NIB introduced customers to the Clerical Medical International (CMI) product and received a commission for any business which resulted. Most policy holders nominated NIB as their investment adviser. Customers "seeking an IR£denominated bank deposit investment" were encouraged to direct CMI to put the funds on deposit with NIB. Many customers did this. "NIB sought this business in the interests of its deposits base."

NIB paid CMI interest, which provided a return for the policy holder in accordance with the contract with CMI. "The attractions of this strategy are the security of the capital invested while generating a return, accessibility for encashment purposes, the provision of death benefit, and the ability of the policy holder to defray tax liabilities which might accrue on investments".

The bank denied that it has, or ever had, a sales team which was focused on colluding with customers in evading tax. "To date no evidence has been uncovered by the bank or made available to it that would substantiate this claim. Neither is there any evidence that a concerted campaign was engaged in to identify specific types of customers for the purposes of tax evasion."