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High Severity

Personal Criminal Liability for Officers

This provision makes every director, officer, or person concerned with management personally criminally liable for any corporate violation of the Act's extensive technical and administrative requirements. Business leaders face up to 2 years imprisonment and fines of 200-10,000 penalty units for corporate compliance failures—even for technical violations like incomplete audit logs or API integration delays. The "due diligence" defense places the burden on defendants and doesn't prevent costly criminal prosecution. This creates extreme personal risk for business leadership, deters qualified professionals from serving platform participants, and raises compliance costs substantially as businesses must invest heavily in legal infrastructure to protect officers from criminal exposure.