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High Severity

Disproportionate Penalties for Administrative Non-Compliance

This provision establishes a general penalty of 2,000-10,000 penalty units for any violation where no specific penalty is provided. While general penalty clauses are standard legislative technique, this one creates disproportionate enforcement burdens when applied to the mandatory .gh domain registration requirement. The penalty operates cumulatively with other enforcement mechanisms—annual fines (21), business license suspension/revocation, public contract exclusion, and domain seizure (24)—creating an overwhelming compliance burden for businesses, particularly SMEs. The summary conviction process may not provide adequate procedural safeguards given the severity of business consequences for what is essentially administrative non-compliance with a registration mandate.