Disproportionate Criminal Penalties for Licensing Violations

The provision imposes up to 5 years imprisonment for operating without a license or negligently causing harmful interference - administrative violations that in OECD democracies typically result in fines or license suspension, not criminal imprisonment. This conflates regulatory non-compliance with serious criminal conduct, creating market entry deterrence and compliance cost escalation. The NCA's vague authority to "take any other action that it considers appropriate" (subsection 3(f)) creates regulatory unpredictability, while its unilateral power to impose fines and suspend licenses without independent review concentrates enforcement authority without adequate checks.