exercise detected that the accounts published up to then by the group ’ s holding company – esi – did not reflect their actual financial nature. i must stress that this accounting noncompliance had not yet been reported by anyone – neither the board of directors of bes, nor audit firms, nor any other regulator or supervisor, nor any creditor institution of ges, nor any other individual. again, i would like to stress that all this, including the evaluation of bpi, was in due time shared with the assembly of the republic, in the context of the parliamentary committee of inquiry. third and last question : how did banco de portugal act regarding the internal control problems in esfg ’ s subsidiary in dubai? considering that es bankers dubai is a subsidiary of esfg in dubai, banco de portugal had no mandate to exercise its supervision on an individual basis, although the subsidiary was included in the perimeter of supervision on a consolidated basis. the subsidiary was solely subject to supervision by dubai ’ s supervisory authority ( dubai financial services authority – dfsa ), both in prudential terms and regarding money laundering prevention. however, within the scope of the cooperation process between supervisory authorities, banco de portugal took the initiative to establish various interactions with dfsa. as part of these interactions, dfsa informed banco de portugal of a number of shortcomings in the internal control mechanisms implemented in dubai ’ s subsidiary, also referring to doubts about the origin of the funds invested in www. bportugal. pt ges entities. in addition, dfsa informed banco de portugal of the corrective measures imposed. in view of this information, banco de portugal called on esfg to be informed on the state of implementation of the corrective measures imposed on said subsidiary and of the underlying implementation timeline. in parallel, contact was maintained with dfsa, in order to stay informed about the implementation of the corrective measures imposed. before concluding, let me note that, despite the constraints existing at the time regarding banco de portugal ’ s powers to withdraw the suitability status ( arising both from the law and jurisprudence ), banco de portugal at each moment was strongly committed to making rigorous and careful use of the means permitted by law. a posteriori, and benefitting from the knowledge and information currently available, it is easy – and tempting – to question supervisory action and to claim that supervision could have been carried out differently. however, i firmly believe that, under the extreme

in question could only be provided to the parliamentary committee of inquiry with the authorisation of the people referred to therein. this was the only reason why this note was not submitted to the parliamentary committee of inquiry. thus, contrary to what has been insinuated, this note serves to prove that banco de portugal was analysing all situations that could influence the suitability assessment of members of the board of directors of bes. www. bportugal. pt however, as i have been constantly emphasising and is already on record, namely within the scope of the parliamentary committee of inquiry, banco de portugal's decisions to prevent the carrying out of professional functions are subject to stringent legal conditions. these conditions effectively lay down specific factual prerequisites and, at the same time, the observance of general rules of procedure, proof and reasoning, governing the work of the public authority. at the end of 2013, in relation to the problems coming to light and receiving news coverage for the first time, banco de portugal did not have the necessary factual proof that – within the legal framework then applicable and given the very restrictive jurisprudence of the higher administrative courts – would allow a formal process to be opened to reassess the suitability of the members of the board of directors in question. this is made clear in the note quoted in the report, when it mentions that the information existing at that time had to be duly verified and confirmed for the purposes of any actions in terms of suitability. at no time did that information warrant the immediate removal of any member of the board of directors of bes, or even the immediate opening of a process to that end. what should be emphasised here, to remove all doubt, is that as a result of that and other information, the competent services in banco de portugal undertook work to obtain confirmation of potentially relevant facts for the suitability assessment, both regarding those concerned – namely through the exchange of written communications and through face - to - face meetings – and regarding other entities. in this assessment process ( as was fully outlined to the parliamentary committee of inquiry ), banco de portugal did not approve the registration requests to carry out functions in other grupo bes entities, which culminated in – after calling for successive explanations and clarifications from the members of the board in question, both written and face - to - face – the withdrawal of those requests by the individuals themselves in march and april 2014. in parallel, banco de portugal implemented actions to