The victim of the fraud was an experienced businessperson who invested €1m in two Appian managed sub-funds in March 2005. The Central Bank added that "had it not been for the financial position of the firm, the Central Bank would have imposed a financial penalty of €825,000". Under the Central Bank Act 1942 the regulator is not allowed to impose a monetary penalty on a firm if it would cause the financial service provider to cease business. Central Bank's director of enforcement and anti-money laundering Seána Cunningham said: "This is the first time the Central Bank has imposed a sanction on a firm where there has been a loss of client funds from cyber fraud as a direct result of the firm's significant regulatory breaches and failures." Read more: The 'red flags' Appian money minders missed Appian acted on the email instructions of the fraudster and liquidated €650,000 of the real client's investments. Appian states on its website that it manages €800m in assets.