draghi/Letta agenda is about realising the potential of the European economy for its citizens. Finally, last week’s meetings were set against a (continuing) global macroeconomic environment of uncertainty, geopolitical tensions and regional conflicts. They reaffirmed for me the value of engaging with global institutions to address shared challenges. Operating in a small open economy means we value relationships that support our commitment to multilateralism and international cooperation, collaboration and understanding. In that context I was particularly pleased to sign an MOU with the South African Reserve Bank; with a view to share knowledge, experiences and methodologies as we both develop our sustainable finance frameworks and approach to emerging technologies and the evolving payments landscape. More change in the global environment is guaranteed, and the stage is now set for building new relationships, adopting new frameworks and creating new paradigms for the world that our children and grandchildren will inhabit.

Promontoria Finn Limited (Clone) - Central Bank of Ireland Issues Warning on Unauthorised Firm

Deutsche Bank Wealth Management (CLONE) / Deutsche Bank AG (CLONE) / DB UK Bank Limited (CLONE) - Central Bank of Ireland Issues Warning on Unauthorised Firm

Colman Doyle Finance Limited (Clone) - Central Bank of Ireland Issues Warning on Unauthorised Firm

Gett Finance - Central Bank of Ireland Issues Warning on Unauthorised Firm

IntroductionGood morning everyone and thank you for the invitation to speak to you today.1We find ourselves in interesting times.The global economy has been fragmenting along geopolitical lines for nearly a decade, but this trend has accelerated, marking a swift transition with implications across the short, medium, and long term for economies big and small, alongside the other significant – and more familiar – economic transitions of ageing societies, a changing climate and an increasingly digitalised world. Recognising and understanding these transitions is fundamental if we are to shape policies that build economic resilience and enable households, businesses, and communities to navigate challenges and seize opportunities. In my remarks today I will provide a perspective of a small, highly open, highly globalised economy to these global shifts, albeit one that is both part of the world’s largest single market and which has particularly strong trans-Atlantic links with the US. I will conclude with some thoughts on the continuing need for a multilateral approach and taking the opportunity to create new paradigms. Finding opportunities in the face of headwindsFor Ireland, as one of those highly open and very well-connected economies, an environment of trade barriers, and policy uncertainty and unpredictability is unwelcome and entails economic costs. In 2023, almost 17 per cent of Ireland’s exports were to the US, with 36 and 12 per cent to the rest of the EU and the UK, respectively. Around a quarter of employment in Ireland is in US firms.2 So, as well as the ramifications of the wider trend towards more fragmented global trade, understanding the implications of changes in US policy have been key areas of focus for us at the Central Bank of Ireland. Some of the key findings from our analysis offer lessons of broader relevance, particularly for small, open economies.First, to understand the potential impact of US tariffs on Ireland, it is important to have a clear picture of the Irish economy. It comprises a small number of large, productive, globally oriented foreign-owned multinational enterprises (MNEs), alongside domestic Irish-owned firms that dominate employment. MNEs make up 3.2 per cent of active firms, but around one quarter of aggregate employment. However, MNEs are not homogenous. We estimate that roughly half of MNE workers are employed in non-tradable sectors, largely serving the local economy, for example in the retail and accommodation sector. This type of ‘horizontal’ foreign direct investment (FDI) is relatively insensitive to tariffs. However, the most material risk to the Irish economy comes from the other half, who use Ireland as an export platform for their global sales, serving the rest of the EU, US, and broader international markets. These firms are concentrated in sectors such as pharmaceuticals (‘pharma’) and information technology, directly exposed to tariffs and other US industrial policy choices. US-owned firms account for 70 per cent of employment in these export-oriented MNEs and over 80 per cent of capital investment. As I said earlier, Ireland’s strong links with the US stand out in an EU context: we have the highest concentration of US MNE activity of any EU country, both in manufacturing and outside manufacturing. Over the last number of months, we have looked at the potential effects of tariffs on this type of FDI, particularly in the pharmaceutical and medical devices sectors. Our analysis suggests that 15 per cent tariffs – as per the recent agreement – will reduce exports to the US. But they are not prohibitive to trade. For one thing these firms have already made huge capital investments in setting up their production facilities in Ireland. Another is that US tariffs do not diminish Ireland’s attractiveness as an export platform to the rest of the EU or other non-US destinations.3More than half of Ireland’s pharma exports are destined for the rest of the EU or other non-US countries and so are not subject to any new tariffs. In addition, while we know that US tariffs can affect the pricing of pharma products, our analysis also shows that the sensitivity of Irish pharma export volumes to tariffs is likely to be relatively low in the short-run given the highly specialised nature of pharmaceuticals produced in Ireland.Irish-owned firmsWhile MNEs understandably get a lot of attention, given they are the primary source of Ireland’s exposure to US tariffs, it is also important to examine the exposure of domestic, Irish-owned, firms. Our analysis shows that, although they are not as export and import-intensive as foreign multinationals, over 80 per cent of workers in Irish-owned firms in manufacturing, wholesale and retail participate in international trade, whether exporting or importing goods. The key difference between such exporters and MNEs is that the former are far more likely to export to our nearest neighbours geographically – the rest of the EU and the UK – rather than the US market. Only 12 per cent of Irish-owned firm exports are to the US, which is a lot smaller than the 30 percent we see in aggregate. In total, 5 per cent of employees work in Irish-owned firms that export to the US. However, Irish firms that export to the US tend to be among the most productive and geographically diversified Irish exporters. Their exports to the US account for only a third of their total exports on average, and under a tenth of their total sales, some of which are also directed to the domestic market. Taking this into account, we estimate that less than 1 per cent of workers in Irish firms are directly tied to US exporting activity. A key question is whether such firms will be able to adapt to tariffs and potentially diversify to other markets. Of course, the extent to which they have to do that will partly depend on US importers and ultimately US consumers but recent survey evidence – before the EU-US trade deal – suggests they will be able to do so.4 It found that one third of manufacturing firms in the Irish market were already taking steps to diversify towards other markets. Notably, Irish firms exporting to the US had lower production, employment, and price expectations than other exporters, but this was entirely driven by those that were not diversifying.One other notable result from this research is the two-sided nature of international trade within firms. Around 98 per cent of manufacturing exporters also import intermediate inputs. Irish firms exporting to the US import almost four times more from the US than other exporters. This highlights how interdependent global supply chains have become, and how difficult it can be to anticipate the ripple effects of tariffs and other similar policies.Projections for the Irish economyWhat does this imply for our economic projections? While the economic outlook for Ireland is not as favourable as it would have been had tariffs not been introduced, the effective tariff rates now in place covering EU-US trade are not prohibitive to trade. However, policy uncertainty remains elevated, even if it has fallen from its peak earlier in the year.Overall, the domestic economy showed resilience in the first half of 2025, but headwinds persist. Continued expected growth in real disposable incomes, amid a stable labour market – labour force participation is high, and unemployment is low – supports continued growth in consumer spending. But, some signs of easing momentum are emerging and supply-side constraints to sustainable growth in the domestic economy remain prominent.Overall, our latest projections anticipate a slowdown from 2.9 per cent growth this year to just over 2 per cent in the coming years.5The new agreement between the EU and US, although yet to be fully implemented, is expected to moderately reduce Irish growth in the medium-to-long run, driven by activity in MNE-dominated sectors, particularly pharmaceuticals and chemicals. The current tariffs of 15 per cent lead to reduction of around 1 per cent in Irish economic output relative to a no-tariff scenario over the long-term. Diverted exports to markets outside the US partially offset the direct impact of the tariffs.Consumption and particularly investment, on the other hand, both fall faster and further than GDP, as firms and households respond more rapidly to the new environment, settling close to 2.5 and 3.5 per cent respectively below the baseline. We also anticipate that tariffs will lead to a moderate structural shift, with reduced manufacturing activity and increased service sector growth as resources are reallocated in response to these global shocks. This reallocation helps to mitigate the negative effects of tariffs on goods. Longer-term, economic policymaking faces a less-integrated global economy. Geoeconomic fragmentation is one of a number of key structural changes – along with population ageing, a changing climate change, and the ongoing march of digital technologies – that the global economy will have to adapt to. In the case of Ireland, capital investment and productivity have historically accounted for around 80 percent of Irish economic growth.6 So, in fact, the main risk for Irish economy from this fragmentation is lower investment flows. A geopolitical shift towards ‘friend-shoring’ in the EU could potentially help compensate any reduction in future investment by US MNEs, although our research suggests that this regionalisation of economic linkages is likely to be inflationary and could weaken economic growth across the euro area.7The Euro areaGeoeconomic fragmentation of course does not just impact Ireland. In the case of the euro area, it poses several risks to the inflation and growth outlook. As US tariffs are global in nature, there is the potential that trade diversion is stronger than the current (rather limited) effect assumed in the latest ECB staff projections. Scenario analysis suggests that this would have only a mild effect on the euro area, with increased exports to the US offset by weaker exports to China and the rest of the world. Apart from diverting to different markets, Chinese firms could also lower their export prices to offset the effect of US tariffs. In this scenario, an increase in (cheaper) Chinese imports has a large negative impact on inflation and growth.8And of course, there is the possibility that tariffs may induce bottlenecks as firms restructure their global supply chains. A scenario resembling pandemic-era disruption would see inflation rise considerably, when accounting for input-output linkages through production networks, but have a minimal effect on growth. As for our current monetary policy, at our last meeting in September, my colleagues and I on the ECB’s Governing Council decided to keep rates unchanged. We continue to be in a good place with the disinflationary process behind us, the European economy showing resilience and inflation where we want it to be. Real euro area GDP growth is projected to average 1.2 per cent in 2025, 1 per cent in 2026 and 1.3 per cent in 2027. Surveys suggest the economy maintains positive underlying momentum. While the trade agreement with the US has reduced uncertainty somewhat, the overall impact of the change in the global policy environment will only become clear over time. Risks remain that renewed trade tensions could further dampen exports, investment, and consumption. By contrast, higher than expected defence and infrastructure spending and productivity-enhancing reforms would add to growth. We are not pre-committing to a particular rate path and will continue to determine the appropriate monetary policy stance by following a data-dependent and meeting-by-meeting approach. In particular, we will base our interest rate decisions on our assessment of the inflation outlook and the risks surrounding it, in light of the incoming economic and financial data, as well as the dynamics of underlying inflation and the strength of monetary policy transmission. Policy recommendations Where does that leave us? The Irish economy faces the current challenges from a position of relative strength, which policymakers can harness in supporting the economy to adapt over both the short and long run. Ireland has benefitted from decades of FDI-led growth, and its interconnections with the US economy and its membership of the EU have led to higher productivity, investment, and human capital. This, along with Ireland’s open, flexible, and skilled labour force, creates strong conditions to adapt to geoeconomic shifts. Nonetheless, a slowdown in inward investment flows would reduce Ireland’s long-run growth potential. Global fragmentation could also affect other long-term goals, such as the transition to net zero, by restricting the supply of critical inputs for new technologies.It also brings to the forefront the need for clear priorities in Irish and European economic policy. First and foremost, policy needs to focus on the fundamentals, managing the short term while planning for the medium term, ensuring our frameworks are fit-for-purpose and learning the lessons of the past while preparing for the future. Successful economies need stable and sustainable macroeconomic frameworks and sound fiscal and monetary policies, along with stable and well-regulated financial systems and well-functioning markets.For Ireland, against a backdrop of strong economic and population growth, continuing to attract investment will require a particular focus on closing infrastructure gaps in water, energy, transport, and housing as the Government set out in its Budget last week. Of course, we shouldn’t just stop at the border. Ireland is part of the world’s largest single market and there is untapped potential both in it integrating further into that market  as well as  in overall European economic activity.9 One year on from Mario Draghi and Enrico Letta’s reports on the future of the European economy, it remains essential that we make progress on their recommendations, if we want to tap – and indeed realise – that potential.  As the world’s largest trade bloc – accounting for around 15.8 per cent of world trade10 – deepening the Single Market offers a hedge against broader global trade fragmentation, helping to reduce an over-reliance on external dependencies, fostering innovation, and promoting stable growth. That includes realising the potential of the EU’s capital markets and unlocking the almost €12 trillion in savings and cash deposits held by Europeans.11The need for collective solutions in the face of global challengesAt this point in the twenty first century, it is undoubtedly the case that the most significant headwinds we face today, be they from geoeconomic fragmentation or managing the challenges of a changing climate or harnessing digitalisation and innovation, are global in nature and demand collective solutions. This is precisely where organisations such as the Atlantic Council and in fact the IMF – at the start of its Annual Meetings this week - have important roles to play. The Council’s mission – to promote constructive leadership and engagement in international affairs and provide a forum for navigating the economic and political changes defining our times – is precisely what we need today so that we help to shape policy choices and strategies that create a more free, secure, and prosperous world.The IMF’s convening power brings us all to the same table, offering a vital forum for dialogue and coordinated action among its members. It’s not a theoretical exercise but the essential work of managing a more uncertain world, one that requires us to see past domestic concerns to the broader interconnected reality. The IMF’s role of promoting stability and cooperation for every single member and acting as an independent and trusted advisor is more critical now than ever, and I have long appreciated its dedication to providing candid assessments across the globe. st is earned through transparency, accountability, and a demonstrated credible commitment to act in, and serve, the best interest of society. I value this clear-eyed view and the stability it underpins.ConclusionSmall, open economies value engagement with global institutions to address shared challenges. Whether we are central bankers or government officials, we value the relationships – whether international financial institutions or trans-Atlantic councils – that support our commitment to multilateralism and international cooperation, collaboration and understanding. Diversity of experience and diversity of thought strengthens us both as institutions and as individuals. We need to recognise that the world which we grew up with has changed and that, coupled with the ongoing transitions we face, more change is guaranteed. I suggest that our energies should be tilted towards the challenge of creating the new world ahead of us rather than the comfort of preserving the old. The stage is now set for building new relationships, adopting new frameworks, and creating new paradigms for the world that our children and grandchildren will inhabit. I know that Irish institutions are committed to international cooperation, and we will continue to advocate for – and play a key role in – developing the new multilateral order that our economies need and our communities want.1 Thanks to Cian Ruane, Thomas Conefrey, Conor O’Shea, and Martin O’Brien for their help in preparing these remarks.2 CSO Publication: Business in Ireland3 Signed Article: On the Fault Line? The Irish economy in a time of geoeconomic fragmentation - CBI (2025) - See Box C “Multinational Expansion in the Era of Trade Conflicts” based on the model in Garetto, Oldenski, Ma and Ramondo (2025). 4 Survey data on exporter behaviour is sourced from a special module of the monthly European Commission’s monthly Business and Consumer Surveys (BCS) sponsored by the Central Bank of Ireland. See figure 10 in Signed Article Q3 2025.5 Quarterly Bulletin 3 20256 Conefrey et al., 2024.7 Clancy, Smith and Valenta, 2024 8 Scenario analysis conducted as part of the ECB staff macroeconomic projections for the euro area - September 20259 See President Lagarde’s remarks at the Bank of Finland’s 4th International Monetary Policy Conference.10 The EU’s role in global trade11 Governor Makhlouf remarks at NABE  

Governor of the Central Bank of Ireland Gabriel Makhlouf spoke today at the Atlantic Council during IMF World Bank Week in Washington DC.Speaking ahead of the event, Governor Makhlouf said: “Ireland is a small, highly open, highly globalised and very well-connected economy in an increasingly fragmented world.   An environment of trade barriers and policy uncertainty and unpredictability has economic costs for us. Our analysis suggests that 15 per cent tariffs will reduce our exports to the US. But they are not prohibitive to trade, and our latest projections anticipate a slowdown from 2.9 per cent growth this year to just over 2 per cent in the coming years.“This serves to highlight that while the US market is important for Ireland, it is far from our only one.  “Ireland is part of the world’s largest single market. We are facing the current challenges from a position of relative strength, having benefitted from decades of FDI-led growth.  We have a flexible and skilled labour force, strong economic and population growth, and a welcome, intense focus from Government on closing infrastructure gaps in water, energy, transport, and housing. “However, it remains essential that Ireland integrates further into the EU’s single market and for the Single Market itself to deliver on its potential as set out in last year’s recommendations from Mario Draghi and Enrico Letta.”“New ways of working and new relationships are vital in the face of the headwinds we see globally.  “That is why institutions like the Atlantic Council and the IMF are important.  We in Ireland value our engagement with global institutions and we value relationships that support our commitment to multilateralism and international cooperation, collaboration and understanding.“The IMF’s convening power brings us all to the same table, offering a vital forum for dialogue and coordinated action. It’s not a theoretical exercise.  It is the essential work that helps us see past our domestic concerns to the broader interconnected reality.”Commenting on current monetary policy, Governor Makhlouf said: “We continue to be in a good place with the disinflationary process behind us, the European economy showing resilience and inflation where we want it to be.” “We are not pre-committing to a particular rate path and will continue to determine the appropriate monetary policy stance by following a data-dependent and meeting-by-meeting approach.”Concluding, Governor Makhlouf said: “We need to recognise that the world which we grew up with has changed and that more change is guaranteed. “I suggest that our energies should be tilted towards the challenge of creating the new world ahead of us rather than the comfort of preserving the old. The stage is now set for building new relationships, adopting new frameworks, and creating new paradigms for the world that our children and grandchildren will inhabit. I know that Irish institutions are committed to international cooperation, and we will continue to advocate for – and play a key role in – developing the new multilateral order that our economies need and our communities want.”ENDSFurther InformationRead the full text of Governor Makhlouf’s speech on our website. 

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