Unpredictable Reporting Obligations with Criminal Liability

The Authority can require participating institutions to provide "any information as may be prescribed" without advance specification, creating compliance cost uncertainty for businesses. Combined with 18's criminal penalties (up to 2 years imprisonment), this open-ended reporting obligation forces businesses to maintain expensive monitoring systems and exposes corporate officers to personal criminal liability for institutional reporting failures. The seven-day notification requirement for changes adds operational pressure, particularly burdensome for SMEs with limited compliance resources.