Vague Renewal Standards Threaten Businesses

The Authority can refuse license renewal on broadly worded grounds including "poses a risk to public health, public safety or public security," "deteriorated below the required standards," or failure to comply with undefined "directives"—without specifying objective criteria, notice requirements, or opportunity to respond. Ground (i) allows the Authority to enforce its own penalties through license revocation by linking renewal to "financial obligations" to the Authority or other public institutions, concentrating enforcement power without independent review. Combined with 40's severe criminal penalties for unauthorized transfer, businesses face existential uncertainty and cannot easily exit or restructure when facing discretionary refusal.