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Critical Severity

Disproportionate Penalties Threaten Business Survival

This provision imposes catastrophic penalties that could destroy businesses for regulatory violations. Immediate suspension of operations (97.7) without notice or hearing can shut down businesses instantly, destroying customer relationships and business value before any appeal. Financial penalties include up to 10% of annual turnover for gross negligence (97.9)—potentially bankrupting smaller enterprises—plus monthly fines that escalate indefinitely for audit delays (97.5). Permanent license revocation (97.8) for undefined "repeated violations" creates permanent market exclusion, while up to 7 years imprisonment for hosting data without accreditation (97.4) creates personal criminal liability for business decisions. These penalties far exceed international norms (GDPR uses administrative fines, not imprisonment) and create existential risks that will deter investment and entrepreneurship in Ghana's ICT sector.