4By a letter of 31 August 2015, issued on the basis of Article 131(5) of the Financial Regulation, read in conjunction with Article 109(1) of that regulation, as well as Article 145 of the Implementing Regulation, in the version applicable until 31 December 2015, according to which the authorising officer responsible, after having given the persons involved the opportunity to submit their observations, may impose administrative and financial penalties which are effective, proportionate and dissuasive on beneficiaries of grants who, inter alia, have been found to be in serious breach of their obligations, the Commission informed the applicant that it was planning to exclude the applicant from contracts and grants financed by the EU budget for a period of two years. Article 145 of the Implementing Regulation in the version applicable until 31 December 2015 provided, inter alia, that exclusion from contracts and grants financed from the EU budget may last up to 5 years from the date on which the infringement is established, or up to 10 years in the event of a repeated offence. The Commission added that, in the event that that penalty was imposed, the applicant would be registered in the central exclusion database, referred to in Article 108 of the Financial Regulation in the version applicable until 31 December 2015, as well as in the Early Warning System, as provided for in Article 12 of Commission Decision 2014/792/EU of 13 November 2014 on the Early Warning System to be used by authorising officers of the Commission and by the executive agencies (OJ 2014 L 329, p. 68), which replaced the previous decision on the Early Warning System and which was itself replaced by the provisions of Article 105a(1)(a) as well as Article 108(2) to (4) of the Financial Regulation in the version applicable from 1 January 2016, concerning ‘early detection of risks threatening the Union’s financial interests’. It must be noted that, in its letter, the Commission also made reference to the relevant provisions of the Financial Regulation and of its Implementing Regulation applicable at the time the facts alleged occurred. The provisions of the regulations to which the Commission referred in its letter are, in essence, identical to those cited at the beginning of this paragraph.