FAI chief operating officer Rea Walshe was appointed to be the main liaison between the ODCE and other bodies investigating corporate governance at the association, despite concerns about a conflict of interest.
Walshe, who previously helped former CEO John Delaney and an honorary secretary with personal legal matters, has been responsible for assisting officers acting for the ODCE with their enquiries since last year.
This was raised as a concern within the FAI, sources told the Sunday Independent.
Walshe also facilitated work carried out by officials who worked on audits by Mazars and Kosi before their reports on finances and corporate governance were sent to the FAI and Sport Ireland. Both reports have since been referred to an Garda while the ODCE probe remains ongoing.
At least one of these reports includes the claim that Walshe acted on behalf of Delaney in a personal litigation case and was paid €2,500 afterwards, against corporate governance best practice and Law Society rules for in-house solicitors.
In-house solicitors must set up a solicitor firm and provide professional indemnity insurance if they wish to provide legal services to a party other than their employer. The Sunday Independent understands Walshe did not have such insurance. As an FAI employee, Walshe is permitted to act as a solicitor only on matters relating to company business and is not indemnified for other legal work.
While being appointed as chief liaison does not preclude Walshe's work at the association from being examined, her work for Delaney on a personal litigation case was questioned and considered a reason for her not to be the nominee to facilitate investigations.
It was also raised as a concern when she was briefly made interim CEO last year following Delaney's departure.
However, board members have said they are satisfied Walshe declared her work for Delaney and former FAI honorary secretary Michael Cody last year. Details of her work for Delaney and Cody only became public knowledge last month and Sport Ireland said it was not made aware of the potential conflict of interest before she was assigned to a committee reviewing corporate governance and recommending a series of reforms at the FAI a year ago.
Last week she was reappointed as COO despite questions about her role in the previous administration.
She went through an interview process to retain her role and the decision has been supported publicly by FAI interim CEO Gary Owens. He told The Currency website he is satisfied Walshe is "talented" and "knows all the reforms that are required".
Typically, the ODCE will work with a company secretary when carrying out its investigations. Walshe has been registered as the company secretary since 2017.
The ODCE said it could not comment on the matter due to the statutory confidentiality obligations under which the office operates. The FAI declined to comment.