AXA Life Europe DAC

The Central Bank has determined the appropriate fine to be €5,200,000, which has been reduced by 30%2 to €3,640,000 in accordance with the early settlement discount scheme provided for in the Central Bank’s ASP. The three breaches have been admitted by ALE. ALE’s weak internal control framework meant that it failed to identify and monitor a cohort of policies in relation to which policy related documentation was unclear, despite having been made aware of concerns in this regard. This failure meant that ALE was unable to inform its policyholders of information which was relevant to them. Firms must also manage conflicts of interest appropriately and establish and apply robust mechanisms for doing so. Conflicts of interest are an inherent risk to all regulated entities and, when not properly managed, they pose a risk to consumers and diminish market integrity. In this case, ALE’s failure to implement effective processes and procedures to manage conflicts of interest, meant that it did not give adequate consideration to potential conflicts of interest. The sound supervision of cross-border activities, be it under free provision of services or the right of establishment, is an important part of the Central Bank’s mandate.