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High Severity

Censorship Before Judicial Review

Division decisions ordering content removal or corrections must be complied with immediately, with "administrative and criminal penalties" threatened for non-compliance (59.2). While appeal rights exist, the provision does not explicitly protect speech pending judicial review. This means the Division—whose Director is appointed by the President—can censor potentially protected speech (political commentary, investigative journalism, public interest disclosures) with judicial correction only available after the censorship has occurred. This inverts democratic norms where speech remains available until a court determines it unlawful, creating a prior restraint effect that particularly harms time-sensitive speech and encourages self-censorship even among speakers with strong legal defenses.