Automatic Criminal Liability Deters Innovation

This provision makes every director, manager, officer, and shareholder automatically criminally liable for any corporate ICT offense unless they prove due diligence—reversing the burden of proof. For digital startups, this means founders and investors face criminal prosecution and imprisonment for regulatory violations they may not have caused or known about. Combined with 86's penalties (up to 2 years imprisonment) and 90's business prohibition powers, this creates a severe chilling effect on entrepreneurship and investment. Investors cannot reasonably accept criminal liability for portfolio companies' compliance, while founders must divert resources from innovation to extensive compliance documentation. This directly undermines the bill's innovation goals, including the regulatory sandbox.