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High Severity

Criminal Liability Creates Compliance Trap

This provision imposes criminal penalties (fines and imprisonment) on corporate officers and managers who "ought reasonably to have known" about employee or user violations and "failed to take all reasonable steps to prevent" them. For businesses, this creates an affirmative duty to actively monitor and censor all content to avoid prosecution—but the underlying offences (misinformation, hate speech, private facts) have vague definitions that make compliance standards unclear. The result is a compliance trap: businesses must invest heavily in monitoring infrastructure or face criminal liability, but cannot know with certainty what conduct they must prevent. This creates barriers to market entry for startups and SMEs that cannot afford compliance costs, deters foreign investment due to unpredictable legal risk, and forces businesses to choose between over-censorship or criminal exposure for management.